Tribunal Criminal Tribunal for the Former Yugoslavia

Page 44796

 1                           Tuesday, 10 December 2013

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

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

 6             JUDGE KWON:  Good morning, everyone.

 7             THE WITNESS: [Interpretation] Good morning.

 8             JUDGE KWON:  Yes, Mr. Karadzic, please continue.

 9             THE ACCUSED: [Interpretation] Good morning, your Excellencies.

10     [In English] Welcome, Judge Lattanzi.  We are glad you are back with us.

11     Good morning, everyone.

12                           WITNESS:  KW12 [Resumed]

13                           [Witness answered through interpreter]

14                           Examination by Mr. Karadzic: [Continued]

15        Q.   [Interpretation] Good morning, Witness.  Can you hear me,

16     Witness?  Can you hear me?

17             JUDGE KWON:  Mr. Witness, do you hear me in your language?

18             THE WITNESS: [Interpretation] Yes.

19             JUDGE KWON:  Did you also hear Mr. Karadzic's question?

20             THE WITNESS: [Interpretation] Yes.

21             THE ACCUSED: [Interpretation] Thank you.

22             MR. KARADZIC: [Interpretation]

23        Q.   Could you please tell us when your column split and into how many

24     columns?

25        A.   In the village of Bornica, we split into three separate columns.

Page 44797

 1     And we went in three different directions.

 2        Q.   Thank you and when was that, on what day?

 3             JUDGE KWON:  Yes.

 4             MS. PACK:  Your Honour, I just noticed there was a bundles of

 5     papers open on the witness's desk, and I just wanted to clarify exactly

 6     what they were and if the witness is referring to them.

 7             JUDGE KWON:  Yes.  Mr. Witness, could you tell us what documents

 8     you are looking at at the moment?  Or you have with you?

 9             THE WITNESS: [Interpretation] I have an exhibit from the ground,

10     and it is not a problem at all, I'll remove every single piece of paper

11     from the desk so your wishes shall be granted in that respect as well.

12     Here you are, no more papers, go ahead.

13             JUDGE KWON:  To refresh your memory, if you need to take a look

14     at one of those documents, please let us know.  There should be no

15     problem.  Shall we continue?

16             THE ACCUSED: [Interpretation] Thank you.

17             MR. KARADZIC: [Interpretation]

18        Q.   If you think that the Trial Chamber may wish to see the papers,

19     we can ask for that.  When did those columns split, on what day?

20        A.   It was in the evening on the 11th.

21        Q.   Thank you.  And those columns, did they communicate to each

22     other, and if that was the case, how did you do that?

23        A.   Now, everybody, forgive me, Your Honours, Judges.  Can you be

24     please -- can you explain how we communicated?

25             THE INTERPRETER:  Could the witness and the accused please be

Page 44798

 1     asked not to overlap and wait for the interpretation to finish.

 2             JUDGE KWON:  Could you repeat your question, Mr. Karadzic?

 3             THE ACCUSED: [Interpretation] I apologise.  I seem to be the

 4     culprit.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   You answered one part of my question.  The second part of my

 7     question is this:  Did you have physical contact?  Did you open fire at

 8     each other during that first night and in what part of the territory?

 9             MS. PACK:  [Microphone not activated]

10             JUDGE KWON:  I'm not sure he answered one part of your question

11     at all.

12             THE INTERPRETER:  The interpretation was not finished,

13     Your Honour.

14             THE ACCUSED: [Interpretation] Your Excellencies, it was not

15     recorded.

16             JUDGE KWON:  Yes, ignore everything.  Could you ask your question

17     again?

18             THE ACCUSED: [Interpretation] Thank you.

19             MR. KARADZIC: [Interpretation]

20        Q.   How did those three columns communicate with each other?  How did

21     they inform each other of things?

22        A.   We had military Motorolas.

23        Q.   Could the VRS listen to your conversations?

24        A.   I really can't tell you.  I know nothing about that.  I don't

25     know whether the VRS listened to us.  We had an encounter with the VRS at

Page 44799

 1     Kaldrmica.

 2        Q.   Thank you.  You spoke about that yesterday.  Did you get close to

 3     each other during that first night when those three columns moved about?

 4        A.   When we passed the first Serbian line at Kaldrmica, between

 5     Konjevic Polje and Kasaba, one group passed and one group went in the

 6     direction of Tumaci [phoen] hill.  The other group went in the direction

 7     of Cerska.  From Kaldrmica to the school, there is a part there and the

 8     third group, Zulfo Tursun's group, arrived from the third side from Nova

 9     Kasaba.  They had to by-pass a hill.

10             When we arrived, when one part of the column arrived at

11     Odaca [phoen], that night we were informed that there were problems and

12     that the Serbs had set out from Kaldrmica to cut off Zulfo Tursun's army

13     and that with his troops he would not be able to get to Udrc.  And then

14     one group separated, about 200 of us men, to assist them in order to

15     protect Zulfo Tursun and his troops.  We came down from Udrc towards one

16     part of Cerska, between the two hill tops, and when we arrived there, we

17     formed a line there, some 200 of us.  We formed a line and we had contact

18     with Zulfo Tursun who was from the other side of that hill so we met with

19     him.  We joined up with him.

20             In the meantime, as for the Serbs coming from down there and

21     shooting, Zulfo Tursun and ourselves accompanied by the late Ejub Golic

22     deployed.  We met those people, some 130 to 150 metres away from us.

23     They were shooting and we shot back at them.  It was only in the morning

24     that we saw what we had done, Ibro Duda was killed, some of the troops of

25     his were also killed, and some of the people.  We managed to collect the

Page 44800

 1     weapons and the ammunition and we swore to each other that we would never

 2     tell anybody who we had killed and how we had done it.

 3        Q.   According to you, how many people died there?

 4        A.   According to me, a lot of people died there.  I don't know how to

 5     explain.  Maybe 500 to 600 people, even that would be too few, but let's

 6     say it was between 450 and 500 people altogether.

 7        Q.   Thank you.  Could you please tell us, did you know anything about

 8     incidents in Srebrenica before you left?  Were there any casualties there

 9     as a result of shelling and could you observe those happenings?

10        A.   And I would like to ask you to explain to me whether you're

11     talking about that case when I was deceived by Mladjo and Cvrk, and Cvrk

12     was the goalkeeper.  Is that about the killing of the children by

13     shelling?

14        Q.   Can you tell us what that was all about?

15        A.   Before that happened, a few days before that, a dispatch arrived

16     at the Independent Mountain Battalion in Glogova, and in that dispatch

17     Mevludin Zukic, who could read the dispatch, arrived from Sarajevo from

18     Izetbegovic personally, that we had to protect ourselves because there

19     would be fire.  That meant that there would be an attack on Srebrenica

20     and that we had to do something urgently in order to transport the people

21     or that those people from NATO who were supposed to come to Srebrenica to

22     help us, to protect us, that's how we were supposed to defend ourselves.

23     And then a game was played, a tournament was organised in the football

24     pitch, and children were playing.  I was not on duty at that time.  I

25     don't know whether Mladjo asked for help from Ejub Golic.  I suppose that

Page 44801

 1     the commanders knew what would happen, I went with a man called Cvrk from

 2     Zvolica [phoen].  I went to help them and in the courtroom in Srebrenica,

 3     there was something in the bags, I didn't know what that was, and when

 4     I arrived on the scene and when -- there was the 120-millimetre mortar

 5     that had fired that shell.  We arrived there.  When we arrived there

 6     I saw that, or rather, I thought that they would open fire on Bratunac or

 7     Ljubovija or perhaps some town in Serbia.  And then my Mladjo told me

 8     that I was free to go.  I arrived almost to the command of the

 9     Independent Mountain Battalion.  That shell was fired from up there.  And

10     a few minutes later, people started running from the football pitch, from

11     the school, towards the centre of Srebrenica where our command was.  What

12     happened, everybody was asking.  And somebody said Chetniks shelled the

13     football pitch and some children got killed.  All of a sudden, everybody

14     started saying that it was done by Chetniks, by the Serbs.  It was

15     ascribed to them.

16        Q.   And in Srebrenica itself, what was being said about the incident?

17        A.   In Srebrenica itself, nothing was being said.  What was being

18     said was two days later when I went to the front line, I was on the front

19     line, with my colleagues and we discussed that whole matter.  The story

20     was learned in Srebrenica a few days later when I came back to

21     Srebrenica, and I lived in Srebrenica at the time.  Can I mention the

22     name of the place where I lived?

23        Q.   You don't have to.

24        A.   He came to me and said that I had to go to an interview.  I was

25     taken to the garbage depot.  I didn't know where they were taking me

Page 44802

 1     until one group of guards from the Independent Battalion at Glogova was

 2     returning and they asked them where are you taking?  They told them and

 3     they started to defend me.  They returned me and I suppose that, like

 4     many others before me, I was supposed to be liquidated in that garbage

 5     depot, and then I was detained in the department store.  I was there for

 6     a couple of days.  I was detained.  And then the late Ejub Golic arrived,

 7     took me to the command and told me not to tell anybody about that because

 8     it was all over but we shouldn't be talking about that to anybody.

 9             JUDGE KWON:  When was it?

10             THE ACCUSED: [Interpretation] Thank you.

11             THE WITNESS: [Interpretation] In 19 -- as far as I can remember,

12     I believe that it was in 1995, two or three months before the attack on

13     Srebrenica, thereabouts.  Because the attack on Srebrenica was launched

14     very soon after that.

15             JUDGE KWON:  Yes, please continue.

16             MR. KARADZIC: [Interpretation]

17        Q.   Can you please tell us in view of your closeness to Oric and

18     others, what was the objective of the BiH, or rather, those few

19     commanders in Hornje [phoen]?  What was their strategic goal?

20        A.   How can I explain to you, Mr. President and Judges, what the

21     objective was?  We knew what the objective of Naser Oric was and those

22     people in Srebrenica who were closer to him.  Their objective was to

23     defend Srebrenica.  People were supposed to defend Srebrenica and the

24     others were supposed to get rich.  Why?  The humanitarian aid, when it

25     arrived, we would be waiting for humanitarian aid for seven or 15 days

Page 44803

 1     for it to be distributed but before that, it was taken to the marketplace

 2     and it was sold there it by Naser's people and we were left with the

 3     remains.

 4        Q.   And what were the intentions with regard to the Serbian

 5     territories and the Serbian villages?

 6        A.   Let me tell you immediately that I did not understand your

 7     question at all.  I don't know how to explain that to you.  From the very

 8     beginning of the war, the intention was every Serb wanted to live in

 9     their own land, they didn't want to leave, and now what happened there,

10     how did it change overnight, I really can't tell you.  We -- I apologise

11     for interrupting myself.  All of us who knew each other, be it a Serb or

12     a Muslim, we all wanted to live together.  And then an operation happened

13     and we saw each other in that operation.  We called out each other's

14     names but Naser Oric did not want us to socialise.  He didn't want us to

15     communicate with anybody.  And people who wanted to talk to each other

16     would be either killed or put into prison.

17        Q.   Thank you.  In your view, and to what extent was there a

18     connection or influence of Sarajevo over developments there and to what

19     extent did Oric himself do that?  You explained this about the shell a

20     moment ago.  What was the influence of Sarajevo?

21        A.   Mr. President, Judges, already in 1993, from Sarajevo, either

22     from Izetbegovic personally or whoever, we got something in writing.  How

23     do I put this?  And you displayed that here in one case when Naser Oric

24     was talking at this youth centre in Srebrenica where there is a

25     disco-club now, he's talking about this conversation.  In 1993, we got

Page 44804

 1     this offer to reach an agreement so as to leave Srebrenica which was

 2     offered for some parts near Sarajevo, Ilijas, Vogosca, Blazuj, and that

 3     had started, as far as I remember, in 1993.  UNPROFOR people came with

 4     helicopters to get the army and the wounded out.  And Swedish trucks took

 5     people out.  This went on for seven days until that ambush of

 6     Zulfo Tursun and Naser on the yellow bridge, and then he came and said

 7     the Chetniks ambushed the people.  But people were leaving for seven

 8     nights and seven days and the Serbs let us go, they went to Tuzla, they

 9     went through Bratunac and Zvornik.

10        Q.   Thank you.  What was the motive Oric's motive, to prevent the

11     people from leaving?

12        A.   Well, his motive was because we figured all of that out until

13     1995, until the attack, how to explain this to you, Mr. President?  That

14     there was not a single military force, no force could have gone through

15     the line that we held in 1995.  He wanted to make as much money as

16     possible to keep Srebrenica, to have decorations so the people would say

17     Naser Oric did this, Naser Oric did that.  As far as I know, Naser Oric

18     was not tried here for the killing of some Muslims already in 1993 and

19     1994.

20        Q.   Thank you.  You mentioned Izetbegovic and his instructions.  Did

21     you personally have some experience with Izetbegovic, the president, and

22     his son?

23        A.   In 1997, yes, I did meet with Alija Izetbegovic, when an offer

24     was made to me.  That lady colleague of yours who was in power and the

25     Red Cross from Geneva, you and everybody, the Judges, have these

Page 44805

 1     documents, when I was freed because of this false killing, and I was

 2     amnestied on the basis of that paper, and I was exchanged for that

 3     captain that we mentioned a bit yesterday.  And then Alija Izetbegovic

 4     gave me -- I had that little military booklet, and there is also this

 5     certificate with my name and surname stating how much money we as

 6     military had received, and he paid me in cash right there and then, and

 7     Efendi Ceric was present and I got 50.000 German marks then.  They took

 8     me to a different building, some other people, they got me a passport and

 9     they paid these people to take me to this country where I was.

10        Q.   Thank you.  Could you find anything out during this meeting that

11     would be of interest to us?

12        A.   Well, how do I put this?  I can just say, as I said to that

13     gentleman of yours, that investigator, I said that then at that moment in

14     1997, my name was deleted from that list of participants in war.  You

15     know that military list?  You're not on this military list, you're not in

16     these papers, you're not going to exist any more.  It was not done only

17     in my case, it was done in the case of some people who were far greater.

18        Q.   Thank you.  Efendi Ceric, did he take part in that conversation?

19        A.   He was there, he sat there, and he also got a sum of money out

20     there that he collected through that mosque committee, I'm talking about

21     Alija Izetbegovic and Efendi Ceric.  From the two of them, I received

22     50.000 marks.

23        Q.   And what was that money intended for?

24        A.   Well, it was intended for - how do it I put this? - so that I no

25     longer -- so that I would no longer exist in Bosnia, go to a different

Page 44806

 1     country, work there.  You don't know certain things and there you go.

 2     That's what I meant.

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12             JUDGE KWON:  Very well.  We can redact that but why do we need

13     more detail about this in private session, Mr. Karadzic?

14             THE ACCUSED: [Interpretation] We just need private session from

15     where he arrived from, how he arrived in Sarajevo.  It's a unique way of

16     arriving, that's why perhaps that could be used for decoding.

17             JUDGE KWON:  I'm asking you what relevance does it have at all,

18     the meeting of this witness with younger Izetbegovic in 2010.

19             THE ACCUSED: [Interpretation] Because of the circumstances

20     involved, Excellency and the people who took part in this and how they

21     treated the witness and why.

22             JUDGE KWON:  Very well.  We'll go into private session.

23                           [Private session]

24   (redacted)

25   (redacted)

Page 44807

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23   (redacted)

24                           [Open session]

25             THE REGISTRAR:  We are in open session, Your Honours.

Page 44808

 1             THE ACCUSED: [Interpretation] Thank you.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   How were you treated in SIPA and what was expected of you, if

 4     anything?

 5        A.   I mentioned that a bit yesterday.  When I came to SIPA to the

 6     second floor, in front of Bajro Kulovac and Damir Alagic, that's when

 7     I discussed this with Kulovac, why he is talking about these six persons

 8     of -- from Skelanci when they did not take part in these killings, and he

 9     said, I found evidence, casings, et cetera, and I said, All right, but

10     your people were not killing, and he said, I know better than you, and

11     here are these papers, write this.  And I read this piece of paper and

12     what it said was that I was never in Srebrenica from 1992 to 1995.

13     I didn't want to sign that and then I was slapped in the face and kicked,

14     and --

15             THE INTERPRETER:  The interpreter did not understand the last

16     sentence.

17             THE WITNESS: [Interpretation] Then Bajro Kulovac and --

18             JUDGE KWON:  Please repeat from where you said you read this

19     paper -- "... piece of paper and what it said was that I was never in

20     Srebrenica from 1992 to 1995."  Please start over again from there.  And

21     speak very slowly, please.

22             THE WITNESS: [Interpretation] When I came to SIPA with

23     Damir Alagic and Bajro Kulovac from OSA police, I was taken to SIPA to an

24     office.  When I arrived in SIPA at the office, first, with Bajro Kulovac

25     I had this discussion as to why six men from Skelanci who were 30 or 40

Page 44809

 1     years old were convicted, although they were not involved in the killings

 2     in Kravica.  He answered that he had evidence, he found the casings, he

 3     found the flesh, the bones and that he found clothes.  And I said, All

 4     right, you found that as evidence.  And these people, these casings that

 5     you found, are they with their fingerprints?  And he said, You have no

 6     right to interfere in that.  I am the man in charge and you should sign

 7     this paper here and this paper of one page and a half contained my name

 8     and surname, confirming that I was not in Srebrenica from 1992 to 1995.

 9             I, Judge, did not want to sign that.  In the presence of

10     Damir Alagic, Bajro Kulovac slapped me in the face and I fell off the

11     chair and then he managed to kick me in the stomach.  How do I put this?

12     Then Damir Alagic said that he should calm down because I came and you

13     know full well where I was and where I came from and that he would take

14     care of all of that.  Then I was taken, accompanied by Alagic and

15     Kulovac, to the office of the main director of SIPA, where Damir Alagic,

16     when this man walked in through the door, did not want to talk to this

17     director.  He asked for Bosniaks.  He didn't want to talk to this man

18     because this man was a Serb.

19             At the time, this man -- well, this other man came, a Muslim,

20     I guess, now was he the deputy director of SIPA, I don't know exactly.

21     This man came and asked me whether I was forced to give a statement at

22     the prosecutor's office in Bijeljina or not.  I said -- I just managed to

23     say I was not forced, it's mine.  I just wanted to say it was in good

24     faith.  Damir Alagic put his hand on my left shoulder and he said that he

25     would take care of this.  So from there, I left SIPA and I was in the

Page 44810

 1     street for two days and two nights until a lawyer found me and now

 2     I don't want to mention his name.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Thank you.  Are you the only person who was registered as being

 5     killed, or do you know of other cases that people were registered as

 6     being killed and who were nevertheless alive like you?

 7        A.   There are other people like that, Mr. President, Judges,

 8     Prosecutors, but these people are abroad and some of them are in the

 9     federation to this day.  How do I explain this to you?  I asked your

10     co-ordinator, as we call him, I asked for a computer, laptop, that we sit

11     down and I can find all of them on Facebook and we can go and see them

12     and have a cup of coffee, but we were not allowed to cross over from

13     Republika Srpska to the federation.  So that the Court could see here

14     today that these people are still alive, whereas their parents receive a

15     pension to this day.

16             THE INTERPRETER:  Interpreter's note:  We did not hear the

17     question.

18             THE WITNESS: [Interpretation] Most probably --

19             JUDGE KWON:  Repeat your question, Mr. Karadzic.

20             MR. KARADZIC: [Interpretation]

21        Q.   Are any of these people registered in some of the lists that are

22     of interest to this Tribunal?

23        A.   Yes, there is this list.  It was given already in Bijeljina,

24     I think, and it's because of that list that Alagic and Kulovac threatened

25     me that I should not dare speak about that, that's why I fared this way.

Page 44811

 1     I would like to see this list here in court, if possible, whether that is

 2     the list or another list.

 3        Q.   You said that that is what you suffered for the most?

 4        A.   Yes.

 5        Q.   Thank you.

 6             THE ACCUSED: [Interpretation] 1D99586, could that please be shown

 7     to the witness in e-court.  Could it please not be broadcast?  That's

 8     probably what it is.  Could it please not be broadcast?

 9             THE WITNESS: [Interpretation] I would just like to ask something.

10     Can -- can a person ever light a cigarette here in Holland?

11             MR. KARADZIC: [Interpretation]

12        Q.   Hardly.

13             THE ACCUSED: [Interpretation] 1D99586.  Do you have the good

14     number?  And don't broadcast it.

15             JUDGE KWON:  Could you repeat the number?

16             THE ACCUSED: [Interpretation] 1D99586.

17             JUDGE KWON:  Is it not simply 9586?

18             THE ACCUSED:  Maybe, sorry.  [Interpretation] Yes, that's the

19     right number, 9586.

20                           [Trial Chamber and registrar confer]

21             THE ACCUSED: [Interpretation] Not to be broadcast, please.

22             MR. KARADZIC: [Interpretation]

23        Q.   Can you tell us what this document is?

24        A.   That's the first page of my - how shall I call it? - war diary.

25        Q.   Thank you.  Can we go to page 7.  Can you tell us in

Page 44812

 1     public session where are these people and how did you come to have these

 2     names?  What is this list?  And then we'll close the session for any

 3     additional information.

 4        A.   It's the list of people who are alive and whose parents receive

 5     pensions on account of them being registered as dead.

 6        Q.   Did you mention in Potocari?

 7        A.   Yes.

 8        Q.   Did you meet with any of these people?  Do you know them?

 9        A.   There are some people who are in Switzerland, there are some who

10     live in the US, some in France.  There is this man of yours who lives in

11     Holland.  I don't know whether they live in Holland under their own name

12     or under some other name, but if I had my laptop I could get them on

13     Facebook for you and you could talk to them on Skype maybe.

14        Q.   These circled names, except 15 or 16, are they alive?  You are

15     satisfied that they are alive?  You know that for a fact?

16        A.   All of these names that are circled are the people with whom I

17     have had contact.

18        Q.   Thank you.

19             THE ACCUSED: [Interpretation] I tender this diary under seal.

20             THE WITNESS: [Interpretation] It is because of this list that

21     I had my bones broken.

22             JUDGE KWON:  I would ask more questions as to the -- this diary,

23     this war diary, when he wrote, and et cetera.  Could you carry on.  I

24     will ask him.  When did you write this, Mr. Witness?

25             THE WITNESS: [Interpretation] I wrote this when I was you know

Page 44813

 1     where for three and a half years, and through this writing and these

 2     documents that I provided to your Office of the Prosecutor here in

 3     The Hague of the ICTY who visited me.

 4             JUDGE KWON:  As a Judge, I know nothing about this.  I asked when

 5     you wrote this.  Could you assist us when you wrote this?

 6             THE WITNESS: [Interpretation] That was written while I was --

 7     I don't want to reveal now where I was.

 8             THE ACCUSED: [Interpretation] Could we go into private session?

 9             JUDGE KWON:  Yes.

10                           [Private session]

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 44814











11  Page 44814 redacted.  Private session.















Page 44815

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24                           [Open session]

25             JUDGE KWON:  Who has the original of this --

Page 44816

 1             THE REGISTRAR:  We are in open session, Your Honours.

 2             JUDGE KWON:  Thank you.  Who has the original of this document?

 3             THE ACCUSED: [Interpretation] I hope the witness can answer.

 4             THE WITNESS: [Interpretation] The original of this document is in

 5     my possession.  I don't have it here now but it's in my handwriting and

 6     everything, and the Bijeljina prosecutor's office has it.  I don't know

 7     if it's before this Court, if it's available, if the Court can see it.

 8             JUDGE KWON:  And you're tendering this document, Mr. Karadzic?

 9             THE ACCUSED: [Interpretation] Pages 1 and 7, your Excellency.

10             JUDGE KWON:  Very well.

11             Yes, Ms. Pack.

12             THE WITNESS: [Interpretation] When you could admit into evidence

13     all that you've admitted, I stand by all the documents that I've written.

14     I paid for them with my life.  I fought 17 years to sit in this box, to

15     be on this stand, and I am addressing you, the four main people in this

16     Court, to approve my going to the federation and my presence there.

17             JUDGE KWON:  This is a criminal proceedings against Mr. Karadzic.

18     It is for the accused to tender the documents or exhibits and to

19     determine what documents he should tender.

20             Yes, Ms. Pack.

21             MS. PACK:  In short, in my submission, this -- admitting this one

22     page of a document compiled by the witness after the war in the manner of

23     a statement, a diary, a book, a statement, that's what it amounts to, in

24     essence, is admitting part of a prior statement but not in compliance

25     with the procedures that are available under the rules.  There has been

Page 44817

 1     an effort to admit this witness's statement given to the Defence legal

 2     advisers under 92 ter and that application was refused and the witness is

 3     called viva voce, and just to admit part of something else that he's

 4     compiled to assist in the presentation of his evidence is plainly wrong

 5     in my submission.

 6             JUDGE KWON:  But as a matter of practicality, the witness can

 7     read out these -- this list of names and he can say that they are alive,

 8     so there is no difference, as a matter of fact.

 9             MS. PACK:  As a matter of fact, Your Honour, is of course right.

10             JUDGE KWON:  And what you said seems to go to the weight.  I will

11     consult my colleagues.

12             MS. PACK:  Thank you.

13                           [Trial Chamber confers]

14             JUDGE KWON:  Yes, we will mark these two pages pending

15     translation.

16             THE REGISTRAR:  It receives Exhibit MFI D4183 under seal, Your

17     Honours.

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

19     have no further questions at this moment.

20             THE WITNESS: [Interpretation] Can I get some water?

21             THE ACCUSED: [Interpretation] Yes.  I wonder if the witness needs

22     a break maybe.  You can ask him.

23             THE WITNESS: [Interpretation] Maybe if I can just have one

24     cigarette.

25                           [Trial Chamber confers]

Page 44818

 1             THE WITNESS: [Interpretation] Nothing is allowed here.  If the

 2     International Court cannot give me a break, who can?  I remember

 3     everything.  It's not easy for me.  I don't even know what the date is

 4     today.  Nobody is asking me what I've gone through in my life, in the

 5     1990s.  I'm soaked now completely.  It's all coming out of me.  Let me

 6     tell you, Judge, every year, never mind that this is 2013, this may go on

 7     with me until the day I die.  All that I went through in 1995, on that

 8     date or seven days before, I have health problems.  I sit down and cry.

 9     Sometimes I wanted to kill myself.  And nobody, not even your Prosecutor

10     who visited me, did not enable me to come here before, for me to show you

11     what this is all about.  I'm asking for a break to have a cigarette.

12             JUDGE KWON:  We were planning to have a break at 10.30 but we'll

13     have a break now for 15 minutes and resume at ten past.

14                           --- Break taken at 9.56 a.m.

15                           --- On resuming at 10.13 a.m.

16             JUDGE KWON:  Ms. Pack, we will have another 20 minute break at

17     10.30.

18             MS. PACK:  Thank you, Your Honour.

19                           Cross-examination by Ms. Pack:

20        Q.   Witness, you are here today finally testifying in The Hague,

21     something you have wanted to do for many years; is that right?

22        A.   Yes.

23        Q.   Because you consider yourself to be an important witness, you

24     witnessed, so you believe, many important events during the war; is that

25     right?  Is that your evidence?

Page 44819

 1        A.   Yes.

 2        Q.   You witnessed Muslims killing each other, the ABiH killing

 3     Muslims, killing children in Srebrenica, you know that Muslims whose

 4     families are claiming benefits because they are dead, you know they are

 5     alive, you personally witnessed, so you say, every conspiracy theory that

 6     everyone else gets to read about in the press; is that right?

 7        A.   Yes.  And you have to ask that of the three women of Srebrenica

 8     as well as Sulejman Backovic [as interpreted], a teacher.  You should ask

 9     them how come they know better what happened in Srebrenica than we who

10     were actually there at the time.

11        Q.   Because you know so much, so you say, people want to kill you,

12     they beat you, they put pressure on you, or they ignore you; is that

13     right?

14        A.   Madam, I was beaten.  I've been ignored.  A lot of bad things are

15     written about me in the newspapers.  A lot of the bad things are known in

16     the public.

17             THE ACCUSED: [Interpretation] Transcript.

18             MS. PACK:

19        Q.   You --

20             JUDGE KWON:  Yes, just a second.

21             THE ACCUSED: [Interpretation] Line 19 and 20, the witness said:

22     You should ask the first three women from the Mothers of Srebrenica, this

23     is an association, the SDA and Sulejman Tihic.  This is what the witness

24     said.

25             JUDGE KWON:  Do you confirm that, Mr. Witness?

Page 44820

 1             THE WITNESS: [Interpretation] Yes.

 2             JUDGE KWON:  Yes.  Please continue, Ms. Pack.

 3             MS. PACK:

 4        Q.   You were even captured on tape, so you say, on more than one

 5     occasion.  We saw a recording yesterday of you apparently in Pale.  You

 6     told us yesterday there was some footage of you with General Morillon

 7     during his speech in Srebrenica in 1993.  And let me ask you this:  There

 8     is one interview, the first interview you had with the Defence legal

 9     adviser who is here in court, Goran Petronijevic, your first interview,

10     you said you saw your shoe in footage of Kravica warehouse; is that

11     right?  Do you remember saying that?

12        A.   Madam, there was a print of the shoe, and I asked them to take me

13     there to get that shoe as hard evidence.  However, we did not have the

14     time to go there and to fetch the shoe.

15        Q.   You have avidly followed The Hague and the state court trials,

16     haven't you?  You've watched these trials on television, on the internet;

17     is that right?

18        A.   Madam Prosecutor, let me tell you in answer to that, I've watched

19     some the cases.  Because I had to work to survive, I didn't have time to

20     sit and watch all the trials.  I did it when I had the time to do that.

21     And then I would see a witness talking about Srebrenica here.  I found

22     that the hardest thing in my life because those witnesses did not tell

23     the truth as to what they had seen.  Their testimonies were biased and

24     what they said was that they were ill treated by the Serbs, and nobody

25     says nor do they dare say that they were treated in Srebrenica from 1992

Page 44821

 1     to 1993, that we were all tortured by the other locals of Srebrenica, by

 2     Naser and his men.  Who is it who came to this courtroom and said that?

 3     If you want me to -- if you want to co-operate with me and the

 4     Prosecutor's office want to co-operate with me, I can bring 50 people who

 5     would tell you the same thing as I'm saying.  They are afraid to say the

 6     same thing in Bosnia because they are ill treated, they are provoked,

 7     they are threatened and everything else, and people have to suffer.  They

 8     are hungry, they are thirsty, and they are afraid.

 9        Q.   Well, you tell us you can bring 50 people who would give some

10     evidence or other.  You have taken it upon yourself to research these

11     cases, haven't you?  You've spoken to people who you consider to be

12     witnesses yourself; is that right?

13        A.   Madam, you can't understand me, but please try.  Listen

14     carefully.  I'm going to tell you in very short lines.  Since 2003 I have

15     suffered, when -- I suffered when I was in that country where I lived

16     from 2003 to 2007.  There was a search warrant for me when Naser Oric was

17     here in 2003 and 2004 because he was afraid that I would hide and he

18     didn't want me to come here while he was still here.  And Madam, at that

19     time --

20        Q.   I'm interrupting you, my apologies, but I'm interrupting you.

21     I asked you a question, I'd like you to answer it, please.  You have

22     taken it upon yourself to research these cases, haven't you?  Can you

23     answer that question for me?

24        A.   I took it upon me because I've been fighting to come here since

25     1996.  The authorities would not allow me to do that.  The Sarajevo

Page 44822

 1     police arrested me, they beat me, the Sarajevo SDA fabricated all the

 2     evidence against me, so I did not manage to come here.  Many people are

 3     familiar with my case.  They know what has happened to me and as a result

 4     of that, they themselves are afraid to come here and talk to you.  Now

 5     I've answered your question.

 6        Q.   You -- I don't want to mention where you were but you were in a

 7     place over the last few years, we talked about it in private session,

 8     when you were there, this was your preoccupation, wasn't it?

 9     Preoccupation was researching these cases?

10        A.   No, Madam.  I'm not you.  It is not up to me to research

11     anything.  No, Madam.  I was free in that place, I was not ill treated,

12     I was not forced to do anything.  I sat down and I wrote about my case,

13     Madam.  I wrote to the President of Republika Srpska, to Rajko

14     Kuzmanovic.  I wrote to Miro Dodik [as interpreted] who is in office now.

15     I wanted to take them to the sector of Srebrenica.  I wanted to take them

16     to a grave -- graves and nobody was interested in doing that in Republika

17     Srpska.  How would you feel knowing that you have written to somebody,

18     imploring with them to be taken to the grave to excavate your fellow

19     Muslims [as interpreted] from the grave and at the same time you're

20     watching on television and Rajko Dokmanovic [as interpreted] doesn't want

21     to help you.  How would you feel?  And those people, that woman, they

22     were all killed right in front of me.

23             THE ACCUSED: [Interpretation] Transcript.

24             JUDGE KWON:  Yes?

25             THE ACCUSED: [Interpretation] Line 8, "to excavate your fellow

Page 44823

 1     Serbs from the grave," not "fellow Muslims."

 2             THE WITNESS: [Interpretation] Yes.  I did mention the Serbs, not

 3     the Muslims.

 4             THE ACCUSED: [Interpretation] And on line 9, the family name is

 5     "Kuzmanovic," not "Dokmanovic."

 6             MS. PACK:

 7        Q.   You followed closely, didn't you, the trial of the members of the

 8     Special Police Brigade who were indicted for the Kravica warehouse

 9     killings at the state court?

10        A.   No, Madam.  I saw their photos in newspapers, and as soon as

11     I saw their photos and I recognised my school colleague, I immediately

12     asked from the prison warden to invite somebody from the Prosecutor's

13     office, I wanted to tell them that those lads were not there.

14     Bajro Kulovac then came and threatened me not to talk about that any

15     more.  That was my first encounters with Bajro Kulovac in the prison,

16     when I was in there.

17        Q.   Yes.  I realise now that prison was mentioned in open session.

18     So I can say I've been talking about the period when you were in prison,

19     when you were following these trials.  Let me just ask you this:  You

20     have been desperate, haven't you, desperate, to come and testify here as

21     a witness?

22             THE ACCUSED: [Interpretation] Objection.

23             THE WITNESS: [Interpretation] I fought for that.

24             JUDGE KWON:  Objection overruled.  Can we go back -- go into

25     private session briefly?

Page 44824

 1                           [Private session]

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16                           [Open session]

17             JUDGE KWON:  Yes, we are in open session.

18             Please continue, Ms. Pack.

19             THE ACCUSED: [Interpretation] I had an objection.  Madam Pack

20     repeats in her question that the witness followed those trials from

21     prison.  She makes it look like the witness confirmed that.

22             THE WITNESS: [Interpretation] No, I didn't confirm that.

23             MS. PACK:

24        Q.   Well, when were you looking at photos in newspapers and watching

25     the television and seeing the footage that you've been talking about

Page 44825

 1     related to The Hague proceedings and the state court proceedings?

 2             THE ACCUSED: [Interpretation] Could the witness please be asked

 3     not to mention the name of the place?

 4             THE WITNESS: [Interpretation] Madam, I was in prison.  In 2003

 5     I was not in prison.  I could have been here.  Your Prosecutor from here

 6     paid me a visit at that time.  And there was another man from Srebrenica

 7     who testified here, but I'll talk about that in private session.  You

 8     have his video-clip, you have his testimony, and he was the first to ever

 9     mention that -- my name before the Prosecutor who had brought him from

10     that country.  And when he visited me, he listened to that conversation

11     and ever since I've had problems.  And Naser Oric was here at the time.

12             MS. PACK:

13        Q.   I want to just show you a part of your first interview with the

14     accused's lawyer, Goran Petronijevic and Milomir Savcic, his chief

15     investigator, this is while you were in prison in February 2010.

16             MS. PACK:  It's 65 ter 25759.  And I'd like to go, please, in the

17     English, to page --

18             THE ACCUSED:  No broadcast, I suppose.

19             MS. PACK:  Not to be broadcast.  I'm grateful to Dr. Karadzic.

20     English page 198, B/C/S page 193.

21        Q.   This is at the end of your interview, relatively near the end of

22     your interview.  It's line 31 down in the English and I'll read it out

23     and you can read the corresponding B/C/S.  You say -- talking about

24     giving evidence, you say:  There is no problem, if you want tomorrow or

25     the day after, in five in 10 days, come again, we shall sit down, but

Page 44826

 1     please know so from now on I only ask for protection.

 2             Do you see where I'm reading from?

 3             THE ACCUSED:  Serbian page is not --

 4             MS. PACK:  Sorry, it's the next page in the B/C/S, please.  Thank

 5     you.

 6        Q.   See where it begins?  It's the first -- second paragraph with

 7     your initials.  So I'm starting there.  And then I read on:  So from

 8     today on I only ask for protection, that nothing would be known about me

 9     until my turn to testify comes.  Would that be defence of Karadzic or

10     some other issues only to say the Serbs did not take Srebrenica

11     heroically and they did not take that either, but Srebrenica was sold for

12     money, no one has to convince me, we, the army, have abandoned it so they

13     could come in on that terrain.

14             Question:  You are worried about your safety?  Answer:  I'm

15     worried about my safety.  From here I want --

16             JUDGE KWON:  Next page.

17             MS. PACK:  My apologies.  Next page.  Thank you very much,

18     Mr. President.

19        Q.   So it's just going on to the large paragraph:  I'm worried about

20     my safety.  From here I want only that the trip would be secured for me.

21     So when I would go to testify from here, so I get out in March from here,

22     I want a car to be waiting for me and to take me to testify, et cetera.

23             It goes on.

24             And you go on to say:  As people would say, not to see the

25     territory of the former Yugoslavia, so it could only be Holland,

Page 44827

 1     The Hague, and the stand.  In quotes, "Take the stand, do you claim

 2     this?"  I do, bring me that man, come here, do you think that this was

 3     here?  It was, where did you do this?  Here and here.  And I'm running

 4     away from Sarajevo, to tell you the truth, as there would be violence

 5     down there as down for me it would be --

 6             Answer:  Are you ready --

 7             Question:  Are you ready to eventually testify in The Hague about

 8     all this what we talked about?

 9             Answer:  Could we go now immediately?

10             Question:  Well, we cannot because the procedure is such.

11             Answer:  Let me say --

12             THE ACCUSED:  Serbian new page, please.

13             MS. PACK:  Thank you very much.

14        Q.   Answer:  Let me say I understand but it could be now, tomorrow,

15     the day after tomorrow.  I'm now here, but that also my condition would

16     be met.  I am not asking to take the stand as I see on TV some trials in

17     The Hague.  There is a link, some other voices.  Face to face, would it

18     be Ratko Mladic?  Would it be, for example, Seselj?  Would it be

19     Karadzic?  Over the next page.  Would it be Naser Oric?  Would it be

20     Smajo Mandzic?  Would it be Zulfo Tursun, face to face?  What I went

21     through, what I saw, I do not fear God.  I do not fear to look you here

22     into the eye.  I do not fear any court.

23             Does that capture -- does that recall well, Witness, your

24     enthusiasm to testify here in The Hague?  It was an exciting prospect for

25     you, wasn't it?

Page 44828

 1        A.   Madam, what it says here, I stand by it.  I stood by it when we

 2     talked to the person whose name I should now mention or perhaps not.

 3     When I provided this statement, I stood by every word.  And then when

 4     I was released, 22 days later, I was kidnapped, I was beaten, my bones

 5     were broken, I barely survived and got to the civilian police, to the

 6     person who finally protected me in my town, in the place where I was

 7     born.

 8             I spent 22 days there under the protection of the civilian police

 9     because when I provided this statement and when I mentioned the names of

10     all those people that you have just read out, ever since then I've had

11     problems with people in the place where I was born.  And - how shall

12     I put it? - in the entire federation, I will always have problem with the

13     whole world because of that.  Let me tell you, I'm looking you in the

14     eye, Madam, we have a problem in this country where I come from.  They

15     are asking after me.  People are -- come to me at all costs.  They are

16     trying to get in touch with me.  If they only knew my address, they would

17     finish me off because I'm the only person in this courtroom that

18     sacrificed my own life and whatever I have now I fought for it.  I just

19     implored with the people who have a link to you, to the

20     International Criminal Tribunal, to bring me here as soon as possible.

21     I wanted to come at the moment when I provided that statement.  On the

22     12th March 2010, when I was released, in the last moments people came in

23     two jeeps and they were supposed to fetch me and take me to an unknown

24     destination.  I have witnesses for that.  I have proof of that.  I have

25     documents about those people who were waiting for me.  And in the last

Page 44829

 1     ten seconds, I managed to get -- to avoid getting into the car.  Those

 2     people were from the federation, from Sarajevo.  And they told me that

 3     later, only later did I learn about that.

 4             MS. PACK:  Perhaps, Your Honour, now would be an appropriate

 5     time, a convenient time.

 6             JUDGE KWON:  Yes, we'll have a break for 20 minutes, and resume

 7     at 11.00.

 8                           --- Recess taken at 10.38 a.m.

 9                           --- On resuming at 11.07 a.m.

10             JUDGE KWON:  Yes, please continue, Ms. Pack.

11             MS. PACK:  Thank you, Mr. President.  Can we go briefly into

12     private session, please?

13             JUDGE KWON:  Yes.

14                           [Private session]

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 44830











11  Pages 44830-44832 redacted.  Private session.















Page 44833

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19                           [Open session]

20             THE REGISTRAR:  We are in open session, Your Honours.

21             MS. PACK:

22        Q.   I'm just going to read on the first page what this report says in

23     relation to you, and, as I've said, some of it isn't legible but in the

24     larger second paragraph --

25             JUDGE KWON:  We will not broadcast this.

Page 44834

 1             MS. PACK:  It's not broadcast.

 2             JUDGE KWON:  Yes, sir?

 3             THE WITNESS: [Interpretation] I'm asking just for a second,

 4     please.

 5             JUDGE KWON:  Yes?

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15             JUDGE KWON:  Just a minute.  We are now in open session.  Shall

16     we go back to private session to discuss this issue?

17                           [Private session]

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 44835











11  Pages 44835-44837 redacted.  Private session.















Page 44838

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5                           [Open session]

 6             THE REGISTRAR:  We are in open session, Your Honours.

 7             MS. PACK:

 8        Q.   Now, Witness, I'm just going to read out to you a part of what

 9     was written about you in this report.  So let me --

10             THE ACCUSED: [Interpretation] Let me just ask:  These documents

11     are not being broadcast; correct?

12             JUDGE KWON:  Yes, we are not broadcasting this document at all.

13     Rest assured.

14             MS. PACK:

15        Q.   So back to the document.  I'm going to read an extract which

16     won't identify you.  On page 2, please, of the B/C/S and English -- could

17     we go to page 2 of the B/C/S.  Thank you.  Now I'm just going to read an

18     extract about halfway down the page:

19             "Intellectual abilities of" you "are limited.  They are at the

20     level of physiological dullness.  This is an immature, neurotic and

21     passively dependent personality."

22             And then we just go down.  The next paragraph begins again,

23     "Intellectual abilities," and details the category of physiological

24     dullness.  And then says:

25             "Information acquired, details certain tests, indicates that this

Page 44839

 1     is a non-integrated and emotionally immature person who has severe issues

 2     with interpersonal communication, view of parent figures, as well as

 3     views on primary and other family."

 4             And so it goes on, and it repeats those findings in the

 5     conclusion at the following page in the B/C/S.

 6             Do you remember those findings being made in relation to you?

 7     Don't need to say when or where.

 8        A.   Let me tell you after that that I am seeing this paper for the

 9     first time.  I only have the judgement.  I only have seen the judgement

10     from 1996.  They never gave me this paper and I don't know who wrote this

11     because during the retrial in 2008-2009, if that is the same man, then I

12     don't know what to say because during the retrial he defended me and he

13     described all that had happened to me he.  But if it is the man

14     from Banja Luka, from 1996, then that man did say awful things about me,

15     only to get me sentenced, and I had problems with psychiatrists because

16     one of them was telling the truth and the other one wasn't.  And nobody

17     ever showed this to me before you.  Somebody should bring this man to

18     court.

19        Q.   I'll leave it there.

20             MS. PACK:  I would ask for this document to be admitted, please,

21     perhaps all three pages is better than just this page.

22             MR. ROBINSON:  Yes, we object, Mr. President.  There hasn't

23     been -- the witness hasn't confirmed, first of all, the --

24             THE WITNESS: [Interpretation] I also object.

25             JUDGE KWON:  Yes, please continue, Mr. Robinson.

Page 44840

 1             MR. ROBINSON:  Yes, Mr. President.  The witness hasn't confirmed

 2     anything about the document.  I think it's also a very limited probative

 3     value, if there were some traits that would go to falsehoods, that might

 4     be relevant, but intellectual abilities marginally relevant to

 5     credibility.  So number 1, we don't believable that the document -- the

 6     foundation has been laid through this witness for the admission of the

 7     document; and, number 2, even if there were such a foundation, we think

 8     that the probative value is outweighed by any prejudice.

 9             JUDGE KWON:  Would you like to add anything, Ms. Pack?

10             MS. PACK:  Yes, Your Honour.  Whilst the witness might not have

11     confirmed this document, I -- he has broadly confirmed the fact of having

12     been examined in this period by psychiatrists.  I don't want to go into

13     too much detail.  But he certainly has confirmed that whilst he might not

14     remember the specific content of this, he certainly confirmed a

15     sufficient -- provided a sufficient basis for admission of this document

16     and it's a matter for you to consider the weight you attach to it.

17                           [Trial Chamber confers]

18             JUDGE MORRISON:  Mr. Robinson, is there any contest as to the

19     provenance of this document as opposed to the acceptance of its clinical

20     findings?

21             MR. ROBINSON:  Well, we don't have any information one way or the

22     other on it.  All we can see is on the face of the document, the very

23     same things that you could see.  So we can't tell you that, yes, we

24     dispute the provenance or we have some information that calls the

25     provenance into question.  But at the same time, we don't know that there

Page 44841

 1     is correct provenance to this document so we are basically in the same

 2     position that you are on that.

 3             JUDGE MORRISON:  The other issue is this:  You mention or

 4     submitted that the probative value is outweighed by prejudice.  Is this

 5     really a document where prejudice arises?

 6             MR. ROBINSON:  Well, it depends on how you view somebody being

 7     called dull and, you know, not having very much intelligence.  There is

 8     some prejudice to that, I think.  It doesn't really go to whether the

 9     witness ought to be believed.

10             JUDGE MORRISON:  Without being facile about it, Mr. Robinson, one

11     can imagine an irate teacher in school calling a student dull.  They may

12     not like it very much, but it's not really prejudicial.  It may be mildly

13     abusive as far as the pupil is concerned.

14             JUDGE BAIRD:  Ms. Pack, we would like very much to hear you reply

15     to Mr. Robinson.  Thank you.

16             MS. PACK:  On the topic of provenance?

17             JUDGE BAIRD:  Indeed, yes.

18             MS. PACK:  On that topic, I have what I would urge you to

19     consider is the first page of this document, which you've seen which

20     identifies the provenance of this report very clearly.  It passes the

21     report on to another party.  I'm not sure whether we should have dealt

22     with it in private session.  You can see the contents of the first page.

23     We can perhaps go back to it.  It says:  This is the report that was

24     taken on this date, and we now hereby forward it to you.  So, in my

25     submission, there couldn't possibly be an issue about the provenance of

Page 44842

 1     this document.

 2             JUDGE MORRISON:  Could you also address the Court on whether you

 3     think this is one of those classes of documents which raises the

 4     probative against prejudicial balance?

 5             MS. PACK:  I -- I don't think it does.  This is a -- this is a

 6     document which is being used to offer, in my submission, insights into

 7     this witness, and the issue of probative versus prejudicial, in my

 8     submission, doesn't arise.  It's not so prejudicial that it shouldn't be

 9     admitted.  It's not so probative for this to be a question that you

10     really need to consider.  It simply goes to offering insight into this

11     witness, into his motivations, into his capacity, perhaps, to be

12     manipulated.  But that is, in my submission, what is to be offered by

13     this document, and that's why I read it to the witness.

14                           [Trial Chamber confers]

15             JUDGE KWON:  The Chamber will receive it.  All the issues go to

16     the weight.  We will assign a number for this but we will put it under

17     seal.

18             THE REGISTRAR:  It receives Exhibit P6559 under seal,

19     Your Honours.

20             MS. PACK:  Thank you, Mr. President.  We will go on.

21             THE WITNESS: [Interpretation] May I be allowed to say a word,

22     please?

23             JUDGE KWON:  Not at this time, Mr. Witness.  Ms. Pack will ask

24     you a question.

25             MS. PACK:

Page 44843

 1        Q.   We are moving on, Witness.  You have written to the Prosecutor's

 2     office, we've seen, in Sarajevo urging them to take you seriously as a

 3     witness and a victim of genocide, haven't you?  We saw the letter that

 4     you sent them, yesterday?

 5        A.   Yes, I wrote to them.

 6        Q.   Let's return to the letter we saw yesterday.  It was admitted in

 7     evidence as D04182.

 8             MS. PACK:  Shouldn't be broadcast, please.

 9             JUDGE KWON:  I wanted to raise it with you, but, Ms. Pack, I take

10     it you're not going to spend more time than Mr. Karadzic?

11             MS. PACK:  Of course not, Your Honour.  Certainly I shouldn't be

12     anywhere near that time.  I think we are waiting for this document to

13     come up.

14        Q.   Let me just read out the first paragraph.  This is while you were

15     in prison in 2008.  And you say:  I am requesting the esteemed state

16     prosecutor's office, et cetera, an invitation to testify in the matter of

17     the horrific events, mainly war crimes, for which I could prove to be an

18     extremely important or even key witness.  Those are very extreme cases

19     for my personal knowledge which I don't want to detail in this request.

20     And then you request the esteemed prosecutor's office to invite you

21     urgently in your office in Sarajevo so I can state exact information

22     which is important for this state as well as the Prosecution in

23     The Hague.  Then you say:  I am a witness and a victim of genocide and

24     mass destruction of people who died in horrific events in the period 1993

25     to 1995:

Page 44844

 1             "Dear gentlemen, I know exact dates and executors of the serious

 2     crimes committed against the innocent civilian population."  It goes on

 3     to the passage that Dr. Karadzic read out in court yesterday.

 4             It's right, isn't it, Witness, that you were desperate to be

 5     interviewed by the Prosecutor's office?

 6        A.   Yes.  I wanted that, and I said that in my statement as well.

 7     I wanted that.  And this is the letter which I wrote when Bajro Kulovac

 8     visited me for the first time, when I was threatened and when I started

 9     telling about what Naser had done.  Then he took me to the bathroom and

10     told me that I was not to talk about either Naser or Zulfo Tursun.  And

11     then my problems escalated.  That was my first encounter with

12     Bajro Kulovac and then my second encounter with him was in 2010.

13        Q.   Let me just clarify because I'm a little confused.  You say, do

14     you now, that when you were first visited by Bajro Kulovac, that's whilst

15     you were in prison, you were threatened --

16        A.   Yes.

17        Q.   And taken to the bathroom, yes?

18        A.   Yes.  And it was the duty policeman who knew about that and then

19     the Republika Srpska and then the prison where I was, and you can see the

20     address where I was.  The entire prison and everybody jumped their feet

21     to defend me and protect me because people knew what would happen to me,

22     because I did not want to do what Bajro Kulovac wanted me to do.

23     I wanted to come on TV to publicly say what Bajro Kulovac and the

24     prosecutor's office in the federation of Bosnia and Herzegovina were

25     doing.  And at that time, I was prevented from saying what Naser Oric and

Page 44845

 1     the other commanders had done.  And ever since then my life has been

 2     endangered, and if you will allow me to tell the name of the person who

 3     was convicted for war crimes and sentenced to 16 years, the other to

 4     30 years, none of them were there, and people were going to liquidate me

 5     because of those papers.  The entire administration of the prison knew

 6     who was prepared to kill me, and if they had not stood up to defend me

 7     I would have been killed and I would not be able to testify here today.

 8     I can tell you the names of those people who saved me.  I don't see a

 9     problem in that, just say the word, and this is the message that --

10        Q.   This story you're telling us now, this story about being

11     harassed, it seems, during an interview that was conducted in prison,

12     right, that's the story you're telling us today, yes?

13        A.   Madam, when the prosecution arrived in the prison to talk to me,

14     when I started telling them my story about how things had happened, then

15     Bajro Kulovac, the prosecutor who worked for the prosecutor's office of

16     Bosnia-Herzegovina, took me to the corridor, I asked him to go to the

17     bathroom and a policeman who was on duty in the prison was behind us and

18     he told me, when it comes to Naser, Zulfo, and others, don't tell me

19     anything about them.  And ever since then, Madam, I've had problems.

20     When we completed that conversation, he went to Sarajevo.  A message came

21     to that prison where I was, that I would not come out of that prison

22     alive because there are Muslims there who had been sentenced to 20 years,

23     to ten years, I don't know whether they had been bribed to do things or

24     what, but the word came from outside that I had to be killed.

25             One of the convicts heard about that and informed the prison

Page 44846

 1     administration what would happen to me when I was taken out to lunch, and

 2     the police were waiting for us to come to lunch.  One of the convicts was

 3     in front of me, (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted) and I was

11     supposed to be in the prosecutor's office in Sarajevo and I was supposed

12     to testify about those people in Skelanci but nobody wanted to invite me

13     as a witness.  They believed a false witness, Enver Svico [phoen], and he

14     told them the story that was the story of my life and not his life.  He

15     lied.

16             JUDGE KWON:  You interrupted the interpreters, Mr. Karadzic.

17     Yes, what did you say?

18             THE ACCUSED:  Line 5, or at least the end of line 5, should be

19     redacted.

20             JUDGE KWON:  We'll consider that.

21             MS. PACK:

22        Q.   Nobody wanted to invite you as a witness?

23        A.   No.

24        Q.   Let me just clarify this encounter.  You gave a very long

25     statement to the SIPA investigators who came to interview you in prison

Page 44847

 1     in May 2008.  Do you remember that?

 2        A.   Yes.  If you're talking about the arrival of Bajro Kulovac,

 3     I remember that.

 4        Q.   Yes.  And you signed, or perhaps you don't remember, we can look

 5     at it in a moment, but you signed your name on every single page of that

 6     statement and at the end of it, yes?  Remember that?

 7        A.   I remember that.  But, Madam, I was never invited to testify.

 8     Why I wasn't?  Because they did not want to invite me to Sarajevo.  It is

 9     easier to convict somebody on false evidence.  And after I gave my

10     statement, when Bajro Kulovac returned to Sarajevo and when Naser and

11     everybody else learned of what would happen, ever since then my life has

12     been in danger.  I'm not afraid of that statement before you or before

13     God.  You can show it to whoever.  You can play it for the entire world.

14     There were perhaps three or four CDs altogether.

15        Q.   Yes, can we just clarify.  This statement that you gave, a number

16     of pages which you signed, you gave that statement before or after you

17     were taken to the bathroom by Bajro Kulovac, as you've described moments

18     ago?  I would just like to clarify with you what happened in that

19     encounter.

20             THE ACCUSED:  Could it be --

21             THE WITNESS: [Interpretation] Before, before.

22             THE ACCUSED:  -- shown to the witness so to avoid any confusion?

23             MS. PACK:  We'll get there.

24        Q.   Before we look at your statement I want to ask you about one

25     thing that you spoke about this morning and yesterday.  And I want to

Page 44848

 1     deal with this carefully because I think it's upsetting for you to deal

 2     with it.  It's 1992, in Bratunac.  You told us yesterday, transcript

 3     T 44745, you told us that your mother and son stayed when you were taken

 4     off and held at the location in Bratunac you described while you were

 5     taken to the stadium.  Now, is that right?  Is it right that after you

 6     were taken off to the stadium, you never saw your son and your mother

 7     again after that moment in 1992?

 8        A.   Madam, may I start?  Let me answer.  When I was taken out of the

 9     cellar of my house, together with four or five other people, my mother

10     and my son stayed behind in the house, on the first floor.  When we were

11     taken out of that basement, when we -- and when we were taken to the

12     gate, do you want the name of those people?

13        Q.   We don't need names.

14        A.   When they took us to the gate, it was only then that my mother

15     came out of the house carrying my first son.  I was the last in the

16     column.  We were being taken to the football pitch.  And I didn't manage

17     to see who opened fire.  There were two men.  I didn't have the time to

18     turn around to see who had killed them because when I was turning my head

19     to see who had fired the shots, I could only see them falling down.  So

20     much for me on that.  And as for my mother and my son, another

21     prosecutor's office will investigate that because I can see that you here

22     do not want to hear the names of those people.  They were found last year

23     and they were buried.  First they were exhumed and then they were

24     reburied.  You can go to Bratunac and you can see it for yourself.  And

25     don't ask me about that, about my family, about relatives.  When you

Page 44849

 1     received those papers, why didn't you come looking for me?  Why didn't

 2     you come and ask who that man was?  Where is he?  Why didn't you look for

 3     me?  You and this Tribunal.  You in Sarajevo, when you found the papers,

 4     why didn't you say we need to talk to this man?  Let's see where he is.

 5     And the things that were imputed on me that I had been convicted for the

 6     killing of one Muslim, it was down to the politics, Bosko Djukic, did

 7     that, Naser did that, to make sure that I did not come out of the prison

 8     alive.  Bring them here.  I want to look them in the face.  I want to see

 9     all the documents.  I want to say to the Judges here all the documents

10     that you are going to show to me here today, no problem at all.  I can

11     sit here for the whole day today or for the entire month.  Show me all

12     the documents.  I want to see these people who authored those documents

13     face to face.  I want them all to sit here like these people are sitting

14     here today.  I want to look him in the eye.

15             MS. PACK:  Can we go, please, to 65 ter 25520.

16        Q.   Now, this is the witness examination record, the record of your

17     interview with SIPA.  Can we have this not broadcast, please.  Now, I'm

18     just going to read out the content of the first page while we are waiting

19     for it to come up.  It's the title page.  It's an interview -- a witness

20     examination record and it's dated the 16th of May, 2008.  And you are

21     being interviewed by two SIPA investigators - you see it now, it's come

22     up - Bajro Kulovac and Zarko Kalem.  And you see your name there?  Can

23     you see all that there on the first page?

24        A.   Yes, I can.

25        Q.   And if we just go a few pages on, just to get a sense of this

Page 44850

 1     document -- well, you can see, first of all, your signature is at the

 2     bottom of this first page; right?

 3        A.   Yes.

 4        Q.   And you remember signing every page of this document and being

 5     warned --

 6        A.   I've just told you that I signed everything, and as for this

 7     other gentleman, SIPA investigator Zarko Kalem, is he a fat guy?  If he

 8     is then bring him here to the courtroom, whenever you want, I'll be here

 9     and I will listen to him telling you what was happening to us.

10     I personally invite this man, Zarko Kalem, to come here and tell you what

11     happened, how I made sure to escape the destiny that had awaited me and I

12     did it already in that bathroom.  I managed to save myself.  He can tell

13     you that.

14        Q.   So it's the Zarko Kalem, is it, who was in the bathroom with you?

15     What do you say he did in the bathroom?  This is in May 2008 when he

16     interviewed you.

17        A.   Madam, Bajro Kulovac was with me in the bathroom, and if this man

18     Zarko Kalem, is a fat guy, he will know when I returned from the

19     bathroom, that I started shouting and screaming and he knows what the

20     police officer told him when I had come out of the bathroom.  I'm

21     inviting this man to tell you.  And that policeman who escorted me, he

22     returned and when I said to that guy, Zarko, and that Prosecutor was

23     there and that recording clerk who were recording on CD what I was

24     saying, and when he was told what had happened, from then on I never

25     wanted to talk to them again.  And this guy, the fat Zarko Kalem, the

Page 44851

 1     investigator, he said that he would write a complaint about the conduct

 2     of his colleague towards me.  So you invite him and I am inviting also

 3     the police officer, the sergeant, as a witness and I don't want to

 4     discuss this document at all.  This document should have been discussed

 5     in Sarajevo.  I should have been invited as a witness instead of being

 6     threatened with murder while at the same time an innocent man is being on

 7     trial.  And because of that in 2010, I was beaten up because I did not

 8     want to overlook this.  I gave a statement to that effect.  I asked them,

 9     why did you call Skelanci.

10        Q.   Let's just try and deal with this occasion, and not go on to

11     other matters so we are dealing with this occasion.  You write this long

12     statement which you sign at some point, take a long -- you write this

13     long statement, you have this long interview, rather, you then go to the

14   (redacted)

15   (redacted)

16        A.   Yes.  In the prison, in the presence of the police sergeant.  And

17     when I was supposed to testify, nobody called me because they realised

18     that I would give them all the details.  And if you think that I am a

19     psychopath or something of that kind, I'm inviting you to put me on a lie

20     detector and show me documents because I had been through all of that for

21     three years, and before all of you --

22        Q.   That's fine --

23        A.   Don't make me look like a fool.  I'm telling you this was a

24     fabricated process.  Bajro Kulovac and Damir Alagic fabricated all that

25     and the other guy, what's his face, Batko Izetbegovic.  Madam, my life

Page 44852

 1     was at stake.  I was threatened for having spoken about all the cases,

 2     about that diary.  I was threatened with liquidation.  I was threatened

 3     that I would never leave the prison alive.  People came to me from SIPA,

 4     all the Gods came to fetch me so I wouldn't appear here.  Damir Alagic

 5     called me on the telephone and threaten on the telephone.  He told me

 6     that I was looked for by The Hague and if -- he told me don't talk to

 7     them before I arrived.  I don't want to discuss this.  I will discuss

 8     this only when I see Bajro Kulovac and others.  This fell through and

 9     because of that I had to sign the paper that I talked about because they

10     forced me to sign a paper at the SIPA that I was never in Srebrenica.

11     I don't want to discuss this at all.  When I see these people here then I

12     can talk to them eye to eye.  Eyeball to eyeball, can I talk to them.

13     I don't want to discuss these documents before I see these people before

14     this International Tribunal, the most famous Tribunal in the world for

15     seeking the truth.  They want to make money.  That's all they are after.

16     They are fighting for the votes.  And my people are starved even more

17     than during the war.  My people are more afraid.  Muslims, Croats and

18     Serbs are more afraid now than they were during the war.  I'm talking on

19     behalf of everybody.  I want this document to be tendered and admitted

20     into my defence.  I want this Trial Chamber to call all these people,

21     Damir Alagic, Kulovac.  And that Alagic called me on the telephone in

22     2010.  He says:  The Hague is after you, if they find you, you don't tell

23     them anything before I arrive, I will do everything.  And he said that he

24     sent some papers here, and he says:  You no longer exist in this story.

25     I saved your life once and that's it.  And that was when Naser Oric --

Page 44853

 1        Q.   Okay --

 2        A.   Hold on.  You stop threatening me.  My life is at stake, not

 3     yours.

 4             JUDGE KWON:  No, not at all.  Ms. Pack was never threatening you

 5     at all.  Please listen to the question.

 6             THE WITNESS: [Interpretation] I didn't say, Judge, that she was

 7     threatening me.  I was threatened because of the documents that she is

 8     now showing me.

 9             THE ACCUSED: [Interpretation] No, no.  The transcript is wrong.

10     The transcript is wrong.  The witness did not say that the Prosecutor is

11     threatening him.  He says that he has been threatened.

12             THE WITNESS: [Interpretation] Because of these papers, my life is

13     at stake, and now you're showing me these papers from the time when they

14     were done in 2008, 2009.  Why didn't you ask me to come when these papers

15     were drafted?  Why didn't you look for those people who took that

16     statement?  Why didn't you invite me here?  I wanted to look you in the

17     face then and tell you what I know like I'm telling you now.  Why didn't

18     you ask me to come then?

19             JUDGE KWON:  I'm stopping you.  Mr. Witness, I stopped you.

20             THE WITNESS: [Interpretation] I don't want to talk to you any

21     more.  Can I get some water?

22             JUDGE KWON:  Yes, Ms. Pack.

23             MS. PACK:  Thank you, Your Honour.

24        Q.   It's difficult, Witness, isn't it, when you've been caught in a

25     lie; right?  It's difficult not to lose your temper.

Page 44854

 1        A.   Nobody, Madam, caught me in a lie here because I'm not afraid of

 2     you or this Court when I'm telling the truth.  It's difficult for you

 3     because you're unable to bring this Kulovac and this Zarko people before

 4     this Court to tell you what really happened.  And I can bring you the

 5     whole prison administration and the police sergeant who was on duty then

 6     and two more people to testify what I was told in that prison and how

 7     I was threatened.  I have five witnesses and you bring me this Zarko

 8     Kalem and Bajro Kulovac to confront me.  And I can bring five more

 9     witnesses to confirm what had been done to me.  I didn't come here,

10     Madam, to lie, that's one.  And I'm not afraid of that.  I was telling

11     the truth.  And while I was interrogated and while I went in the field,

12     I passed everything, I passed the lie detector test and I passed

13     everything and all the documents in evidence.

14        Q.   [Overlapping speakers]

15        A.   Everything that Sarajevo writes, I don't give a damn about it

16     until I see those people from Sarajevo here.  What Bajro Kulovac, what

17     Damir Alagic writes, this Bakir Izetbegovic, until I see them sitting on

18     that bench over there, then I can bring my own witnesses to testify what

19     they had done with my life.  The rest I will not discuss until that time.

20        Q.   We will get this over much quicker if you answer more coherently

21     and less lengthily.  Now, let me just ask you:  What do you say happened

22     in the bathroom at the prison just after your interview when you signed

23     this interview?  What do you say happened?  And just tell us in a

24     sentence.  Don't need to give us -- go into anything else.

25        A.   Madam, what happened is that I should not dare speak about

Page 44855

 1     Kravica or Srebrenica at all for fear of Bajro Kulovac.  I was told that

 2     by Bajro Kulovac in the presence of the police sergeant, and when

 3     I returned inside with the police sergeant, this Zarko Kalem, his name is

 4     written here, I was shouting, I was screaming, Why are you threatening

 5     me, et cetera, et cetera, and then I left the office.  And the news of

 6     that incident reached the deputy minister of Republika Srpska, who is

 7     being attacked because Bajro Kulovac and Damir Alagic were telling him

 8     that I'm crazy.  They showed a programme, 60 minutes on the BHTV.

 9     Damir Alagic appeared in that TV show saying that I'm crazy, that I don't

10     know what I'm talking about, et cetera.  That's why I don't want to

11     discuss any papers from Sarajevo until I am able to confront these

12     people.

13        Q.   Were you hit, were you beaten, by the investigator when you were

14     in the bathroom?

15        A.   In the bathroom I was told only that, it was in 2010 that this

16     man beat me up.

17        Q.   You see, it's pure fantasy, isn't it, Witness, pure fantasy, what

18     you're telling us?

19        A.   If it's fantasy bring those people here to confront me, if I'm

20     fantasising.

21        Q.   Let's look at what you told the investigators when you were

22     interviewed.  It appears at some length.  Paragraph 5 of the statement,

23     which is still up but not being broadcast.  We are going to the English

24     at page 2 and the B/C/S at page 4.  Now, in these paragraphs, you tell

25     the tragic story of the death of your son.  It's a little different from

Page 44856

 1     what you told the Court today.  Let's read it.

 2             MR. ROBINSON:  It's page 5 in the English.

 3             MS. PACK:  I think in the e-court actually -- my apologies.

 4     Absolutely right.  It's page 5 in the e-court in English, and page 4 of

 5     the B/C/S, as I said.

 6        Q.   Now, I'm going to not read out the names:  My mother came out of

 7     the house carrying my son, child from my first marriage.  As she was

 8     coming down the stairs, when she was on the second stair holding him in

 9     her arms I saw - this is a person I'm not going to name - approaching my

10     mother and placing a rifle barrel against my son's head and fired it so

11     that he killed both my mother and son by one bullet.  The child fell out

12     of her arms from the impact of the shot and the bullet hit my mother in

13     her chest causing her to fall off the stairs.  Other than myself, my

14     father, someone else and a woman were observing this.

15             So you describe this event in some detail and you note that your

16     father also witnessed the manner in which your son was killed.  Now, was

17     that the truth that you told on that occasion?

18        A.   Madam, my father was not a witness to this, nor was he able to

19     see.  That's two.  Three:  A moment ago I told you also that I heard a

20     shot fired from a rifle but I didn't see by who.  And this name you

21     actually didn't mention, that name features in the statement in my

22     evidence today and yesterday.  He was on the spot, and he's the man who

23     knows best about the way my mother was murdered.  And with that man -- I

24     had an agreement with that man many years later because once he had saved

25     my life and another time I saved his life.  When somebody gives you your

Page 44857

 1     life as a gift, whereas he could have killed you, it's a great gift.

 2             THE INTERPRETER:  The interpreter didn't hear the last sentence

 3     about 48 hours.

 4             THE WITNESS: [Interpretation] You also see the name and surname

 5     of another person who lives in Holland here.  You can bring him, I'll sit

 6     over there on that side.  And if you want me, I'll tell you his name, the

 7     man who was there and who has been living in Holland for I don't know how

 8     many years.  The man who was brought to Visoko together with me for an

 9     exchange, you can bring him as well.  Muhamed Ahmetovic, that's the one.

10             MS. PACK:

11        Q.   So you now say your father didn't witness this event but other

12     than that, this is your account of your son's tragic death?

13        A.   Ma'am, I don't know about my father, whether he was ever there.

14     All I know is that when I saw him, when I lived with him for a couple of

15     months, he told me somebody had visited him at the house, at his house,

16     and he refused to talk to that person.  But I had even greater problems

17     because he wasn't willing to talk, he wasn't willing to tell the truth.

18     Whenever I mention about the things that had happened, including the

19     murder of my mother, he says:  I don't know about it.  I won't talk about

20     it.  I don't know what kind of agreement he had made with Bajro Kulovac,

21     but I have other witnesses.  I once came to see him with a woman who had

22     been a witness to this but he wasn't willing to discuss it even then.  He

23     has a new child, a new wife.  He was enjoying benefits that I was dead.

24     He went to Tuzla, then he came back to pick up his things.  He said you

25     can't live here any more, et cetera.

Page 44858

 1             THE ACCUSED: [Interpretation] Transcript.

 2             JUDGE KWON:  Ms. Pack, please ask your question again.

 3             MS. PACK:

 4        Q.   Your father --

 5             JUDGE KWON:  Don't talk about father, yes.  But she asked about

 6     your son's death.  What you stated in the statement is correct?  That was

 7     the question.

 8             THE WITNESS: [Interpretation] Judge, listen to me carefully,

 9     listen carefully to what I'm going to tell you.  You have that statement

10     that I gave yesterday.  Can I say the name and surname of that man?  When

11     the man invited me and said that he would have a drink, that's his

12     brother.  That's the younger brother.  And this story is about the elder

13     brother.  Since we had an agreement, you will let me go, you will let me

14     live, I'm not going to deal with this case, nobody is going to arrest

15     this man, if I'm able to forgive that, I, who have suffered the most, and

16     I don't want this discussed, the matter of my mother and son, I want you

17     to bring this Ahmed -- Muhamed Ahmetovic.  He lives here in Holland.

18             JUDGE KWON:  Did you say something, Mr. Karadzic?

19             THE ACCUSED:  There is problem with transcript.  The whole

20     sentence is missing from the page 61, line 15 and 16, witness said that

21     his father didn't want to tell the truth.  It is not recorded.

22             JUDGE KWON:  Very well.

23             THE INTERPRETER:  Interpreter's note:  It is in a couple of lines

24     before that, line 16.

25             JUDGE KWON:  The interpreters are telling us that it's in --

Page 44859

 1     already in the transcript, line 16.  Yes.

 2             Please continue, Ms. Pack.

 3             MS. PACK:

 4        Q.   I'm still not clear, Witness, that you answered my question.

 5     This account that you give here in the statement, this very detailed

 6     account of the circumstances of your son's death, which you saw, do you

 7     say this is true?

 8        A.   Ma'am, you have really decided to make me look like an idiot.

 9        Q.   Witness, I just want you to answer the question, okay?

10        A.   I don't want to discuss this.  I let that man go free.  He's

11     living his own life.  He offered me my life in exchange, and end of

12     story.  End of story about this document.  I don't want to hear one more

13     word about it.  And don't make me talk here and make me look like a fool.

14     I've told you, all these papers regarding this statement are not a

15     problem but I don't want to judge this man.  When I was telling the

16     truth, you should have come for me then and brought me here.  When I was

17     telling the truth, I was getting only threats in return.  Why have you

18     not been looking for me, Madam?

19        Q.   Witness --

20        A.   I'm asking for a break.  I cannot listen to you anymore.  You are

21     trying to depict me like I don't know what.  Let's go to the lie

22     detector.  I need a break and I need a cigarette.  In all over the world,

23     everybody has the right to a break now and then.

24        Q.   Witness, you are not answering this question because unbelievably

25     you lied about the circumstances of your own son's death.

Page 44860

 1        A.   I answered you yesterday and I wasn't lying about my son's death.

 2     I did not want to mention the name of that man.  That's the only problem.

 3     I told you a moment ago, when you asked me, that we were getting out from

 4     the basement and my mother and my son were also coming out of the house.

 5     I didn't see that man.  I just did not want to mention his name.

 6     I don't -- I want a cigarette.  I don't want to go on a hunger strike

 7     here.  I didn't go on a hunger strike even when things were much worse

 8     for me.  I was telling the truth.  People were writing it down on a

 9     computer.  I told you I was the last in the column of people coming out

10     of the basement.  I heard the shot.  I didn't see the man, so I don't

11     want to mention that man.  This written on this paper, it means that

12     I saw the man who was shooting but I don't want to mention him.  You can

13     repeat the lie detector test.  I just didn't want to mention the man who

14     shot, who fired that shot.  You know what, if you don't let me out of

15     here, I'm going to light one here.  I am inviting, I'm calling this

16     witness, Muhamed Ahmetovic, to come here because he was there and he saw

17     it better than anyone.

18             JUDGE KWON:  I'm stopping you, Mr. Witness.  If you have further

19     questions, we will take a break, Ms. Pack.

20             MS. PACK:  Yes, just a few more.  I won't be long, Your Honour.

21             JUDGE KWON:  How long?

22             MS. PACK:  I'll aim to wrap it up in 15 or 20 minutes.

23             JUDGE KWON:  We'll take a break then.  We will have a break for

24     45 minutes and resume at quarter past 1.00.

25                           --- Recess taken at 12.29 p.m.

Page 44861

 1                           --- On resuming at 1.18 p.m.

 2             JUDGE KWON:  Yes.  Shall we continue.

 3             MS. PACK:  Thank you, Mr. President.

 4        Q.   After your release from prison, you went to the offices of the

 5     State Investigation and Protection Agency, SIPA.  You went there on the

 6     16th of March, 2010; right?

 7        A.   Madam Prosecutor, you should ask me how I got to SIPA in 2010.

 8     It wasn't of my own accord, 2010.

 9             MS. PACK:  I'd like to bring up a statement, an official record,

10     please, it's 65 ter 25500.  Shouldn't be broadcast.

11        Q.   This is an official record of an interview with you on the

12     16th of March, 2010, a SIPA official record.  And I'm going to read out

13     what it says, I'll be careful not to identify you.  If Mr. Robinson is

14     concerned about me reading any of the paragraphs specifically, then I'd

15     be grateful if he would let me know in advance as we go through.  So the

16     first paragraph, just to summarise it, you came voluntarily to the

17     offices of the State Investigation and Protection Agency, gives the

18     address, on 16th of March, 2010.  He was accompanied by Alagic, Damir,

19     attorney at law, whose offices and so on.  Damir Alagic is your lawyer,

20     right, was your lawyer?

21        A.   Yes, who ruined my life.

22        Q.   You've been making these allegations today and in your statement

23     and previously, he hit you, he beat you with the investigator who

24     interviewed you in 2008.  We've heard that.  Let's just go on with this.

25     Witness stated that the reason why he wanted to talk to members of SIPA

Page 44862

 1     was the fact that he was engaged by lawyer Goran Petronijevic as a

 2     Defence witness for The Hague defendant Radovan Karadzic, immediately

 3     after his release from prison on the 12th of March, 2010.  Witness was

 4     instructed what and how to testify in written form.  That's the

 5     allegation you made to SIPA on the 16th of March, 2010;

 6     right?

 7        A.   No, Madam.

 8        Q.   Well, let's see how it goes on.  We will jump the next paragraph,

 9     we'll go down to the last one on that page in the English, it's same page

10     in the B/C/S, it's the fourth paragraph in the B/C/S.  A few -- talks

11     about a discussion in the warden's office in the prison, a certain

12     correctional officer told you that some people who wished to talk to you

13     had arrived.  She told witness that she had written authorisation that

14     they can talk to him and that people in question.

15             THE INTERPRETER:  Could we please have the reference in B/C/S so

16     we can precisely read what you are reading from to the witness.  Thank

17     you.

18             MS. PACK:  My apologies to the interpreter.  It's the fourth

19     paragraph of that page that you see on the screen.  I just paraphrased it

20     a little.  But I'm going to read it now directly.

21             JUDGE KWON:  Is it fourth paragraph?

22             MS. PACK:  Yes, it is.

23             JUDGE KWON:  Fourth paragraph refers to 12th of March, 2010.  But

24     I don't see such date in the fourth paragraph in English.

25             MS. PACK:  That's the fifth paragraph.

Page 44863

 1             JUDGE KWON:  Yes, fourth, I see.  Very well.

 2             MS. PACK:  Yes, so the fourth paragraph, I paraphrased it a

 3     little.  And then we go over the page in English, please, to page 2 and

 4     stay on the same page in the B/C/S.  That's the fourth paragraph in the

 5     B/C/S on the first page, that is when Petronijevic, Goran, came to visit

 6     him with another person whom witness did not know.  On that occasion,

 7     Goran allegedly told witness that he would be released and that he would

 8     ensure witness was protected from threats from Bosniaks, that Goran would

 9     change witness's name and that he would get him papers on the name of -

10     I won't read out the name - that witness would initially be taken to

11     Serbia and that after his testimony he would be returned to a third

12     country - I won't name the third country - from where he had been

13     deported and where his wife and daughter lived.  They talked to him --

14        A.   Madam, I don't have a daughter.

15        Q.   Is that the only area which you disagree with here?  The rest is

16     accurate, is it?

17        A.   It's not accurate.

18        Q.   Let's go on.

19        A.   I want you to show me the rest, please feel free to go on.

20        Q.   They talked to him from 11.00 in the morning until 19.30.  The

21     interview was allegedly recorded by an audio recorder.  They said that he

22     had been in Srebrenica the entire time.  They said that he should talk

23     about the events in Srebrenica, particularly about the events after the

24     fall of Srebrenica.  They told him that he needed to co-operate with them

25     in full.  Next paragraph.  Witness was released from prison on the

Page 44864

 1     12th of March, 2010, and was met by three persons at the parking lot in

 2     front of the gate.  These persons were lawyer, Petronijevic, Goran, and

 3     another two persons unfamiliar to him.  They told him to get into the car

 4     with him.  The vehicle was a red Golf 2.  He did not remember, et cetera.

 5     It goes on.  As soon as they arrived - this is the place where you were

 6     taken to, perhaps it's better not to read it out - the two persons who

 7     accompanied Petronijevic took him to the police station where witness

 8     regularly reported to the police.  Witness was obliged to do so because

 9     of his conditional release.  Witness stated that all police officers were

10     familiar with the two persons accompanying him and that everyone said

11     hello to them.  After they had left the police station, witness was

12     allegedly taken to Motel Peric - I won't say where that was - where he

13     was met in room 33 which was on the second floor.  He spent the night

14     alone in the room.  In the morning he was picked up by the same person.

15     It goes on.  A lot of detail about this -- this -- the circumstances of

16     your stay in this motel.  And I'll just go on to the following page in

17     the English, and I think --

18             JUDGE MORRISON:  I think you're going slightly too fast for the

19     French translation.

20             MS. PACK:  My apologies.

21        Q.   Witness spent the night in that apartment.  In the morning of the

22     next day, Goran Petronijevic and these two other persons came to the

23     apartment.  Goran brought quite a few pieces of A4 format printouts.

24     Goran told witness to read those pages, to study and memorise what was

25     written as he would need to testify in relation to what was said in the

Page 44865

 1     text.  Goran also told witness that he would be taken to Belgrade on

 2     Wednesday where he would give testimony at the prosecutor's office.

 3     Before they had left, witness requested a TV set or a radio, and so on.

 4             I'll leave the next paragraph, a few more details.  And then we

 5     get to tomorrow morning, that is on the 15th of March, 2010,

 6     Goran Petronijevic and these two other persons came to the apartment

 7     again.  Petronijevic brought a voice recorder and posed questions to

 8     witness.  Petronijevic would then show him with his finger which portion

 9     of the printed text he should read.  The witness allegedly read out parts

10     of text shown to him by Petronijevic.  The witness stated that he

11     remembers that his name and general information which he read were

12     written at the beginning of the text, the rest of the text and the

13     questions had to do with the column which headed towards Tuzla after the

14     fall of Srebrenica.  The questions had to do with whether or not Muslims

15     killed each other, whether they opened fire on Serbs.  He replied to

16     these questions by reading the text from the printouts according to which

17     Muslims did kill each other.  He was then asked about Naser Oric,

18     Tursunovic and others, and he read out prepared answers.  The interview

19     took about two hours.

20             Goes on.  Following page in the English, after the interview was

21     over, Petronijevic and those two other persons left the apartment, told

22     them he can go out, but that he should be careful not to be recognised.

23     And then apparently before he left the apartment, he - that's you - hid a

24     number of pages given to him by Goran under the drawer and underneath the

25     oven in the apartment while the rest of the pages remained on and

Page 44866

 1     underneath the table.  Then you go on later, he phoned Alagic, Damir, the

 2     lawyer who previously represented him in the murder case, goes on to

 3     describe your movements, and then the lawyer -- then you check in with

 4     your lawyer.  In the end you say -- in your last paragraph you say -- at

 5     the end, the witness stated that the information in his statement given

 6     to the SIPA representatives was incorrect but that he had given such a

 7     statement because of the fact that the interview was conducted in the

 8     offices of the prison where he did not feel safe.

 9             It goes on.

10             So, these allegations, these are allegations you made about

11     Goran Petronijevic to SIPA when you got out of prison because you thought

12     that these allegations might finally get you the attention of the BiH

13     state authorities and SIPA; right?

14        A.   No, Madam.  I just have a wish for you to give me an answer.  Who

15     is the man who wrote this?  (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 44867

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10     (redacted)  I would want to see him so that he could

11     say before all of you when it was that I gave this statement.

12             JUDGE KWON:  Just a second.  Could we go back to private session

13     briefly?

14                           [Private session]

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 44868

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15                           [Open session]

16             THE REGISTRAR:  We are in open session, Your Honours.

17             JUDGE KWON:  Yes.  Please continue.

18             THE WITNESS: [Interpretation] Judges, this person that signed

19     this statement and wrote it, I never sat with this man, never had coffee

20     with him, never talked to him.  That is one thing.  And now, also, what

21     is mentioned here, (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25             JUDGE KWON:  Please continue, Ms. Pack.

Page 44869

 1             MS. PACK:

 2        Q.   Well, Witness, you now lie and say you didn't make these

 3     allegations and you cover yourself, don't you, with this story about

 4     being beaten up by the SIPA investigation and by your own lawyer; right?

 5     Covering yourself, covering the first lie.

 6        A.   Madam, I never said that Damir Alagic beat me.  What I said was

 7     that I was beaten by Bajro Kulovac in his presence.

 8        Q.   Well, it's a matter for the record but you said earlier today

 9     that he hit you.

10             MS. PACK:  I'd like to admit this document, please.

11             JUDGE KWON:  Yes.

12             THE WITNESS: [Interpretation] Bajro Kulovac.

13             JUDGE KWON:  Mr. Robinson?

14             MR. ROBINSON:  No objection.

15             JUDGE KWON:  Yes, we will receive it under seal.

16             THE REGISTRAR:  It receives Exhibit P6560 under seal.

17             MS. PACK:

18        Q.   Then you went on to report your story to the press, didn't you?

19             MS. PACK:  Can we have 65 ter 25435.

20             THE ACCUSED:  Not to be broadcast, too.

21             MS. PACK:  This is not to be broadcast, obviously.

22             THE WITNESS: [Interpretation] May I say something?

23             MS. PACK:

24        Q.   Wait for my question, please.  So you went to the press with your

25     lawyer and you reported your story about Goran Petronijevic, the story

Page 44870

 1     that would give you the notoriety you were seeking; right?

 2        A.   Let me tell you straight away about the press.  You see this

 3     picture here?  You see this Damir Alagic sitting there?  Do you know

 4     where this picture was taken and how it was taken?  Now, Damir Alagic

 5     wanted to present me to the public in a certain way, just to cover up the

 6     fact that I left Bijeljina, disappeared from Bijeljina.  As far as I

 7     know, about this press and all the rest, what was happening in SIPA,

 8     according to my information, you in The Hague did know about that and my

 9     life was in danger at the time.

10        Q.   Let's just look at this story, shall we?  So its title we can

11     see:  How Karadzic's attorney recruit witnesses.  You say they changed my

12     name so that I could testify in The Hague, and then you've got a long

13     paragraph, and it basically duplicates your allegations that you made

14     when you voluntarily attended SIPA's offices.  It repeats those

15     allegations.

16             So in the second paragraph, it says, witness -- the witness, whom

17     the RS Supreme Court testified to five years in prison for allegedly

18     killing a Bosniak from Srebrenica in 1995, goes on to say what the lawyer

19     says about that, your lawyer, supporting your claims, says we are

20     supposed to testify in The Hague under a new identity that numerous

21     killed men from Srebrenica were actually alive or that the Muslims

22     themselves had killed them.  And then he goes on to describe your

23     account, and we can see that here in the English on the first page, and

24     then we can go over.  It basically duplicates what you said to SIPA.  We

25     can go over in the English to the following page.  Under the heading:  He

Page 44871

 1     was learning names, it says:  Following this, the witness continues, an

 2     attorney visited him every day and brought in papers which he had to

 3     learn by heart.  It quotes you:  I had to know but heart the names of 36

 4     Muslim who are listed as killed in Srebrenica whom I would testify to in

 5     Belgrade and in The Hague that they were alive or that the Muslims had

 6     killed them.  However, whilst breaking my fingers and drawing crosses on

 7     my body, they did manage to extract a confession from me for something

 8     I hadn't done once they won't ever again.  Seem to be alleging there that

 9     these lawyers, Dr. Karadzic's lawyers, were drawing crosses on you.  I'm

10     not going anywhere from the federation, the witness told us, who managed

11     to escape, and so on.  There we are.  This was the story you gave to the

12     press; right?

13        A.   That's not right, Madam.  Damir Alagic, when they took this

14     picture of me, he went to this radio television, wherever this paper is

15     from, and they gave that interview and they rigged all of it.  That is

16     one thing.  Number two, the Defence - how do I put this? - Karadzic's

17     attorneys they never cut me.  They never beat me.  They did not ask me to

18     do anything by force.  I was cut in Bratunac, in the camp, on the

19     10th of May, 1992.  What they wanted, not from -- they didn't want me to

20     speak about that ever.  And then Damir Alagic, they put this here so that

21     they could all launder this - and how do I put this? - to have this case

22     removed.  When I was brought from the police in Sarajevo by Bajro Kulovac

23     and Damir Alagic they frisked me and they found a calling card in my

24     pocket, a few cigarettes, a telephone, a lighter, and also I had problems

25     with that telephone.  The main co-ordinator knows that.  How do I put

Page 44872

 1     this?  The Karadzic Defence main co-ordinator, when the police in my

 2     native town protected me.  For this statement, and for the statement at

 3     that moment, you were informed about that, you in the Prosecutor's office

 4     in The Hague, you were informed what was being done to me, what was

 5     happening to me.  Through the public, Damir Alagic tried to remove me,

 6     just so that I wouldn't reach you and then you, here, from The Hague,

 7     called and you did what I said in my statement, that Damir Alagic called

 8     me on the phone and said The Hague is looking for you, do not contact

 9     them by any means until I arrive there, and I will take care of all of

10     that.

11             Madam, so all of this is what I refer to in my statement.  All of

12     this was rigged.  I was framed.  And I've been saying that yesterday and

13     today.

14             Sorry, Judge, I was informed in those moments when I was brought

15     to SIPA, to this main director there, and I said that in my statement,

16     that the director, the main director of SIPA asked me whether I was

17     forced to - how do I explain this to you? - did I say this because I was

18     forced to or did I do it of my own free will in Bijeljina to

19     Nebojsa Jovanovic, Prosecutor, or did I do that voluntarily?  And I said

20     that in my statement and when I tried to say to him, to this director of

21     SIPA, that I was not forced to provide anything, and it's contained in my

22     statement, and then Damir Alagic put his hand on my left shoulder and he

23     said I'll take care of all of that.  I was then taken out of SIPA and

24     I was outside for two days until I was found by another man who knew me

25     from Konjevic Polje.

Page 44873

 1        Q.   Witness, wait, wait, wait.  You had your photo taken for the

 2     papers; right?  This is a photo of you taken for the press on the 16th,

 3     17th of March; right?

 4        A.   Yes.  This is a photo, but are you wondering how come I'm sitting

 5     next to Damir Alagic in this photo?  Look better.  Took the original of

 6     the paper and you will see that we are talking about two different

 7     snapshots, two different photos.  And they were rigged.  And Damir Alagic

 8     wanted to do his utmost not to have him here.  You know, you're a

 9     Prosecutor and the co-ordinator is familiar with the case because at the

10     time he also had problems because the article was about him as well.

11     They searched me, they found his visit card, his calling card, and

12     Damir Alagic composed all this based on that calling card because he

13     wanted to prevent me from contacting this gentleman whom you can see.

14     Damir Alagic took that calling card from me and he said, I'll deal with

15     that, to prevent me from contacting that gentlemen.  When I was beaten,

16     when I was in prison, when my life was destroyed in Sarajevo in the

17     federation, at that time, I used all the means to get in touch with

18     somebody in order to survive because I had been threatened.  Perhaps

19     eight or nine months later, when I found out that --

20        Q.   Just wait, please.  Wait, wait, Witness.  You're lying.  When

21     you --

22        A.   Okay.  I'm lying.  Bring Damir Alagic here and then we'll see who

23     is lying.

24        Q.   [Microphone not activated]

25             JUDGE KWON:  Microphone.

Page 44874

 1             THE INTERPRETER:  Microphone for the --

 2             MS. PACK:

 3        Q.   When you attended SIPA's offices in March 2010, you were still

 4     trying to figure out, weren't you, if you could get anything out of him,

 5     right, if they could be your route to testifying in the state court or

 6     The Hague, and then you realised, didn't you, that they had investigated

 7     your claims and they didn't believe them.

 8        A.   And did they find any papers on the desk?  Who was it who

 9     investigated?  Did they find anything, any papers, under that cooker in

10     the apartment where I allegedly was?  Did they find any papers, if they

11     indeed carried out that investigation?  Was anything found?

12        Q.   Witness, you made the decision, didn't you, that Dr. Karadzic's

13     team were your route to The Hague; right?  So you piled claim upon

14     preposterous claim, depending on who you were talking to.  You signed a

15     statement full of lies and you've come here today to lie to these Judges;

16     right?

17        A.   No.  This is not correct.  Judges, you have that in my statement

18     and what I have been saying since yesterday.  And I stand by my words.

19     I stand by the statement that I provided in the country from which I have

20     arrived here.  And as for what you said about my mother and my son,

21     I repeated what is on paper already.  And I asked the main co-ordinator

22     to release that person and that person should not be touched by anybody.

23     I mentioned their names at the time.  I was telling the truth, I was

24     telling the truth about the murder of my mother and my son, but I don't

25     want that person to be touched, to be arrested or tried.  And as for what

Page 44875

 1     Damir Alagic did and the document that you showed me that was signed by

 2     Ejub Zukic, those things were rigged by them in the federation.  They

 3     wanted at all cost to clear their names and they wanted to blame

 4     Karadzic's Defence for everybody.  That's number one.  And number two,

 5     Madam, let me tell you:  I am here and I have fought for -- against such

 6     thieves and such truths for 17 years.  I wanted you to help me as a

 7     Prosecutor, I wanted to arrange a meeting with these people with your

 8     mediation, before you.  And then, only then, will you be able to see and

 9     hear who is telling the truth and who is lying.

10             MS. PACK:  I have no further questions, but I'd like to ask for

11     the report to be admitted, please.

12             JUDGE KWON:  You're not tendering the interview or statement?

13             MS. PACK:  I'm grateful.  I thought I'd asked for that to be

14     admitted.  Yes I'd like to have both of those admitted, please.  It's the

15     65 ter 25500, the record, and the news report, 254 --

16             JUDGE KWON:  How about 25520?  2008.

17             MS. PACK:  I wanted just to have the page.  Yes, please,

18     Your Honour.  We rose rather quickly, and, I'm sorry, I should have dealt

19     with that when we returned.

20             JUDGE KWON:  I'm not recommending you to tender but I'm just

21     checking.

22             MS. PACK:  I'm grateful.  If I could just have that page that

23     I read out which was the -- which I can identify for the Registrar,

24     65 ter 25520, it was page 5 of the English and B/C/S page 4.

25             JUDGE KWON:  I'll hear from Mr. Robinson.

Page 44876

 1             MR. ROBINSON:  No objection.

 2             MS. PACK:  And then of this 25500, I'd like to have that all

 3     admitted, please.  It's substantially read through, but I would like to

 4     have it admitted, and, furthermore, the report, 25435.  Apologies for

 5     doing it all at once.

 6             JUDGE KWON:  You answered all -- with respect to all of those

 7     items.

 8             MR. ROBINSON:  I did, Mr. President, yes.

 9             JUDGE KWON:  We will receive them all.

10             THE REGISTRAR:  65 ter 25520 receives Exhibit P6561 under seal,

11     65 ter number 25435 receives Exhibit P6562 under seal, and

12     65 ter number 25500 was already admitted as Exhibit P6560 under seal,

13     Your Honours.

14             JUDGE KWON:  Thank you.  Yes, Mr. Karadzic.  Do you have any

15     re-examination?

16             THE ACCUSED: [Interpretation] Yes, Excellencies.  I want to

17     clarify some things that we heard during the cross-examination.

18                           Re-examination by Mr. Karadzic:

19        Q.   [Interpretation] Witness, earlier yesterday it was suggested to

20     you by the Prosecutor that you had decided to tell the truth after having

21     decided to talk to my Defence team and then you got in touch with my

22     Defence team.  When did you decide to tell the truth and to shed light on

23     everything that you know about the crimes?

24             MS. PACK:  I never at any point did I ever suggest to the witness

25     that he ever told the truth, perhaps once a very long time ago.

Page 44877

 1     I really -- this has no connection with my cross-examination.

 2             JUDGE KWON:  No.

 3             THE ACCUSED: [Interpretation] Your Excellencies, such wordings in

 4     the Prosecutor's questions happen every day.  In their questions, there

 5     are a lot of suggestions and allegations that you don't allow me to

 6     correct at all.

 7             JUDGE KWON:  Just come to your question.  What is your question?

 8             MR. KARADZIC: [Interpretation]

 9        Q.   My question is this:  Did you decide to tell the truth, did you

10     decide to testify - let's not mention the word truth - after having got

11     in touch with my Defence team?

12             MS. PACK:  He's putting words into the witness's mouth.  Totally

13     inappropriate.

14             THE ACCUSED: [Interpretation] But, please, the Prosecutor

15     suggested --

16             JUDGE KWON:  Mr. Karadzic, probably you may ask Mr. Robinson how

17     to formulate your question.

18             THE ACCUSED: [Interpretation] This is just a follow-up on the

19     Prosecutor's allegation and that was that the witness decided to use my

20     Defence team in order to be put in the position to testify, and that that

21     was why he testifies the way he does.  I'm asking him whether that is the

22     fact, and, if not, when was it that he decided to speak out and to

23     testify?

24             THE WITNESS: [Interpretation] Mr. President, since 1996, when

25     I was in that office where I was detained -- when I was detained, ever

Page 44878

 1     since then I have wanted to come here and to tell you what I have been

 2     telling you so far.  However, the -- some individuals from the federation

 3     prevented me from coming here earlier.  I'm not here only because of you.

 4     I'm not here only to be seen by somebody or even by this Tribunal or this

 5     Bench, I'm here of my own accord and I have managed to do that.  I am a

 6     happy man.  I wanted to come here when Naser was here but then a search

 7     warrant was issued against me and I was prevented from coming here.

 8             Ever since then, from 2003 or 2004, things have been happening,

 9     and I have suffered the brunt of those things, all in order to prevent me

10     from saying what had happened, and this is what I said in my statement,

11     that there are people who will come here and who will confirm my story.

12     However, these people are now looking at me because they know what

13     happened to me at the hands of Bajro Kulovac, and those are the leaders

14     of the SDA and the Mothers of Srebrenica.  Now they are all looking with

15     their eyes wide open at me to see how you will react when you see such a

16     strong witness as me.  The documents that the Prosecutor presented and

17     showed to you, my only wish is for these people to come here and look me

18     in the eyes, eyeball to eyeball, to see when and how they recorded all

19     those things, when they wrote all those statements.  I'm not looking for

20     anything else from you, the International Criminal Court.

21             MR. KARADZIC: [Interpretation]

22        Q.   Thank you.

23             THE ACCUSED: [Interpretation] I would like to call up D4181 in

24     e-court.  And could it not be broadcast.

25             MR. ROBINSON:  It's D4181.

Page 44879

 1             MS. PACK:  He's talked about this picture.

 2             THE ACCUSED:  Yeah, maybe 82, 4182.  [Interpretation] Not to be

 3     broadcast as well.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   When did you meet my legal adviser?

 6        A.   In 2010.

 7        Q.   Thank you.

 8        A.   I can't remember the month exactly.  It was sometime in January

 9     or February.

10             THE ACCUSED: [Interpretation]

11        Q.   D4182, not to be broadcast, please.

12             MR. KARADZIC: [Interpretation] When did you write this letter to

13     the Prosecutor's office?

14             MS. PACK:  Your Honours, we have been through this in direct

15     examination and in cross-examination.  I just can't see how anything new

16     can have arisen.

17             JUDGE KWON:  Is it not too early to object?  You cross-examined

18     about this document.  And just he asked as a beginning the date of the

19     document.  Let's see how it goes, yes.

20             THE WITNESS: [Interpretation] You see, Judge, it says very

21     clearly that it was written on the 11th of April, 2008.

22             MR. KARADZIC: [Interpretation]

23        Q.   Thank you.  Did you know anybody from my team at the time?

24        A.   No, I did not.

25        Q.   Thank you.  Yesterday, on page 101, line 22, this is for the

Page 44880

 1     other participants, you stated this:  Damir Alagic brought me to SIPA.

 2     Earlier today in both the questions and the SIPA documents, it says that

 3     you went to SIPA voluntarily.  Did you?

 4        A.   No.  I stand by the statement that I gave here and to your

 5     co-ordinator.  I can give you his name.  I repeat that I was forcibly

 6     taken to Sandici, from there to the Kladanj, to the police, by car, to

 7     Damir Alagic and then Damir Alagic took me and went -- me to SIPA,

 8     Bakir Izetbegovic was there as well as Naser Oric.  And there I stated

 9     that Naser Oric did not beat me there, he just provoked me, he called me

10     traitor, and so on and so forth.  And when that was finished,

11     Bajro Kulovac came and then he took me to SIPA.  From the first police

12     station, there I was searched, and there they found the calling card of

13     your co-ordinator.  It was in my pocket, and Damir Alagic immediately

14     took it and said he would deal with that.  Why is that?  Because I had

15     provided a statement in 2010, I don't remember when, whether it was in

16     January or February, to your Defence team, let's call them that.

17             I can give you his name, if you wish.

18        Q.   No, it doesn't really matter.  I suppose to the person who is

19     sitting here today?

20        A.   Yes.  Ever since then, in Sarajevo and in the federation, some

21     people, Bosniaks, learned that I had got in touch with your Defence team

22     and then I was supposed to be liquidated, and I mentioned it in my

23     statement.  What I've seen so far from the Prosecutor, all that was

24     rigged by Damir Alagic in the federation, he's the one who produced this

25     newspaper article because there was a question at that time as to what to

Page 44881

 1     do with me and where to send me.  I got a paper from the Kosevo hospital

 2     where Damir Alagic took me in order for the doctors to proclaim me

 3     insane, and when the main doctor in the hospital arrived and a lady

 4     doctor with him and when they realised that I was not insane, they

 5     wouldn't admit me.  I have a paper proving what they did at the hospital

 6     to me on that day.  Ever since then, I was on the street until I was

 7     found by that man whom I mentioned in my statement.

 8        Q.   Thank you.  With the Trial Chamber's leave, I would like to ask

 9     you to send us a copy of that paper, testifying to their attempt to

10     hospitalise you at the psychiatric ward.

11             You said earlier today that you had left of your own accord to

12     the newspaper.  Did you ever go to a newspaper of your own will?

13        A.   Mr. President, as far as what newspapers write, Damir Alagic is

14     the one who should be here and tell you eyeball to eyeball how they

15     rigged that article.

16        Q.   Thank you.  And then Damir Alagic called you and told you that

17     The Hague Tribunal was looking for you.  Did he tell you why

18     The Hague Tribunal was looking for you?

19        A.   No, he did not tell me why.  He just called me and told me this:

20     The Hague is looking for you.  If they find you, don't talk to them

21     before I come.  I will deal with it.  I will be the one doing all the

22     talking.  He told me that on the phone, and after that, perhaps three

23     days later, I received news from my father who is in Tuzla that

24     I received a threat from a group of Naser's men and that I could not come

25     back home.  I had to disappear.  I came to the town where I was born and

Page 44882

 1     the civilian police there helped me because he knew the story.  I would

 2     like to call the head of the civilian police there as a witness.

 3        Q.   Could you tell us which of the Tribunal's services was looking

 4     for you at the time?

 5        A.   I really can't tell you.  I don't know.  You're talking about

 6     Damir Alagic?  I really don't know.  He only told me that The Hague was

 7     looking for me.  He says, The Hague is looking for you.  If The Hague

 8     finds you, don't talk to them until I arrive.  I don't know who was

 9     looking for me.  And, Mr. President, they know that The Hague was looking

10     for me.

11        Q.   Thank you.  We will ask the Registry to find out and inform us

12     who it was that was looking for you.  And the interview in the prison,

13     your first interview, was it recorded?  Did you say everything literally

14     or was it typed while you were talking or was it hand recorded?  Are you

15     the one who worded things the way they were recorded or is it somebody

16     else who did that?

17        A.   Can you please explain?  Are you talking about my letter when

18     they arrived from Sarajevo or about your defence?

19        Q.   When they came to visit you, Kulovac, for example.

20        A.   Everything was recorded on computer and on DVD.

21        Q.   Thank you.  And when was that downloaded and typed on paper?

22     When did you sign that?

23        A.   I believe that it was on the same day when I went to the

24     bathroom.  That -- I signed that and then the policeman protected me.

25        Q.   Very well.  Did you say only what is written there or did

Page 44883

 1     somebody actually formulate your words for you?

 2        A.   What the Prosecution presented as my statement on paper and my

 3     signature, that should have been completed in the Prosecutor's office in

 4     Sarajevo during the Defence case of those six guys from Sarajevo.

 5     Bajro Kulovac did not invite me as a witness, the document was removed,

 6     and those guys received sentences of up to 30 years.

 7        Q.   Thank you.  On page 60 earlier today a mention was made on the --

 8     of the killing of your mother and son.  There was a slight confusion

 9     there.  I would like to call up on the ELMO a document which shouldn't be

10     broadcast.  We need to see the first and the last pages in that document.

11     Please do not mention your father's name.  It has been suggested that

12     your son -- your father had also witnessed the killing of your mother and

13     son.  Can we first see the first page?  Don't give us the name.  Could

14     you just tell us who that person is and whether he told the truth about

15     the event?  This should not be broadcast.

16             MS. PACK:  I've got this in English.  Perhaps it would be better

17     so everyone could see it and we've got in e-court.

18             JUDGE KWON:  I'm sorry.

19             MS. PACK:  The document that is being shown on the ELMO, I have

20     it in English and B/C/S and in e-court, so it might be easier just to use

21     that.  Can I suggest that that is uploaded.

22             JUDGE KWON:  Do you have it in English?

23             MS. PACK:  Yes, it's uploaded and it has got a translation, yeah.

24     Yes, Your Honour.  If I just find the 65 ter number, it won't take me a

25     moment.

Page 44884

 1             JUDGE KWON:  Very well.

 2             MS. PACK:  It's 65 ter 25505.  And it obviously shouldn't be

 3     broadcast.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Don't tell us the name, just tell us who the man is and how you

 6     are related to him, if you are.  The third line from the bottom of the

 7     page where it says "witness."

 8        A.   Yes.  I know him.  And I want to tell you now very publicly, when

 9     the Prosecutor asked me about that, I said that I had heard from this man

10     here that he was visited by some Prosecutors and they asked him about the

11     murder of my mother and son, and he did not want to provide a correct

12     statement to them because he didn't want to get involved.  And from the

13     moment he provided his statement, the people at the top denied everything

14     that I said based on his words, and I would like to tell everybody here

15     whatever the Prosecutor presented today is what I said myself, if I can

16     remember it well.  I'm now addressing the main co-ordinator to find that

17     recording.  When I first met him, I told him that I did not want this man

18     to be sentenced for this, to be convicted for this, because -- because

19     his younger brother saved my life.  I know that at the very beginning

20     I said to your main co-ordinator what had happened.  I did not want this

21     man to suffer because his brother saved my life.

22        Q.   Can we see the last page, or rather the sixth page?

23     Paragraph 11.  It will be easier.  Can you see that he says here that he

24     asked you where she was, you said she had come out to the first floor

25     with the child in her arms, that Pasan [phoen] and Pasan's family were

Page 44885

 1     recorded as missing, that Pasan's family was found, that the others were

 2     not, that was in 2009; is this correct?  He says:  As far as my wife's

 3     and grandson's fates are concerned, I didn't see exactly what had

 4     happened to them.

 5        A.   And I told Madam Prosecutor that he was not able to see.

 6        Q.   So as far as this matter is concerned, the statement is correct?

 7        A.   The statement where he says he hadn't seen the murder of his wife

 8     and grandson, that's true.  He wasn't able to see.  But the process, the

 9     proceedings that are now going on in the federation and Republika Srpska

10     you can see that he went to court with two witnesses, and those two

11     witnesses giving a statement before the Court said in his defence that

12     they had seen that the Chetniks had thrown grenades through the window,

13     killing my mother and son.  And based on his statement before the Court,

14     there are papers in the house, all the property was signed over to him,

15     and I was recorded as dead.

16        Q.   Thank you.  Is this Ejub Zukic the same one that signed your

17     statement?

18        A.   Ejub Zukic.  Possibly.  I don't know the man.  The man who gave

19     the statement should tell you with whom he was there.

20             MS. PACK:  Your Honour.

21             JUDGE KWON:  Yes?

22             MS. PACK:  Just before -- in case Dr. Karadzic is about to leave

23     this document, I think in fairness, that the entire of that paragraph 12

24     should be read because it's only been partially summarised, and there is

25     more to it than what was read out.  And for the record, if it's not

Page 44886

 1     sought to admit that then I would ask that -- preferably 11 and 12 but

 2     certainly 12 is read.

 3             JUDGE KWON:  Without reading out the real names?

 4             MS. PACK:  Yes, of course.

 5             JUDGE KWON:  Would you like to do that?

 6             MS. PACK:  Yes, of course.  And just with perhaps a little bit of

 7     11:  As far as the fate of my wife and grandson are concerned, I did not

 8     see exactly what happened to them.  Last time I saw her was before I left

 9     the cellar to light a cigarette and she remained inside.  When I returned

10     the witness told me that she had gone upstairs and that she had carried

11     my grandson in her arms.  I know that after that, we were -- I know that

12     after we were taken to the stadium, the women were left behind in the

13     village, describes the women, all of them and my wife and my grandson,

14     all of them are registered as missing.  As far as I know -- it goes on,

15     paragraph 12:  After getting to Visoko and later on to Zivinice, I kept

16     searching for my wife.  As soon as I learned that some refugees arrived

17     from Bratunac, I would go to look for my wife and grandson.  I inquired

18     about them.  My son, the witness, was also asking around about the fates

19     of my wife and my grandson and he never once mentioned that my wife was

20     killed.  I know that my son, the witness, went to Srebrenica, et cetera.

21     Goes on.  I just wanted to make sure that the full record is read.  Thank

22     you.

23             JUDGE KWON:  Thank you.

24             THE WITNESS: [Interpretation] Can you allow me for just one

25     second because I now only saw what's written here.  I want to refute the

Page 44887

 1     statement of this man.  That woman and that child were not in the

 2     basement.  I invite the witness Muhamed Ahmetovic who lives here in

 3     Holland.  My mother and son were not in the basement.  They were

 4     upstairs.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   Thank you.  There was a number of people in the basement.  Why

 7     were they in the basement?

 8        A.   On the 10th of May, 1992, when the shooting started from those

 9     hills all around Bratunac, Kik, Susko Brdo, Gornica [phoen], we went into

10     hiding in the basement because bullets were hitting the roof and tiles

11     were falling off, so we hid in the basement and my mother and son

12     remained upstairs.  They were not in the basement.

13        Q.   Let's clarify this.  How many experts have talked to you?  One or

14     two?  During the first examination ordered by the Court, how many

15     psychiatrists have spoken to you?

16        A.   Mr. President, I just want to understand, in which case, which

17     experts, because as you know well, there are two or three cases in which

18     I'm involved.

19        Q.   In 1996, when the investigating judge asked that you be examined

20     by an expert, and we saw that document, it was almost illegible, how many

21     of them were there?

22        A.   There was only one, that forensic expert from Serbia, who

23     reappeared again when the retrial was going on.  He told the Court how

24     I had come to be in Zvornik and all that had gone on.  Nebojsa Jovanovic

25     denied that I was beaten in Zvornik, that I was mistreated by the police,

Page 44888

 1     and the Prosecutor, Nebojsa Ivanovic, therefore asked for a new

 2     examination by a new expert.  Then I was taken to Banja Luka to be seen

 3     by a new expert, but the expert in Banja Luka did not agree with his own

 4     colleague from 1996, the good man who had seen me and who came to my

 5     retrial, the man who had seen in 1996 that I was a broken man.  So since

 6     the two of them could not agree, they invited a third expert, a woman,

 7     who claimed that I only want to be acquitted, freed, in order to appear

 8     here, in order to be able to come here.

 9        Q.   Am I understanding you correctly that there are three forensic

10     reports in that whole process which started in 1996?

11        A.   Yes.

12        Q.   In this first case, when the first expert examined you, were some

13     tests done?  How long was the interview and what were these tests?

14        A.   I need to make you understand one thing.  The man comes to see

15     you in an office, he asks for some personal details, then he reads the

16     judgement and then he appears before the Court and he says, You are

17     guilty of this and that and that, et cetera.

18        Q.   It says there --

19             JUDGE KWON:  Just a second.  Please repeat your question.

20             MR. KARADZIC: [Interpretation]

21        Q.   In that report, it is written that there were two of them and

22     that they applied four tests, including one that I know very well, MMPI,

23     but they did not apply the IQ test, although they made a finding on your

24     intellect.  Did they perform any tests?

25        A.   Never.  In no place wherever I met those three experts, including

Page 44889

 1     the one from Serbia who knew my case in 1996, the one in Banja Luka and

 2     the woman who came to my trial, I never saw them all together, only one

 3     by one, and they read my judgement and they took my judgement into court

 4     and testified in that way.

 5        Q.   Are you able to tell us, did you give a statement to some

 6     judicial institution in Belgrade?  Were you questioned by the judiciary

 7     in Belgrade?

 8        A.   What is this about?

 9        Q.   About all these events, about all that you know.  Were you

10     questioned before a Judge or a Prosecutor in Belgrade?

11        A.   Yes.  It was a bogus trial, and a false conviction, and that's

12     why I begged all these Prosecutors and lawyers and Judges to find me a

13     lawyer who would institute this procedure immediately, urgently, because

14     I can't tell you -- I can't get over it that I had been in prison for

15     nothing.

16        Q.   In that interview, did you speak about the events in Sarajevo?

17     And did you tell the truth?

18        A.   One hundred per cent.  And I swear on everything that is most

19     sacred to me, but the people in that Prosecutor's office and the Judges

20     could not understand what I was saying for a long time until we went out

21     into the field in Republika Srpska.  I had been drawing them maps to show

22     them where things were, and I gave them statements, I drew places and

23     scenes and sometimes we worked days and nights with these Prosecutors and

24     Judges and investigators, but when we finally came to the scene, they

25     couldn't believe how exact my maps were.  Every stone, every rock, was

Page 44890

 1     exactly drawn.

 2        Q.   You said that you had offered Serbian authorities and

 3     representatives -- that you could show them some mass graves of the

 4     Serbs.  Are there any that are still unidentified, mass graves of Serbs

 5     and Muslims?

 6        A.   That's what I said yesterday.  I asked this

 7     International Tribunal to approve that we go to the federation, to the

 8     crime scenes, Hajvazi primarily, that's the one that interests me the

 9     most because there must be evidence there, because when we went to those

10     locations, the federation authorities did not allow us to go there.  They

11     did not guarantee our security.

12        Q.   Thank you.  I have no further questions.  Thank you, Witness.

13             JUDGE KWON:  Well, that concludes your evidence, Mr. Witness.  On

14     behalf of the Chamber, I'd like to thank you for your coming to The Hague

15     to give it.  Now you are free to go.  But please remain seated.  We will

16     rise all together.  We will rise for five minutes.

17             MR. ROBINSON:  Mr. President, can we go on maybe till 3.00 today?

18             JUDGE KWON:  We will discuss it when we return.

19                           [The witness withdrew]

20                           --- Break taken at 2.29 p.m.

21                           [The witness entered court]

22                           --- On resuming at 2.36 p.m.

23             JUDGE KWON:  Before we continue, can I hear from you about the

24     witness schedule for this week, Mr. Robinson?

25             MR. ROBINSON:  Yes, Mr. President.  Because we have a lot of

Page 44891

 1     witnesses here this week, we've asked some of those who are not in a

 2     hurry that they have to go home to stay a little bit longer, and so we

 3     are skipping some of the witnesses that we had originally planned earlier

 4     in the week.  So this is Mr. Matovic in front of you, and he will testify

 5     today and probably continue tomorrow morning.  At which point the next

 6     witness will be Mr. Milicic and then Mr. Kovacevic.  If we have sometime

 7     tomorrow, we can begin the testimony of Mr. Radikovic.  But on Thursday

 8     at 9.00 a.m., we need to start and conclude the testimony of

 9     Colonel Blagojevic.  And then we need to have the testimony -- the direct

10     examination of General Tolimir on Thursday.  And, as a result of that,

11     Mr. Miskovic, who was scheduled for earlier this week, will now be

12     testifying next week and Radikovic will continue his testimony next week

13     if he begins it at all tomorrow.

14             JUDGE KWON:  Do we need to revise the subpoena for

15     General Tolimir.

16             MR. ROBINSON:  I don't believe so.  We filed a notice that it's

17     to be on the 12th and his legal adviser is here and ready to proceed, so

18     I don't think that anything further is necessary.

19             JUDGE KWON:  Thank you.  Today we need to rise at least five or

20     ten to 3.00 given that the Judges have a plenary today.

21             Would the witness make the solemn declaration.

22             THE WITNESS: [Interpretation] Shall I begin?  I solemnly declare

23     that I will speak the truth, the whole truth and nothing but the truth.

24                           WITNESS:  VLADIMIR MATOVIC

25                           [Witness answered through interpreter]

Page 44892

 1             JUDGE KWON:  Thank you, Mr. Matovic.  Please be seated and make

 2     yourself comfortable.  Going back to the schedule, Mr. Robinson, there is

 3     no need for the Chamber to sit on Friday?

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

 5             JUDGE KWON:  Thank you.  Yes, Mr. Karadzic, please proceed.

 6                           Examination by Mr. Karadzic:

 7        Q.   [Interpretation] Good afternoon, Mr. Matovic.

 8        A.   Good afternoon, Mr. Karadzic.

 9        Q.   May I ask you to leave a short pause between my questions and

10     your answers?

11             JUDGE KWON:  Whether it's important or not, I note that,

12     Mr. Matovic, you are the 200th Defence witness for this case.

13             MR. KARADZIC: [Interpretation]

14        Q.   Thank you.  With Mr. Matovic, there is always some round figure.

15     Have you given a statement to the Defence team?

16        A.   Yes.

17             THE ACCUSED: [Interpretation] 1D09095 is the document I would

18     like to call up in e-court.

19             MR. KARADZIC: [Interpretation]

20        Q.   Do you see your statement before you on the screen?

21        A.   I'll need my glasses.  I see it, but not well enough to read.

22     But, I know approximately.

23        Q.   Have you read and signed that statement?

24        A.   Yes.

25             THE ACCUSED: [Interpretation] Could the witness please be shown

Page 44893

 1     the last page, in the Serbian?

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Is this your signature?

 4        A.   Yes.

 5        Q.   Thank you.  Does this statement faithfully reflect what you said?

 6        A.   Yes.

 7        Q.   If I were to put to you the same questions today, would your

 8     answers be essentially the same as recorded in the statement?

 9        A.   Yes, yes.

10        Q.   Thank you.

11             THE ACCUSED: [Interpretation] I tender this statement under --

12     your Excellencies, under 92 bis.

13             JUDGE KWON:  Any objection, Ms. Edgerton, to admit this pursuant

14     to Rule 92 ter?

15             MS. EDGERTON:  No.

16             JUDGE KWON:  We will admit it.

17             THE REGISTRAR:  It receives Exhibit D4184, Your Honours.

18             JUDGE KWON:  Yes.  Please continue.

19             THE ACCUSED: [Interpretation] Thank you.  I will read a very

20     short summary of Mr. Matovic's statement and then I'll have a couple of

21     questions for him.

22             [In English] Vladimir Matovic was a long-term journalist for

23     "Borba" magazine in Belgrade and an adviser to former president of the

24     Federal Republic of Yugoslavia, Dobrica Cosic.

25             In July 1995, former President Cosic and others in Serbia became

Page 44894

 1     concerned that the international community would use the Bosnian Serbs'

 2     military action in the Srebrenica area as a justification for military

 3     action against the Serbs.

 4             At the request of former President Cosic, Mr. Matovic travelled

 5     to Srebrenica area in July 1995 where he witnessed the large number of

 6     Bosnian Muslims who had gathered at Potocari.  He proceeded to Pale where

 7     he met with President Karadzic.

 8             Mr. Matovic states that from his conversation with

 9     President Karadzic on that occasion, it was clear to him that President

10     Karadzic was not well-informed concerning the events in Srebrenica.  It

11     seemed to Mr. Matovic that President Karadzic was getting his information

12     about the Srebrenica events from CNN.

13             Mr. Matovic returned to Pale a few days later to deliver a letter

14     written by President Cosic and Patriarch Pavle.  To the best of his

15     recollection, he did not see President Karadzic on this occasion but left

16     the letter with a secretary.

17             MR. KARADZIC: [Interpretation]

18        Q.   [Interpretation] Now I'd like, Mr. Matovic, to ask you to tell us

19     whether you were close enough to President Cosic while he was president

20     and later until the end of our war?

21        A.   Well, he invited me to join his team.  I left my job as a

22     journalist.  I joined his office.  I was a press officer for 90 days, and

23     since I knew him, I had known him for a long time, and I sided with him

24     always in the public, although he was not always very popular in the

25     public eye because President Cosic was a renowned writer, a huge number

Page 44895

 1     of books printed in a very large circulation and translated into many

 2     languages.  He was a writer who wrote about the national tragedies of

 3     Serbs through various wars.  Briefly he was a prominent author, and one

 4     of his books is the title, "The Serbian Issue - Democratic Issue."

 5        Q.   Were you aware of his attitude to Muslims and Croats?

 6        A.   Of course, especially since I started working with him, and even

 7     before, while I was working as a journalist, I had to deal with this

 8     issue and keep myself abreast and I was familiar with his position and

 9     opinions.  And after one conversation I had with Alija Izetbegovic,

10     I conveyed to Cosic the gist of that conversation, and Alija Izetbegovic

11     had served time in prison in Sarajevo, I'm trying to tell this briefly,

12     to give you the shortened version, anyway I conveyed to Cosic that it was

13     a big question because the ruling party in Sarajevo and their newspaper,

14     "Oslobodjenje," wanted to print an interview --

15             JUDGE KWON:  Please do not overlap because you are speaking --

16     both of you are speaking the same language.  You should put a pause

17     between the question and answer.  But before we ask you to repeat, yes,

18     Ms. Edgerton?

19             MS. EDGERTON:  Well, I was waiting, Your Honours, to see where

20     this was going, a bit concerned as to whether or not we were about to

21     hear some kind of attestation on behalf of President Cosic because none

22     of that is in the statement that this witness signed, at all.  And if

23     this goes my further, we have a notice issue.

24             THE ACCUSED: [Interpretation] I don't -- I don't intend to repeat

25     anything from the statement.  I just wanted to ask the witness if he was

Page 44896

 1     aware of the emotional and other position of Mr. --

 2             JUDGE KWON:  No, the issue was the notice to the Prosecution of

 3     the subject matter of the witness's evidence.  Mr. Robinson, can you

 4     assist us?

 5             MR. ROBINSON:  Well, not really, Mr. President.  I was present at

 6     the proofing, but I didn't see that this was coming up so I don't really

 7     know exactly what Dr. Karadzic is seeking to elicit here.

 8             JUDGE KWON:  How much longer do you need to conclude your

 9     examination-in-chief?

10             THE ACCUSED: [Interpretation] One minute.  It depends on the

11     answer.  All I want to know is what he knew about President Cosic's

12     altitude towards Muslims and my own.

13             JUDGE KWON:  He answered the first question.  Yes.  Your second

14     question?

15             MR. KARADZIC: [Interpretation]

16        Q.   A second question:  Do you know what President Cosic thought

17     about my attitude to the Muslims?  How did he see me?

18        A.   Well, that's a difficult question because his relationship with

19     you -- I don't know whether it was friendly, harmonious, but in that

20     whole Serbian environment after the establishment of the council, the

21     board, in Belgrade, which was the opposition to the then-government,

22     established a forum to protect freedom of speech.  And since he heard

23     that Mr. Izetbegovic had been arrested and he was about to be tried

24     because of his position on religion and his public statements, he put it

25     before the Belgrade association and put forward his position which was

Page 44897

 1     very courageous at the time.

 2        Q.   Can you just answer the question:  How did President Cosic see my

 3     attitude to the Muslims?

 4        A.   Well, he always had only the nicest things to say about you.  He

 5     spoke of you as a prominent poet, intellectual, psychiatrist, et cetera,

 6     et cetera.  And on most political issues, including that one, he spoke of

 7     you very well, saying that you were one of the people in Sarajevo and in

 8     Bosnia-Herzegovina as a whole who was seen as a leader of the Serbs.  He

 9     saw you as somebody who shared his views that nobody should be arrested

10     for any kind of public statement, and Izetbegovic's wife came, together

11     with a delegation of the families of all those who were arrested because

12     of that Islamic Declaration, she brought a lot of money --

13        Q.   It's enough for now because that's not in the statement.  That's

14     why I wanted it on record.  Thank you.  I have no further questions.

15             JUDGE KWON:  Yes.  Mr. Matovic, we will adjourn here for today

16     and continue tomorrow morning at 9.00.  Tomorrow morning you will be

17     cross-examined by the representative of the Office of the Prosecutor, but

18     while you are giving testimony, I would like to advise you not to discuss

19     about your testimony with anybody else.

20             THE WITNESS: [Interpretation] All right.  Thank you.

21             JUDGE KWON:  The hearing is adjourned.

22                           --- Whereupon the hearing adjourned at 2.54 p.m.,

23                           to be reconvened on Wednesday, the 11th day of

24                           December, 2013, at 9.00 a.m.