1 Tuesday, 11 July 2000
2 [Open session]
3 [The accused entered court]
4 --- Upon commencing at 9.38 a.m.
5 JUDGE MAY: This hearing is to take evidence from Zagreb by means
6 of a video conference link, there being three witnesses, is that right,
7 Mr. Sayers, for whom we have summaries?
8 MR. SAYERS: Yes, Mr. President. In order, as we've notified the
9 Prosecution a few weeks ago: Ivica Kristo, followed by Srecko Kristo, and
10 finishing up with Ilija Zuljevic.
11 JUDGE MAY: Very well. Now, let us see if the link is
12 established. Can you hear us? Let the witness take the oath.
13 COURT TECHNICIAN: The witness is being picked up at the moment.
14 He should arrive in a few seconds.
15 JUDGE MAY: Mr. Sayers, it may be more comfortable if counsel sits
16 down for this proceeding, particularly while we're waiting for things.
17 MR. SAYERS: I'm obliged, Your Honour. Thank you very much.
18 JUDGE MAY: Yes. Let the witness take the declaration.
19 THE WITNESS: [Interpretation] I solemnly declare that I will speak
20 the truth, the whole truth, and nothing but the truth.
21 WITNESS: IVICA KRISTO
22 [Witness answered through interpreter]
23 [Witness testified via videolink]
24 JUDGE MAY: Yes, Mr. Sayers.
25 MR. SAYERS: Thank you, Mr. President.
1 Examined by Mr. Sayers:
2 Q. Good morning, Mr. Kristo.
3 A. Good morning.
4 Q. Mr. Kristo, just to introduce myself, my name is Stephen Sayers,
5 and along with my colleague, Mr. Mitko Naumovski, we represent Dario
6 Kordic. I would just like to ask you a few questions today, and take your
7 time in answering, please. It's important to get a clear transcript.
8 Could we start, please, with asking you your full name, sir.
9 A. Ivica Kristo.
10 Q. Mr. Kristo, I'm going to take you very quickly through a few
11 preliminary details regarding your personal background. It's true that
12 you were born on April 15th, 1956, in the city of Zenica, I believe.
13 A. Yes.
14 Q. You're married and you have two sons.
15 A. Yes.
16 Q. I believe that you were trained as a painter in vocational school,
17 following which you worked for a construction firm in Zenica.
18 A. Yes. Yes.
19 Q. Before the fighting broke out, sir, in 1993, I believe that you
20 used to live with your family in a suburb to the south-west of the city of
21 Zenica called Raspotocje.
22 A. Yes.
23 Q. And during the war your wife and sons left Zenica, but you stayed
24 there throughout the conflict.
25 A. Yes.
1 Q. I believe that you participated in the formation of the Zenica
2 branch of the Croat Democratic Union of Bosnia and Herzegovina and in the
3 formation of the Croat Defence Council formations in that city.
4 A. Yes. Yes.
5 Q. In October of 1992 you were appointed to serve as a reserve
6 company commander in the HVO.
7 A. Raspotocje, yes.
8 Q. Yes, sir. And following the end of the war, you left the city of
9 Zenica and you currently live in the north of the Republic of Croatia, in
10 the town of Varazdin.
11 A. Varazdin, yes. Yes.
12 MR. SAYERS: All right. And with the Court's permission, I do
13 intend to lead the witness through most of the outline, with the exception
14 of paragraphs 14 through 17, unless the Prosecution objects.
15 Q. I believe, sir, that you have described in the outline that you
16 signed on July 9th how tensions in the city of Zenica started to grow
17 towards the end of 1992.
18 A. Yes.
19 Q. The first serious incident involving actions taken against the
20 Croats was in the autumn of 1992, when the Muslims physically took over
21 Zenica military barracks after the Serbs had left and proceeded to aim
22 three tanks at Croat suburbs, an action which you yourself visually
23 observed through binoculars.
24 A. Yes.
25 Q. During the end of 1992/early 1993, Mr. Kristo, we have already
1 heard that numerous Muslim armed formations from all over Bosnia, in
2 addition to the local Territorial Defence, were stationed in the town.
3 Could you just give us, please, a listing, as far as you can recall, of
4 the Muslim armed forces that were to be found in Zenica at the end of 1992
5 and during 1993.
6 A. The names?
7 Q. Yes, if you can remember.
8 A. No. MOS, Muslim forces, Mujahedin, the Patriotic League.
9 Q. All right. Was MOS another name for the 7th Muslim Brigade, or
10 was the 7th Muslim Brigade a detachment that was separate from MOS?
11 A. The Mujahedin were the leaders of MOS.
12 Q. All right. But the question I asked was: Was the MOS, M-O-S, the
13 same as the 7th Muslim Brigade, or were these two separate military units?
14 A. The same.
15 Q. All right. I take it, sir, that the large concentration of armed
16 forces on the Muslim side in Zenica was a factor that contributed to the
17 escalation of tension in that city between the Croat and the Muslim
19 A. Yes.
20 Q. Now, in contrast to the well-armed Muslim military units in the
21 city, sir, how well armed were the HVO military units? Could you please
22 let us know, help us out with that?
23 A. Well, pretty poorly. In that part where I was, in Raspotocje,
24 less than 40 per cent of soldiers were armed.
25 Q. Very well, sir.
1 MR. SAYERS: Proceeding, Mr. President, to paragraph 11 of the
3 Q. I believe, sir, that there were approximately 500 or so so-called
4 Mujahedin in the city of Zenica and that these men were both locals and
5 from foreign countries.
6 A. Yes.
7 Q. Could you tell us a little bit about the Mujahedin, what they did
8 in the city, how they contributed to the escalation of tensions that
9 you've described? Help us out with that, please.
10 A. They were quartered at Bilimisce, in the school, in the music
11 school in the heart of Zenica, and they had vans without -- and three of
12 them sat in front with their rifles pointing in front, because there were
13 no windshields, and they drove around with and without permission. And
14 they had their rifles, they had machetes, and weapons.
15 Q. You've also described a number of incidents involving the playing
16 of music and the use of loudspeakers on these vehicles. Could you tell us
17 a little bit about that, sir.
18 A. Yes. I can tell you that they were airing this Arab music, which
19 I couldn't understand, and none of us could. And this was also aired in
20 the barracks and all the places where they were accommodated.
21 Q. All right. In your outline, Mr. Kristo, you've also described the
22 commission of acts of aggression against the population of Croat villages
23 in the Zenica area. And you've outlined incidents such as shooting at
24 barrels of brandy, the killing of pigs and the threatening of civilian
25 population. Could you tell us a little bit about that? Did you see that
1 yourself, or are you just reporting what you were told by others?
2 A. Yes, I personally experienced when they came to my uncle's house
3 and asked him if he had any pigs. He did not. Then they came, saw the
4 barrels and fired at them. And I saw it with -- I saw it with my own eyes
5 when they left, and they killed two pigs belonging to a close relative of
7 Q. Thank you, sir. And just for the Court's information, in our
8 video exhibits at Tab 13, there's more videotape footage of this kind of
9 activity, there's no point in showing that and wasting time. The Court
10 can view that for itself and reach its own conclusions.
11 Let me turn to the period just before the fighting broke out in
12 Zenica in April of 1993, Mr. Kristo. We've already heard evidence from
13 others that the increasing tension and the escalation of incidents between
14 the two communities led to about 2.000 Croat civilians leaving Zenica
15 before April of 1993; is that consistent with your recollection?
16 A. Yes.
17 Q. Now, did these people leave voluntarily as a result of propaganda
18 or did they leave out of fear?
19 A. Fear.
20 Q. As far as you're aware, Mr. Kristo, did you ever hear about or see
21 anybody in Zenica trying to do anything to reduce the incidents of
22 Mujahedin activities around the villages in your area?
23 A. No.
24 Q. And I believe that you personally watched a parade in 1993, early
25 on in 1993, where President Izetbegovic came to Zenica and reviewed
1 Mujahedin and handed them green and black flags?
2 A. Yes, I saw it with my own eyes.
3 Q. All right. Mr. Kristo, I'm just going to go forward in time to
4 April 18th, 1993. Could you describe for the Court, please, in your own
5 words, who attacked whom in Zenica. Which side attacked which side,
6 please, and could you describe what life was like during the first few
7 days of that attack, sir?
8 A. Between the 18th and 19th, that is, at 5.15 in the morning, our
9 headquarters at Podbrijezje was attacked and they also immediately set out
10 to conquer where we had our guards and everything because they had
11 prepared it all against all the hill features where -- which we held.
12 Q. All right. You just said that at 5.15 in the morning your
13 headquarters in Podbrijezje was attacked. Attacked by whom?
14 A. Together the army of Bosnia-Herzegovina, the so-called one.
15 Q. All right. Some suggestion has been made in the course of this
16 case, Mr. Kristo, that it was actually the HVO that supposedly attacked
17 ABiH forces in Zenica. What do you have to say about that?
18 A. I have to say that that is not true because I was there throughout
19 the war, and all the rest, and I know because I saw them come out of the
20 barracks, the direction they were going and what places they were taking.
21 Q. Very well. In paragraph 17 of your outline, you describe the fact
22 that you were hugely outnumbered. In your estimation, Mr. Kristo, what
23 was the ratio between the number of attacking ABiH forces and the number
24 of defending HVO forces? Can you give us an estimate?
25 A. One to ten.
1 Q. Ten ABiH troops for every HVO soldier; is that what you're saying?
2 A. Yes, perhaps even more.
3 Q. All right, sir, and you have described that the HVO surrendered to
4 the TO military police on April 19th, 1993; is that correct?
5 A. Yes.
6 Q. So in total, there would have been about one, or at most two days
7 of actual combat between the attacking ABiH forces and the defending HVO
9 A. It started in the morning and by the afternoon, it was all over.
10 Q. Now, were any representations made to you about what would happen
11 to you if you elected to surrender to the TO military police?
12 A. Yes. We were told that we would suffer no consequences if we
13 surrendered our weapons and that they would protect us.
14 Q. And what actually happened?
15 A. After we surrendered the weapons in Raspotocje, about which I'm
16 talking Mujahedin also arrived and the TO, the Territorial Defence
17 police ...
18 [Technical difficulty]
19 JUDGE MAY: I understand the position to be that they are working
20 on the connection. We'll wait for a few minutes and see if it can be
21 re-established. If it can, of course we'll go on in the usual way. If
22 not, we'll take a break.
23 The news is that the lines are down in Zagreb, or to Zagreb. The
24 result being, obviously, that we can't go on for the moment. What we'll
25 do is we'll take the adjournment now for a quarter of an hour in any
1 event, and if lines are not reconnected, of course, it will have to be
3 --- Break taken at 10.07 a.m.
4 --- On resuming at 10.30 a.m.
5 JUDGE MAY: I understand the line has been re-established. Yes.
6 MR. SAYERS: Thank you, Mr. President.
7 Q. Mr. Kristo, before we had that unscheduled break, you were
8 discussing the assurances made to you by the Mujahedin that you would not
9 be imprisoned, and then you were describing what actually happened. What
10 did actually happen, sir?
11 A. [No interpretation]
12 JUDGE MAY: We're not getting any translation.
13 MR. SAYERS: If I could just interrupt you, Mr. Kristo,
14 unfortunately there's a technical problem here in that we're not getting
15 an English translations of what you're saying. The English translation is
16 coming over the Croatian channel, Mr. President.
17 JUDGE MAY: Thank you, Mr. Sayers.
18 THE INTERPRETER: Can it be heard now? Is it coming now.
19 JUDGE MAY: Yes. Let's start again.
20 MR. SAYERS: Yes, Mr. President.
21 THE WITNESS: [Interpretation] Very well.
22 MR. SAYERS:
23 Q. Sorry about this, Mr. Kristo, but perhaps I could just ask you to
24 describe when you were imprisoned, for how long, please, and the
25 conditions under which you were detained in April of 1993.
1 A. Three days. Three or four days later they came and called me to
2 what they called an information interview at KPD prison. The ABiH
3 military police took me there, not to the main entrance but to the side
4 entrance, and they held me there for four days. They released me on the
5 fifth day. Meanwhile they abused me. They were asking about the rest of
6 the weapons, the mortars and other things, where had we hidden it. And
7 that was not true, because we had surrendered everything. I was
8 mistreated at the KPD. I was tied to a radiator. I was constantly
9 abused, with very little food. I had almost nothing to eat.
10 Q. When you say that you were constantly abused, Mr. Kristo, was that
11 verbal abuse or physical abuse, or both?
12 A. Both.
13 Q. All right. I think that you've just described that you were taken
14 to the KPD prison premises. Is it also right that other Croat prisoners
15 were taken to the Babina elementary school by Mujahedin and also to the
16 music school facility in Bilimisce that you've just described?
17 A. Yes, that is correct.
18 Q. I believe that you were detained a second time on the 16th of
19 October, 1993, Mr. Kristo. Could you just describe the length of that
20 detention and what happened to you during the time that you were
22 A. Yes. I was arrested again on 16 October, in front of my house.
23 They surrounded me. They came in a white Golf and they again said, with
24 their weapons pointed at me, that I was being taken to an information
25 interview, and I was taken to Bilimisce. I know I was there until the
1 afternoon. Then they put me in a van, the same one I had described before
2 that belonged to MOS. And then they took me -- they took a left turn and
3 took me through the city, but I couldn't orient myself anymore. Then they
4 brought me to that location which I could not recognise, and later on I
5 learned that that was the Babina elementary school. Can I go on?
6 Q. Who were your captors?
7 A. There were two Mujahedin, two Arabs, and two MOS members,
9 Q. All right. And how long were you detained, sir, at this facility?
10 A. I spent 40 days at the Babina elementary school.
11 Q. Could you describe what happened to you during that 40-day
12 detention by the Mujahedin and MOS members.
13 A. Yes, I can. Every night I was in a room with two persons I had
14 not known. One said that he was from Kakanj and the other one from
15 Breza. And every night I could hear, from 2.00 a.m. until 4.35 in the
16 morning, I could hear screams in other rooms. Also the three of us were
17 taken out individually every second, every third sometimes, every fifth
18 day, and abused. They beat us up.
19 Q. Were these beatings simply with fists or with implements too?
20 A. Fists and rubber batons. It was also the rifle butts.
21 Q. And I take it that you were physically injured fairly badly as a
22 result of these regular beatings that were administered to you.
23 A. Yes. Also we suffered from the lack of food in those 40 days. I
24 can say that I ate, all in all, about one kilogram of bread.
25 Q. And did you lose any body weight during the detention that you
12 Blank page inserted to ensure pagination corresponds between the French
13 and English Transcripts.
1 endured, sir?
2 A. Yes. When I was arrested, I weighed about 100 kilos, and after I
3 was released, 40 days later, I weighed 72 kilos.
4 Q. All right. Let me just wind up the questions that I have for you,
5 Mr. Kristo, and thank you very much for your patience. You've described
6 in your outline being a witness to several shells, artillery shells
7 falling on Zenica on April 19th, 1993. Just a couple of questions in
8 connection with this subject, sir.
9 First, had Zenica been shelled by the Bosnian Serb army artillery
10 before this date, before April 19th, 1993?
11 A. Yes.
12 Q. And you made some conclusions or you've given some conclusions in
13 paragraph 23 of your outline regarding where these shells came from, in
14 your estimation. Where did they come from?
15 A. The shells came from the positions on Mount Vlasic, where the
16 Serbs were deployed.
17 Q. Do you know whether the Serb artillery deployed on Mount Vlasic
18 had sufficient range to reach the city of Zenica?
19 A. Yes.
20 Q. All right. Do you know -- I take it that you're saying that in
21 your estimation, the BSA artillery did have the range to reach Zenica from
22 positions on Mount Vlasic.
23 A. Yes.
24 MR. SAYERS: Mr. Kristo, thank you very much. No further
25 questions at this time, from me, anyway. And now I believe that
1 Mr. Cerkez's lawyer, Goran Mikulicic, may have some questions for you, but
2 maybe he does not.
3 JUDGE MAY: Yes, Mr. Mikulicic.
4 Cross-examined by Mr. Mikulicic:
5 Q. Good morning, Mr. Kristo. My name is Goran Mikulicic, I'm an
6 attorney from Zagreb, and in this matter I represent Mr. Cerkez's
7 interests. I have only several questions for you, and will you please
8 answer them to the best of your recollection.
9 Mr. Kristo, you told us that you were personally present in early
10 1993 in Zenica, when President Izetbegovic, Alija Izetbegovic, personally
11 reviewed the troops there.
12 A. Yes.
13 Q. Mr. Kristo, do you recall how Mr. Izetbegovic, as President of the
14 BH republic, saluted the ABiH troops?
15 A. "Allah-u-ekber".
16 Q. It was not coming-- there it is in the record. It was in Arabic?
17 A. He said, "Selam Aleikum" and they responded, "Allah-u-ekber".
18 Q. Was that unusual for you?
19 A. Of course.
20 Q. You also told us that President Izetbegovic handed them over the
21 green and black flag.
22 A. Yes.
23 Q. And this was shown on Zenica television. Was this flag an
24 official flag of Bosnia-Herzegovina?
25 A. No.
1 Q. What type of flag was it, if you know?
2 A. The official BiH flag was the one with lilies.
3 Q. And the other one?
4 A. I don't know about those two flags. I don't know what the green
5 one or the black one represented.
6 Q. Thank you. Mr. Kristo, you described your suffering in Zenica --
7 A. Yes.
8 Q. -- and suffering of other Croats there. If someone was to tell you
9 that the mistreatment of Croats in Zenica at that time were part of
10 disinformation, would that be correct or not?
11 A. That would be disinformation itself.
12 Q. Mr. Kristo, perhaps we did not understand each other. Is it
13 correct that Croats in Zenica, and you personally, were mistreated?
14 A. Yes.
15 Q. Thank you. My last question to you, Mr. Kristo, while you were in
16 prison, you said that you were brought for interviews with the police and
17 army security officers?
18 A. Yes.
19 Q. Do you know the name Ramiz Suvalic?
20 A. No.
21 Q. Did he come to the prison for interviews?
22 A. No, he did not.
23 Q. Have you heard that he had come for some others?
24 A. Yes, those who had entered through the main entrance, he was with
25 them. I entered through the side entrance, and I was only interviewed by
1 the lower-ranking officials and policemen.
2 MR. MIKULICIC: [Interpretation] Thank you Mr. Kristo, I have no
3 further questions.
4 THE WITNESS: [Interpretation] Thank you.
5 MR. NICE: I have some questions for you from the Prosecution.
6 Cross-examined by Mr. Nice:
7 Q. You say in your summary that you were involved in the formation of
8 the HDZ in Zenica and of the HVO. How senior or junior were you in either
9 of those organisations?
10 A. In the HDZ, I was simply a member. In the HVO, I was commander of
11 the reserve troops of Raspotocje.
12 Q. Did you attend any meetings of the leadership of either the HDZ or
13 the HVO?
14 [Technical difficulty]
15 MR. NICE: I don't always have that effect.
16 Q. Mr. Kristo, I'll just repeat the last question because you may not
17 have heard it, and that is --
18 A. I had not heard it.
19 Q. -- did you attend any meetings of the leadership of either the HDZ
20 or the HVO?
21 [Technical difficulty]
22 MR. NICE:
23 Q. Mr. Kristo, did you hear the question this time?
24 [Technical difficulty]
25 MR. NICE: Obviously my fault.
1 Q. Mr. Kristo, did you hear the question?
2 [Technical difficulty]
3 JUDGE MAY: Mr. Nice, I'm told it's the thunderstorm in Zagreb and
4 not you, but I don't know whether it would be sensible to use another
6 MR. NICE: Let me try. While we're waiting for the connection,
7 what I will do is, having got an answer to the question, go straight to
8 the absolutely critical questions I must ask in case the rest of the call
9 is unsuccessful. It means I shan't be dealing with things strictly
10 chronologically, but I hope that will be understood.
11 JUDGE MAY: Can you hear us, Mr. Kristo? Can you hear us?
12 [Technical difficulty]
13 JUDGE MAY: Yes, Mr. Nice, let's see how we get on.
14 MR. NICE:
15 Q. Mr. Kristo, did you hear the question I asked you sometime ago
16 about being present at meetings of the leadership?
17 A. Yes.
18 Q. Can you just answer that question?
19 A. As far as the HDZ meetings is concerned, only large rallies and
20 not the leadership meetings. As far as the HVO is concerned, it was just
21 for guidance, but I did not participate in any top meetings.
22 Q. For the moment I'm going to go right to the end of your evidence,
23 for fear further breaks in transmission between here and Zagreb, so that I
24 can deal with the matters that you dealt with last. You say that you were
25 detained on what, the 18th or the 19th of April?
1 A. It was not 18th or 19th, it was three days following the conflict
2 which was around the 21st. That was the first time.
3 Q. The reason I ask you that is because in the summary of yours
4 that's been served on us, you say that they started arresting all Croats
5 on the 20th, but you say that by the 19th they'd already imprisoned all
6 military men from Cajdras?
7 A. Yes. Yes. This is what I said. I was at Raspotocje, not at
9 Q. How far is Raspotocje from Zenica?
10 A. From the town itself, three kilometres.
11 Q. Just to clarify this, you're not suggesting that there was an
12 attack by the ABiH on Zenica itself on either the 18th or the 19th of
13 April, are you?
14 A. 18th to 19th, the ABiH attacked the HVO.
15 Q. But not actually in Zenica itself?
16 A. Yes. Wherever the HVO was deployed, everything was attacked
18 Q. You weren't in Zenica on the 18th, were you?
19 A. I was.
20 Q. It's then my mistake for not understanding what you've told us.
21 You were in there on the 18th, but you didn't surrender then?
22 A. We surrendered on the 19th, in the afternoon.
23 Q. And on the 19th, where were you?
24 A. At Raspotocje.
25 Q. Had you been there all day on the 19th?
1 A. Yes.
2 Q. So were you taken into custody straight away on that day?
3 A. No. Two days later.
4 Q. So having surrendered, what did you do? Did you stay in your
5 barracks, or what happened? What was the form of the surrender?
6 A. The ABiH police told us that everyone was surrendered, that we
7 should not try anything, that we should surrender peacefully, that we
8 should turn over the weapons, and that they would guarantee our lives and
9 everything else.
10 Q. In any event, throughout the 19th, you were at Raspotocje and you
11 were not in Zenica?
12 A. Yes. That is a suburb.
13 Q. So you were there for -- several kilometres away from where the
14 shells landed when they landed near to the radio station?
15 A. From the centre.
16 Q. Yes. You were several -- thank you. You say that there was a
17 generalised attack on the HVO, but are you aware that on the 19th, people
18 were in the centre of Zenica, going about their business of shopping and
19 so on, and it was such people that were killed by the shells that landed.
20 A. Yes, but I don't know that.
21 Q. Well, the next thing is this: Are you aware, from what you will
22 have heard at the time, that Radio Zenica was the only local radio station
23 at that time that was not under HVO control?
24 A. Radio Zenica was not under the HVO control, no.
25 Q. That's correct. And indeed its broadcasts were upsetting to and
1 irritating to the HVO, weren't they?
2 A. Yes.
3 Q. In the military, where you were a reserve company commander, did
4 you or did you not have any particular skill in relation to heavy
6 A. No. No. We only had guard duties.
7 Q. Yes. You have no expertise in relation to artillery shells of any
9 A. Yes, I do. I was in the military, in the former military, where
10 we had exercise, and I was a crewman with a tank crew.
11 Q. Because you've told us in your evidence, and indeed in your
12 summary, that you were present and watched the shelling of Zenica, but
13 that simply isn't right, is it; you weren't present.
14 A. Yes. I was about 500 metres away from where the shells fell.
15 Q. I'm sorry. I don't understand that, because you've just told me
16 you were in the place where your barracks were all day, and that was
17 several kilometres away. You told us that you were there all day on the
18 19th, so you can't have been 500 metres away. Please explain.
19 A. I was at Raspotocje, and from Raspotocje, that direction, it could
20 be about 500. From my house, one can see the whole of the former Tito
21 Street, where the shells were falling near the department store.
22 Q. I'm sorry. I don't have a plan of the area with sufficient detail
23 to pick up Raspotocje at the moment, and we can't use overhead projectors
24 with you in Zagreb, but did you not tell me some questions ago that
25 Raspotocje -- was it four or five kilometres away?
1 JUDGE MAY: Three.
2 MR. NICE: Three. Thank you, Your Honour.
3 Q. Three kilometres away from the centre of town?
4 A. Yes. That is Raspotocje from the beginning. The whole Raspotocje
5 to the end of Raspotocje is some five or six kilometres. That is what the
6 beginning of Raspotocje is called.
7 Q. Well, you say that you were able to say where these shells came
8 from. How were you able to do that, please?
9 A. Yes, because I was looking straight towards the centre of the town
10 and the shells were falling in my direction, that is, facing me. And when
11 it fell on the asphalt, I saw it splinter.
12 Q. Two points about that, then. First, you weren't being accurate
13 when you told me a few questions ago that you weren't aware of people
14 being about the town doing their ordinary business, because you must have
15 been able to see the people in the street. Did you see the people in the
17 A. Well, I saw people, what they were doing. I mean, I saw people
18 moving about.
19 Q. The second thing is: Simply from seeing a shell land, you cannot
20 tell the direction from which it came, can you? You can only tell the
21 direction from which it came if you actually see the fire or light that
22 comes when the shell is actually fired.
23 A. You can't see the gun which fired the shell, but you can conclude
24 where it arrived from, because I know where Zenica is and I know where
25 Vlasic is.
1 Q. But you couldn't see the trajectory, you couldn't see the path of
2 the shell, because the paths of shells are invisible to the naked eye
3 because they're too fast.
4 A. Yes, I know, but one can see the flame.
5 Q. But you didn't see the flame coming from Vlasic; you just simply
6 saw, if your evidence is correct --
7 A. No, I did not, but I know. I saw where the shell landed on the
8 street and where the fragments then fell.
9 Q. Were you looking out specially for this shell or was it by chance
10 that you saw it?
11 A. It just happened.
12 Q. You know that the HVO had artillery on Puticevo, don't you; you
13 know that?
14 A. No, I don't.
15 Q. You know where Puticevo is, don't you?
16 A. I've heard, but I don't know.
17 Q. You say that Zenica then was attacked on the 18th of April. Can
18 you give us the details of what you say was the nature of the attack upon
20 A. We were attacked, and their sole objective was to capture us and
21 to have us lay down the weapons.
22 Q. My mistake for not being clear. What actually do you say happened
23 in Zenica? Forget what happened at your barracks. What do you say
24 actually happened in Zenica, so far as the HVO was concerned, and when?
25 A. Nothing happened in Zenica, because everybody had left Zenica to
12 Blank page inserted to ensure pagination corresponds between the French
13 and English Transcripts.
1 Podbrezje. Then we were in Raspotocje, and all the units were out of
2 Zenica. Nobody was in the town except the police.
3 Q. Thank you. So, and I think I touched on this earlier, there was,
4 in fact, no attack within Zenica by the ABiH on the HVO on the 18th or
5 19th of April?
6 A. Where the police was in the school --
7 THE INTERPRETER: We couldn't not hear the end of the sentence.
9 MR. NICE:
10 Q. The police were in the school. I think the interpreters would be
11 grateful if you'd just repeat your answer.
12 A. The school Sestra Ditri [phoen] is where the HVO police was. And
13 what was going on there, I don't know, because I was at Raspotocje, but
14 they were there and that was the only thing that was in the centre.
15 Q. All other HVO had left the town; is that correct?
16 A. Well, we were all out of the town Raspotocje, Gornje, Zenica,
17 Podbrezje, along the front line.
18 Q. And no Croats would be left around in the town, or very few; is
19 that the position?
20 A. The civilians were there, but the troops that were there, they had
21 pulled out of Zenica, left Zenica.
22 Q. I'm not in a position to accept or challenge your account of your
23 own imprisonment, but just help us with this: You say that you were
24 rearrested on the 16th of October. Was anything said to you by those
25 detaining you about what reason they had to do this to you?
1 A. For interviews, yes.
2 Q. But no other explanation ever given beyond that?
3 A. No, no, no.
4 Q. Have you ever given any earlier account in the form of a statement
5 about your experiences to any other body, investigating judge, or anything
6 of that sort, or not?
7 A. No, I did not, because there were threats; if anyone learned of
8 it, then that would be the end of me.
9 Q. And that was threats at the time, presumably, you mean?
10 A. Yes, in the school, yes.
11 Q. Since then, you haven't made any statements to any other body,
12 international or national, about your experience?
13 A. No, to no one. To no one.
14 Q. I'm sorry I'm dealing with things out of order, but it's for the
15 reason I gave before. Having become the company -- the reserve company
16 commander that you were, did you go to the swearing-in ceremony in
17 December of 1992 in Zenica?
18 A. No, I did not.
19 Q. Did you go to any such ceremonies ever?
20 A. I was at the HDZ rally and I wasn't at the troop review.
21 Q. The HDZ rally, when was that?
22 A. In the beginning of 1992.
23 Q. Who ran that rally, who were the main speakers?
24 A. Well, Josip Pojavnik, Mirko Sakic, he was the president of the
1 Q. Anybody else that you can remember?
2 A. Well, that was the Zenica area. I know them, and they were among
3 the first.
4 MR. NICE: Your Honour, I'm not going to take this witness through
5 the items that I dealt with with the other witness yesterday when we can
6 go through documents. In the circumstances, that's all I'm going to ask
7 him. Thank you.
8 MR. SAYERS: No more questions, Your Honour, thank you.
9 JUDGE MAY: Mr. Kristo, thank you for giving your evidence to the
10 Tribunal. You are released and free to go. Thank you. And we'll have
11 the next witness.
12 THE WITNESS: [Interpretation] Thank you.
13 [The witness withdrew]
14 JUDGE MAY: Yes, let the witness take the declaration.
15 THE WITNESS: [Interpretation] I solemnly declare that I will speak
16 the truth, the whole truth, and nothing but the truth.
17 WITNESS: SRECKO KRISTO
18 [Witness answered through interpreter]
19 [Witness testified via videolink]
20 JUDGE MAY: Thank you. If you'd like to take a seat.
21 Yes, can we have the picture from Zagreb, please.
22 MR. NAUMOVSKI: [Interpretation] Thank you, Your Honours.
23 Examined by Mr. Naumovski:
24 Q. Good morning, Mr. Kristo. Will you please give your name to the
1 A. Good morning, I am Srecko Kristo. I was born on the 19th of June,
2 1954 in the village of Kaonik, municipality of Busovaca.
3 Q. Very well, thank you. I shall lead you through most of your
4 statement, with the Court's leave, to try to bring this to an end as
5 quickly as possible because we have some technical difficulties. Would
6 you just listen to my questions and give us short answers. You are
7 married and a father of two, and with your family you live in Busovaca; is
8 that correct?
9 A. Yes, it is.
10 Q. You are in the restaurant business and that was what you have
11 devoted your career to. For the past 12 years, you had your own
12 restaurant in Busovaca and that is where you work; is that so?
13 A. Yes, it is.
14 Q. Mr. Kristo, on the 24th of January 1993, you went from Busovaca to
15 Kiseljak with a friend of yours, Igor Bogdanovic; is that correct?
16 A. It is.
17 Q. You set off around 9.00 in the morning, and in point of fact, you
18 were going to Konjic because you were going to buy a jeep there?
19 A. Correct.
20 Q. In Konjic, you did buy the jeep as you were planning to do and you
21 returned to Kiseljak sometime around 1400 or rather slightly before that.
22 A. Yes, correct.
23 Q. And after a short stop in Kiseljak, you set off to -- for
25 A. Correct.
1 Q. And on your way from Kiseljak to Busovaca, you dropped into a ...
2 [Technical difficulty]
3 MR. NAUMOVSKI: [Interpretation]
4 Q. I shall repeat the question. On your way from Kiseljak to
5 Busovaca, you stopped by a coffee -- a cafe called Jelenov Gaj, which is
6 some kilometres before Kacuni; is that correct?
7 Could you hear me? Can you hear me, Mr. Kristo?
8 [Technical difficulty]
9 MR. NAUMOVSKI: [Interpretation]
10 Q. Can you hear me now, Mr. Kristo?
11 A. Yes, I can.
12 Q. So let us move on. When you left Kiseljak and headed for
13 Busovaca, you dropped by a pub called Jelenov Gaj which is a few
14 kilometres before Kacuni?
15 A. Yes.
16 Q. And the owner of the place warned you that it would be better for
17 you to head for Busovaca as quickly without delay because there was some
18 gunfire that could be heard from Kacuni?
19 A. Yes, correct.
20 Q. And he told you on the same occasion that before you, a military
21 policeman, Ivica Petrovic, had headed in the same direction.
22 A. Yes.
23 Q. You knew Ivica Petrovic, didn't you?
24 A. Yes.
25 Q. And you followed the advice of the publican and decided it would
1 be better to have some company. So you hurried on your way in order to
2 catch up with Ivica Petrovic; is that correct?
3 A. It is.
4 Q. And you caught up with Ivica Petrovic's vehicle only after you
5 entered Kacuni, somewhere near the crossroads where the road then branches
6 off to the silo which is not far from the mosque.
7 A. Correct.
8 Q. Ivica Petrovic's vehicle was already stopped in the street when
9 you arrived.
10 A. Yes.
11 MR. NICE: I object to any further leading of the witness.
12 MR. NAUMOVSKI: [Interpretation]
13 Q. Tell us, please, when your vehicle stopped behind Ivica Petrovic's
14 vehicle, what happened then? Did anyone come up to you?
15 A. Could you repeat the question, please?
16 Q. When you came to a stop behind Ivica Petrovic's vehicle, did
17 anyone come to your vehicle?
18 A. Yes, at that point, when we caught up with Ivica Petrovic's
19 vehicle, we were surrounded by soldiers of the BH army. They surrounded
20 us from both sides of our vehicle and forced us out. We had to leave the
21 vehicle with the engine switched on.
22 Q. Tell us, those soldiers that were around in that area, were they
23 armed and did you spot what kind of weapons they had?
24 A. Yes. They were armed 100 per cent with automatic rifles,
25 semi-automatic rifles and hand-held launchers.
1 Q. Were some of the rifles also equipped with anti-personnel mines?
2 A. Yes.
3 Q. So, at some point, you were forced to get off the car?
4 A. Yes, they ordered us to get off the car. They ordered me and the
5 driver, Igor Bogdanovic.
6 Q. Tell us, please, did you -- were you and Igor Bogdanovic wearing
7 civilian clothes or some other clothing?
8 A. We were both wearing civilian clothes.
9 Q. And what about Ivica Petrovic, did you see him?
10 A. Ivica Petrovic was ahead of us. He was standing by his jeep of
11 the military police, and he was in the military police uniform.
12 Q. Tell us, when you left the car, what did those soldiers order you
13 to move in, what direction?
14 A. When we got off the car, they told us to put our hands up and we
15 did so. And they drove us in front -- to move to front of them. They had
16 their rifles aimed at our backs so that we moved under their orders.
17 Q. In what direction did they tell you to move, or rather, force you
18 to move?
19 A. Well, we moved towards Kacuni, or rather, they took us towards the
20 silo where the BH army was, and their prison.
21 Q. Just to explain to the Court, they forced you to get off the main
22 road and take a side road in the direction of the silo.
23 A. Yes, correct.
24 Q. And so you started in that direction. What did you see as you
25 walked down that road towards the silo?
1 A. When we started in front -- ahead of those armed soldiers of the
2 BH army, I cast a look and there were about 10 or 15 vehicles of the then
3 UNPROFOR which were turned heading from Busovaca towards Kiseljak. Some
4 of the vehicles had been diverted towards the silo and other vehicles
5 stayed on the main road from Busovaca to Kiseljak and were stopped there.
6 Q. When you observed these vehicles, did you think that you were
7 going to be in a better situation now?
8 A. Yes, of course. I thought that there would be no problems. I
9 thought that they would be solving the situation.
10 Q. Very well. What happened in the meantime? Did anybody arrive?
11 A. While we were walking in front of the ABiH soldiers in the
12 direction of their silo, where ABiH soldiers were stationed, and I guess
13 where the prison was, from the direction of Busovaca an armoured vehicle
14 arrived, an HVO vehicle. This was a makeshift armoured vehicle, and it
15 went by the UNPROFOR vehicles which were parked on the road. Even while
16 we were walking with our hands up, under orders of ABiH soldiers, the
17 vehicle approached us, and then the soldiers who were taking us in the
18 direction of silo scattered to the left and right, and they took cover on
19 the side of the road and opened fire on the HVO patrol vehicle.
20 Q. Mr. Kristo, was this a real armoured vehicle or was it just a
21 truck which had some plates mounted on it?
22 A. It was an improvised or makeshift vehicle that only had armoured
23 plates put on it.
24 Q. You said that the soldiers took cover and opened fire on the
25 vehicle. Did they open fire out of small arms or also the heavy weapons?
12 Blank page inserted to ensure pagination corresponds between the French
13 and English Transcripts.
1 A. Yes, they opened fire on the HVO vehicle, which arrived from the
2 direction Busovaca, out of all the weapons they had on them. I was still
3 on that road with my hands up, and in that moment I saw that from a
4 house -- I saw some red dust coming from this house, that the roof tiles
5 were breaking up and falling. That means that somebody had fired a
6 rocket-propelled grenade at the vehicle but had missed it and hit the roof
7 of this house.
8 Q. We can move right on to paragraph 14 in your outline. What
9 happened at that time? Did you see what happened to Ivica Petrovic and
10 Igor Bogdanovic?
11 A. While I still held my hands up, I saw Ivica Petrovic. At that
12 point, we had parted a little bit, one to the left, one to the right, when
13 the shooting had started. I turned around and I saw Ivica Petrovic who
14 had been hit, and unfortunately he died. I was petrified with fear. And
15 I also saw Igor Bogdanovic as he was trying to cross the road and enter
16 our jeep. However, he was hit by a rocket-propelled grenade fired from a
17 semiautomatic rifle.
18 MR. NAUMOVSKI: [Interpretation] Your Honours, we would like to
19 introduce -- to tender several exhibits. We do not need to show it to the
20 witness, but this is death certificates of these two individuals, Ivica
21 Petrovic and Igor Bogdanovic. Also, page 225 of Colonel Stewart's book
22 "Broken Lives," which describes the death of the two individuals at the
23 location which has just been described by the witness. Perhaps we can be
24 given the numbers for the exhibits and we can move on.
25 JUDGE MAY: Just one moment.
1 THE REGISTRAR: The death certificate of Igor Bogdanovic shall be
2 Defence Exhibit D299/1. The death certificate of Ivica Petrovic shall be
3 Defence Exhibit D300/1. The extract from the book "Broken Lives" shall be
4 Defence Exhibit 301/1.
5 MR. NAUMOVSKI: [Interpretation]
6 Q. Mr. Kristo, I was about to tell you that the reason for our
7 waiting was of technical nature, because we need to have the exhibits
8 properly registered.
9 So let us conclude about this incident. You were an eyewitness of
10 the deaths of Ivica Petrovic and Igor Bogdanovic?
11 A. Yes, an eyewitness.
12 Q. We can move through the rest of the outline swiftly. While you
13 were observing what was going on, did you also observe a vehicle which was
14 trying to manoeuvre its way around to turn facing Busovaca?
15 A. Yes. One of the vehicles, one of the UNPROFOR jeeps, was
16 manoeuvreing in the road, moving left and right, trying to turn around in
17 the direction of Busovaca.
18 Q. Did you try to use the opportunity to leave this place?
19 A. Yes. When I saw that this vehicle was turning around, I ran over
20 to it, to this UNPROFOR vehicle. I grabbed the right-hand side. I
21 climbed on it and I grabbed the window.
22 Q. Did you open -- did you say something to the soldiers who were
24 A. There were four soldiers in the vehicle. They were all armed with
25 rifles. They turned to me. I quickly tried to tell them, in German, that
1 I will pose no problem, that I was a civilian, and that I needed to be
2 taken out of this situation, to Busovaca.
3 Q. So in other words, you asked them to help you, as a civilian?
4 A. Yes.
5 Q. So did they help you?
6 A. While I was explaining this, that was about ten metres [as
7 interpreted], a soldier who was sitting in the passenger's seat grabbed me
8 by my hands and kicked me off the vehicle.
9 Q. So you were thrown off the vehicle, but you had moved away from
10 the spot where Ivica Petrovic and Igor Bogdanovic were killed?
11 A. Yes.
12 Q. And following that, if I follow your outline, you tried to hide.
13 A. Yes. Still not knowing what was going on, I -- this jeep was
14 moving slowly, so I ran behind it and I ran in the direction of Kacuni and
15 tried to hide in a house, but it was locked. Then I went around it. I
16 saw a shed, and that's where I hid at that time.
17 Q. Can you tell us: Were you able to flee in the direction of
19 A. No. I could not flee, because I observed soldiers and civilians
20 in the centre of Kacuni and I heard the sounds of unloading of a truck.
21 They were unloading timber, big logs, with which they barricaded the road.
22 Q. Just to clarify, from the mosque in Kacuni, in order to get to
23 Busovaca, to cross the bridge --
24 A. Yes, cross the bridge. And on that location, this is where the
25 truck was unloading the logs, and you could not cross it, either on foot
1 or in a vehicle.
2 Q. We can just move quickly through the paragraph 18. It was
3 wintertime and you were dressed very lightly because you had left your
4 jacket in the vehicle?
5 A. Yes. We had left our jackets in the back seat of the vehicle, and
6 we only had light shoes and light tops on.
7 Q. While you were freezing in that shed for several hours, did you
8 observe that the ABiH soldiers were searching for you?
9 A. When I entered the shed, I noticed soldiers and civilians. They
10 were all running towards the road. They were cursing Croats, Ustashas.
11 And they were deploying mines on the road and they were also looking for
12 me. I think that they thought that I had crossed the bridge and fled in
13 that direction, not realising that I was still hiding.
14 JUDGE MAY: One moment. Mr. Kristo, you've got some paper in
15 front of you which you appear to be reading from. What is the paper,
17 A. No, I'm not reading from the paper, and this is probably the paper
18 that you yourself also have.
19 JUDGE MAY: It's a summary of your evidence, is it?
20 A. Yes.
21 JUDGE MAY: Well, it may be better if you put it away and so
22 there's no doubt about it.
23 THE WITNESS: [Interpretation] No problem.
24 JUDGE MAY: Yes, Mr. Naumovski.
25 MR. NAUMOVSKI: [Interpretation].
1 Q. Thank you, Your Honour. We'll proceed swiftly, Mr. Kristo. You
2 spent several hours in the shed and when the dust gathered, you moved on
3 towards the school at Kacuni without realising that the soldiers were
5 A. Yes.
6 Q. Because you were not able to hide there, you moved on. In which
7 direction did you go?
8 A. I spent two or three hours in the shed, but this was already dusk,
9 5.00, 5.30. I moved on towards the school, the elementary school, without
10 realising that the soldiers were there, actually, the ABiH headquarters.
11 So I crawled up to the school building, then I got up. There is an
12 athletic field by the school and I ran across it and entered a forest.
13 Q. You hid in the forest almost two days.
14 A. Yes. Because I was encircled there. I hid there all night
15 walking very quietly through the forest because I did not know the
16 terrain. I had thought that they had set up barricades. I thought that
17 it would have been easiest for me to go in the direction of Kiseljak
18 through the forest. So that is what I did.
19 Q. So as you backtracked towards Kiseljak, you arrived in the village
20 of Gusti Grab?
21 A. Yes, I walked through the forest all night. When they overheard
22 my footsteps, they would open fire. I would then stop and stay quiet, and
23 this is how I went through the night. And the next morning, I arrived in
24 the village called Gusti Grab.
25 Q. When you arrived there, was there fighting there? That is, the
1 attack, had the village been attacked, and who had attacked the village?
2 A. At that time, it had still not been attacked. But I saw
3 civilians, women, children, packing their bags and suitcases and preparing
4 to leave that place because they had heard that ABiH soldiers were
5 advancing towards them.
6 Q. Could gunfire be heard in the area?
7 A. Yes, throughout the night and all day the next day, gunfire could
8 be heard.
9 Q. A group of the civilians were transported by buses to Kiseljak and
10 you went with another group.
11 A. Yes, we started out towards Kiseljak on foot using village roads,
12 and the dusk again had fallen and the situation calmed down somewhat. We
13 all took shelter in a house owned by Niko Grubesic, that is, his parents,
14 and waited for the buses to come from Kiseljak to pick up the civilians.
15 We waited there for two or three hours because we arrived at that house
16 around midnight and the buses arrived around 5.00 or 6.00. They loaded up
17 as many civilians as they could; children, elderly. They boarded them and
18 they took them in the direction of Kiseljak.
19 Myself and two or three younger men went back to that restaurant
20 called Jelenov Gaj.
21 Q. Niko Grubesic's house is in the part of the village called
23 A. Yes.
24 Q. Their Honours have already heard this, but Niko Grubesic's parents
25 did not leave, they stayed behind.
1 A. They stayed behind thinking -- they thought they would join the
2 rest later.
3 Q. Did you hear what had happened to them?
4 A. Yes, they were both killed.
5 Q. When you were leaving Gusti Grab and moving towards Oseliste
6 through the forest, did you notice anything else; fighting or some houses
7 on fire?
8 A. Yes, there was gunfire, there was smoke probably from houses
9 being -- having been set on fire and things like that.
10 Q. Very well. Mr. Kristo, if I understand you correctly, instead of
11 proceeding to Busovaca, you went back to Kiseljak. How many days did you
12 stay in Kiseljak?
13 A. Yes. Because I couldn't go to Busovaca, I returned to Kiseljak
14 and I spent there 17 days.
15 Q. Were the jeep and your valuables, money, ever returned to you?
16 A. No. We tried, but without success.
17 Q. And the last point that I need to ask you about. You are aware
18 that a witness in this matter, I think it was Witness AE, he said that on
19 January 24, which is what you refer -- that only one person was killed,
20 while the second Croat mentioned by this witness allegedly was escorted by
21 the ABiH soldiers in the direction of Busovaca. Is that true what he
23 A. No, it is not true. What is true is that two people were killed,
24 the military policeman, Ivica Petrovic, and the gentleman who was with me
25 in the vehicle, Mr. Igor Bogdanovic. And by sheer luck, I was able to
1 save myself and I survived.
2 MR. NAUMOVSKI: [Interpretation] Thank you, Mr. Kristo. I have no
3 further questions. I assume that the Prosecution may have some questions
4 for you.
5 MR. MIKULICIC: I have no questions, Your Honour.
6 Cross-examined by Mr. Nice:
7 Q. Mr. Kristo, I have some questions to ask you for the Prosecution.
8 The cafe that you own in Busovaca, is that the Cafe Bos?
9 A. Yes, it's the Cafe Bos.
10 Q. Was that a cafe that was particularly resorted to by the members
11 of the HVO in the conflict?
12 A. There was no conflict until then and there were no HVO soldiers
13 there, but when the conflict started, they were in the -- in this cafe but
14 I was in Kiseljak, I didn't know anything about it.
15 Q. You stayed in Kiseljak until when?
16 A. I stayed there 17 days. I know that it was exactly 17 days.
17 Q. And you were back in Busovaca in February of 1993.
18 A. Yes.
19 Q. You stayed there throughout the war, is that right, in Busovaca?
20 A. Yes.
21 Q. At the cafe?
22 A. Yes, even though it was not working after that anymore.
23 Q. I see. You gave up the cafe and went to live in Croatia when?
24 A. No, I did not give up the cafe, and I did not move to Croatia.
25 Q. You now -- you still live in Busovaca?
1 A. Yes.
2 Q. You've had to travel from Busovaca all the way to Zagreb today or
3 yesterday; is that right?
4 A. Yes. I arrived in Zagreb two days ago, two days ago, day before
6 Q. Just give me one minute, sorry. Have you been in Busovaca then
7 continuously? I'm sorry, my mistake.
8 A. I don't understand.
9 Q. No, no, it was my mistake. On the 24th of January of 1993, you
10 say you went to buy a jeep. So first you went to Kiseljak, you had to
11 pass that checkpoint?
12 A. I went to Kiseljak -- I apologise. I went, but I did not go in a
13 jeep. I went in a passenger vehicle with a friend and I went to get the
15 Q. I understand that. But first of all, you had to pass the Kacuni
16 checkpoint; correct?
17 A. At that time, there were no checkpoints on the road because had
18 there been any, I wouldn't have gone.
19 Q. Well, are you saying that there was no checkpoint and no sign of a
21 A. No, at that time there were no checkpoints. The movement was free
22 from Kiseljak to Konjic, Zenica, anywhere. At least personally, I went
23 there and there were no checkpoints at that time.
24 Q. And was this a road you had been using regularly at that time?
25 A. I didn't understand.
1 Q. Had you been on the road, say, the previous day, the 23rd, or the
2 day before that, the 22nd?
3 A. Not a day or two, but perhaps ...
4 Q. Were you aware of any previous problem with the same position at
5 Kacuni with there being a checkpoint there? Were you aware of any
6 previous problem?
7 A. No. There were no checkpoints. And had there been any problems,
8 I probably would not have gone with money on me.
9 Q. But Mr. Kristo, four days before all this happened on the 24th,
10 four days earlier, all Muslim businesses in Busovaca had been blown up.
11 You don't recall that?
12 A. No. How do you mean, Muslim companies or businesses?
13 Q. Well, shops and cafes and businesses in Busovaca were blown up
14 four days earlier.
15 A. No, no, no. I don't recall that. I don't think there was any of
16 that, because everything was open.
17 Q. Were you in your cafe over the preceding three or four days?
18 A. Yes. I was there around the clock, because that was my workplace.
19 Q. There was a murder as well. Do you remember the murder, anything
20 about a murder that happened about four days before, a man called Mirsad
22 A. No, I am not aware of that.
23 Q. Well, let's go back to the 24th of January. You passed the exact
24 place where the checkpoint was subsequently to be, and there was no sign
25 of a checkpoint; there were no barriers, no vehicles, nothing. Is that
12 Blank page inserted to ensure pagination corresponds between the French
13 and English Transcripts.
1 the position?
2 A. Yes. There was nothing. The road was clear.
3 Q. And what time of the morning do you think it was that you passed
4 on your way for Kiseljak? Half past 8.00? 8.00?
5 A. Between 8.00 and 9.00. Around 9.00. I'm not quite sure, but I
6 think it must have been between 8.00 and 9.00.
7 Q. You then went off and bought the jeep, and you paid for that in
8 cash, did you?
9 A. Yes.
10 Q. Incidentally, before I move on, did you take no part at any stage
11 in the fighting or in the organisation of affairs in Busovaca throughout
12 the conflict?
13 A. No.
14 Q. Were you the only Srecko Kristo in Busovaca, or was there another
16 A. There are several of us.
17 Q. Is one of those a military policeman, one of the other ones of the
18 same name?
19 A. I do not know him myself. I think he's somewhere from
20 Lasva -- rather, Dusina, where another massacre happened.
21 Q. Now, you've given an account of coming back, but when you came
22 back, of course, you have to be in three cars all together, don't you:
23 your friend's car, your jeep, and then, by the time you joined up with
24 Petrovic, Petrovic's vehicle. So is it three vehicles?
25 A. No. The friend who had taken us to Kiseljak had gone back, and I
1 and Mr. -- or rather late Igor Bogdanovic, we had gone in his vehicle to
2 get the jeep in Konjic.
3 Q. And who was this other friend, then? What was the name of this
4 friend who took you all the way there?
5 A. I think his name was Marko Vuleta. Marko Vuleta and Franjo
7 Q. When you heard of what was the problem ahead at the checkpoint,
8 you joined up with or you --
9 [Technical difficulty]
10 MR. NICE:
11 Q. Mr. Kristo, I'll repeat what I was asking you just before we lost
12 transmission. When you heard of what the problem ahead of you at the
13 checkpoint was, you joined up effectively with Ivica Petrovic; is that
15 A. On my way back from Konjic to Kiseljak, and from Kiseljak towards
16 Busovaca, we stopped by the Jelenov Gaj cafe, and there we heard from the
17 owner that something was afoot in Kacuni and that --
18 Q. Let me save you some time. I understand what your account is on
19 that. I'm leaping ahead of you to the place where you say that you joined
20 up with Petrovic, or you caught up with Petrovic. Now, by the time
21 Petrovic got to the checkpoint, had you already caught him up or was he
22 there ahead of you?
23 A. There was no checkpoint, but armed and masked soldiers had stopped
24 Ivica Petrovic's jeep and we had just caught up with it.
25 Q. Now, is it possible that Petrovic had already fired some shots
1 before you arrived?
2 A. No. No, he did not, because when we made it where it was, he was
3 disarmed. He had been disarmed. His pistol and his belt were lying down
4 on the road.
5 Q. And, therefore, he may have fired some shots before you ever
7 A. No, no, he couldn't have, because we saw him. We were driving
8 behind him, perhaps a kilometre or so. He was stopped by masked and armed
9 soldiers on the road, which was open for traffic and free.
10 Q. You've made reference to UNPROFOR vehicle or vehicles. Was there
11 already an UNPROFOR vehicle at this point in the road at the time that you
12 arrived? Indeed, was it trying to get through?
13 A. When I came up, or rather when we were stopped by those armed
14 troops, UNPROFOR vehicles, the then-UNPROFOR vehicles, some ten or fifteen
15 of them -- I don't know exactly -- were then diverted towards the silo, as
16 you look from Busovaca, and other vehicles were along one of the lanes on
17 the road. But some of them were diverted towards the silo, and that came
18 as a surprise to us.
19 Q. What nationality of UNPROFOR do you say it was that was involved
21 A. I wouldn't really know, but I do know that it was UNPROFOR, and
22 one more or less knows who was there in January 1993. Whether they were
23 coming from Busovaca, whether they were just passing by or coming up, I
24 don't know.
25 Q. How many vehicles all together were there for UNPROFOR?
1 A. I couldn't really say, because it was all happening so fast, but I
2 should say around ten.
3 Q. What colour were these vehicles painted? Camouflage colour?
4 A. No.
5 Q. What colour, then?
6 A. White, I think.
7 Q. And just disposing of the UNPROFOR vehicles, you're saying that in
8 due course one of them simply threw you off his vehicle, effectively, when
9 you were turning to him for help. Can you help us at all with the
10 nationality of that person to whom you spoke?
11 A. I couldn't really tell you what state he came from, but in all
12 that fracas and fear, I gripped and took hold of the jeep which was
13 manoeuvreing to go back to Busovaca. And I addressed those soldiers in
14 German, as much as I knew it, to give me a lift to Busovaca because they
15 had already turned and headed for Busovaca. But probably afraid that the
16 troops which had -- who had stopped there and were seizing vehicles might,
17 when firing at me hit, them. That must have been the reason why they
18 simply threw me out of their vehicle.
19 Q. And after your return to Busovaca to dispose of this, you made no
20 complaint to UNPROFOR at all through local officials or on your own
21 account about what had happened?
22 A. Well, no, I spent 17 days in Kiseljak and by that time, barricades
23 had risen all around so that I came with a Croat and a Muslim through
24 Visoko, Zenica, that is Kakanj, Zenica, to Vitez, and then I returned home
25 in Busovaca. And by that time, it was practically the state of war but it
1 wasn't that, it was saving our lives.
2 Q. But in any event, at the checkpoint itself, a significant number
3 of UNPROFOR vehicles were being blocked and diverted from their chosen
4 route by these men at the checkpoint or whatever we described it as.
5 A. I must repeat it once again. There weren't barricades, because
6 had there been any, nobody would have taken the road. It was open, free,
7 for all individuals. Those who wanted to travel could travel and did
8 travel. There were no barricades, there were no roadblocks. Even when I
9 came up, there were no roadblocks there. We were simply stopped by armed
10 troops, and we had to come to a stop because they had aimed at us their
11 rocket launchers and rifles, and we could not stop -- we were stopped at
12 an open place.
13 Q. When you got there, apart from the men on the road, were there
14 other men, apparently ABiH men, in the fields or whatever on either side
15 of the road?
16 A. I didn't understand the question. What do you mean when I came
18 Q. If I said "when I came home," then that's my mistake. When you
19 got to the place where --
20 A. I did not get home, I went to Kiseljak.
21 Q. When you got to the place where the men were in the road is what I
22 was asking you about. When you got to the place where the men held you
23 up, were there other men or were there some men in the fields at the side
24 of the road?
25 A. I don't know if there were any in the field, but 10 or 15 of them
1 were armed, surrounded us, "Hands up," and we could not really look left
2 or right. Only the UNPROFOR vehicles were diverted towards the silo, they
3 were there, Ivica Petrovic's vehicle and our vehicle.
4 Q. It's true that at some stage in this incident, you personally were
5 escorted by an ABiH soldier or soldiers along the road; is that correct?
6 A. The soldiers of BH army, they were only around us, and I'm telling
7 you that I got hold of the UNPROFOR jeep which drove me some 10 metres or
8 so towards Busovaca and then they threw me off. And I then ran to Kacuni
9 and hid in a shed and there were no -- there was no escorting by the BH
10 army. Had they been escorting me, they would have been -- locked me up in
11 a prison because two men had already been killed. So there was no
12 escorting, it was either being killed or imprisoned.
13 Q. Could you tell us, and this is what I was asking you about, that
14 there was a time when you were being led to the road that led towards the
15 silos; is that right?
16 A. No. They -- we had arrived to the junction where it branches off
17 towards the silo.
18 Q. But my point, and I'm sorry if I didn't make it clearly, but my
19 point was there was a time when you were being led by HVO soldiers
20 along -- I beg your pardon, by ABiH soldiers, along the road; correct?
21 A. Yes. After they stopped us before the crossroad to the silo,
22 about 50 metres or so, and made us get off our jeep, both of us, and Ivica
23 Petrovic, who was already out of his vehicle, and they made us move
24 towards the silo, that is to the crossroad. The crossroad leading to the
25 silo was about 50 metres away. It was at that moment that the HVO vehicle
1 came up and then there was gunfire all around.
2 Q. All right. But in any event, somebody -- if there was somebody
3 standing in the field, he would have seen you at one stage being led along
4 a road by ABiH soldiers, correct, or he could have seen you being led
5 along the road by ABiH soldiers?
6 A. Yes, "if."
7 Q. You then say that you held on to the side of this vehicle, this
8 UNPROFOR vehicle but only for a few metres; correct?
9 A. Yes.
10 Q. How many metres do you say that was, roughly?
11 A. 10, 15 maybe.
12 Q. So that the soldiers who were escorting you were only ever going
13 to be, at most, 10 or 15 yards away from where you were when the UNPROFOR
14 soldier pushed you off the vehicle?
15 A. Well, more, perhaps 20 or 30, because they had scattered to the
16 left and right when the HVO armoured vehicle had come and we had moved
17 forward, and that is when the gunfire started. And when the fire was
18 opened, one stood to the left, one to the right, and it was there in all
19 this melee we still had our hands up and looked what was going on, and the
20 ABiH troops had taken cover on both sides and they were firing at the HVO
22 JUDGE MAY: Mr. Nice, I'm going to interrupt you for a moment.
23 It's well beyond the hour and a half.
24 MR. NICE: Yes, of course. I shan't be long if that helps.
25 JUDGE MAY: You won't be many minutes. I'm grateful to those in
12 Blank page inserted to ensure pagination corresponds between the French
13 and English Transcripts.
1 the booths for supporting us over this lengthy period. It's obviously
2 much better if we could finish. Would that be all right and then we'll
3 have lunch?
4 THE INTERPRETER: No problem, Mr. President.
5 JUDGE MAY: Mr. Nice.
6 MR. NICE: I will do my best.
7 Q. And then this little HVO, or small HVO vehicle, you say, came
8 along. And at what did that fire?
9 A. I don't know. I do not think that any fire came from that
10 vehicle. Inside it, I could see three soldiers and they were on a patrol
11 or -- I don't know. I mean, I don't know what they were doing.
12 Q. Well, then, it's my mistake for misunderstanding it, but why
13 should the ABiH soldiers who were guarding you and taking you to the road
14 where the silos were, why should they suddenly run away if, in fact, all
15 that was happening was that an HVO vehicle was arriving which wasn't going
16 to threaten anyone?
17 A. Well, I guess because they had stopped the military policeman,
18 Ivica Petrovic and me. And realising that we were from Busovaca and that
19 was -- and those were masked troops who either wanted to capture the jeeps
20 and rob us, and that is what they did, and they were afraid that somebody
21 would -- I don't know. I mean they scattered. I don't know why. And
22 they perhaps fired at that vehicle fearing that they might fire at them.
23 I don't know.
24 Q. Or is the position that, in fact, you did manage to escape that
25 same day to Busovaca, you were taken there by somebody from the ABiH?
1 A. No way. Out of the question. They could have only escorted me
2 like the two who ended up in prison.
3 Q. One thing that is clear on your own account is that there were two
4 people killed at the checkpoint, one being Petrovic and the other your
5 companion, and what sort of weapon killed him; do you know?
6 A. Yes, yes. Not possibly, but they were killed. Well, I think it
7 was an automatic rifle that Ivica Petrovic was hit by, and from what I
8 learned later, outrages were committed upon his body. And Igor Bogdanovic
9 was hit from a rocket launcher in the stomach.
10 Q. And do you know the proper name for the rocket launcher?
11 A. It is a grenade and you can put it on the rifle. I'm not sure.
12 Q. So if somebody were to describe how two Croats, however described,
13 were killed at a checkpoint in Kacuni on the 24th, on your account, that
14 would be an accurate account, wouldn't it?
15 A. This is as I told you, because I'm the only one who saw it from
16 the other side. However, I would say once again there was no checkpoint
17 there. It was stopping a vehicle in -- stopping a moving vehicle. That
18 is what it was.
19 Q. Was the weapon that killed your companion a Zolja? Was that the
20 name of the weapon?
21 A. No. No.
22 Q. Do you know what a Zolja is?
23 A. I don't think so. I mean, because I didn't see it, because he was
24 buried and subsequently transferred to Kiseljak.
25 Q. My last question is just this: Are you quite sure you were in
1 Busovaca in those last four days before, that is, between the 20th and the
3 A. I didn't understand.
4 Q. Are you quite sure you were in Busovaca between the 20th and the
5 24th of January?
6 A. I was in Busovaca. That is where I resided. That is where my
7 family was. But I could have been in Zenica or in Travnik or in Vitez.
8 Q. But you were in Busovaca on those four days, and you've had a
9 chance to think about it and we've had one or two breaks in transmission,
10 I think. You really have no recollection --
11 A. I can't remember.
12 Q. You really have no recollection at all of any incidents happening
13 in Busovaca a day or so -- or about four days before you went off to buy
14 your jeep?
15 A. No. Was I there one of those days? I told you: I went around
16 Zenica, Travnik, Busovaca, Kiseljak. I went around and I did not hear
17 about any incidents at that time. Had there been any, I guess I wouldn't
18 have gone to buy a jeep at such a time.
19 MR. NICE: Nothing else. Thank you.
20 MR. NAUMOVSKI: [Interpretation] I do not have any supplementary
21 questions. Thank you, Mr. Kristo, once again.
22 JUDGE MAY: Mr. Kristo, thank you for giving your evidence to the
23 International Tribunal. That is all. You are free to go.
24 THE WITNESS: [Interpretation] Very well. Thank you.
25 [The witness withdrew]
1 JUDGE MAY: We'll adjourn now for the luncheon adjournment. We
2 will take slightly longer than usual and we'll be back at half past 2.00,
3 when we'll sit again.
4 --- Luncheon recess taken at 12.30 p.m.
2 --- On resuming at 2.31 p.m.
3 JUDGE MAY: Yes, are we through to Zagreb?
4 THE REGISTRAR: Yes, we are, Your Honour.
5 JUDGE MAY: Let the witness take the declaration.
6 THE WITNESS: [Interpretation] I solemnly declare that I will speak
7 the truth, the whole truth, and nothing but the truth.
8 WITNESS: ILIJA ZULJEVIC
9 [Witness answered through interpreter]
10 [Witness testified via videolink]
11 JUDGE MAY: Yes, Mr. Naumovski, Mr. Sayers.
12 Examined by Mr. Sayers:
13 Q. Good afternoon, Mr. Zuljevic. Let me just explain. My name is
14 Stephen Sayers, together with my colleague, Mitko Naumovski, we represent
15 Dario Kordic. I'd like to take you fairly quickly through the outline
16 that you signed. Let's just start with your full name, sir, would you
17 state that for the Court?
18 A. My name is Ilija Zuljevic. I was born on the 13th November, 1953.
19 Q. I believe that you were born in the village of Hrasnica in the
20 municipality of Uskoplje?
21 A. That is correct.
22 Q. Just going through your background fairly quickly, Mr. Zuljevic, I
23 believe that you went to elementary school in Pavic Konj, to high school
24 in Zagreb, and to college in Sarajevo where you studied theology and
1 A. That is correct.
2 Q. I believe that you also worked as a priest after your college
3 career and that you graduated from college and worked as a priest after
5 A. Correct. That's right, I was a chaplain.
6 Q. All right. And I understand that you got into hot water with the
7 communist authorities as a result of your activities in writing a
8 newspaper article that caused you some legal difficulties and the loss of
9 your passport and civil rights at the hands of the communist government
10 for approximately ten years.
11 A. Correct.
12 Q. And I believe that you continued to work as a chaplain, or as a
13 priest, until 1988.
14 A. Correct.
15 Q. And two years after that, you joined the Croat Democratic Union of
16 Bosnia-Herzegovina and became one of the three members of its secretariat,
17 each of whom was directly responsible to the president of the party.
18 A. Correct.
19 Q. You worked first, sir, with Davor Perinovic, the first president
20 of the HDZ-BiH and then with Mr. Stjepan Kljuic, the second president of
21 the party?
22 A. That is correct.
23 Q. And following that, you left that job in February of 1991 to
24 become Deputy Minister for Veteran's Affairs in the government of the
25 Socialist Republic of Bosnia-Herzegovina.
1 A. The Socialist Republic of Bosnia-Herzegovina, that is correct,
3 Q. Thank you, sir. I believe at that time, the prime minister of the
4 government was Jure Pelivan.
5 A. He was.
6 Q. And when the country declared its independence, became the
7 Republic of Bosnia-Herzegovina you stayed on in your position with the new
8 government until the summer of 1992.
9 A. Correct.
10 Q. I believe that you left Sarajevo, the city of Sarajevo on the 31st
11 of May of 1992 and joined the HVO civil government in Grude.
12 A. That is correct.
13 Q. You began working in the information and propaganda department,
14 sir, but shortly after that, you began working as the head of the
15 subdepartment for labour and social care in the HVO Department of Social
17 A. Correct.
18 Q. And when the Croat Republic of Herceg-Bosna was established in
19 August of 1993 when the ministries of the government were set up, you
20 became Minister of Labour, Welfare and Family holding that position until
22 A. Correct.
23 Q. And I believe that you and your family now live in Zagreb in the
24 Republic of Croatia and that you are currently not working, sir.
25 A. Correct.
1 Q. Now, the next part of your outline, and we're at paragraph 7, Your
2 Honours, deals with matters of background, Mr. Zuljevic, which I am sure
3 that you will appreciate in a case as long as this we've heard a lot about
4 already. So I'd like to take this material very quickly, if we can, and
5 with the Court's permission, and assuming no objection from the
6 Prosecution at this stage, I'd like to lead the witness through it.
7 Turning to the situation in Sarajevo in 1991 and 1992,
8 Mr. Zuljevic, is it true that it was difficult to gather a sufficient
9 number of Croats in Sarajevo to form a political party?
10 A. It was difficult to gather enough Croats to join the HDZ because
11 they still did not quite believe that communism would leave the stage so
12 easily. People were simply afraid.
13 Q. All right. And you've described how, in 1990, all three
14 newly-formed parties, the SDA, the SDS, and finally the HDZ-BiH all, as it
15 turned out, were headquartered in the same building in Sarajevo in the
16 very early days.
17 A. Not 1999. In 1990, yes, 1990. We had our offices in the same
18 building, that was the Novo Sarajevo building, and the offices were really
19 next door. The communication between us was excellent. People mingled,
20 discussed, and debated how to get the best election results, and people
21 were on friendly terms and were fair and correct to one another.
22 Q. All right. And that's a situation that, over the next year or so,
23 changed fairly substantially. Could you explain, in very brief outline,
24 sir, how that proceeded to happen?
25 A. When we elected the joint executive power after the first free
1 elections in Bosnia-Herzegovina, several months later, changes evolved
2 after the new government was elected. Everything functioned very well in
3 those first months. We were celebrating the victory, the triumph over the
4 communist regime and everybody was fair and correct.
5 Later on, there was a radical turn. First of all, the SDS members
6 changed, they became more arrogant and pushing. They pushed on their own
7 issues which were not going for joint solutions, but were very
8 obstructionist and not positive at all for the work of the government.
9 Later on, a part of the Bosniak Muslim members of government also
10 changed their positions. And what they endeavored to do was to bring in a
11 lot of religious elements in the programmes such as not to convene the
12 sessions of the government on Fridays when -- which was a prayer day.
13 Then a lot of Turkish words were being introduced into the official
14 language, so that several months into the work of the government, three
15 separate factions started emerging.
16 We were the least numerous and we were the tip on the scale, so to
17 speak. We did what we could to work with the -- in this situation where
18 everybody was pulling to their own side. If I can give you a couple of
19 examples, I can, for instance, recall when the village of Ravno fell. We
20 asked that the only item of the session of the government be the fall of
21 the village of Ravno and the behaviour of the Yugoslav People's Army, but
22 I believe that Mr. Mahmut Cehajic, deputy prime minister of the government
23 asked that the word grave, "grave sites" be replaced by the word "mezar"
24 which we thought was inappropriate because we had just suffered an
25 attack. Also in the same session, Mr. Velibor Ostojic asked that the word
1 "medvjed" which is a Bosnian word for bear be replaced with a Serbian
2 version of the same word, and this was not a serious approach to the work
3 of the government.
4 Q. I appreciate that background information, Mr. Zuljevic. If we
5 could just take this in a fairly expeditious way. You said in your
6 outline that Bosnian Croats attempted to participate in good faith in the
7 governments of both the Socialist Republic of Bosnia-Herzegovina and the
8 Republic of Bosnia-Herzegovina after it was founded on March 6th of 1992.
9 It's true, is it not, that in the Jure Pelivan government, Croats occupied
10 the position, for example, of Minister of Defence? That was Jerko Doko?
11 A. Mr. Jerko Doko.
12 Q. And you've identified in your outline other positions, seven
13 specifically, which Croats held in the Pelivan government, some examples
14 being Miljenko Brkic, who was Minister of Science and Culture; Tomislav
15 Krsticevic, who was the Minister of Communication; Josip Goluza, being the
16 Deputy Minister for Economy, and one other example being you?
17 A. Deputy minister.
18 Q. Yes. And one --
19 A. That is correct.
20 Q. One other example being you, Deputy Minister of Veterans' Affairs;
21 is that right?
22 A. Deputy Minister, that is correct, and that is more than Assistant
23 Minister, the title above.
24 Q. Thank you. Now, in paragraph 10 of your outline, sir, you make
25 some comments about Mr. Stjepan Kljuic, the former president of the HDZ
1 BiH. I believe that he actually resigned while you were in Sarajevo, but
2 towards the end of your time there.
3 A. That is correct.
4 Q. Were you familiar at all with the reasons for his resignation from
5 the position of president of the party?
6 A. My assumption is that Mr. Kljuic resigned at the insistence of the
7 leadership of the municipal council, especially the councilmen from
8 Herzegovina who were not satisfied with the way he was leading the party.
9 Q. I understand that the resignation occurred at a party meeting at
10 Siroki Brijeg, but were you there when Mr. Kljuic actually resigned?
11 A. No, I was not there.
12 Q. All right. And you make some other comments about Mr. Kljuic from
13 your personal observations derived from attendance at other meetings.
14 Could you just fill us in a little bit upon your perception of Mr. Kljuic
15 as a party functionary, sir?
16 A. Mr. Stjepan Kljuic, as the leader of the party, arrived suddenly.
17 We did not know him at all. His leadership of the party was fairly
18 autocratic. He did not want to do a number of things, especially certain
19 things that we in the secretariat wanted him to do because it was too
20 difficult for us at the secretariat level to do that. Also, Stjepan
21 Kljuic was a person who knew how to take pleasure in things. He was even
22 a bit too much concerned for his -- about his appearance, his pipe and his
23 hairdo and his clothing, and he did not really cut the figure of a
24 political leader that was needed at the time.
25 Q. How well did Mr. Kljuic understand the needs and wants of the
1 grass roots level, if you like, the rank-and-file party members in the
2 municipalities as opposed to in the capital? Do you have any views on
3 that, Mr. Zuljevic?
4 A. I don't know that well, but I think that they didn't communicate
5 that well and that the number of representatives from western Herzegovina,
6 even Kupres, Bugojno, Gornji Vakuf, et cetera, did not see things the same
7 way as he did.
8 Q. All right. And you've made the comment that his real political
9 support came from members of the party actually in the capital, in
11 A. Yes. He knew personally the majority of these people, and it was
12 easier for him to communicate with them. I believe that he did not have
13 close contacts with people who came from the countryside, both culturally
14 and by their mentality.
15 Q. All right, Mr. Zuljevic. Let's move on a little bit. One of the
16 claims being made by the Prosecution in this case is that Bosnian Croat
17 political institutions generally, and their leaders specifically, engaged
18 in a widespread and systematic campaign of discrimination or persecution,
19 specifically against Bosnian Muslims, throughout the territory encompassed
20 by the Croat Community of Herceg-Bosna initially, and later, towards the
21 second half of -- or in the second half of 1993, also in the territory
22 encompassed by the Croat Republic of Herceg-Bosna. During your extensive
23 association with the HZ HB --
24 [Technical difficulty]
25 [Trial Chamber confers with registrar]
1 MR. SAYERS: I don't know if we're still in communication with
2 Zagreb, Mr. President.
3 JUDGE MAY: They're working on it.
4 [Trial Chamber confers with registrar]
5 MR. SAYERS:
6 Q. Mr. Zuljevic, it appears that we are back again. My apologies for
7 the brief delay.
8 A. It's all right.
9 Q. Sir, we were just covering, and I hope to speed this up a little
10 bit, the points in paragraph 11 and 20 in the outline that you signed two
11 days ago. As we have told you, one of the claims being made in this case
12 is that the Bosnian Croat political institutions and their leaders,
13 specifically, engaged in a campaign on a widespread and systematic basis
14 of discrimination and persecution against Bosnian Muslims and that
15 campaign was waged throughout the territory of the Croat Community of
16 Herceg-Bosna and later in the Croat Republic of Herceg-Bosna as well as in
17 the municipality of Zenica. What do you have to say about that? Did you
18 hear any evidence of that? Did you ever hear anyone advocating such a
19 policy, please tell us.
20 A. Political organisations of Bosnian Croats, the HDZ and then the
21 Croat Community of Herceg-Bosna and the Croat Republic of Herceg-Bosna
22 were not founded with a view to becoming a stumbling block or institutions
23 of hatred directed at any people or individual. The only concern behind
24 the establishment of these political institutions was the protection of
25 the interests and rights of the Croat people in Bosnia-Herzegovina.
1 Nothing, neither the statement or the programme, nor the statute of the
2 HDZ or the Croat Community of Herceg-Bosna, that is Croat Republic of
3 Herceg-Bosna were never -- never showed that those communities considered
4 themselves something outside, something exterior of Bosnia-Herzegovina but
5 only as organisations that would help to preserve the constituent nature
6 and autonomy of the Croat people in Bosnia-Herzegovina and its cultural
7 accomplishments. And all that makes it an autonomous and constituent
8 people of Bosnia-Herzegovina equal with the other two peoples.
9 Had I ever heard, noticed or seen or come to the -- or realised
10 that there was any form of segregation of separation, of belittlement,
11 subjugation, persecution or any other form of repression against the other
12 two peoples, I would not have taken part in such institutions and I think
13 that as a Croat, I would be ashamed of such institutions.
14 Q. All right, sir. You say in paragraph 11 of your outline that the
15 HZ HB was a temporary institution and did not have a defined territory and
16 that you made provision, from the outset, for other municipalities to join
17 this body at a later time and you also make an observation that you did
18 not attempt to extend the HZ HB into communities with -- where only few
19 Croats lived. Why was that?
20 A. I repeat, the temporary nature of the Croat Community of
21 Herceg-Bosna reflected its true intentions because it never aspired to
22 grow into any form of independent state with some invented right of
23 secession and integration with other states. A temporary nature attests
24 to the fact that all the Croat Community of Herceg-Bosna intended was
25 within Bosnia-Herzegovina regulated by the tripartite agreement in
1 accordance with the wishes of the representatives of the three peoples.
2 I therefore think, it is of utmost importance to stress the
3 provisional nature of this and of the statute. And all of the documents
4 show, that is, all those letterheads show that there is Bosnia-Herzegovina
5 in the forefront and then everything else and that applies to all the
6 executive institutions of that community and I shall repeat, temporary
8 Q. All right. Let me see if I can move on to paragraph 12, Your
9 Honours, and take up the progression of your experiences in a
10 chronological fashion, sir.
11 I believe after the siege of Sarajevo had begun. As you've said,
12 you left towards the end of May of 1992, and from there you went to Grude
13 to put yourself at the disposal of Mr. Mate Boban, the president of the
14 HZ HB.
15 A. Correct. When we left Sarajevo or rather while we still
16 functioned somehow as a government, we were planning to relocate the
17 government to several places. We mostly agreed with Muslims and Bosniaks
18 that it should be in the free territory, and the free territory was by and
19 large controlled by the HVO, the defence.
20 After I left Sarajevo, and I left Sarajevo together with
21 Mr. Boras, Mr. Brkic and a JNA officer. The journey was very arduous
22 indeed, the bullets and shells, and I placed myself at the disposal of the
23 organisation in Grude and Mr. Boban because something had to be organised,
24 something had to be done as people were simply in utter confusion and it
25 was impossible to organise any life, life with any sense at all. One had
1 to organise health care, salaries for workers, production, to change the
2 purpose of the special purpose production and so on and so forth.
3 In a nutshell, one had to arrange life and make it function in the
4 largest possible part of the Bosnian-Herzegovinian territory, and that is
5 why I placed myself at the disposal of Mr. Mate Boban.
6 Q. Thank you, Mr. Zuljevic. We've also heard a lot of evidence, as
7 you will appreciate, regarding the development of the government after
8 these early days of confusion in the spring of 1992, and that as the
9 institutions of government gradually became more organised, I believe that
10 you, yourself, began to work in the organisation of the HVO's Department
11 of Social Affairs.
12 A. Correct. As I am a humanist by vocation, it was only natural for
13 me to be engaged in affairs, in matters which had to do with my life
14 option, my attitude to life. That was how I began to organise the
15 subdepartment for social welfare because I had to establish cooperation
16 with humanitarian organisations, starting from the Red Cross and all the
17 other humanitarian organisations which were arriving there or sending
18 their emissaries to the territory of Bosnia-Herzegovina. Each was very
19 hard to do, that because we had to start from scratch. We had to
20 establish communication, to seek assistance of all kinds. At times we
21 received it, but at times there were only promises and people were ever
23 There was an increasing number of refugees, of expelled, of
24 displaced. They all had to be accommodated, transit had to be provided to
25 the free territory. In a word, to offer comfort to people if nothing
1 else, and offer them advice.
2 Q. Now, while you were head of the HVO's subdepartment of labour and
3 social care, was there any practice or policy of discriminating against
4 anybody or providing less than a person's fair share to that -- to a
5 person based upon considerations of ethnicity or things of that variety,
7 A. We had three criteria only: That somebody was a human being, that
8 he was willing to accept this aid, and that he was in need of that aid.
9 Those were the criteria governing my subdepartment and there is ample
10 evidence that there was no discrimination because such ideas are foreign
11 both to me and to the institution that I headed and which was
12 representative of that community which was called the Croat Community of
14 Q. You give some specific examples in your statement of providing aid
15 to Muslims when asked to do so. Could you just fill the Court in on a few
16 examples, if you could do so in just a few words, Mr. Zuljevic.
17 A. Well, it's like this: I mean to the Court, to the Defence, and to
18 the Prosecutor's office, I have already stated that I have proof in my
19 summary. One of the examples are brothers, the mayor of the Ilidja
20 municipality, I mean his surname just escapes me -- oh, yes, Mahmutovic,
21 Huso Mahmutovic and his brother, Selver. They can testify about the
22 relief that I sent to Sarajevo because they personally told me that
23 Sarajevo is in debt to me, and that they would try to pay back that debt
24 because when they were having it hardest, I distributed the aid to
25 everybody and, in particular, the besieged Sarajevo at the time when it
1 was very difficult to do.
2 Q. Very well, Mr. Zuljevic. You provide a few other examples of this
3 in your outline, but I do not think that it is worth the time to spend in
4 going over those, because the Court has got a lot of background on this
5 already. But is it fair to say that in the western part of Mostar there
6 were Muslims and Serbs who had already retired and were receiving pensions
7 and who continued to receive those pensions during the war, just as did
8 the Croats?
9 A. In west Mostar, the pensions were small because we had scarce
10 funds. At the time when I headed the subdepartment, subsequently the
11 ministry, we could pay out some 50 German marks. I believe there were
12 some 3.000 Muslims on the west bank and some four to five hundred Serbs.
13 And they received those pensions -- Croats, Muslims, and Serbs alike --
14 and this can again be attested to by numerous Muslims, Bosniaks, who were
15 also frequent visitors in the depots which were under this subdepartment
16 and from which relief was equally distributed to all. None of my men was
17 allowed to commit a single mistake.
18 Because I speak as a humanist and a man who is also a father, and
19 I experienced -- I knew what hunger meant, what destitution meant, and
20 this is why I drew the special attention to treat everybody equally. And
21 those who are in Mostar can again testify about this. Many have done so,
22 because they sent letters of appreciation on behalf of their humanitarian
23 organisations with which we cooperated and who were receiving relief
24 through our subdepartment.
25 Q. Yes, sir. And we have asked the Court to mark as exhibits some
12 Blank page inserted to ensure pagination corresponds between the French
13 and English Transcripts.
1 representative examples of these, and we'll look at these in just a
2 second. But before we get there, is it true that while you were serving
3 in the HVO, most of the HVO departments had a Muslim deputy or assistant,
4 and that this was true, for example, in the departments of justice,
5 finance, internal affairs, and education?
6 A. In the beginning, it was difficult to find people who would be
7 Muslims, Bosniaks, and would be willing to work for the HVO, because such
8 people would be branded by their people as traitors. And yet many came
9 and said they would be quite willing to help, that all this was absurd and
10 that we should work together, that we should be human beings in the first
11 place and then inhabitants of Bosnia-Herzegovina, neighbours. There were
12 many of those who worked. Whether they were deputies or assistants, I can
13 no longer remember, but I know that there were such.
14 Q. And the policies of non-discrimination and even-handed
15 distribution of welfare and humanitarian assistance that you've described
16 with reference to the HZ HB, did those carry over into your service, or
17 your experience, at least, in the Croat Republic of Herceg-Bosna, and
18 specifically with respect to your administration of the -- or the
19 performance of your duties as Minister of Labour, Welfare, and Family?
20 A. This policy was not only carried over; an increased emphasis was
21 laid on it, because as time went by, we were having more and more funds,
22 and we were therefore in a situation to distribute more funds, to the
23 benefit of those who were in need of those funds.
24 Q. But with respect to your distribution policies, was there any
25 deliberate preference given to groups of people based upon considerations
1 such as ethnicity, or not?
2 A. Personally, I do not think that any one of those who worked could
3 give more or less. They were mostly parcels which had been already
4 prepacked, that is, before they arrived in Bosnia-Herzegovina and
5 different European countries. Those were the so-called donations. So we
6 did not know what was in them, but it was mostly things that had been
7 packed before they reached us.
8 Q. These aid packages, were they distributed to all residents of the
9 area for which you were responsible or just to Croat residents?
10 A. They were distributed to all residents. The only thing that could
11 have varied -- if it was a large family, they would get two parcels; if
12 there were fewer members in a family, they would be allotted one parcel.
13 So that was the only criterion. In some cases, some people received more,
14 some less humanitarian aid.
15 Q. Thank you. If I could just turn your attention to the two
16 exhibits that we have previously supplied to the registrar, the first
17 being a decision on establishing the headquarters for organising and work
18 coordination on caring for displaced persons and refugees, dated June
19 21st, 1993; and the second being a representative sample of letters of
20 appreciation and letters of commendation and thanks that you received as a
21 result of your work in the Ministry of Welfare, Labour, and Family.
22 MR. SAYERS: If I could get an exhibit number for the first
23 document dated June 21st, 1993, please.
24 THE REGISTRAR: The document shall be numbered Defence Exhibit
25 D302/1. The second document, the letter of appreciation, shall be
1 numbered Defence Exhibit D303/1.
2 MR. SAYERS:
3 Q. Mr. Zuljevic, if I could turn your attention to the first
4 document, the one dated June 21st, 1993. Just a question or two about
5 this. This is a decision signed by Dr. Jadranko Prlic, who I believe was
6 the president of the HVO throughout your service in the HVO.
7 A. Correct.
8 Q. This decision provides for the coordination of activities on the
9 distribution of humanitarian aid to the population in areas where
10 delivering humanitarian aid was not possible because of war activities and
11 various other things.
12 [Technical difficulty]
13 A. -- Martin Raguz, Darinko Tadic. He was responsible for the
14 department of refugees, displaced persons
15 THE INTERPRETER: We could not hear the beginning of the sentence.
16 MR. SAYERS:
17 Q. Yes. I'm afraid we had a slight technical difficulty which
18 blocked out some of your earlier answer, but let me take you very quickly
19 through this document. Mr. Kresimir Zubak was appointed to be the
20 president of this headquarters for coordination of the distribution of
21 humanitarian aid; right?
22 A. Right.
23 Q. You were one of the committee members along with three other
25 A. I was one of the members; correct.
1 Q. And then if I could just ask you to look at the second series of
2 documents, sir. Just a few comments in connection with these.
3 MR. SAYERS: And Mr. President, for the Court's convenience I've
4 had these marked numerically on the bottom right-hand corner.
5 Q. If I could ask you to turn to the third page in, Mr. Zuljevic, or
6 for you the fourth page in the original Croatian. This is a -- could you
7 just explain to the Court what this is?
8 A. This is a letter of thanks of Merhamet, which is a charitable
9 association. Such as the Christians have Caritas, among the Muslims in
10 Bosnia-Herzegovina, it is the Merhamet. It is the central humanitarian
11 organisation of the Bosniaks in Bosnia-Herzegovina. And on this occasion
12 they are thanking us for having received -- for correct and fair
13 cooperation, and I do not feel like commenting on the rest of it.
14 Q. Very well, sir. If you could just turn to the second page of this
15 package. This comes from the Ministry of the Interior of the Republic of
16 Bosnia and Herzegovina and from the Centre of Security Services in
17 Sarajevo. Could you just tell the Court what this document refers to,
19 A. This document says that we sent to Sarajevo, through their
20 representative, I believe it was Mr. -- the gentleman that I have just
21 mentioned. Oh, yes, Mr. Mahmutovic. And they received humanitarian
22 relief from us. I don't know exactly how much it was, but I believe it
23 was two or three truckloads of food which went there. And the only
24 condition was to distribute it equally among the population, and if there
25 were any Croats, to also include them in the distribution, like all the
1 Muslim Bosniak families. The feedback information that I received was
2 that Mr. Selver had successfully distributed it and that a number of
3 families at Ilidja also received this aid.
4 MR. SAYERS: If I could just ask the registrar to turn to the 11th
5 and 12th pages.
6 Q. There's a document here from the Serb National Union to you
7 specifically, as Minister of Labour and Social Welfare in the HR HB. Do
8 you recognise this document as a document that you received from the Serb
9 National Union, sir?
10 A. I have something else before me. I recognise a document -- oh,
11 here it is. Serb National Union, Mostar. Oh, yes. Dr. Milan Bodiroga,
12 who stayed in Mostar throughout the war and dedicated himself to caring
13 for the small community of Serbs who had stayed in Mostar, after several
14 batches of relief, thanked me personally and the ministry that I headed,
15 for all the aid that they had received, and this is what this document is
17 Q. And the last document about which I have questions is page 15 and
18 16 of this document, a document that you received from Mr. Sead Pasic on
19 behalf of Esperanca, the humanitarian society in Mostar. Could you tell
20 me a little bit about this, Mr. Zuljevic?
21 A. The humanitarian society Esperanca was set up to help Muslims who
22 had stayed on the west bank. Their work had been approved by this
23 ministry. Mr. Sead Pasic and Mrs. Mirsada headed -- ran this society.
24 But to make it succeed, to make the society work, they needed assistance:
25 financial, material, and also assistance in food, clothing, and the rest.
1 And I was happy to see that, because I could then empty the depot number 2
2 which I had, so I gave the food and clothing to distribute, governed by
3 their conscience, and I believe that is what they did.
4 Q. Thank you very much, Mr. Zuljevic. I'm finished with the exhibits
5 and we can go back to your outline and I'd like to try to speed through
6 this last part here.
7 At paragraph 15, you say that in the spring of 1992, most of your
8 energies, most of the Croat people's energies went to the fight against
9 the Bosnian Serb army and this was channeled through the HZ HB, HVO and
10 ultimately through the HR HB. You've made the observation that during the
11 wartime period, the political party, the HDZ-BiH was largely inactive.
12 Can you just help us out with that?
13 A. That is correct.
14 Q. Are you aware --
15 A. That is correct. Can you hear me now?
16 Q. Yes. We know that the HDZ held its second convention, second
17 annual convention in mid-November 1992, but are you aware of the HDZ-BiH
18 holding any conventions or party meetings at the leadership level of the
19 party in 1993 at all, sir?
20 A. I was fairly busy with activities which I described to you, but I
21 know that the activities of the parties were frozen and that this civilian
22 HVO had taken over most of the civilian affairs and the military component
23 that was engaged militarily.
24 Q. All right. Now, we've heard from another witness in this case
25 that you travelled along with Mr. Zoran Buntic and Mr. Kresimir Zubak to
1 Central Bosnia transported by UNPROFOR in April of 1993; do you recall
2 that trip?
3 A. Yes, I recall the trip. It is true we did travel, myself,
4 Mr. Buntic, and Mr. Zubak. We all went to Central Bosnia. We used the
5 UNPROFOR vehicles. I believe that there were two or three APCs involved.
6 It was the first time for me to have travelled in an APC, and it has very
7 small windows so I couldn't see around, but I know that we arrived in
8 Central Bosnia. And I remember well that on the way back, in Konjic, fire
9 was opened on those APCs, and a vehicle tried to get into the column of
10 vehicles but the vehicle was prevented from doing so.
11 Then we were asked to assist people because we saw that the
12 vehicle had skidded off the road and somebody in the vehicle was wounded,
13 injured. We saw that through those little windows, but we were then told
14 that we should not leave, that these people were in -- responsible for our
15 safety and so we moved on and I don't know what happened.
16 Q. All right. Just a few quick questions in connection with this
17 subject. Mr. Buntic was the Minister of Justice of the HVO civil
18 government, was he not?
19 A. That's right.
20 Q. And Mr. Kresimir Zubak was one of the vice-presidents of the HVO.
21 [Technical difficulty]
22 MR. SAYERS:
23 Q. Can you hear me now, Mr. Zuljevic?
24 A. I can hear you.
25 Q. All right. The question was: Mr. Kresimir Zubak was one of the
1 vice-presidents of the HVO, I believe that's the case.
2 A. That is correct.
3 Q. Did you, yourself, accompany Mr. Buntic when he went to visit
4 Mr. Marinko Jurcevic, the District Military Prosecutor in the Travnik area
5 in April of 1993?
6 A. No, I did not accompany him.
7 Q. Very well. Let me turn, very quickly, if I may, Mr. Zuljevic, to
8 the last subject which is Mr. Kordic. I believe that you first met
9 Mr. Kordic in February or March of 1992 when you were dispatched by the
10 Prime Minister, Mr. Pelivan, to Novi Travnik as a member of a three-person
12 A. That is correct.
13 Q. The other two members of the delegation being Avdo Hebib and
14 Tomislav Krsticevic. Mr. Hebib was a Muslim, the deputy minister for the
15 federal civil police in the Republic of Bosnia-Herzegovina, I believe?
16 A. I believe that he was the deputy minister for the civil police.
17 Q. Yes, sir, thank you. And I believe that the occasion for your
18 delegation's visit was because of the stopping of weapons being
19 transported or distributed from the Bratstvo plant in Novi Travnik for use
20 by the JNA.
21 A. Correct. We had information in the government that the special
22 production of armaments in Travnik was speedily being directed to
23 Belgrade, that the most valuable machinery was being dismantled and sent
24 out, and that this should be stopped and that these -- these machines
25 should stay in Bosnia. This was discussed a month previously, but the
12 Blank page inserted to ensure pagination corresponds between the French
13 and English Transcripts.
1 situation worsened in the meantime and the government adopted a decision
2 after the transports which were taking the machinery and finished products
3 out of Travnik.
4 They were stopped and we went over there to resolve the situation
5 in order to avoid an open conflict between the representatives of the JNA
6 and the civilian population, and we went over there to see what we could
8 Q. Did the committee decide to support the actions that Mr. Kordic
9 had taken in connection with the stopping of arms coming out of that
10 factory or not?
11 A. As far as I recall now, I think it was an unanimous decision by
12 the commission to keep the weapons and machinery from the Travnik -- from
13 the Bratstvo factory in Novi Travnik, to keep them there. That the
14 situation was very volatile, that one -- that everything should be done to
15 support the local population, and I believe that the trucks were parked in
16 another village near Novi Travnik and they never went to Belgrade. I
17 don't know what happened with the trucks subsequently.
18 Q. And about a month later, I believe that you had another
19 conversation or another occasion to have contact with Mr. Kordic along
20 with Mr. Munir Jahic and Mr. Hadzic and the subject was to request their
21 help to acquire arms to defend Sarajevo. Could you tell us exactly what
22 help you were asking for in this April of 1992 time frame?
23 A. Our assistance was requested and we met. It could have been in a
24 hotel near Kiseljak, I don't recall exactly, but I remember that we were
25 there with a delegation and our goal was to get weapons from -- for
1 Sarajevo. We did not ask for the price. We were prepared to pay any
2 price. The sad fact is that, unfortunately, Mr. Kordic didn't have the
3 money so we never received the weapons.
4 We went back to Sarajevo, and Sarajevo was already surrounded, and
5 the snipers were already in their positions, so we went back to Sarajevo
6 under those circumstances.
7 Q. All right. And Mr. Jahic and Hadzic who had, along with you,
8 requested this assistance to defend Sarajevo, those two gentlemen were
9 Muslims from the SDA political party, I believe.
10 A. That is correct. Mr. Munir Jahic was a Minister for Urban
11 Development and Water Systems and Mr. Hadzic was a prominent member of the
12 SDA, and I believe that he was killed in an assault about a month later.
13 Q. Just winding up the direct examination, Mr. Zuljevic, could you
14 tell us a little bit about Mr. Kordic? How did he strike you, a man of
15 fiery rhetoric or a man of measured political discourse, you tell us.
16 A. Mr. Kordic impressed me as a very honest man, a great
17 humanitarian, a man who is capable of self-sacrifice. I believe that his
18 views were very humanistic. His speeches were never fiery.
19 If there was any "fire" in him, it was only to mobilise his own
20 people who needed to protect its equal rights in Bosnia-Herzegovina and
21 who was to stay in Bosnia-Herzegovina, and maintain good neighborly
22 relations with everyone else in Bosnia. This is my impression of
23 Mr. Kordic and allow me to continue to view Mr. Kordic in this way.
24 Q. One final question, sir: Did you ever hear Mr. Kordic utter
25 speeches which incited violence or did you ever hear him make pejorative
1 or derogatory comments about any other ethnic group including Bosnian
3 A. I never heard anything like that and I believe that this is not
4 something that is like Mr. Kordic. He is respectful of other people and I
5 don't believe that this is either his style or his vocabulary. I cannot
6 believe in this, and I believe it is my right not to believe it.
7 MR. SAYERS: Thank you very much, sir, no further questions.
8 MR. MIKULICIC: No questions, Your Honour.
9 Cross-examined by Ms. Somers:
10 Q. Mr. Zuljevic, can you please tell us when you prepared your
11 summary, where you prepared it, and were you shown or were you read back
12 in your native tongue the translation that was done from the English to be
13 sure that it was the same as your Croatian summary?
14 A. Yes. Because I do not speak English, it was read back to me in
15 the offices of the Defence counsel. I signed it when -- this was after
16 having been read back the document on Sunday.
17 Q. I take note that there are points in paragraph 10 that appear only
18 in the original but that are not translated into English, and I take note
19 that in paragraph 14, there are matters in English which do not appear in
20 the original. Were you, again, read it back? Was it read back to you in
21 Croatian after an English translation had been done to be sure that the
22 translation was faithful to your original?
23 MR. SAYERS: Mr. President, if there is a challenge to the
24 accuracy of the translation, I wonder if we could have specified precisely
25 what the alleged inaccuracies are.
1 MS. SOMERS: Yes, of course, I'd be happy to.
2 JUDGE BENNOUNA: [Interpretation] Ms. Somers, let's not waste our
3 time on this. The witness has just told you that he's read the Croatian
4 part, that he has signed it, that he doesn't speak English. If there are
5 discrepancies between the two takes, well, you have to turn to the counsel
6 of the witness. Let's not waste time on the issue of the summary.
7 MS. SOMERS: Your Honour, I fully agree. I wanted to bring to the
8 Court's attention that there are some matters that are not translated
9 which, in fact, do change and we can put our challenge in writing if that
10 would be better so that we can handle with limited -- the Court should
11 know that it's not accurate. Thank you.
12 Q. Can you tell us, please, you were born in a municipality which you
13 describe as Uskoplje. Does your birth certificate read Uskoplje or Gornji
15 A. In my birth certificate, it says Gornji Vakuf because when I was
16 born in 1953, that place was called Gornji Vakuf.
17 Q. And Muslims today still call it Gornji Vakuf, is that correct? It
18 is the Croat population of HZ HB which has renamed it Uskoplje; is that
20 A. From 1236, I believe that the entire area was called Uskoplje.
21 From 1700-something when the base created Vakuf, that was renamed into
22 Gornji Vakuf. A part of Gornji Vakuf which was --
23 Q. Forgive me for interrupting you. I think you've probably gotten
24 the point. I would like to ask you, please: In what municipality were
25 you living and/or working when you entered the HDZ BiH?
1 A. When I joined the HDZ BiH, I lived in the municipality of Stari
2 Grad, or old town, in Sarajevo.
3 Q. Why did you leave the priesthood?
4 JUDGE MAY: I'm not sure that's relevant.
5 MS. SOMERS: I'd like to --
6 JUDGE MAY: It was a long time ago, Ms. Somers. No.
7 MS. SOMERS: Okay.
8 Q. Can you tell us, please: When you started your early career in
9 the HDZ BiH, you describe yourself as a member of the secretariat. Was
10 that a minute-taker position or were you an actual secretary? Please
11 define the position.
12 A. That would be very difficult to define, because we were only three
13 in the office, and everybody did everything. At a time when there was a
14 lot of activity leading to the elections, nobody asked what each
15 individual's job was, but everybody covered everything.
16 MS. SOMERS: If I could ask, please, that Exhibit -- it's a
17 recalled Exhibit, 2719, which was admitted through Mr. Kljuic, be put on
18 the ELMO. I can give you the Croatian copy if you need it. It would be
19 good, I think, just to turn to the last page of it so that we can look at
20 the signing-off.
21 Q. How many times -- if you recognise your own name appearing there.
22 I do not think the signature is terribly obvious. But how often did you
23 in fact take notes or sign off as the note-taker for various minutes of
24 the HDZ BiH meetings?
25 A. I don't recall how many times it was, but I remember that
1 occasionally I was the note-taker, and occasionally I sent out invitations
2 for meetings to various members and signed them.
3 Q. When you finished taking your notes, did you check them for
4 accuracy and send them out to the membership for correction?
5 A. I don't fully understand.
6 Q. When you took the minutes and signed off, as reflecting your role
7 of minute-taker, before these minutes became official records of a
8 meeting, did you ask the membership to look them over to see if they were
9 accurate and reflected the actual agenda and the attendance?
10 A. Every minute had to be authorised by either the presidency or the
11 president of the party. It could not be released as raw, unedited
13 MS. SOMERS: Just for the record, I note that this document which
14 is in front of you is from a date as early as 1990.
15 Q. In your comments about the roles that you played in the early
16 years of the party, you mentioned an assistant ministry position in
17 Veterans' Affairs. Was that the position that Stjepan Kljuic helped you
19 A. Correct.
20 Q. And that is the position that is for veterans of the Second World
21 War, correct, not a terribly active role, or am I incorrect about the
22 degree of work involved in it?
23 A. The amount of work in that ministry and the money allocated for --
24 or the budget of this ministry was second after the Ministry of Defence.
25 Q. You had difficulties getting a job after you left the priesthood,
1 is that correct; people were somewhat shunning you? Mr. Kljuic assisted
2 you, did he not, during this very difficult time?
3 A. It is wrong to say that people shunned me. The political system
4 did not want to give me job opportunities because we were on opposite
5 sides in our philosophies. I was a second-class citizen and we had no
6 common language. As far as Mr. Kljuic is concerned, I don't know whether
7 his assistance was ever concrete except that he supported me, in addition
8 to the party leadership, for me to be appointed the deputy minister.
9 Q. Why were you a second-class citizen, in your own mind? Based on
11 A. I was a second-class citizen because I had no passport, I could
12 not travel abroad. For a while I could not even leave the territory of my
13 own municipality without notifying the police authorities about my
15 MS. SOMERS: If the usher could very briefly put in front of the
16 witness Z10, please, dated 6 August 1991. And it would be the English
17 page -- I'll see if I can find the Croatian page. I don't actually have
18 it. It's on the ELMO. It would be under point 4, please. And there's a
19 reference to a written report about the ministry, about work in the
20 ministry. It would be -- let's see. If you can push it -- go down a
21 little bit, please. Let's see. It would be just above "Item 1." Okay.
22 There it is. Right.
23 Q. There is a report -- there is a reference, Mr. Zuljevic, in these
24 minutes of the main board of the HDZ BiH held in Prozor Rama on 6 August
25 1991, to a report that you had written about your ministry. Do you have
12 Blank page inserted to ensure pagination corresponds between the French
13 and English Transcripts.
1 that report with you or did you provide it to the lawyers for Mr. Kordic?
2 A. I don't have that report on me.
3 Q. Thank you. The comments about Mr. Kljuic span a number of the
4 points that are raised in your direct testimony, and I would like to ask
5 you about your relationship with Mr. Kljuic. You have acknowledged that
6 he indeed assisted you in getting a significant position. You, in fact,
7 supported him for a period of time, did you not?
8 A. Correct. Even to date I have nothing against Mr. Kljuic as a man.
9 MS. SOMERS: In fact, if the usher could show, please, Z31.1.
10 Q. If you have this -- if you can see this exhibit, Mr. Zuljevic,
11 this is -- if you recognise it, you are the "Ilija", and the "Ignac" is
12 Mr. Kostroman. This is a birthday greeting sent to Mr. Kljuic on his
13 birthday in 1991. Do you recognise this very friendly greeting?
14 A. Correct.
15 Q. And in this very friendly greeting, I believe the Latin would
16 roughly translate to "A friend in need is a friend indeed." You express
17 sentiments about Stjepan Kljuic such as: "We hope that you are remembered
18 in the history of the Croat people in the way that you deserve!" "Write
19 our history with the mind, heart, and more." Very positive feelings
20 towards Mr. Kljuic; is that correct? These are your feelings, or were
21 your feelings?
22 A. Correct. Correct.
23 Q. Can you pinpoint a moment in time when those feelings changed, or
24 an event, perhaps, link it to?
25 A. It cannot be related to a particular event. I believe a number of
1 things played a part. Stjepan Kljuic began to avoid the secretariat. He
2 was getting away from us and we felt that a distance between us was
3 growing, and I think it dates back to that time.
4 MS. SOMERS: Z2744, please.
5 JUDGE MAY: Ms. Somers, how long do you think you'll be with this
6 cross-examination? Because it's about time for a break.
7 MS. SOMERS: Your Honour, I have about another seven documents.
8 And I have really tried to tailor this. I have been watching this on the
9 monitor this morning to see that we've had some breakdowns, so I'm trying
10 to go as fast as possible. If I could have the benefit of maybe another
11 35 minutes, I think I could try to wind it up.
12 [Trial Chamber confers]
13 JUDGE MAY: We'll take a ten-minute break.
14 --- Recess taken at 4.05 p.m.
15 --- On resuming at 4.18 p.m.
16 JUDGE MAY: Yes, Ms. Somers.
17 MS. SOMERS:
18 Q. Mr. Zuljevic, returning to the document which should be labeled
19 Z2744, it is from an HDZ meeting, 26 August 1991 which indicates that you
20 were -- I believe you were in attendance, just to confirm. If not in
21 attendance, my question to you is: Item number 4 in the conclusions
22 discusses your appointment to a Council for Culture and Education. What
23 was the purpose of that council? Did it actually do anything? If you
24 could explain quickly to the Court, please.
25 A. I think it is true that I was appointed to the Council for
1 Culture. I don't remember what it did, but I can claim with certainty
2 that it didn't do much.
3 Q. You were, however, appointed by, is it Stjepan Kljuic who
4 appointed you?
5 A. The president can't appoint anybody. This must have been the work
6 of the Presidency.
7 Q. And can you tell us, please, at any of the meetings, notes from
8 which, or minutes from which we have presented to you, are any complaints
9 about Mr. Kljuic raised by you?
10 A. No, not as far as I can remember.
11 Q. Thank you. I will deal momentarily with your various positions
12 which you held in Herceg-Bosna, but I must ask you, so as to try to stay
13 in a chronological order, this Court has heard testimony from a witness
14 who indicated that you accompanied Mr. Kordic in April of 1992 to Novi
15 Travnik. Was this the same mission that Mr. Pelivan sent you on? Were
16 you in Novi Travnik only on behalf of a mission organised by Mr. Pelivan?
17 A. Correct. I found Mr. Kordic in Novi Travnik when I got there.
18 Q. The particular witness, "P", indicated that you and Mr. Kordic,
19 and you are saying that this was on behalf of Mr. Pelivan, told the
20 members of the TO, or members of the Muslim leadership that the TO had to
21 submit itself, or subjugate itself to the HVO. Is this something that
22 Mr. Pelivan asked you to represent?
23 A. No, he never asked that and [indiscernible] who were Dario Kordic
24 and I to order anything like that, I don't understand this.
25 Q. That essentially is my question to you: On whose behalf if this
1 occurred, would you have been raising this demand; Pelivan or Boban?
2 A. I repeat, I repeat again that I never uttered such a demand on
3 anyone's behalf, nor did I utter such a demand at all.
4 Q. You have made a very passing reference to working in the IPD in
5 your summary, and briefly, Z128.2 -- excuse me, before we get on to that,
6 another position which you held when you crossed over to the Herceg-Bosna
7 side was on a commission to deal with the monitoring missions; is that
8 correct? Do you recall that?
9 A. I don't, and I am not aware that we ever had a session devoted to
11 MS. SOMERS: Could the usher put Z128.2 on the ELMO, please.
12 Q. Mr. Zuljevic, before you is a document dated 10th of June 1992 in
13 Grude signed by Mate Boban, president, and the document indicates that --
14 A. I can't see the document.
15 Q. Do you recall, now recall that Mate Boban in June of 1992 -- were
16 you going to say something, if not, I'd like to ask you a question.
17 A. I wanted to say that I see that this appointment arrived, but now
18 I know, I see simply -- I -- we never met. The commission never met in a
19 session because I had already gone to work towards the organisation of the
20 subdepartment for social welfare.
21 Q. Now, on this commission, there was Pasko Ljubicic, Ante Valenta
22 and Stanislav Nussbaum as well as somebody named Ivan Bosnjak, a
23 physician. Do you recall what you were going to do or is it sufficient to
24 assume that the introductory material about dealing with the monitors was
25 the purpose of this de jure appointment...
1 [Technical difficulty]
2 MS. SOMERS:
3 Q. Is it sufficient to assume or to accept that the purpose listed at
4 the top of the document was the sole purpose of this de jure appointment
5 that you and the others received but de facto never did anything with; is
6 that correct?
7 A. As far as I know, there was no session or meeting with the -- with
8 those people, ever. Because I don't even know all these people. For
9 instance, I don't know Ivan Bosnjak.
10 Q. In point number four on your outline, your summary, you mentioned
11 in passing that you worked in the Information and Propaganda Department,
12 the IPD.
13 MS. SOMERS: Would the usher be kind enough to present Z135.1.
14 Q. In front of you is a document dated 18 June 1992, eight days after
15 the first document we just showed you, also signed by Mate Boban
16 appointing you not as a worker, but as the head of the IPD. Can you
17 please describe how you -- excuse me?
18 A. That is correct.
19 Q. How did you manage -- how were you able or how long did you hold
20 the position as head of IPD, please?
21 A. I think for about a month.
22 Q. And then what?
23 A. And then I began to organise the subdepartment for labour and
24 social welfare.
25 Q. And at -- when did that appointment officially come through for
2 A. I don't remember when it came exactly, but one can find it in the
3 official gazette of the Croat Community of Herceg-Bosna.
4 Q. That also was an appointment by Mate Boban; correct?
5 A. I believe that the appointment was signed by Mr. Prlic with a
6 certain delay.
7 Q. How did you meet Mate Boban and when did you first meet Mate
9 A. I met him in Sarajevo in the parliament of Bosnia-Herzegovina at
10 the time when he was representing the municipality of Grude.
11 Q. Do you recall Mate Boban addressing the Croat intellectuals of
12 Sarajevo and urging them to abandon Sarajevo to come to Grude? This would
13 be in 1992.
14 A. I don't remember that. I don't recall that.
15 Q. What event made you leave your position in the Bosnia-Herzegovina
16 government and go to work for the government of Herceg-Bosna?
17 A. Simply, it was very difficult to enter Sarajevo and to put one's
18 life at risk and enter Sarajevo and leave the family, leave one's family,
19 one's children, one's relatives, friends and so on and so forth. I think
20 it was absurd. The possibility was sort of for the relocation of the
21 government of Sarajevo as I have already told you and its institution in
22 the free territory.
23 Q. What you joined in what you're describing as free territory was
24 not the Sarajevo government; it was a different government, was it not?
25 A. I didn't understand. What government were you referring to?
1 Q. The government of the Croatian Community of Herceg-Bosna, with its
2 various departments, including the Information and Propaganda Department,
3 did not belong, or was not under --
4 A. My apologies. Go ahead.
5 Q. In fact, Alija Izetbegovic was not presiding over your work in
6 Herceg-Bosna; is that a fair statement?
7 A. Our work, no.
8 Q. Did Mate Boban promise you these positions before you left
10 A. No. You can see that from various short appointments.
11 Q. You went to Grude, and at what point did you go to Mostar?
12 A. I went to work in Mostar in a car, but I stayed in Grude in a
13 hotel. And then after a while, I moved to Mostar altogether.
14 Q. When you arrived in Mostar, did you observe shelling between the
15 Croat side and the Serb side -- sorry, the Croats and the Muslims and the
16 Serb side. Was there shelling going on?
17 A. Shelling was a daily occurrence.
18 Q. Can you give us a qualitative difference between the shelling in
19 Sarajevo and the shelling in Mostar, please?
20 A. The shelling of Sarajevo was much more intense and heavy and
21 almost constant; and in Mostar you could find breaks, sometimes several
22 hours, sometimes several days.
23 Q. You made a point in your summary, as well as in your testimony, of
24 discussing something you seemed to suggest was a petty linguistic matter
25 by Muslim representatives of the Bosnian government. There was a
1 particular word that you found -- that you cited, and that was the word,
2 was it, for cemetery. Did you find that -- what was your objection to
3 having that as an agenda item? I think the word was, if I may just
4 refresh your recollection, the word was "mezarluk." Does that sound
5 correct? Or "mezarluci," perhaps?
6 A. Correct. That was not the only example. Mr. Mahmut Cehajic in
7 that session said that all places that -- all plates at the entrance of
8 cities be also displayed in Cyrillic, Roman, and Arabic, which was
10 Q. This is -- you've given a name of Mahmut Cehajic as if it were two
11 names. Is this Rusmir Mahmutcehajic, the last name being Mahmutcehajic,
12 or is this another person to whom you're referring?
13 A. Yes.
14 Q. So it was your error as to his name, the name of this man whose
15 agenda you objected to?
16 A. It was a slip of the tongue.
17 MS. SOMERS: Z192.1, please.
18 Q. I must tell you that the next document is in English only, for
19 which I apologise, but it is an UNPROFOR document and I cannot help it.
20 If I could ask for the cover page, the very first page of the document, to
21 be placed.
22 The document which is before you is essentially a draft
23 translation by members of UNPROFOR, and on the very first page of it there
24 are a number of abbreviations and terms which concerned UNPROFOR enough to
25 address. On the page below the various initials, I would like to turn
12 Blank page inserted to ensure pagination corresponds between the French
13 and English Transcripts.
1 your attention simply to the word "mezarluk," which appears to be the same
2 word that you thought insignificant. Apparently UNPROFOR saw a
3 significance in this term. Can you comment on this?
4 A. When I used "mezarluci" -- it is here misspelled. It is without
5 an "r" [sic]. Mezarluk is how it should be spelled. But that was not
6 such a priority, to go into a legislative debate over a single word when
7 you had a village which had fallen, which was part of the integral
8 territory of Bosnia-Herzegovina. And if the gentleman from UNPROFOR had a
9 special interest in this, it is important to be concerned and consider
10 cemeteries; people should be concerned about their living as well as their
12 Q. Cemeteries occupy a very important place, do they not, in a number
13 of religions, including in Islam; is that correct?
14 A. Absolutely correct.
15 Q. I would just like to briefly ask you a couple of questions about
16 some positions you held which were specifically referred to in Z192.2.
17 Again I must apologise. It is only in English. But the document is a set
18 of notes taken during a simultaneous interview -- or an interview of Mate
19 Boban by someone who worked for an NGO -- I believe it was Helsinki Watch,
20 the Helsinki Committee, perhaps -- who subsequently worked for this
21 institution. On what is labelled page 5, which is the first page of this
22 set of notes, Mr. Boban specifically told this individual that you, Ilija
23 Zuljevic, a former priest, was in charge of the Social Work/Refugee
24 Department, and that access and information could be had. Were you ever
25 visited by any persons from NGOs, from particularly Helsinki Watch or
1 Human Rights Watch, who indicated that you were sent by Mr. Boban -- that
2 they were sent by Mr. Boban? Excuse me.
3 A. I don't recall that. I would have certainly remembered if anybody
4 from the Helsinki Watch would have come. Maybe they came under some other
5 name, but not on the behalf of Helsinki Watch. I don't think anybody came
6 to visit me.
7 Q. And then on page number 7 -- it is listed on page 7, although it
8 is not the seventh page -- Mr. Boban again tells the interviewer that
9 there is a specific person responsible for refugee questions, and again
10 mentions you in Mostar. Were you in Mostar on May 9th, 1993?
11 A. Of course, I cannot recall what happened specifically on 9th of
12 May. And as far as refugees and displaced persons are concerned, the
13 government office which was in charge of it was headed by Mr. Darinko
14 Tadic, and perhaps this person went to him. Mr. Boban may have directed
15 it to me, but maybe somebody else then redirected him to the right person.
16 Q. Where was your office in Mostar?
17 A. My office in Mostar is on the right bank of the Neretva River, in
18 the former aluminum company building.
19 Q. Perhaps it will refresh your recollection to remind you that on
20 the 9th of May the HVO rounded up and expelled, first by internment in a
21 number of camps, most of the Muslim residents of Mostar West, and to some
22 degree East. Does that refresh your recollection about the events of that
23 day to tell us whether or not you were in Mostar on that day?
24 A. I cannot recall at all. Again, I don't know what happened that
25 day. I have heard such things, but I cannot recall whether I was in
1 Mostar on that day or not.
2 Q. Have you heard of the following locations: the Heliodrom, Gabela,
4 A. Yes, I have.
5 Q. In the course of your work as a humanist, were you asked to assist
6 any of the persons, mainly Muslim civilians and some POWs, who were
7 interned there?
8 A. No. I was not asked at all any assistance. The military had
9 their own offices, they had their own prisoners. I was in charge of
10 certificates and Mr. Darinko Tadic was in charge of the refugees. And I
11 think that that covers my answer, or your question.
12 Q. Mr. Prlic was the man who you said appointed you to the position
13 that you held at the time. Did Mr. Prlic ask for any input from you about
14 the camps in which these persons were detained before he and Mate Granic
15 from Croatia began to disband the camps in September 1993? Were you
16 involved in that process?
17 A. No.
18 Q. How many times did you have dealings with Dario Kordic from the
19 first time until today, please, and when was the first time you met him?
20 A. As I said, sometime in 1992, and as far as number of meetings is
21 concerned, there were a number of them.
22 MS. SOMERS: Z307, please.
23 Q. This document which will be placed before you, I want to tell you,
24 is phonetically in your language as it is from packet radio or so it says,
25 and there is an English translation provided. This document is dated,
1 excuse me, I'll wait.
2 The document is dated the 10th of December, 1992. I'm sorry for
3 going back in time a little, but I must ask you this, and it is sent from
4 the Croatian Community of Herceg-Bosna, the Busovaca regional staff to the
5 Croat Defence Council presidents of a number of municipalities listed
6 above and is signed by Dario Kordic.
7 Now, at this -- what is asked or what is demanded is that these
8 persons supply the data of persons killed, persons missing, names and ages
9 of children of soldiers killed in action, the severely wounded, those
10 taken prisoner, number of pensioners in the municipality, number of
11 unemployed, number of exiles and refugees, and Kordic directs persons who
12 are responsible for collecting this data to send this information to you.
13 You were a minister, were you not, at that time or you were a head of a
14 department at that time?
15 A. Correct. Yes. In order to be able to compile a sociological
16 picture of what was going on on the ground.
17 Q. So Mr. Kordic could direct your functions as well. He's signing
18 here as vice-president of the Croatian Community of Herceg-Bosna, and he
19 is ordering certain things to happen and he's ordering you to do certain
20 things. Are there any other occasions that you can think of where you
21 received such orders initiated by Mr. Kordic?
22 A. I don't recall a single order by Mr. Kordic reaching me because I
23 was exclusively answerable to Mr. Prlic as the prime minister. I don't
24 see whether this -- I couldn't read the text, whether this was an order to
25 me personally, but I know that in my ministry, that the request went out
1 to all the municipalities to compile these -- this information in order so
2 that we could the picture of what we had on the ground.
3 Q. Thank you. You made mention of a number of Muslim ministers, and
4 this Court has heard a reasonable amount of testimony about these
5 persons. Are you aware of from where these Muslims came, were they
6 natives of Central Bosnia or do you know anything about their origins?
7 For example, do you know if they were from Posavina?
8 A. I don't know where the Muslim ministers were from, except for
9 those with whom I worked more closely. I know that the minister, Resad
10 Bektic was from Sarajevo, Mr. Munir Jahic was from Tuzla. He was also a
11 professor at the university. Then minister of the interior was from
12 eastern Bosnia. He was a -- in the BH government while I was there and so
14 Q. At what point in time were these persons engaged in ministry-level
15 positions, can you tell us from when to when, please?
16 A. Immediately after the democratic elections they were appointed.
17 The government replaced the communist government in Bosnia-Herzegovina.
18 Those were my colleagues, and some of them remained in their positions and
19 some did not. I don't know when Mr. Muhamedcengic left. I don't know
20 when Alija Delimustafic left, he went abroad. I don't know about Munir
21 Jahic and so on. I only saw Mr. Resad Bektic who was the minister for
22 economic affairs, he was later in Zagreb. So that's all I can say about
23 all these ministers.
24 Q. I have noticed and I must ask you this question, I apologise that
25 it got skipped, I think it was because of the break coming. But when you
1 listed earlier the number of Croats who were part of the BiH government at
2 various points in time, I noticed that you did not list Stjepan Siber, why
3 would that be?
4 A. Stjepan Siber was not in the government in my time, he was neither
5 minister nor deputy minister. He may have had some lower-ranking position
6 in one of the ministries so I don't know him.
7 Q. No, actually he was the deputy commander of the army of
8 Bosnia-Herzegovina. Can you confirm that of the group that you listed,
9 only Jerko Doko did not go over to the HZ HB side; is that a correct
10 assessment of political affiliations?
11 A. It is very difficult to look inside people to -- when --
12 considering who went where. It also has to do with who was involved to
13 what extent. I had a meeting very recently with Mr. Jerko Doko, he was
14 not involved in affairs of the Croatian Community of Herceg-Bosna and/or
15 the Croatian Republic of Herceg-Bosna.
16 JUDGE BENNOUNA: [Interpretation] Ms. Somers, I think it's time to
17 put an end to the cross-examination because this is about the end of the
18 time that had been given to you.
19 MS. SOMERS: May I ask the Court's indulgence for a final
21 JUDGE BENNOUNA: [Interpretation] Yes, do.
22 MS. SOMERS:
23 Q. You had suggested that the only persons who supported Stjepan
24 Kljuic were the Sarajevo-based HDZ persons. May I ask you, do you know
25 Martin Udovicic?
12 Blank page inserted to ensure pagination corresponds between the French
13 and English Transcripts.
1 A. I didn't understand the question.
2 Q. I shall repeat it. You had indicated in your testimony that the
3 principle base of support for Mr. Kljuic was the Sarajevo HDZ members. My
4 question to you is: Did you know Martin Udovicic? Do you know the man?
5 A. Correct. He was the president in old Travnik.
6 Q. Right. And are you aware of Mr. Udovicic unflinching support for
7 Stjepan Kljuic?
8 A. I am not aware of him supporting him that much because he was also
9 saying that he didn't support him.
10 Q. And is that based on your reading minutes by Ignac Kostroman? Is
11 your conclusion of his not supporting Kljuic based on the minutes of
12 various HDZ meetings taken by Ignac Kostroman?
13 A. No. I personally was in a situation when my father was ill and he
14 was in Novi Travnik, and I frequently was in communication with Mr. Martin
15 and he was telling me the opposite of what you just said.
16 Q. One last question: Did you ask for any information about Ahmici,
17 about the events of Ahmici when you were in Central Bosnia with Kresimir
18 Zubak and Mr. Zoran Buntic? You, as a former religious person and
19 humanist, did you follow up on anything there?
20 A. I asked for no information and I said that I felt for all the
21 people who suffered and I sympathised with their families. And had I had
22 an opportunity, I would have gone there and help out these people.
23 MS. SOMERS: Thank you.
24 MR. SAYERS: No further questions, Your Honour.
25 JUDGE MAY: Mr. Zuljevic, thank you for coming to the -- into the
1 office to make your -- to give your evidence to the Tribunal. You are now
2 free to go. Your evidence being over.
3 THE WITNESS: [Interpretation] Thank you.
4 [The witness withdrew]
5 JUDGE MAY: Yes, Ms. Somers.
6 MS. SOMERS: Sorry, I'm not terribly familiar with this set up
7 with the monitors. I have been asked to raise three housekeeping matters,
8 two and then one follow-up on something.
9 JUDGE MAY: I think you might get on your feet now.
10 MS. SOMERS: We need to request time to deal with an affidavit
11 tomorrow that has come in, and if we could be granted that time.
12 JUDGE MAY: Yes.
13 MS. SOMERS: Also we'd ask the Defence to provide the summary
14 immediately for Ante Puljic. He is a significant witness, and we
15 anticipate a lot of work tonight on that. And further, during the break,
16 on the matter that I raised about the translation issue of the Zuljevic
17 summary, we've confirmed our concern over inaccuracy with the
18 interpreters, and we will present that in some form. If the court would
19 like it verbally, we can do it, or we can do it in a written form.
20 JUDGE MAY: I shall think in a written form if you will, Ms.
22 Yes, we ought to deal with as many affidavits as we can tomorrow
23 because there have been some in last week and also we must hear the
25 MS. SOMERS: Thank you.
1 JUDGE MAY: Very well, half past nine.
3 --- Whereupon the hearing adjourned
4 at 5.00 p.m., to be reconvened on Wednesday
5 the 12th day of, July 2000, at
6 9.30 a.m.