1 Tuesday, 11th April 2000
2 [Open session]
3 --- Upon commencing at 9.38 a.m.
4 [The accused entered court]
5 JUDGE RODRIGUES: [Interpretation] Good
6 morning, ladies and gentlemen; good morning to the
7 technical booth. The interpreters, are you there?
8 THE INTERPRETER: Yes, Your Honour.
9 JUDGE RODRIGUES: [Interpretation] Good
10 morning to the Prosecution, the Defence, Mr. Krstic,
11 the court reporters, the legal assistants. We are
12 still in the same composition, and we are here to
13 continue the hearing of the Krstic case.
14 According to what I see in front of me, it is
15 Mr. McCloskey. Yes, will you please tell us what we're
16 going to do today.
17 MR. McCLOSKEY: Mr. President, we have a
18 witness that will be testifying, a woman. We're going
19 back to Potocari briefly and she will be testifying in
20 open session. Her name is Hava Hajdarevic.
21 JUDGE RODRIGUES: [Interpretation] Thank you
22 very much. I was waiting for the interpretation.
23 Mr. Usher, can you have the witness brought
24 in, please.
25 [The witness entered court]
1 MR. McCLOSKEY: She has her earphones on
2 under her scarf, so you may want to make sure they work
3 and all.
4 JUDGE RODRIGUES: [Interpretation] Madam, can
5 you hear me?
6 THE WITNESS: [Interpretation] I do.
7 JUDGE RODRIGUES: [Interpretation] Good
8 morning, madam.
9 THE WITNESS: [Interpretation] Good morning to
11 JUDGE RODRIGUES: [Interpretation] Thank you
12 for coming here to the Tribunal. Before testifying,
13 you are going to read the solemn declaration, which the
14 usher will give you.
15 THE WITNESS: [Interpretation] I solemnly
16 declare that I will speak the truth, the whole truth,
17 and nothing but the truth.
18 WITNESS: HAVA HAJDAREVIC
19 [Witness answered through interpreter]
20 JUDGE RODRIGUES: [Interpretation] You may be
21 seated, madam.
22 [The witness sits down]
23 JUDGE RODRIGUES: [Interpretation] Madam, for
24 the moment you will be answering questions which the
25 Prosecutor, Mr. McCloskey, who is standing to your
1 right, is going to put to you.
2 Mr. McCloskey, you have the floor.
3 MR. McCLOSKEY: Thank you, Mr. President.
4 Examined by Mr. McCloskey:
5 Q. First of all, can you tell us your name, and
6 spell your last name, please.
7 A. My surname is Hajdarevic; my name, Hava.
8 Q. And can you spell your surname?
9 A. H-a-j-d-a-r-e-v-i-c.
10 THE INTERPRETER: The first letter is "H".
11 I'm sorry.
12 MR. McCLOSKEY:
13 Q. How old are you?
14 A. I'm 53.
15 Q. Are you Muslim by faith?
16 A. I am.
17 Q. Where are you from?
18 A. From Srebrenica.
19 Q. Did you spend most of your life in the
20 Srebrenica area?
21 A. I did.
22 Q. Were you living there on July 11th, 1995?
23 A. I was.
24 Q. Where in Srebrenica were you living?
25 A. I was living at the exit from the town,
1 towards Potocari, towards Bratunac.
2 Q. Who were you living with then?
3 A. I had two sons, a daughter-in-law, and a
4 two-and-a-half-year-old granddaughter. Then my mother
5 came to stay. My brothers and sisters-in-law, they
6 were living with me.
7 Q. Where was your husband at the time?
8 A. My husband was captured, and in 1994 he was
9 exchanged and then he was in Tuzla.
10 Q. So he wasn't in Srebrenica in July of 1995.
11 A. He wasn't in Srebrenica, no.
12 Q. What happened on July 11th that caused you to
13 make a decision?
14 A. I had to leave the house because the Serb
15 army entered the town from up there.
16 Q. Why did the presence of the Serb army make
17 you have to leave?
18 A. Because they would have killed me, I wouldn't
19 exist now.
20 Q. Where did you decide to go, and who went with
22 A. I decided to go to UNPROFOR to seek their
23 protection, and from there to go to Tuzla, and my whole
24 family went with me.
25 Q. Can you tell us who was in your family that
1 went with you to UNPROFOR?
2 A. With me were a daughter-in-law and a
3 sister-in-law, my brother's two children, my
4 granddaughter, and my mother. And the other
5 sister-in-law and brother were living in town and they
6 also went to Potocari.
7 Q. Were your two sons adult age at that time?
8 A. They were.
9 Q. What did they do?
10 A. They went through the woods. We parted
11 there, with my brothers and sons, and we went to
13 Q. You have three brothers; is that right?
14 A. I now have one and two of them are gone.
15 Q. So you haven't seen two of your brothers and
16 your two sons since they left to go through the woods;
17 is that right?
18 A. That is right. I never saw them again.
19 Q. When you say you went to UNPROFOR, was that
20 in Potocari?
21 A. Yes. Yes, in Potocari.
22 Q. Where did you stay when you got to Potocari?
23 A. It was the afternoon, on the 11th. We wanted
24 to go to UNPROFOR. The UNPROFOR wouldn't let us go any
25 further, there was a ribbon across the road, so we
1 stayed behind where the hangars are and the Zinc
2 Factory and the garages. And we asked to be put up
3 somewhere, and I spent the night next to the zinc
5 Q. The next day, did Serb soldiers arrive some
6 day to Potocari, the next day, on the 12th?
7 A. Yes, they did.
8 Q. About what time did you first notice Serb
9 soldiers arriving?
10 A. I really can't remember exactly now. I think
11 it was about noon.
12 Q. Can you tell us about what you saw?
13 A. I saw some of them coming from the woods,
14 towards Pecista. They were coming downhill; they were
15 burning things and shooting. And another group were
16 coming from Bratunac, together with Mladic.
17 Q. Could you tell what things were burning?
18 A. Mostly the old houses and haystacks, so as to
19 intimidate us. And we were watching all that because
20 there was a hillside and we were down in the valley and
21 we could see what was happening on the slopes.
22 Q. Did you see General Mladic arrive?
23 A. I did. I saw him.
24 Q. What did you see happen after he arrived?
25 A. UNPROFOR had those ribbons across the road,
1 and he came up there and they probably didn't let him
2 enter. So he returned towards Bratunac, from where his
3 group was coming, and then he joined the group and they
4 walked in among the people.
5 Q. What happened?
6 A. What happened? I went back to my mother and
7 daughter-in-law and sister-in-law. The children
8 started crying. There was panic. We were, indeed,
10 Q. Did you see anything else that day?
11 A. I saw -- this was later, I had spent the
12 night by the zinc plant. Then I took my family and we
13 entered the factory to spend the night inside. Since
14 the soldiers started walking around among the people,
15 then they started taking out our young men and taking
16 them away.
17 Q. What were these soldiers dressed like?
18 A. They were dressed in military camouflage
20 Q. These were Serb soldiers?
21 A. I suppose so. How do I know? They had black
22 gloves with their fingers showing.
23 Q. They weren't Dutch soldiers.
24 A. No. No, not then, no. The first night we
25 were safe. The Dutch soldiers were protecting us. We
1 were okay that first night.
2 Q. That was the night of the 11th that you were
3 safe; is that right?
4 A. Yes. Yes.
5 Q. Now, when the soldiers started taking men
6 away, what did you do with your family?
7 A. When I saw four soldiers bringing ten young
8 men and taking them away, then I became scared and I
9 realised what would happen. And then I took my family
10 and we went along the road and spent the night inside
11 an old bus, to be as close as possible to UNPROFOR.
12 Q. Did you ever see any Serbs that you were able
13 to recognise from before the war?
14 A. I only saw my neighbour, Slavoljub. Towards
15 nightfall, he was going towards the garages. He had a
16 black uniform on him.
17 Q. What was his last name?
18 A. Grujicic.
19 Q. About how old was he?
20 A. Slavoljub, he's an older man. Maybe 60 or
21 something. I don't know.
22 Q. All right. Did he have any sons that you
23 knew from before the war?
24 A. He had five sons. We were all living in one
25 neighbourhood. We were friends.
1 Q. Can you name some of the sons of Slavoljub?
2 A. One was Cvijetin, Dzole, Mile, Vitomir, and
3 the youngest one I can't remember. He was the
5 Q. When you saw Slavoljub, was he armed?
6 A. I didn't really see what he had on him. I
7 hid from him so he wouldn't see me, because they did
8 approach us and ask us about our men. They would ask
9 the women about the men and he would have recognised
11 Q. Did you see the group that Slavoljub was
12 with, the group of soldiers?
13 A. Yes, they were five or six of them all in
14 black clothing.
15 Q. And before you hid from them, could you see
16 what they were doing?
17 A. No, no.
18 Q. About what time was this that you saw these
19 soldiers in black including Slavoljub Grujicic?
20 A. It was at nightfall, it was already dark. He
21 was moving in the direction of the garages down there.
22 Q. And about where did you see him, about where
23 was he when you saw him in relation to the various
24 factories and the main road?
25 A. There's a small bridge and there used to be a
1 kind of reception hut there and then you go towards the
2 garages, and that is where I saw him.
3 Q. So was he near the -- near the various
4 factories around the base?
5 A. He was below the road, the other side of the
6 road below the factories.
7 Q. And where did you spend the night that night?
8 A. I spent the night there, close to this bus.
9 Q. You said in around or in one of the old
10 derelict buses that was in and around the bus factory?
11 A. It was a bus. There was a path leading to
12 the garages. The buses of Strela Company used to be
13 parked there. And then to the left, there was an old
14 bus. And there was an outpatient's clinic at Potocari
15 and next to it was this old bus and we spent the night
16 next to this bus. I think there are pictures of those
18 Q. And can you describe what you heard or saw
19 that night, this would be the night of the 12th?
20 A. I heard the worst. I heard people screaming,
21 crying and Ohran was calling out the name of his
22 cousin, "Ahmed, have they killed you, have they
23 slaughtered you?" They were wailing. It was a
24 terrible night.
25 Q. And were there screams going on throughout
1 most of the night?
2 A. Yes.
3 Q. Did you see anything that was happening
4 around you that night?
5 A. That is all I heard. And then you could see
6 the people sleeping on the ground next to the garages
7 and then UNPROFOR, it looked like UNPROFOR walking
8 amongst those people. What they were doing, I didn't
10 Q. The next morning, what did you do the next
11 morning with your family on the 13th?
12 A. The next morning, I got up. I told my family
13 to hurry up and go towards the personnel carrier. And
14 I saw this Ohran who had been calling his sisters on
15 the previous night, his head was all covered in blood.
16 Q. And then what did you do?
17 A. Then we went as quickly as we could towards
18 the buses where they were parked. They all were from
19 Serbia, 7th of July, Raketa, Vagevo; these are the
20 names of the bus companies. They had taken away our
21 men. We got on to a bus; I think it belonged to the
22 7th of July Company.
23 Q. Before you got on the bus, did you see a
24 Dutch soldier on top of a vehicle at some point?
25 A. This was when the Serb soldiers entered.
1 This might have been towards darkfall when you are
2 going towards Srebrenica. There was a vehicle, an
3 UNPROFOR vehicle, and on it there was a soldier lying
4 on his back. Why and how, I don't know. It was so
5 hot, why would he have been lying like that if he
6 hadn't been captured or something?
7 Q. Did you actually see him tied down or did you
8 just see him lying on this vehicle in this heat?
9 A. I just saw him lying on his back.
10 Q. So he might have just been lying in the sun
11 for all you know?
12 A. I don't know.
13 Q. You can't imagine why a person would lie in
14 the hot sun like that.
15 A. That's what I think too. Why would he be
16 lying like that facing the sun in that heat?
17 Q. After you got on the bus, where did you go
18 and your family?
19 A. We went towards Kladanj. We passed through
20 Bratunac. We passed by Kravica.
21 Q. Did you see anything on the way towards
23 A. On a meadow, I saw our men, four rows of
24 them. I don't know how many. I saw a man dressed in a
25 white coat, and he was doing something to a man's head
1 right next to the road. And the others were watching,
2 those four rows of men. And then we went along the
3 road and we came across our men with their hands like
4 this [indicates], and soldiers pushing them along,
5 that's what we saw.
6 MR. McCLOSKEY: For the record, the witness
7 indicated that her hands were on the top of her head,
8 she saw her soldiers with their hands on top of their
10 Q. Do you know what villages you were near when
11 you saw these men in the meadow, and then later on you
12 saw men with their hands on their head?
13 A. This was Sandici, Kravica, as far as Kasaba,
14 that is the route we took; Sandici, Kravica.
15 Q. Now, going back just briefly to when you saw
16 Slavoljub. In one of your old statements, it also says
17 that you saw his son, Cvijetin. Did you actually see
18 his son Cvijetin?
19 A. One of my neighbours, they were all there,
20 but I left early in the morning, about 9.00. And all
21 the others were there, Grujicics and Stevos, and they
22 were all there. And a neighbour of mine asked him to
23 save him but he left and he didn't do anything.
24 Q. So did you see Cvijetin or did one of your
25 neighbours tell you that she had seen him?
1 A. She told me.
2 Q. Did you actually see Slavoljub or did someone
3 tell you that he was there?
4 A. I saw him towards nightfall on the Wednesday,
5 on that Wednesday.
6 Q. Were you eventually let off the bus near
7 Tisca where you had to walk a distance to Kladanj?
8 A. Yes, we got off there. We had two kilometres
9 to cover to reach our territory.
10 Q. And did you make that or did you eventually
11 meet up with your husband?
12 A. When I reached Tuzla, my husband had already
13 left for Germany a month or two before that, I think,
14 in January or February.
15 Q. But you have since been able to be reunited
16 with your husband; is that right?
17 A. I was reunited when he came two months later
18 to Tuzla.
19 Q. I'm sorry to ask you this question, but I
20 think the Court and, perhaps, the world would like to
21 know. How is it living without your two sons and
22 without your three brothers in the wake of the tragedy
23 of Srebrenica?
24 A. How? You have children of your own. Only I
25 know how I feel. I had two sons, now I don't have any,
1 and I lost my brothers too.
2 Q. Okay. Thank you, very much.
3 MR. McCLOSKEY: Mr. President, I don't have
4 any further questions.
5 JUDGE RODRIGUES: [Interpretation]
6 Mrs. Hajdarevic, please have some rest. Take your
7 time. If you need a break, we'll have a break. We
8 understand how painful this must be for you.
9 THE WITNESS: [Interpretation] I thank you
10 too, Your Honour. We could perhaps have a little break
11 if you want.
12 JUDGE RODRIGUES: [Interpretation] Yes.
13 So for the purpose of organising our work,
14 Mr. Petrusic or Mr. Visnjic, how long do you think that
15 the cross-examination will take?
16 MR. VISNJIC: [Interpretation] Not more than
17 five minutes, Mr. President.
18 JUDGE RODRIGUES: [Interpretation] Very well,
19 then, we will still have a 15-minute break. I hope
20 that you will be able to get some rest so that you can
21 come back and continue with your testimony. A
22 15-minute break.
23 --- Break taken at 10.08 a.m.
24 --- On resuming at 10.25 a.m.
25 JUDGE RODRIGUES: [Interpretation]
1 Mrs. Hajdarevic, are you feeling any better now?
2 THE WITNESS: [Interpretation] Yes. I'm fine
3 now. Thank you.
4 JUDGE RODRIGUES: [Interpretation] Very well.
5 Now you're going to answer questions that will be put
6 to you by Mr. Visnjic, who is representing General
7 Krstic in this case.
8 Mr. Visnjic, you have the floor.
9 MR. VISNJIC: [Interpretation] Thank you,
10 Mr. President.
11 Cross-examined by Mr. Visnjic:
12 Q. Good morning, Mrs. Hajdarevic.
13 A. Good morning.
14 Q. Mrs. Hajdarevic, I should like to ask you a
15 question regarding your neighbour Slavoljub Grujicic,
16 the one you recognised in Potocari. Could you tell us
17 whether you had had any argument with him before the
18 war? Did you have any problems with him?
19 A. No. No, I didn't.
20 Q. So you were in good relations before the
22 A. Yes, we were.
23 Q. Thank you very much, Mrs. Hajdarevic.
24 MR. VISNJIC: [Interpretation] Your Honour,
25 this concludes my cross-examination.
1 JUDGE RODRIGUES: [Interpretation] Thank you,
2 Mr. Visnjic.
3 Any additional questions for the witness,
4 Mr. McCloskey?
5 MR. McCLOSKEY: No, Mr. President.
6 JUDGE RODRIGUES: [Interpretation] Judge
8 JUDGE RIAD: [Interpretation] Thank you,
9 Mr. President.
10 Questioned by the Court:
11 JUDGE RIAD: Mrs. Hajdarevic, good morning.
12 A. Good morning.
13 JUDGE RIAD: I'm sorry to bring these
14 memories back to you. You have lost two sons, you have
15 lost three brothers. Did you get any information after
16 they went away what happened to them or where they
18 A. I learned about my sons, that they had
19 reached Baljkovica, the crossing point, and that's all
20 I know about them. As regards my brother, he was in
21 Potocari and he was left there. My cousins, my
22 relatives, they were among those who went to the woods,
23 and I haven't heard of them ever since.
24 JUDGE RIAD: "Ever since" means since July
1 A. Yes.
2 JUDGE RIAD: Do you know many people in your
3 family, in your acquaintance, who also passed through
4 the same sad experiences, where their sons and brothers
5 disappeared and they have no news?
6 A. Yes, I do. There are so many such cases.
7 JUDGE RIAD: The cases of people returning,
8 were there cases of sons and brothers coming back?
9 A. Yes, that happened as well. Azim Begic, he
10 had six sons, and all of them managed to cross over.
11 JUDGE RIAD: Were they in the woods?
12 A. Yes, they were.
13 JUDGE RIAD: Did they tell you what happened?
14 A. Yes, they told us various stories. There
15 were lots of stories.
16 JUDGE RIAD: Good. You mentioned that the
17 UNPROFOR was walking among you with the Serbs, if I
18 remember, and you were hearing screams at the same
19 time. What were the UNPROFOR soldiers doing exactly?
20 A. No, they were not UNPROFOR soldiers, they
21 were Serb soldiers. They had taken their clothes and
22 put them on. They were not members of UNPROFOR.
23 UNPROFOR soldiers wouldn't do anything to us. They
24 would have helped us, like they did on the first
1 JUDGE RIAD: You mean they were dressed as
2 UNPROFOR, they had the UNPROFOR dress?
3 A. Yes, because they had captured both UNPROFOR
4 members and us, and they did as they pleased with
6 JUDGE RIAD: I'll ask you again about Azim's
7 sons; he had six sons. The six sons came out of the
8 woods, were able to come back?
9 A. Yes. Yes, all of them, they reached Tuzla.
10 JUDGE RIAD: They said that many other people
11 were able to get away from the woods, or were they
13 A. Well, they know how it was. People kept
14 coming out for months.
15 JUDGE RIAD: All right. Thank you very
17 JUDGE RODRIGUES: [Interpretation] Thank you
18 very much, Judge Riad.
19 Judge Wald.
20 JUDGE WALD: I have no questions except to
21 thank you for sharing your sad memories with us. I
22 hope they will do the search for truth well. Thank
24 JUDGE RODRIGUES: [Interpretation]
25 Mrs. Hajdarevic, I have only one question to ask of
1 you. I should like to know something about the
2 soldiers who arrived on the 12th of July. You are not
3 sure that they were Serbs; you just know that they were
4 not Dutch. So my question is the following: Did you
5 hear them speak?
6 A. Yes. I was near them. They were taking away
7 our young men, they were taking them to the Zinc
8 Factory. Our mothers were crying, pulling them by
9 their sleeves, telling them to let their sons go. Four
10 of them were taken away, and then another ten, they
11 were taken in the direction of Budak. But they were
12 speaking our language; they were our people.
13 JUDGE RODRIGUES: [Interpretation] So you're
14 saying that they were speaking your language.
15 A. Yes.
16 JUDGE RODRIGUES: [Interpretation] Were they
18 A. In the army? No. No. They were all Serbs.
19 JUDGE RODRIGUES: [Interpretation] So those
20 soldiers were Serbs.
21 A. Yes.
22 JUDGE RODRIGUES: [Interpretation] When you
23 heard them speak, what were they saying?
24 A. Well, they were addressing the mothers who
25 were there. They would, for example, tell her that
1 they would only take her son for questioning and then
2 that they would let him go. That's what they were
4 JUDGE RODRIGUES: [Interpretation] Thank you
5 very much, Mrs. Hajdarevic, for coming here to the
6 Tribunal. I should like to thank you once again, as my
7 colleagues have done, for sharing with us your
8 suffering. I hope that you will always be able to find
9 reason to live, meaning in life, at least to tell us
10 about the terrible things that have happened.
11 Is there anything else that you should like
12 to say, something you haven't had the opportunity to
14 THE WITNESS: [Interpretation] I should just
15 like to ask one question of these gentlemen from
17 JUDGE RODRIGUES: [Interpretation] I'm sorry,
18 Mrs. Hajdarevic, you cannot speak directly to these
19 gentlemen, but perhaps you could ask a general
21 THE WITNESS: [Interpretation] Just a
23 JUDGE RODRIGUES: [Interpretation] Yes,
25 THE WITNESS: [Interpretation] The gentleman
1 from Belgrade, does he have children?
2 JUDGE RODRIGUES: [Interpretation] Well, I
3 suppose he does.
4 THE WITNESS: [Interpretation] Then how could
5 they have come here to defend a man like Krstic? This
6 is all.
7 JUDGE RODRIGUES: [Interpretation] Thank you
8 very much. I hope that the world will be able to
9 answer a question like this, and I hope that this will
10 be an example of how people should be treated. Thank
11 you very much once again, Mrs. Hajdarevic.
12 I should like the usher to accompany
13 Mrs. Hajdarevic out of the courtroom.
14 [The witness withdrew]
15 JUDGE RODRIGUES: [Interpretation]
16 Mr. McCloskey.
17 MR. McCLOSKEY: Before I turn the podium over
18 to Mr. Harmon, who has the next witness, I just wanted
19 you to know that in the future we will be providing
20 evidence on the identities and the units of some of
21 these people that these witnesses have identified. For
22 example, Slavoljub Grujicic was a member of the
23 Bratunac Brigade of the Drina Corps at the time, and
24 you will see those records and witnesses will explain
25 those records.
1 JUDGE RODRIGUES: [Interpretation] In that
2 case, I give the floor to Mr. Harmon.
3 MR. HARMON: Good morning, Mr. President and
4 Your Honours; good morning to my colleagues for the
6 Our next witness will be a young man named
7 Enver Husic, and he's going to testify without
9 JUDGE RODRIGUES: [Interpretation] We shall
10 wait for him then.
11 [The witness entered court]
12 JUDGE RODRIGUES: [Interpretation] Can you
13 hear me, Mr. Husic?
14 THE WITNESS: [Interpretation] Yes.
15 JUDGE RODRIGUES: [Interpretation] Good
16 morning. You are going to read the solemn declaration
17 that the usher will give you, please.
18 THE WITNESS: [Interpretation] I solemnly
19 declare that I will speak the truth, the whole truth,
20 and nothing but the truth.
21 WITNESS: ENVER HUSIC
22 [Witness answered through interpreter]
23 JUDGE RODRIGUES: [Interpretation] You may be
24 seated. Are you comfortable?
25 THE WITNESS: [Interpretation] Yes.
1 JUDGE RODRIGUES: [Interpretation] Thank you
2 very much for coming. For the moment you will be
3 answering questions put to you by Mr. Harmon, who is
4 standing to your right.
5 Mr. Harmon, you have the floor.
6 MR. HARMON: Thank you, Mr. President.
7 Examined by Mr. Harmon:
8 Q. Good morning, Mr. Husic.
9 A. Good morning.
10 Q. Now, I'd like to you relax. I'm going to ask
11 you a number of questions about your experiences. Get
13 First of all, can you spell your last name
14 for the record, please.
15 A. My name is H-u-s-i-c, and my first name is
17 Q. How old are you, Mr. Husic?
18 A. I am 22.
19 Q. Before the fall of the enclave in 1995, were
20 you living in Srebrenica?
21 A. Yes.
22 Q. With whom were you living?
23 A. I was living with my mother and father, two
24 brothers and a sister.
25 Q. Now, at the time of the fall of the enclave,
1 was your father in active duty in the Bosnian army?
2 A. Yes.
3 Q. Was he registered as a soldier or did he
4 actually go to the front line?
5 A. He was just registered as a soldier.
6 Q. Now, you had two brothers. One brother was
7 named Ramiz; is that correct?
8 A. Yes.
9 Q. How old was Ramiz at the time of the fall of
10 the enclave?
11 A. Nineteen.
12 Q. Was he a member of the army?
13 A. No.
14 Q. How old were you at the time of the fall of
15 the enclave?
16 A. Seventeen.
17 Q. Were you a member of the army?
18 A. No.
19 Q. Now, you had one other brother; is that
21 A. Yes.
22 Q. As I understand it, your other brother passed
23 away before the fall of the enclave; am I right on
25 A. Yes, yes.
1 Q. Now, when the enclave was attacked by the
2 Bosnian Serb army, where did your mother and your
3 sister go?
4 A. They went to a place called Potocari.
5 Q. Where did you, Ramiz, your brother, and your
6 father go?
7 A. We went to a place called Kazani where there
8 were many other people and we headed through the woods.
9 MR. HARMON: If I could have Prosecutor's
10 Exhibit 7A placed on the ELMO. I'm going to show you a
11 map and I'm going to ask you to identify certain places
12 on Prosecutor's Exhibit 7A.
13 Q. While we're waiting for the map, can you tell
14 the Judges why was it that you and your father and your
15 brother went through the woods?
16 A. We went because the Serbs were shelling,
17 shooting and we feared we would share the fate of many
18 other people who had, during the war, been killed and
19 slaughtered. And we went to the woods hoping we could
20 reach free territory from Tuzla.
21 Q. Now, could you take a look at Prosecutor's
22 Exhibit 7A which is on the ELMO. Could you point to
23 some of the locations in your journey where you went
24 through the woods and before you actually surrendered.
25 MR. HARMON: Mr. Usher, if you could show the
1 witness the map and then place it back on the ELMO;
2 he's going to need to see it.
3 Q. Take a look at that for just a second,
4 Mr. Husic, and then we'll put it back on the ELMO and
5 then I'd like you to indicate with the pointer your
6 direction of flight.
7 A. Yes. This is it.
8 MR. HARMON: Could you just place that back
9 on the ELMO.
10 Q. Using the pointer, Mr. Husic, could you point
11 for the Judges' benefit the direction of your flight
12 from the time you left Kazani to the point of your
13 surrender, and please point to the ELMO.
14 A. We passed through a place called Susnjari,
15 Buljim, Kamenica, and then Sandici.
16 Q. I notice two of the maps -- two of the --
17 three of the areas are indicated on the map, Buljim is
18 not indicated on the map. Could you point to the area
19 of Buljim on this map since you mentioned it in your
21 A. Yes, I think this is the location
23 MR. HARMON: Indicating the circle in the
24 middle, indicating there's a town in there called Bare,
25 I believe.
1 Q. Now, how many people were gathered --
2 MR. HARMON: I'm finished with the exhibit,
3 Mr. Usher, thank you.
4 Q. Can you estimate how many people were
5 gathered at Kazani before people left the enclave and
6 went in the direction of Tuzla?
7 A. I can't tell you the exact number, but there
8 were a lot of people there.
9 Q. Were there women amongst the people gathered
10 at Kazani?
11 A. Yes, there were. I saw about ten women
13 Q. Were there children?
14 A. I didn't see any.
15 Q. Now, can you describe the manner in which you
16 left the enclave?
17 A. First, we went along a wider road, a group of
18 people. There were a lot of people. It wasn't a
19 proper column across the fields to Buljim. We didn't
20 go along roads, but across the fields a lot of the
21 time. But from a distance, it looked like a column.
22 Q. Okay. Can you tell the Judges approximately
23 your position in the column; were you in the front of
24 the column, in the middle of the column, in the rear of
25 the column?
1 A. We were in the rear, not quite at the very
2 end, but in the last half.
3 Q. Do you remember the date when you left the
5 A. Yes, it was the 11th.
6 Q. Now, accompanying you in the column, were
7 there men with rifles?
8 A. Yes.
9 Q. And in your part of the column, approximately
10 how many men had rifles?
11 A. I could see about 50.
12 Q. Do you know the purpose of the men with the
13 rifles in your part of the column?
14 A. Their purpose was to protect the rear part of
15 the column.
16 Q. Now, briefly, could you tell the Judges what
17 happened once you left Srebrenica and before you
19 A. We reached Buljim from Kazani, that is
20 Srebrenica. I fell asleep from fatigue. I woke up in
21 the morning, it had dawned, and my father and brother
22 were not there. They had left before me.
23 So there were only a few people left in
24 Buljim, and I was among them. There were about 50
25 armed Muslims there, soldiers, and I went down hill
1 from Buljim towards Kamenica.
2 The column was two by two. We went down
3 hill, I saw four dead men. Then we went on. The path
4 was marked with pieces of papers, because they told us
5 that it was mined so we couldn't move away from those
7 The Serbs were shooting. I think they used
8 mortars and infantry weapons and rifle grenades. A lot
9 of people lost their lives there.
10 Then, however, I found my father who was hit
11 by an explosion of a rifle grenade. He wasn't feeling
12 well. He wasn't really hit, but it was the detonation
13 that had affected him.
14 Then we went on, a place called Strane, the
15 shooting stopped, we couldn't hear anything. We just
16 heard the Serbs calling out to one another. At the
17 same time, we suddenly heard something that sounded
18 like the wind blowing and suddenly, the fire came from
19 all sides.
20 My father got up. I helped him go down
21 towards a stream. I saw people falling. A lot of
22 people were hit. And we managed to pull out somehow.
23 We went along the stream and uphill. There weren't
24 many people who had pulled out. We could hear screams
25 and moans and shooting. And my father and I went on.
1 We found my brother and we stopped there.
2 Night fell. We stayed there throughout the
3 night. I fell asleep again. The next day, when it
4 dawned, I saw a lot of dead people around me, they had
5 been killed. Some had been mutilated.
6 After that, my brother wasn't there. I was
7 alone there. I suppose when I fell asleep and the
8 shooting started, they disappeared again. So I went on
9 and found them.
10 There were a lot of people there on a
11 hillside. And what happened then, it was about midday,
12 the sun was out, it was warm and we heard the Serbs
13 from the asphalt road calling out to us to surrender.
14 They were saying, "Surrender, the UNPROFOR is here." I
15 saw a white personnel carrier with a blue helmets. And
16 they said, "Surrender, the UNPROFOR will transport you
17 safely to Tuzla."
18 I had the feeling that if I surrender, I
19 would survive. And I said to my father, let's go and
20 surrender. In fact, I was begging him to. That was
21 the feeling I had. And about 2.00 in the afternoon, we
22 headed downhill towards the asphalt road. Again, we
23 saw UN personnel carriers and blue helmets.
24 As we were coming down, before we reached the
25 road itself, there was a slight climb. There were two
1 Serb soldiers, one on each side standing there.
2 Q. Mr. Husic, let me interrupt you there for
3 just a minute and let me ask you first of all, do you
4 remember the date it was when you surrendered?
5 A. Yes, I do. It was the 13th.
6 Q. Now, I want to show you a film; you've seen
7 this before in my office. It's a film of your actual
9 MR. HARMON: And if I could, Mr. President,
10 have transcripts of the film that I'm going to show
11 disseminated, that would be Prosecutor's Exhibit 103A.
12 Unfortunately, the transcripts are only in English.
13 Then once they are disseminated, I'll ask that the film
14 itself be played.
15 And if the interpreters could please
16 translate as the film is being played. The translation
17 booth has been provided with an English language
19 Now, if the lights could be dimmed, please,
20 and we could play Prosecutor's Exhibit 103, please.
21 [Videotape played]
22 THE INTERPRETER: [Voiceover].
23 I don't know, from some desrt.
24 How long have you been there?
25 We were there two days and two nights.
1 Completely surrounded. What. Where are your
3 I didn't have a rifle, I am a civilian.
4 A civilian? All right, then have no fear.
5 Were you afraid?
6 Who wouldn't be afraid?
7 Hey, hey, you journalist.
8 How come he already arrived, before they
10 Hey, take off that shirt.
11 This one?
13 MR. HARMON: Mr. President, not all of the
14 film and all of the language on the film was
15 translated. I know it's difficult for the interpreters
16 to do it following the film, but the translation that
17 has been provided to the Chamber is a complete
18 translation that has been provided to us by the
19 language service section.
20 Now, if I could have Prosecutor's Exhibit 104
21 placed on the ELMO, please.
22 Q. Mr. Husic, I've placed on the ELMO a still
23 image taken from that film we just saw, Prosecutor's
24 Exhibit 103. Is that you in this still image?
25 A. Yes, that's me.
1 Q. That's you at the time of your surrender; is
2 that correct?
3 A. Yes.
4 Q. Now, Mr. Husic, you described in part of your
5 answer that you surrendered because you could hear
6 Bosnian Serbs calling you down to surrender; is that
8 A. Not only because we heard them calling out to
9 us to surrender but also because we saw UNPROFOR there,
10 because we thought that they couldn't simply kill us in
11 the presence of UNPROFOR. We hoped that UNPROFOR would
12 transport us to Tuzla, as the Serbs themselves had
14 MR. HARMON: Now, Mr. President and Your
15 Honours, I'm going to play another film, and I'd ask
16 that Prosecutor's Exhibit 102A, a transcript from that
17 film, also be distributed to Your Honours before we
18 play the film.
19 Again, if the language booths could try to
20 follow this and translate this film as well.
21 I direct Your Honours' attention just to
22 significant parts of this film. I'll describe it
23 initially. It's Bosnian Serb soldiers calling into the
24 woods for people to surrender, and at the end of film
25 you'll notice an individual wearing a blue UN helmet.
1 So if we could dim the lights, please, and
2 play Prosecutor's Exhibit 102. This is a short film;
3 it only lasts 44 seconds.
4 [Videotape played]
5 THE INTERPRETER: [Voiceover]
6 How many of them got out already?
7 About three or four thousands.
8 And they all surrendered to you here?
10 When we give such a figure, people in
11 Belgrade usually say it is exaggerated.
12 Well, it is exaggerated, of course it is.
13 But that is really how many of them.
14 Yes. So much. So much.
15 There they are, look there.
16 See how he disappeared. There, on the left.
17 Come on, boys, get out freely, boys.
18 He was the one who aimed?
19 Five or six passed.
20 Get out, hey.
21 You see them now, do you see them?
22 There is a whole file of them.
23 Two, that's how it goes, one after the other,
25 About fifteen passed now.
1 So they are coming down like that all day?
2 Surrender, boys.
3 From this morning.
4 All day they are coming out like that.
5 The last group that passed was 400 of them,
6 they came out down there.
7 Uniforms they leave up there, they dress in
8 civilian clothes and ...
9 You down there, come out.
10 Let's go.
11 Hurry up.
12 Hurry up. Faster.
13 MR. HARMON:
14 Q. Now, Mr. Husic, does that film accurately
15 depict the events as you recall them?
16 A. Yes.
17 Q. Now, you testified in your direct examination
18 that you saw white APCs, armoured personnel carriers,
19 belonging to the UN; you saw Bosnian Serbs in blue
20 helmets. Did you also see Bosnian Serb soldiers in UN
21 camouflage flak jackets?
22 A. Yes, I did.
23 Q. Having lived in the enclave and having seen
24 the UN Dutch Battalion soldiers patrolling through the
25 enclave, were you familiar with the UN type of
2 A. Yes, I was, 100 per cent.
3 Q. Were there a lot of Bosnian Serb soldiers
4 wearing UN camouflage flak jackets, as well as the UN
5 blue helmets?
6 A. Not that many. I saw between eight and ten
7 of them.
8 MR. HARMON: If I could have Prosecutor's
9 Exhibits 105, 106, and 107 distributed, first of all,
10 and then placed on the ELMO.
11 These, Mr. President and Your Honours, are, I
12 would say, poor quality still images taken from
13 Prosecutor's Exhibit 103, the film. They are intended
14 to show Your Honours and assist Your Honours, if and
15 when you review the film, with the types of UN flak
16 jackets that are worn by Bosnian Serb soldiers.
17 If you could start, Mr. Usher, by placing
18 Prosecutor's 105 on the ELMO.
19 Q. Mr. Husic, these are still images taken from
20 the film of your surrender. Can you tell us what the
21 soldier who is to the left of the man in the blue shirt
22 is wearing?
23 A. I can recognise here a UN flak jacket. It is
25 MR. HARMON: Now, could we have the next
1 exhibit, Prosecutor's 106, placed on the ELMO.
2 Q. Can you identify what the man, the soldier,
3 on the left-hand side of this image is wearing?
4 A. He's wearing a UN flak jacket.
5 Q. Can you point that out with the pointer,
7 A. Yes, I can. [Indicates].
8 Q. Thank you very much.
9 MR. HARMON: Now could we turn to the next
10 image, which is Prosecutor's Exhibit's 107, and place
11 that on the ELMO.
12 Q. You've seen this from the film. Could you
13 tell the Judges what the soldier on the right side of
14 this image is wearing?
15 A. He's also wearing a UN flak jacket.
16 Q. All right. Thank you very much.
17 Now, you also had an opportunity to review
18 other film in my office, and I'd like to show you --
19 MR. HARMON: I'd like to first of all
20 distribute for the Judges and counsel Prosecutor's
21 Exhibit 101A, which is a transcript in English of the
22 next piece of film footage we're going to show.
23 If we could lower the lights, please, and
24 play Prosecutor's Exhibit 101, please.
25 [Videotape played]
1 THE INTERPRETER: [Voiceover]
2 Boro, shall we swap our pistols.
3 Let me see.
4 Do you have a spare one?
5 I do.
6 All right. Want to swap?
7 MR. HARMON:
8 Q. Do you recognise those two soldiers who were
9 in a reclining position, Mr. Husic?
10 A. Yes, I do.
11 Q. Tell the Judges who those individuals are and
12 what they did to you and to other people who were
14 A. These are two Serb soldiers, whom we have
15 just seen on the screen, that were present there. They
16 were asking people for money, German marks, gold, and
17 everything they had on them. They were searching
19 Q. Now, at the end of this film, you could see a
20 meadow in the film. Is that the location where, after
21 you surrendered, you eventually ended up, on that
22 particular meadow?
23 A. Yes, that is the location.
24 Q. What happened to the bags that were being
25 carried by the men who were surrendering?
1 A. Whoever had a bag or a backpack had to leave
2 it before coming out to the meadow.
3 Q. Where did they have to leave it?
4 A. They had to leave it by the road, by the
5 asphalt road, on both sides of the road. They were not
6 allowed to take it up to the meadow.
7 MR. HARMON: Now, if I could have the next
8 series of exhibits taken to the ELMO, they would be
9 Prosecutor's Exhibits 7/2, 7/5, 7/6, and 7/9.
10 Mr. Usher, we'll start with Prosecutor's
11 Exhibit 7/2.
12 Q. Mr. Husic, have you seen Prosecutor's Exhibit
13 7/2 in my office?
14 A. Yes, I have.
15 Q. Do you see the dotted yellow line that starts
16 at the top left-hand side of the image, comes down past
17 a house and ends in an oval that is on the left-hand
18 side of the image? Do you see that dotted line?
19 A. Yes.
20 Q. Does that dotted line represent your route
21 when you descended from the hills and eventually ended
22 up on the meadow?
23 A. Yes, it does.
24 Q. Now, let me show you the next exhibit, which
25 is Prosecutor's Exhibit 7/5. Do you recognise what's
1 in this photograph, Mr. Husic?
2 A. Yes, I do. I can recognise the meadow and
3 the house I passed on the way.
4 Q. Could you use the pointer, please, and first
5 of all point to the house that you passed on the way
6 down from the mountains.
7 A. [Indicates]
8 MR. HARMON: Indicating, for the record,
9 Mr. President and Your Honours, the largest house, a
10 little bit off the centre of the picture, on the top
11 side of the road.
12 Q. Where is the meadow that you ended up on?
13 A. [Indicates]
14 MR. HARMON: Indicating directly below the
15 house on the other side of the road, an area directly
16 off the road.
17 Could we then have Prosecutor's Exhibit 7/6
18 placed on the ELMO.
19 Q. Mr. Husic, do you recognise what's in this
20 image, Prosecutor's 7/6?
21 A. Yes, I can recognise the rear side of the
22 house, the back part of the house.
23 Q. Could you point to the Judges on which side
24 of the house you passed by when you surrendered?
25 A. [Indicates]. On this side of the house, next
1 to these stairs here [indicates].
2 MR. HARMON: Indicating, for the record, the
3 left-hand side of the image.
4 Lastly, Mr. Usher, if you could place the
5 next exhibit, Prosecutor's 7/9, on the ELMO.
6 Q. This is a panorama, Mr. Husic. You've had an
7 opportunity to see this in my office.
8 MR. HARMON: Mr. Usher, if you could place it
9 a little more to the left, please, so we could show the
11 Q. Do you recognise that building, Mr. Husic?
12 A. Yes, I do.
13 Q. What is that building?
14 A. It was next to this house [indicates] that I
15 passed on my way, on this side of the house
17 MR. HARMON: Mr. Usher, if you could keep
18 moving that image to the left.
19 Q. Do you see the meadow on which you
20 surrendered, Mr. Husic, on this particular panorama?
21 A. Yes, I can see it.
22 Q. Could you point it out?
23 A. [Indicates]
24 MR. HARMON: Indicating a green area to the
25 right of the house, below the road.
1 Q. Now, could you tell the Judges what you saw
2 after you passed the house and after you arrived at the
4 A. I was told to sit down with a group of
5 people, and I went to the left side of the group and I
6 sat down. There were lots of Serb soldiers around us,
7 and to my left was a tank -- I'm sorry, to my right. I
8 could see Serb soldiers coming to the group, asking
9 people for money.
10 They were also taking people away to a nearby
11 cornfield, behind the tank, and they took people away
12 as they pleased. They cursed at them, they cursed at
13 their balija mothers, telling them, "Where is your
14 Alija to help you now? Wait until Ratko Mladic comes
16 Q. Can you tell us, Mr. Husic, how were those
17 soldiers dressed who were surrounding you in the
19 A. Black camouflage uniform -- green.
20 Q. I'm sorry. Would you repeat your answer,
22 A. They were dressed in camouflage uniforms but
23 they were different, not all of them were the same.
24 Q. Could you describe the uniforms as best you
25 can recall them, each of the different types of
2 A. I can remember that there was a blue police
3 uniform, which was also a camouflage uniform, and a
4 military uniform that was used by the Serbian army. I
5 also remember a multicoloured open uniform, light
7 Q. How many blue police camouflage uniforms did
8 you see while you were at the meadow?
9 A. I didn't see a single one, but I could
10 recognise the pattern of the uniform. It was a green
11 camouflage uniform.
12 Q. Now, we have seen in both the films that
13 we've played and the still images, we've seen people in
14 green camouflage uniforms. Is that the type of uniform
15 that you saw, generally speaking?
16 A. Yes.
17 Q. Now, can you estimate approximately how many
18 people were on the meadow when you arrived in the
20 A. Between 900 and 1.000.
21 Q. Did you see anybody, any family member that
22 you knew amongst those people on the meadow?
23 A. Yes.
24 Q. Who did you see?
25 A. I saw two brothers from the village of Osmac,
1 from the municipality of Srebrenica. And I recognised
2 also Ramo who was calling out to people, the man who
3 was wearing a blue shirt.
4 Q. Did you see your father?
5 A. No.
6 Q. Did you see your brother?
7 A. No.
8 Q. So you were alone on the meadow in so far as
9 your direct family relations?
10 A. No, I'm referring only to the video. But I
11 did see my brother and my father in the meadow.
12 Q. Now, can you describe for the Judges what you
13 saw the soldiers doing to the people, the Muslim men
14 who were sitting on the meadow?
15 A. The worst. They were cursing at people, they
16 were kicking them, taking them away to the house.
17 There was a relative of mine, Husic Safet, who was
18 taken away in this fashion, and he never came back. I
19 remember a man who was sitting in front of me, he gave
20 20 German marks to a Serbian soldier wearing glasses.
21 They were taking people away to the cornfield
22 which was behind the tank to the right side. And many
23 of them would come to the group and hit the people.
24 Q. You said you saw some men being taken to a
25 cornfield. Were they Muslim men being taken to the
2 A. Yes. Yes, they were.
3 Q. Did you see those -- the -- did Bosnian Serb
4 soldiers take the Muslim men to the cornfields?
5 A. Yes.
6 Q. Did you see those Bosnian Serb soldiers
7 return from the cornfields without the Muslim men who
8 had been escorted in that direction?
9 A. Yes.
10 Q. Now, continue telling the Judges what
11 happened while you were at this particular meadow.
12 What did you do? What were you asked to do?
13 A. While I was sitting there, a soldier who was
14 on the tank, on my right-hand side, he cursed my balija
15 mother and told me to get up. But the man who was
16 sitting next to me stood up because he was confused.
17 He didn't know whom the soldier had in mind. But then
18 he pointed at me.
19 So I stood up and I went to the tank and they
20 gave me two jerrycans, and I was told to go to the
21 asphalt road and to continue along the road, and to my
22 left, that there would be some water.
23 So I took those two jerrycans and I went to
24 the left, down the road, and I filled them with water.
25 I returned to the meadow, and the Serb soldier ordered
1 me to distribute the water around, but not to give too
2 much to each of the men. This is what I did.
3 After I was coming back the second time, I
4 saw a number of Serb soldiers next to the asphalt
5 road. There was a man of my age there, Samir Krdzic
6 and he had been assigned the same task. He had to
7 bring water to the meadow.
8 While I was standing there, a Serb soldier
9 approached me with an automatic rifle and he cursed my
10 mother, and he asked me why I was laughing. And I told
11 him I was not laughing, and he told me not to speak.
12 But then another soldier came to us and he told him not
13 to touch me. And then he left.
14 So while these young men were standing there,
15 a bus arrived from the direction of Potocari carrying
16 women, and it stopped there near the water.
17 The door of the bus opened, and the driver
18 who was driving the bus, he also probably wanted to
19 take some water. He went to the Serb soldiers and he
20 spoke to them.
21 I had been thinking about escaping, I wanted
22 to try something. And then this opportunity presented
23 itself, and I decided to board the bus and then see
24 what happened. So I threw away the jerrycans and I
25 entered the bus.
1 Meanwhile, the driver was talking to the Serb
2 soldiers who were standing nearby. I got on the bus
3 and I hid amongst the women who covered me with some
5 So when the driver came back, he started the
6 engine, he didn't notice me, and he set off. And
7 during our journey, I heard at one point that the bus
8 was being hit with rocks. Local women were probably
9 throwing stones at the bus.
10 So nothing happened, and the bus stopped in
11 Tisca. I got out of the bus. There were some elderly
12 people who could not walk, and I mixed with the women
13 there and I helped them carry an old woman. And this
14 is how I managed to reach the free territory.
15 Q. Can you describe the soldiers, Bosnian Serb
16 soldiers who were in Tisca? What were they wearing?
17 A. They were wearing those same uniforms as
18 those down there, only they looked a little newer to
20 Q. Describe the uniforms, were they camouflage
22 A. Camouflage, yes, camouflage, green and a sort
23 of off white. It's not really white. I don't know how
24 I can describe that colour. Anyway, they were new
25 camouflage uniforms.
1 Q. I'd like to return to the meadow for one last
2 observation of yours, please.
3 MR. HARMON: If I could have Prosecutor's
4 Exhibit 7/4 placed on the ELMO.
5 Q. And you testified, Mr. Husic, that there was
6 a tank that was on the meadow near the prisoners who
7 were sitting?
8 A. Yes, yes.
9 Q. I'd like to show you Prosecutor's Exhibit 7/4
10 which is now on the ELMO, and do you see the -- could
11 you point out for the Judges the location of the tank
12 that you remember?
13 A. Yes, I can, here [indicates].
14 MR. HARMON: Indicating for the record the
15 unidentified vehicle on the right side of the image.
16 Q. Now, lastly, Mr. Husic, I'm going to show you
17 some additional exhibits?
18 MR. HARMON: If I could have Prosecutor's
19 Exhibits 108, 109, 110, and 111 disseminated. These,
20 Mr. President, Your Honours, and counsel are still
21 images taken from Prosecutor's Exhibit 103.
22 If we could start, Mr. Usher, with
23 Prosecutor's Exhibit 108.
24 Q. Mr. Husic, this is an image from the film of
25 your surrender. Can you please tell the Judges who
1 these two men are?
2 A. They are the brothers that I mentioned when I
3 was telling you about it, Osman.
4 Q. Now, these two brothers, to your knowledge,
5 Mr. Husic, did they survive?
6 A. No, they didn't survive.
7 Q. Did their father survive?
8 A. No. He was taken to the cornfield behind the
10 Q. Let me show you another picture of a man who
11 surrendered to the Bosnian Serb army, again taken from
12 your film of your surrender, Prosecutor's Exhibit 109.
13 Do you see the man in the blue shirt in the
14 middle of that image and he's flanked by two Bosnian
15 Serb soldiers? Can you tell us his name?
16 A. Ramo is his name.
17 Q. Did Ramo survive?
18 A. No.
19 Q. Let me go to the next image which is
20 Prosecutor's Exhibit 110. Again, an image showing a
21 number of men who were surrendering today Bosnian Serb
22 soldiers. Can you identify any specific individual in
23 this exhibit?
24 A. On the right, his name is Juso, and did he
25 not survive.
1 Q. Point out Juso on the exhibit, please.
2 MR. HARMON: Indicating, for the record, a
3 man who appears to be in a brown-coloured coat or
4 jacket and he's on the right.
5 Q. Lastly, in this series of exhibits, let me
6 show you Prosecutor's Exhibit 111.
7 First of all, Mr. Husic, do you see yourself
8 in that exhibit?
9 A. Yes, I do.
10 Q. Could you point out where you are in this
12 MR. HARMON: Indicating the individual who is
13 the second individual from the left-hand side.
14 Q. Now, do you see the man in the camouflage
15 T-shirt directly in front of you?
16 A. Yes, I do.
17 Q. Could you tell the judges what happened to
18 that man?
19 A. They ordered him to take off his T-shirt, and
20 they took him to the cornfield and he also did not
22 Q. Now, in addition, Mr. Husic, to these
23 individuals who were shown surrendering to the Bosnian
24 Serb army, were there a number of other individuals you
25 can identify by name who did not survive?
1 A. Yes.
2 Q. Could you please identify those individuals,
3 who you saw alive on the meadow who not survive?
4 A. I know my neighbours, Husic Mehemed, Husic
5 Mehmedalija, Husic Safet, and another man named called
6 Sead Krdzic. They also did not survive.
7 Q. Do you know an individual named Sajdin Husic?
8 A. Yes. That is my father who also did not
9 survive. He stayed behind there.
10 Q. My last question, Mr. Husic, all of these
11 individuals you've seen in the images and who you have
12 named who did not survive, were they Bosnian Muslims?
13 A. Yes, they were.
14 Q. Mr. Husic, thank you, very much.
15 MR. HARMON: I've concluded my examination,
16 Mr. President.
17 JUDGE RODRIGUES: [Interpretation] Thank you,
18 very much, Mr. Harmon.
19 I think this is a good time for a break
20 before the cross-examination. So we'll have a
21 20-minute break now.
22 --- Recess taken at 11.37 a.m.
23 --- On resuming at 11.56 a.m.
24 JUDGE RODRIGUES: [Interpretation] Mr. Husic,
25 have you had some rest during the break?
1 THE WITNESS: [Interpretation] Yes, I have,
2 Your Honour.
3 JUDGE RODRIGUES: [Interpretation] Now you
4 will answer questions that will be put to you by
5 Mr. Visnjic, who is counsel for the Defence here.
6 Mr. Visnjic, you have the floor.
7 MR. VISNJIC: [Interpretation] Thank you,
8 Mr. President.
9 Cross-examined by Mr. Visnjic:
10 Q. Good morning, Mr. Husic.
11 A. Good morning.
12 Q. Mr. Husic, in your statement, or rather
13 during your direct testimony, you said that while you
14 were going to the woods, and prior to your surrender,
15 that there had been a group of soldiers with you who
16 were armed; is that correct?
17 A. Yes, it is.
18 Q. That there were 50 of them.
19 A. Yes, there were.
20 Q. Let's try to have short breaks between
21 questions and answers.
22 Could you tell me, Mr. Husic, something about
23 those soldiers? Did any of them surrender, of those
24 who had weapons?
25 A. No, I didn't see that.
1 Q. Before you surrendered -- strike that. Could
2 you tell us, please, whether you know where those
3 soldiers with weapons had gone.
4 A. I couldn't tell you anything about that
5 because I didn't see anything.
6 Q. While you were on the hill, could you see the
7 Serb soldiers calling out to you from the asphalt road?
8 A. Yes.
9 Q. How far were you from them at that moment?
10 Could you give us an estimate?
11 A. I couldn't.
12 Q. Did you see them before you decided to
13 surrender or afterwards?
14 A. Could you please be more precise in your
15 questions, sir.
16 Q. At one point you saw Serb soldiers there.
17 Was it before or after you reached the decision to
19 A. We had seen them prior to that.
20 Q. You mean before you reached the decision to
22 A. Yes, that's correct.
23 Q. Thank you. Mr. Husic, how many soldiers,
24 Serb soldiers, approximately, were there at the meadow?
25 A. There were a lot of them. I couldn't tell
1 how many exactly, I couldn't give you the exact number,
2 but they were all over the place.
3 Q. You were living in Srebrenica before 1995,
4 the last three years preceding 1995.
5 A. No. Two years.
6 Q. During those two years, did you leave
7 Srebrenica? Did you get out of Srebrenica?
8 A. No, I didn't.
9 Q. During those two years, did you ever see Serb
11 A. [No audible response]
12 Q. Was there any --
13 MR. HARMON: Excuse me. There was no answer,
14 at least translated, to that question of Mr. Visnjic's,
15 and in order to make the record complete, I think we
16 need an answer to that last question.
17 MR. VISNJIC: [Interpretation]
18 Q. During those two years, for the record,
19 Witness, did you see Serb soldiers?
20 A. No, I didn't.
21 Q. The Muslim army that was in Srebrenica, did
22 they have any special uniform?
23 A. No, I didn't see that but I don't think so.
24 Q. You testified in direct about a difference
25 between three kinds of uniforms, that there was a blue
1 police uniform and two other types of uniform; is that
3 A. Yes.
4 Q. Those were all uniforms of the Serb army.
5 A. Yes.
6 Q. Could you explain, then, to me, you didn't
7 leave Srebrenica and you didn't see Serb soldiers
8 during that time, so how do you know that they used to
9 have different kinds of uniforms?
10 A. Well, at the moment I surrendered, I could
11 observe that, and I also saw that later on on TV and I
12 learned that those were Serb uniforms.
13 Q. Could you give us an estimate of the number
14 of people who were on the meadow where you were?
15 A. Between 900 and 1.000.
16 Q. You testified during the examination-in-chief
17 about a video film, which has been shown by the
18 Prosecutor, where we could see two Serb soldiers who
19 were identified by you as the soldiers who were
20 searching people for money.
21 A. Yes.
22 Q. Could you observe on their uniforms, on their
23 right sleeve, a sign in three colours, with the
24 lettering "Policija" on it?
25 A. No, I didn't.
1 Q. In the vicinity of the location where you
2 surrendered and near the meadow where you were sitting,
3 did you notice a police vehicle of blue and white
5 A. No, I didn't.
6 Q. According to your impression, the Serb
7 soldiers who were moving in the area, were they members
8 of one unit or members of various units? Were they
9 just individuals coming in and out? Were those units
10 outside any control? Was there any command?
11 A. I could see three different kinds of
12 uniforms, so I don't think that they were members of
13 one and the same unit.
14 Q. You mentioned the TV, the watching of TV
15 after you had crossed over to the free territory.
16 Could you tell us whether you had seen Muslim soldiers
17 on TV, those who had managed to break through to the
18 free territory?
19 A. I didn't see any soldiers; I only saw
21 Q. But you did watch TV.
22 A. No, I didn't watch.
23 Q. When you reached Tisca, you got off the bus.
24 A. Yes.
25 Q. And you continued on foot.
1 A. Yes.
2 Q. Did anyone approach you, anyone from amongst
3 the Serb civilians or the military? Was there anything
4 special that you could observe at that moment?
5 A. Nobody approached me personally.
6 Q. Does the name "Ejub Golic" tell you
8 A. Ejub Golic? Yes.
9 Q. Was he a commander of a Muslim unit?
10 A. According to what I have heard, yes.
11 Q. Did he also take part in the breakthrough?
12 A. Yes, I heard that he did so.
13 Q. But you don't know anything else about that.
14 A. No, I don't.
15 Q. Have you heard of a unit called the Mountain
16 Battalion of the Muslim army?
17 A. Yes, I have.
18 Q. The soldiers who were protecting you, who
19 were with your group, were they members of that
20 Mountain Battalion?
21 A. Yes, they were.
22 Q. Thank you.
23 MR. VISNJIC: [Interpretation] Your Honour, I
24 have no other questions to ask of this witness.
25 Thank you, Mr. Husic.
1 JUDGE RODRIGUES: [Interpretation] Thank you,
2 Mr. Visnjic.
3 Will there be any redirect, Mr. Harmon?
4 MR. HARMON: There will be none,
5 Mr. President. Thank you.
6 JUDGE RODRIGUES: [Interpretation] Thank you
7 very much, Mr. Harmon.
8 Judge Riad.
9 JUDGE RIAD: [Interpretation] Thank you,
10 Mr. President.
11 Questioned by the Court:
12 JUDGE RIAD: Mr. Husic, good morning.
13 A. Good morning, Your Honour.
14 JUDGE RIAD: I understood you said that your
15 father did not survive.
16 A. Yes.
17 JUDGE RIAD: You also mentioned that many
18 people did not survive, thousands or whatever. How do
19 you know they did not survive? Do you have any news?
20 Or perhaps they are somewhere.
21 A. I don't think that they have survived. They
22 have been missing for five years, and I think that they
23 were executed like everybody else, that they were
25 JUDGE RIAD: Now, speaking of execution, you
1 mentioned that the soldiers would take the Muslim
2 prisoners behind the tank and they would come back
3 without them. But did you hear shots, or were they
4 slaughtered by knife? How did you understand the
6 A. No shooting could be heard, so I think they
7 did it with a knife or something else.
8 JUDGE RIAD: But no evidence was there. You
9 did not see blood around; you didn't hear shouts,
10 cries. When people are slaughtered, they can react.
11 Did you feel anything? What was the atmosphere like?
12 Of course, they did not disappear by enchantment, but
13 how was it? How did it happen?
14 A. It happened in a simple way. They would come
15 and take men away and the person would never come
16 back. And we didn't hear anything.
17 JUDGE RIAD: You were all in the same --
18 A. They would come -- yes, on the meadow, near
19 the tank.
20 JUDGE RIAD: On the meadow, near the tank.
21 If they were killed, how could they hide them? Where
22 did they hide them?
23 A. I couldn't tell you anything about that. I
24 didn't see it.
25 JUDGE RIAD: Was it in the woods that they
1 could hide them, or you could see the corpses? Was it
2 an open air place where you could see people or a place
3 in the woods so that nobody could see the other?
4 A. It was a cornfield, maize field, not a
5 forest, where they took people.
6 JUDGE RIAD: And the maize was high, it could
7 hide a person.
8 A. Yes. Yes.
9 JUDGE RIAD: Yes. Then, concerning your
10 father, you are sure he did not survive? Did they find
11 his corpse, or did some people inform you that he did
12 not survive? Can we still hope that he is alive?
13 A. I can always hope, but judging by the kind of
14 people who were there, I very much doubt that he would
15 have survived. I didn't hear anything and he has not
16 been identified as one of the killed.
17 JUDGE RIAD: Now, you mentioned something
18 rather important. You said that some of the soldiers
19 were in the Serbian military uniform. Do you mean the
20 military uniform of the Serbian army or of the Bosnian
21 Serb army? Because there is a difference. Do you know
22 the difference?
23 A. Well, I think that they were members of the
24 Serb army, that is, the army of the Bosnian Serbs. But
25 I couldn't tell you the difference.
1 JUDGE RIAD: Did you see any badge on them to
2 indicate which division they were from? Or this was
3 something too difficult at that time.
4 A. It was difficult. I could only see some kind
5 of black ribbons on their shoulders.
6 JUDGE RIAD: And they were, I think, as you
7 said, in camouflage, black and green; is that right?
8 A. Yes, that's right.
9 JUDGE RIAD: Was this indicative of a certain
10 group of military people, of a certain division which
11 you knew about?
12 A. Well, it was indicative of one particular
13 group because there was a group of people who were
14 wearing the same uniforms and those black ribbons.
15 JUDGE RIAD: Do you know the name of the
17 A. No. No.
18 JUDGE RIAD: Now, in one of the exhibits
19 which we saw, the pictures or the movie, there was a
20 very interesting answer of a soldier to another
21 soldier, when one of them was saying, "3.000 have
22 surrendered and the people in Belgrade think we
24 Now, what is the people of Belgrade's
25 business with Srebrenica? Do you have an idea?
1 A. Well, I think they had direct influence on
2 all that, that they were allies of the Bosnian Serbs.
3 JUDGE RIAD: So the soldiers were speaking
4 about Belgrade as if they come from there or what?
5 A. In a different sense, I think, that they --
6 that they were informed about the media.
7 JUDGE RIAD: Now, the last question: When
8 you said that the soldiers were taking people behind
9 the tank and they disappeared after that, whom did --
10 was there any kind of preference or priorities? Whom
11 did they take? Would they take -- did they choose just
12 something like guessing or taking people, a certain
13 kind of people? For instance, people who prove to be
14 military or that sort of thing or young. Was there any
15 indication whom they were looking for?
16 A. They took people at random as they pleased.
17 I know that this young man in a T-shirt was taken away
18 probably because they thought he was a soldier.
19 JUDGE RIAD: And they took other people who
20 were not soldiers, who could not be soldiers?
21 A. Yes. They couldn't be soldiers.
22 JUDGE RIAD: You mean old or children or boys
23 or what?
24 A. Also elderly people and young people. People
25 who were dressed in civilian clothes who were not
1 soldiers and whom I knew.
2 JUDGE RIAD: Thank you, Mr. Husic. Thank
3 you. I hope your father will come back. Thank you.
4 A. Thank you.
5 JUDGE RODRIGUES: [Interpretation] Thank you,
6 Judge Riad.
7 Judge Wald.
8 JUDGE WALD: Mr. Husic, when you started out
9 from Srebrenica with the -- or near Srebrenica with the
10 column of men that were going to go through the woods,
11 did you know the reason why it had been decided that
12 the men who would go through the woods on their own to
13 try to reach Tuzla, and the women and children would be
14 helped to get along to the UN Compound in Potocari?
15 I mean what -- did anybody say out loud what
16 was the basis for that decision since everybody,
17 obviously, wanted to get out and get into the free
19 Do you know why it was decided to have a
20 column of men go through the woods and have the women
21 and children go ahead and the elderly go ahead to the
22 UN Compound?
23 A. I don't know why a decision like that had
24 been reached. I simply followed those men together
25 with my brother and my father. And the main objective
1 of our breakthrough through the woods was to save
2 ourselves because it was believed that the women and
3 children would not be harmed in Potocari. And we knew
4 that they would be transported to Tuzla.
5 JUDGE WALD: But there was, I gather, from
6 your answer, a fear that if the men went with the women
7 and the children up to Potocari, that harm would befall
8 them as opposed to the women and children; is that
10 A. Yes. Yes.
11 JUDGE WALD: When Judge Riad asked you about
12 how you knew that many of the people you talked about
13 or identified did not survive, could you tell us
14 approximately or about how many people you saw the
15 soldiers pull out of the crowd or the column, take away
16 behind the cornfields or in the cornfields behind the
17 tank, you saw something actually done to them to the
18 extent they were taken away, as opposed to people that
19 you just have no idea what happened to them, they just
21 A. You mean from the meadow, concerning the
22 people who were taken away?
23 JUDGE WALD: Yes.
24 A. I don't know what happened to them after I
25 left the meadow. I don't know what was their fate.
1 JUDGE WALD: My question would be how many
2 people did you actually see Serb soldiers take out of
3 the meadow or take out of the column that was going
4 along, take them away and then you never saw them
6 A. Several of them would take them away. One of
7 the men was taken away by two people, two men.
8 JUDGE WALD: Well, let me just ask you one
9 final question about that.
10 Would you say that you saw that happen, you
11 saw a Muslim man taken either out of the meadow or away
12 from the column by soldiers, singled out and taken
13 away? Would you say six, twelve, I don't know, how
14 many, about?
15 A. No, I saw between four and six of such cases
16 that I saw personally.
17 JUDGE WALD: And the rest of the people that
18 you say did not survive, it means that they were either
19 in the meadow or in the column and then they were just
20 never seen again, that you know about. Right?
21 A. Yes.
22 JUDGE WALD: Okay. Thank you.
23 JUDGE RODRIGUES: [Interpretation] Thank you
24 very much, Judge Wald.
25 Mr. Husic, I have two questions for you.
1 While you were still in the woods, at one point in time
2 you heard soldiers speaking about a surrender, that you
3 should surrender because the UNPROFOR soldiers would
4 protect you; is that correct?
5 A. Yes.
6 JUDGE RODRIGUES: [Interpretation] So before
7 you surrendered, did you have an opportunity to see the
8 soldiers or at least the individuals whom you believed
9 to be UN soldiers?
10 A. Yes. They were walking up and down the road.
11 JUDGE RODRIGUES: [Interpretation] So could
12 you then tell us what tilted the balance in favour of
13 the decision to surrender, because you were
14 insisting -- the fact that you saw them, did you insist
15 because of that?
16 A. Well, if we hadn't seen the UN soldiers and
17 the UN personnel carrier, we probably wouldn't
18 surrender. But there was some hope because of the
19 presence of UNPROFOR, and we thought that they would
20 not dare kill us all in their presence.
21 JUDGE RODRIGUES: [Interpretation] What was
22 your reaction when you finally realised that they were
23 not UNPROFOR soldiers?
24 A. Well, I knew what was in store for us. I
25 realised that we had been lured down to the asphalt
2 JUDGE RODRIGUES: [Interpretation] Thank you,
4 My second question is the following: A
5 soldier told you at one point that Alija was not there
6 to protect you but that you will wait and that you will
7 see Ratko Mladic, who would arrive to the meadow.
8 What was your reaction to those words? Did
9 you believe that Ratko Mladic would come or not?
10 A. We believed.
11 JUDGE RODRIGUES: [Interpretation] Why? Why
12 did you believe that?
13 A. Because whatever they said, they did.
14 JUDGE RODRIGUES: [Interpretation] But when
15 were the threats made?
16 A. At the moment we came down to the meadow, a
17 Serb soldier at one point said, "Wait until General
18 Mladic comes here."
19 JUDGE RODRIGUES: [Interpretation] Did you see
20 Ratko Mladic?
21 A. No, I didn't.
22 JUDGE RODRIGUES: [Interpretation] Do you
23 remember what language the soldiers spoke?
24 A. You mean -- yeah, they were speaking
1 JUDGE RODRIGUES: [Interpretation] But was
2 there a distant accent by which you could tell where
3 they were from?
4 A. No.
5 JUDGE RODRIGUES: [Interpretation] Thank you,
6 very much, Witness. I don't have any other questions.
7 We are aware of the fact that you have lived
8 through some terrible events. You have answered
9 questions that were put to you by the Prosecutor, by
10 the Defence, and by the Judges.
11 Is there anything else, Witness, that you
12 wish to say? Is there anything that have you not had
13 opportunity to say so far?
14 A. I believe I have said everything that I had
15 to say.
16 JUDGE RODRIGUES: [Interpretation] Thank you.
17 Thank you, very much. I believe that there are some
18 exhibits to be taken care of. Witness, could you
19 please stay here a while.
20 Mr. Harmon.
21 MR. HARMON: Mr. President, there are a
22 number of exhibits. There are three film clips which
23 are Prosecutor's Exhibit 101, 102, and 103 and
24 companion transcripts, 101, 102, and 103A.
25 Then there is Prosecutor's Exhibit 104 which
1 is a still photograph taken from the Prosecutor's
2 Exhibit 103 showing the witness, himself.
3 There is Prosecutor's Exhibits 105, 106, and
4 107, a series of still images showing Bosnian Serb
5 soldiers in stolen Dutch UN flak jackets.
6 Prosecutor's Exhibits 108, 109, 110, 111,
7 pictures of people who surrendered alive to the Bosnian
8 Serb army and who have not been heard of since, and who
9 are known to this witness by name.
10 We would move into evidence each of those
11 exhibits, Mr. President.
12 JUDGE RODRIGUES: [Interpretation]
13 Mr. Visnjic, any objections.
14 MR. VISNJIC: [Interpretation] No, Your
16 JUDGE RODRIGUES: [Interpretation] Very well
17 then. Mr. Dubuisson, the exhibits mentioned by the
18 Prosecutor, will be admitted into evidence. Will you
19 please take note of that. Thank you.
20 Mr. Husic, you're still a very young man and
21 you will probably live a very long life. We would like
22 to congratulate you that you have survived, and I
23 know -- hope that you are aware of the importance of
24 the role that you have to tell the story that you have
25 been through. All these events should be condemned.
1 They cannot be tolerated by humanity.
2 We would just like to thank you once again
3 for coming here to testify and wish you a safe journey
4 home. The usher will show you out of the courtroom.
5 Thank you, very much.
6 A. Thank you, Your Honour.
7 [The witness withdrew]
8 JUDGE RODRIGUES: [Interpretation] I see
9 that -- I hope you have another witness, Mr. Harmon.
10 MR. HARMON: Yes, we have another witness,
11 Mr. President, a protected witness. Mr. McCloskey will
12 lead the evidence with the next witness.
13 JUDGE RODRIGUES: [Interpretation] We have
14 worked for 40 minutes. Perhaps we should begin with
15 that testimony and then after that, we will have a
16 longer break so as to manage the time available to us
17 in the best possible manner.
18 Can we have the witness brought in, please?
19 I should like us first to specify the
20 protective measures that are requested.
21 MR. HARMON: The witness will require a
22 pseudonym and face distortion, so the courtroom will
23 have to be prepared for the witness to arrive.
24 JUDGE RODRIGUES: [Interpretation] In that
25 case, Mr. Petrusic.
1 MR. PETRUSIC: [Interpretation] Yes, we are
2 aware of the proposal of the prosecution and we have no
4 JUDGE RODRIGUES: [Interpretation] In that
5 case, it would perhaps be better to have a 20-minute
6 break and when we resume, the Judges will already have
7 the witness in the courtroom. So a 20-minute break,
9 --- Recess taken at 12.33 p.m.
10 --- On resuming at 12.54 p.m.
11 [The witness entered court]
12 JUDGE RODRIGUES: [Interpretation] Good
13 afternoon, Witness L. Do you hear me?
14 THE WITNESS: [Interpretation] I do.
15 JUDGE RODRIGUES: [Interpretation] You're
16 going to read the solemn declaration that the usher
17 will give you, please.
18 THE WITNESS: [Interpretation] I solemnly
19 declare that I will speak the truth, the whole truth,
20 and nothing but the truth.
21 WITNESS: WITNESS L
22 [Witness answered through interpreter]
23 JUDGE RODRIGUES: [Interpretation] Please be
24 seated. The registrar is going to show you a piece of
25 paper with your name written on it. Please tell us
1 only whether that is your name by saying yes or no.
2 THE WITNESS: [Interpretation] Yes.
3 JUDGE RODRIGUES: [Interpretation] Therefore,
4 that is, indeed, your name. Is that your name,
5 Witness L?
6 THE WITNESS: [Interpretation] Yes.
7 JUDGE RODRIGUES: [Interpretation] Now you
8 will be answering questions put to you by
9 Mr. McCloskey, the Prosecutor, who is standing to your
11 Mr. McCloskey, I give you the floor, please.
12 MR. McCLOSKEY: Thank you, Mr. President.
13 Before I get to the witness, one small piece
14 of business from yesterday. We apparently discovered
15 some French translations of yesterday's protective
16 witness' medical records, which I offer as evidence
17 under seal, Exhibit 118A and 117B, which I believe have
18 been provided to the Registry.
19 JUDGE RODRIGUES: [Interpretation]
20 Mr. Dubuisson, do you have the exhibits?
21 THE REGISTRAR: [Interpretation] Yes, I do.
22 I'm going to distribute them to the parties.
23 JUDGE RODRIGUES: [Interpretation] Very well.
24 Thank you.
25 Are you in a position to start,
1 Mr. McCloskey?
2 MR. McCLOSKEY: Yes, we are. Mr. President,
3 is there a particular time you think you might want to
4 break so that I can try to anticipate that, or do you
5 want to just see how it goes?
6 JUDGE RODRIGUES: [Interpretation] Yes. A
7 very good question, and thank you. Perhaps halfway
8 along we'll have a 15-minute break. We've already, I
9 think, have three breaks today, so we'll have a
10 fourth. Today is going to be an exception. We'll make
11 a break about halfway along of about 15 minutes, so you
12 can control your time. Thank you.
13 Examined by Mr. McCloskey:
14 Q. Witness L, none of that involved you, but
15 it's now time to ask you some questions, to have your
17 First of all, can you tell us where you're
19 A. I'm from the municipality of Zvornik, the
20 village of [redacted].
21 Q. What's your birth date?
22 A. I was born on the [redacted].
23 Q. Are you a Muslim by faith?
24 A. I am.
25 Q. Prior to the war breaking out, you were
1 living in the Zvornik area.
2 A. Yes.
3 Q. Where were you working?
4 A. I was working in Belgrade.
5 Q. What was the name of the company?
6 A. Ratko Mitrovic ^.
7 Q. How long had you worked for that company
8 prior to the breaking out of the war?
9 A. I worked there for 18 years and several
11 Q. What kind of work was that?
12 A. I was a construction worker. I was a skilled
13 worker for reinforced concrete.
14 Q. After the war started, when did you move to
16 A. I moved to Srebrenica on the 14th of March,
18 Q. Where were you living on July 11th, 1995?
19 A. On the 11th of July, 1995, I was living in
21 Q. Who were you living with?
22 A. I was living with two brothers.
23 Q. What was your occupation? How did you keep
24 yourself alive?
25 A. We lived off the land, we farmed the land,
1 and we also received some humanitarian aid.
2 Q. Were any of the three brothers in your family
3 in the military?
4 A. Yes, one of my brothers, but he was a cook.
5 Q. What did the three brothers decide to do on
6 July 11th when the town was falling to the Bosnian Serb
8 A. One of my brothers was disabled. He was not
9 disabled during the war; he had a bad leg. He went to
10 Potocari, surrendered to UNPROFOR. And the other
11 brother headed, together with me, into the woods.
12 Q. Did any of your brothers make it?
13 A. Yes. This one who was disabled, he was
14 allowed to cross into our territory.
15 Q. How about your other brother, the brother
16 that was a cook in the army?
17 A. The other brother was with me. He was
18 captured together with me, and I don't know anything as
19 to what happened to him.
20 Q. What did you decide to do on July 11th?
21 A. On July the 11th, when Srebrenica fell, we
22 decided to travel towards the free territory of Tuzla,
23 through the woods.
24 Q. So where did you first go?
25 A. We first went to a rally in the village of
1 Susnjari, municipality of Srebrenica.
2 Q. Do you have any knowledge about the
3 decision-making process that the men took to decide to
4 rally there around Susnjari?
5 A. I don't know, because the commanders must
6 have known. I'm not familiar with that.
7 Q. When you got to Susnjari, about what time did
8 you get there?
9 A. We got there in the evening, perhaps it was
10 around 10.00.
11 Q. So that evening of July 11th, when you got to
12 this area --
13 A. Yes, yes, yes, yes.
14 Q. -- are you able to give any kind of an
15 estimate of how many people were gathered in that area?
16 A. According to an estimate, there were between
17 10.000 and 15.000 people.
18 Q. Is that an estimate someone's told you, or is
19 that your personal estimate from actually looking at
20 the crowd?
21 A. No, it was our personal estimate.
22 Q. When you say "our", who do you mean?
23 A. I mean myself, I mean mine.
24 Q. Were there any women or children in that
25 crowd, or was it mostly men?
1 A. There were only men, as far as I could see.
2 Q. Could you tell how many men were armed with
4 A. There were some with weapons but I don't know
5 the number. Maybe 200, 300. I don't know exactly.
6 Q. These are the ones that were within your area
7 of vision; is that right?
8 A. Yes.
9 Q. So there could have been many more than 200.
10 A. I don't know. I couldn't even see them all.
11 Q. Did you hear any commanders make any
12 decisions or announce anything to the group while you
13 were there in Susnjari?
14 A. No, I didn't hear anything.
15 Q. What happened after you got there?
16 A. What happened was that when we arrived, that
17 evening columns were formed, I heard from this other
18 men, that they started leaving around midnight. My
19 column left in the afternoon.
20 Q. Do you know roughly how many people were in
21 that first column or group of men that left at
23 A. I don't know because the column went
25 Q. So you didn't leave the Susnjari area until
1 the afternoon of the following day. That would be July
3 A. Yes. It was a Wednesday.
4 Q. Do you know roughly how many people were in
5 your group?
6 A. I don't know because as one group left,
7 another went after it. So it would be difficult to
8 tell how many men were in each group.
9 Q. Do you know why the men decided to go through
10 the woods the way they did?
11 A. Because we didn't dare go to Potocari,
12 because we saw the situation, that they had threatened
13 us that if Srebrenica fell, that they would settle
14 accounts with the able-bodied men, and that is, anyway,
15 what they did.
16 Q. When you finally got started in your group,
17 on the 12th, can you describe the journey through the
18 woods until you surrendered?
19 A. When we started from Susnjari, we were going
20 for about 300 metres and then we entered the woods
21 called Buljim. Shortly after that the column stopped.
22 When we stopped, men asked that the few remaining
23 people with weapons should go in front. And those
24 people who were going in front of me saw some dead
25 bodies and they became afraid.
1 Then those under arms went off and we didn't
2 see them again. I don't know whether they abandoned us
3 or what; we don't know. We continued for along as we
4 could see, while the daylight lasted. And then when
5 darkness fell, I spent the night under an oak tree, and
6 then the next day I found a group of people, among whom
7 was my brother.
8 Then shortly after that, Serb soldiers
9 started calling out over the loudspeakers for us to
10 surrender. As we didn't have any loudspeakers, our men
11 would tell them aloud that we would surrender if
12 UNPROFOR or the Red Cross were there. They didn't
13 respond. They gave us an ultimatum, a deadline, until
14 10.00; then they postponed it to 1500 hours.
15 As we thought that the situation was
16 hopeless, the men decided to surrender. As we were
17 coming down, Serb soldiers came onto the road. They
18 were all in uniform, camouflage uniform, and first they
19 asked us to give them any money we had, German marks or
20 dollars or any other foreign currency. Those who had
21 anything gave it up; those who didn't, they didn't.
22 Then they threatened, "If we find money on someone who
23 didn't surrender it," they would suffer the same fate
24 as those before them.
25 Then women and children were passing by the
1 road, as we were standing by the road. And then they
2 ordered us to raise our hands up.
3 After a while, they gave us orders to run for
4 some 50 metres and then go uphill, where we found a
5 large group of people sitting there. So they ordered
6 us to sit down and form lines and rows, and once we
7 did, a Serb soldier, with a scarf on his head -- he was
8 somewhere between 20 and 22 -- he told me that the
9 governments were negotiating an exchange on the
10 principle "all for all".
11 When all of the people had gathered there --
12 according to my estimate, it was about 2.000 to 2.500
13 people -- then this Serb soldier again told us, and on
14 his sleeve it said "The army of Republika Srpska."
15 When those soldiers were changing shifts --
16 Q. I'm sorry to interrupt you. Let me take you
17 back and ask you a couple of clarifying questions, if I
18 can. How many people in your group decided to finally
20 A. I don't know the numbers, but it was a very
21 large column. It was about 200 metres long, and it
22 went two by two in most cases.
23 Q. When you first came to the area where you
24 were able to see Serb soldiers, can you give us any
25 kind of an estimate of how many Serb soldiers you were
1 able to see when you turned yourself in?
2 A. According to an estimate, there were at least
3 50 Serb soldiers. There was a personnel carrier that
4 was parked there, and there were some artillery weapons
5 too, but we didn't dare look at them because we didn't
6 have time. We were running to the place where we had
7 to sit.
8 Q. You said the first group of Serb soldiers was
9 about 50. Do you know what kind of outfits they were
11 A. Camouflage uniforms, as worn by the army of
12 the Republika Srpska.
13 Q. You said this group tried to take your
14 money. What about personal belongings?
15 A. Yes.
16 Q. What about personal belongings that people
17 had with them?
18 A. They seized our personal belongings as well,
19 and if anyone had a hat on his head, they took that off
21 Q. Do you know roughly where this area was that
22 you were finally placed, among of rows of people, near
23 the asphalt road?
24 A. This was between Sandici and Kravica,
25 according to my judgement, because I was coming from
1 the other side. But I think it was somewhere between
2 Sandici and Kravica.
3 Q. What happened once you got there and were put
4 among those rows of other Muslim men?
5 A. When we got there, we had to form rows, and
6 then there was a change of shift and they told us some
7 other troops had arrived also wearing camouflage
8 uniforms. Then they said, "These are Arkan's men." I
9 didn't notice any badges on them or not with the words
10 "Arkanovci" on it because we didn't dare look. There
11 were two soldiers to each row.
12 Then one of those soldiers who was on the
13 personnel carrier said, "Don't let me kill you all, and
14 then I could go to The Hague." He knew what "The
15 Hague" meant even then. He was a young man of 25, not
17 Then when those soldiers came, they said that
18 they were Arkanovci. They forced us to lie down on our
19 stomachs and then shout, "Long live the King," and we
20 did. Then again they told us to sit up. When we sat
21 up normally, then it was about an hour or an hour and a
22 half before nightfall. I didn't have a watch.
23 Then the gentleman, General Mladic, arrived.
24 Q. Excuse me for interrupting you, but the
25 interpreters have to interpret everything you're saying
1 in English and French and you're going a little
2 quickly. So if you could try and slow down and give
3 some breaks so I might be able to ask some questions in
5 A. Yes. Yes, I'll do that.
6 Q. So this second group of soldiers that
7 arrived, the second shift as you've called it --
8 A. Yes, yes.
9 Q. -- how many was in that second shift?
10 A. I don't know the number, but I think, again,
11 there were at least 50, because there were two soldiers
12 to each row and there were more than 20 rows, maybe
13 25. That's why my estimate was about 50.
14 Q. Were those soldiers armed?
15 A. Yes, with automatic rifles.
16 Q. About the time that you said Mladic arrived,
17 do you have an estimate of how many Muslim men were
18 sitting in this area where you were?
19 A. At least 2.000, maybe as many as 2.500.
20 Q. What time did Mladic arrive?
21 A. I didn't have a watch, but it was an hour and
22 a half prior to nightfall, I think.
23 Q. And that time in Bosnia would be roughly what
25 A. It would be about 7.30 because it was
2 Q. How were you able to recognise Mladic?
3 A. I hadn't known Mladic from before, but people
4 who watched television knew him, and I recognised
5 Mladic when I reached free territory.
6 Q. What happened when Mladic got there?
7 A. When Mladic came, he said, "Good evening,
8 neighbours." We replied, "Good evening." And then he
9 said, "The governments are negotiating, and tomorrow
10 you will all be exchanged for all." We will go to
11 hangars. We won't have any supper, but we will have
12 water ^.
13 Q. I'll just ask you to slow down a little bit
14 if you could. Anything else that you remember him
16 A. He said that we would be exchanged the next
17 day, all for all, and he said that we would be given
18 water, that we would go to some hangars. But he didn't
19 say that we would be given any supper, though the
20 previous -- his predecessor said we would be given
22 We thanked him and we applauded him when he
23 promised that he would exchange us the next day.
24 Q. Okay. Can you tell us how long you --
25 between the time that Mladic had spoke to you and the
1 time that you first arrived at the meadow, how long had
2 that been? What period of time did you spend on that
4 A. Five or ten minutes, perhaps.
5 Q. How long were you at that meadow for the
6 whole day?
7 A. We were there for about three or four hours.
8 Q. Did you notice any of the Muslim men being
9 abused in any way during those three or four hours?
10 A. No. No one was abused.
11 Q. Did you see anyone transported, any of the
12 Muslim men transported away in any direction by any
13 vehicles or marched away by foot?
14 A. No, they let a woman go and a child, and two
15 young girls, and they let go eight to ten boys between
16 12 and 14. These were released by one of the Serb
18 Q. Did you hear any announcement about young men
19 or how did you know that they picked out boys 12 to 14?
20 A. They didn't make any announcements, but the
21 boys of that age would get up.
22 A rather large boy that got up, they told him
23 to sit down because he was big enough to carry a
25 Q. Do you have any idea what happened to those
1 young boys that they picked out of the crowd?
2 A. Those children were immediately sent by
3 vehicle and they were released. The vehicle went to
4 free territory to Tuzla.
5 Q. How do you know they were released?
6 A. Because I came across that boy and I asked
7 him and he said yes.
8 Q. So after all this, you ran across one of the
9 boys you saw released in the field in the free
11 A. No, I hadn't seen him, but I spoke to people
12 I had known, and I met him while I was living in
14 Q. Okay. And what happened after Mladic's
15 little speech was over?
16 A. When Mladic finished, he left after some 10
17 or 15 minutes. The vehicles that had taken the women
18 and children to free territory returned.
19 Then we were ordered for the first row to get
20 up and to board the vehicle. Then the first row got
21 up, then the second row, and row by row, I don't
22 remember which row I was in, my turn came. I boarded a
23 trailer of a truck. Then I saw a Serb soldier with a
24 cockade entering and saying that he would board the
25 truck with the driver. He didn't mistreat us, he
1 didn't sit with us. And they drove us --
2 Q. I'm sorry, you said you saw a Serb soldier
3 with a something, I didn't quite understand what it was
4 that you saw this Serb soldier have.
5 A. Cockade, it's a Chetnik badge on a hat that
6 used to be worn by Chetniks.
7 Q. Did this person have a weapon?
8 A. I cannot recollect whether he had a weapon
9 inside the vehicle or not.
10 Q. And the vehicle that you got into, can you
11 describe what kind of vehicle that was?
12 A. It was a truck with a trailer, and I was in
13 the trailer. You know what a truck is and a trailer.
14 Q. Can you tell me what normally is carried in
15 the trailer that you and other men were in?
16 A. One usually transports coal because the sides
17 were rather high, the kind used for coal or
18 agricultural produce that is light so to avoid it
19 spilling over.
20 Q. Can you describe the size of this trailer and
21 the height of the sides?
22 A. The trailer was at least 10 metres long and
23 the sides may have been 1.20 metres, 1.40 metres.
24 Q. About how wide was it?
25 A. Probably two and a half to three metres, I
1 don't know exactly. But that would be my estimate that
2 is how wide it should be.
3 Q. And do you know roughly how many men were put
4 in the back of this trailer?
5 A. I don't know. Between 25 and 30 at least
6 could fit, but I don't remember. I didn't count.
7 Q. Were the men standing or sitting or a
8 combination of both?
9 A. They were sitting. All of them were sitting.
10 Q. So while you were sitting in there, the
11 height of the sides of the trailer must have been well
12 over your heads so it would be difficult to see out; is
13 that right?
14 A. Yes.
15 Q. And could you tell before you actually sat in
16 the trailer how many other vehicles were on either side
17 of the trailer you got into?
18 A. I don't know. There were some vehicles, but
19 how many, I don't know.
20 Q. Do you have any way to give us any kind of an
21 estimate? More than three?
22 A. More, of course. There may have been 10 or
23 15 vehicles.
24 Q. And what kind of vehicles were they?
25 A. There were trucks, trailers, buses, trucks
1 with trailers, because they were driving women and
2 children in all kinds of vehicles.
3 Q. That day while you were in that meadow lined
4 up with the men, did you see vehicles go by you on the
5 asphalt road?
6 A. We only saw those vehicles taking the women
7 and children. There were no other vehicles on the road
8 at the time.
9 Q. And what direction were the women and
10 children being taken into in vehicles when you were
11 sitting on the meadow?
12 A. They were driving them in the direction of
13 Kladanj towards the free territory of the Tuzla region.
14 Q. And when you were put in the back of this
15 trailer, how long were you in the back of the trailer
16 until the truck moved off?
17 A. It moved off soon after that.
18 Q. And which direction did it go in?
19 A. In the direction of Bratunac.
20 Q. And where did it go?
21 A. We were taken to Bratunac and once we got
22 there, they took us to a man who was a driver, and he
23 said that the buses belonged to the Vihor Transport
24 Company and that the garages that were there were also
25 part of the Vihor Company. But I didn't know the man,
1 I just realised he was a driver.
2 Q. Was this the man that was in the back of the
3 trailer with you or someone else?
4 A. He was in the back of the trailer with me, he
5 was in the same trailer.
6 Q. When you got into the town of Bratunac, how
7 did you know you were in the town if you were down low
8 in the bed of this trailer?
9 A. Well, we could see on our left-hand side,
10 because the buildings were three to four floors high.
11 And on the right side, there seemed to have been no
12 buildings at all.
13 Q. And do you know roughly what time of day or
14 evening it was when you arrived in Bratunac?
15 A. It was in the evening at about half past
16 nine. It was already dark.
17 Q. And as you were sitting in the back of this
18 trailer, could you tell how many other vehicles were
19 around your vehicle?
20 A. The vehicles were parked, one after the
21 other. According to my estimate, I know that there
22 were many of them both ahead and behind, and I know
23 that Serb soldiers were looking for men who were on
24 those buses.
25 Q. How do you know Serb soldiers were looking
1 for the men on the buses both in front of you and
2 behind you? Could you hear it or could you see it?
3 A. We could hear them. We could hear them ask
4 about the vehicle, because we didn't know that, we just
5 realised that when they came to our vehicle. First
6 they asked about a village of Pusmulici, near
8 Q. Now, who were they asking about this
9 village? Were these people in your vehicle or one of
10 the other vehicles?
11 A. In one of the other vehicles that were near
13 Q. You were just able to hear this from where
14 you were sitting.
15 A. Yes. Yes, I could hear them. They were
16 talking in loud voices.
17 Q. Why didn't you stand up and look out?
18 A. Well, I didn't dare do it. There were Serb
19 soldiers standing guard around the vehicles. Somebody,
20 I remembered, stuck up his hand and was hit on his hand
21 by a rifle butt by someone.
22 Q. From the sound of the people outside the
23 vehicles, could you get a rough idea of the number of
24 Serb soldiers outside the vehicles?
25 A. No, we couldn't tell the number of those
1 soldiers. We couldn't see them. One of them peeped
2 across the side of the trailer and we could see him.
3 But we couldn't tell how many of them there were around
4 the trucks.
5 Q. Let me go back to what you were telling us
6 earlier. You heard Serb soldiers asking at one of your
7 neighbouring trucks if there was anyone from a
8 particular village. Can you tell us about that?
9 A. Well, they said, "If so and so appears," they
10 would ask for the man's name, surname, and father's
11 name, and then they would take the man to a garage, on
12 which the door was open. At that moment we would hear
13 thuds and people screaming. The man would start to
14 scream, to cry, and then they would shout at him, they
15 would yell at him, and then we could hear fire from an
16 automatic weapon, and then everything would go quiet.
17 This went on throughout the night.
18 Q. Again, I know this is very difficult to
19 estimate, but can you give us any idea of how many
20 different Muslim men you heard that were put in a
21 situation where they were taken out to this area nearby
22 you and where you could hear these sounds?
23 A. We were some 30 metres away from the garage
24 and we were able to observe more during the night. But
25 I couldn't tell you the number because they kept taking
1 people away all night. They also hit people near the
2 trucks with their rifle butts, so we could see that as
3 they were taking them, going past our truck.
4 Q. How was it that you were able to see more
5 during the night?
6 A. Well, it was because, for example, those who
7 were in the middle could raise, a bit, their heads,
8 they could observe things, but those who were next to
9 the sides of the trailer couldn't.
10 Q. Were you able to raise your head at all and
11 look out?
12 A. No, I couldn't. I just had a quick look. I
13 would stick out my head like this [indicates] because
14 the area in the front was a little elevated, and that's
15 how I was able to see what was happening. But I didn't
16 dare to stand up completely.
17 Q. Did any soldiers come to your truck that
18 evening, that night?
19 A. Yes, on two occasions. First, when a soldier
20 came, he asked for a man and a man replied. He was
21 from the municipality of Srebrenica; he was not from
22 the village they were asking about, so they told him to
23 sit down.
24 Then two other men were taken off our
25 trailer, most probably because they had been
1 recognised. One of them was between 30 and 35 years of
2 age; the other one was a bit younger. Most probably he
3 was immediately recognised, because they asked him
4 about his name -- I don't know whether his name was
5 Omer or whether it was his father's name -- but he was
6 taken on the following morning, and we haven't heard
7 anything about what happened to him.
8 Q. Your brother wasn't in the back of the
9 vehicle with you.
10 A. No, he wasn't there at all.
11 Q. Where did you lose track of your brother?
12 A. At the spot where we had gathered while we
13 were sitting on the meadow, and I haven't heard of him
14 ever since.
15 Q. Did you know any of the men that were in the
16 back of the trailer with you, that spent the night in
18 A. I knew only one of them by name. He was also
19 from the Srebrenica municipality. There was nobody
20 from my area, actually.
21 Q. Can you tell us his name?
22 A. Yes, I know his name. He was Mehmed, Mehmed
24 Q. When the morning came, what happened?
25 A. When it dawned, we heard them yelling and
1 shouting, saying, "Now you take them to Alija and
2 exchange them."
3 Q. What else happened?
4 A. At that point the trucks started to move, and
5 they were stopped in the outskirts of Bratunac.
6 Q. I'm going to take you briefly back to the
7 meadow. Did they give you any food while you were in
8 that meadow on July 13th?
9 A. No, they didn't give us any food. They only
10 brought water, but it was our people who actually went
11 to get water. But we were not given any food at all.
12 Q. When you were put in the back of this coal
13 truck, were you given any water back there?
14 A. Yes. On the following day, the driver who
15 was driving us gave us something, and also a young boy
16 from Bratunac.
17 Q. Had you been given any food before they gave
18 you water in Bratunac?
19 A. No. No.
20 Q. Was the date you surrendered on the meadow
21 July 13th, or do you know the dates?
22 A. The 12th. I think -- the 11th, the 12th.
23 Yes, it was on the 13th, that was the date. It was a
25 Q. What happened when you were stopped outside
1 Bratunac? They brought you some water. What else
3 A. They told us that they were waiting for
4 UNPROFOR. So we waited for at least two hours there,
5 on that spot, and a group of Serbian elderly men passed
6 by. Some of them were wearing uniforms; some didn't.
7 They saw some people and they said, "Well, these guys
8 are ours." They probably wanted to take it out on us.
9 Q. How were you able to see these elderly men?
10 A. Well, they were standing on a truck, which
11 was an open kind of truck. It was a FAP truck. It
12 used to be a Yugoslav-produced car.
13 Q. What finally happened?
14 A. Well, finally after that, after we had been
15 there for about two hours, the column continued in the
16 direction of Konjevic Polje, Drinjaca, and Zvornik, and
17 further on in the direction of Tuzla.
18 Q. Did your vehicle turn off as it was driving
19 on the road towards Tuzla?
20 A. When we got to Zvornik -- let me stop a
21 little. After we had left Divic, after we had come out
22 of a tunnel, we were told that an UNPROFOR personnel
23 carrier had joined us. It was near the village of
25 Q. Divic is just south of Zvornik.
1 A. Yes. Yes, in the outskirts of Zvornik, maybe
2 some 800 metres away from the town.
3 Q. Who told you this?
4 A. The soldiers who saw it. At that moment I
5 didn't see the APC.
6 Q. Were there any soldiers in the back of the
7 vehicle with you at any time during this trek from the
8 meadow up, now, to Divic?
9 A. No, there were no soldiers.
10 Q. So where were these soldiers that actually
11 talked to you and told you about the APC?
12 A. Not the soldiers but people who were with
13 us. People talked amongst themselves.
14 Q. So somebody saw an APC and you were talking
15 amongst yourselves.
16 A. Yes.
17 Q. When you went on the road towards Tuzla, can
18 you tell us where you went?
19 A. When we went towards Tuzla, we drove for a
20 short while, and then at one point the truck turned
21 right. I was a little bit familiar with the area, I
22 knew it somewhat better, and I realised that it was
23 moving in the direction of the village of Grbovci. The
24 vehicles were travelling at a very slow place. One by
25 one they reached a schoolyard.
1 Q. Prior to getting to the schoolyard, did you
2 ever take a look out of the back of this truck to tell
3 how many vehicles were travelling along with you, if
5 A. Yes. When we left Bratunac, we reached a
6 location which is called Avdagina Njive. We climbed a
7 hill, and then when we were on top of the hill, we
8 could actually see how long the column of the vehicles
10 Q. Were you able to make out how many vehicles
11 were there or how long the column was?
12 A. The column was a longish one, but I cannot
13 tell you exactly how many vehicles there were.
14 Q. Can you give us a rough estimate or a rough
15 estimate of how many --
16 A. Well, I cannot tell you how long it was, but
17 there were at least 30 vehicles, large vehicles. At
18 least 30 of them.
19 Q. What sort of vehicles?
20 A. There were trucks, trailer trucks, buses.
21 Most of them were really large vehicles. The idea was
22 to transport as many people as possible.
23 MR. McCLOSKEY: Mr. President, we're at the
24 school. It may be a good time to take a break.
25 JUDGE RODRIGUES: [Interpretation] Yes, this
1 is really a convenient time.
2 We will have a 15-minute break.
3 --- Recess taken at 1.43 p.m.
4 --- On resuming at 2.00 p.m.
5 JUDGE RODRIGUES: [Interpretation] We will
6 resume with our hearing.
7 Mr. McCloskey, you may go on.
8 MR. McCLOSKEY: Thank you, Mr. President.
9 Q. Witness L, your vehicle had just arrived at a
10 schoolyard in a place you were familiar with, you
11 called it Grbovci. What happened when your vehicle
12 came to a stop at the schoolyard?
13 A. When we reached the schoolyard, I noticed the
14 UN APC. The letter that was written on it was either
15 "C" or "S". It was something else instead of
16 UNPROFOR. There was only one sign on the APC and there
17 were two soldiers wearing UNPROFOR uniforms.
18 There was also a civilian of 50 to 55 years
19 of age who was walking around with them like an
20 interpreter. These soldiers didn't address us. They
21 were carrying automatic rifles in their hands.
22 So we entered the compound, the yard, and
23 some 30 Serb soldiers were standing there and they
24 ordered us off the trucks. They told us to raise our
25 hands up and to run towards the entrance of the
2 When we were outside the entrance, I was
3 ordered by one of their soldiers to take off my leather
4 jacket. There was a large pile of clothes there. So
5 when I got to the hall, I realised that more than half
6 of the people had already been there.
7 Some elderly people were also there who had
8 been brought from Potocari. There were people as old
9 as 70 years of age, maybe more.
10 At that point, we were ordered to sit down.
11 We were crowded; we were pressed against each other.
12 After everybody had got in, we realised that there were
13 four boys there and they were separated and taken to a
14 corner of the hall.
15 The Serb soldiers who were there --
16 Q. Let me interrupt you a second.
17 A. Yes, please.
18 Q. Do you know about what time your vehicle
19 reached the schoolyard?
20 A. It was in the early hours of the afternoon.
21 I didn't have a watch, but it could have been around
22 1.00, in view of the time when we left Bratunac.
23 Q. These soldiers that were outside the school,
24 you said there were about 30 of them, what were they
1 A. Yes. They were wearing camouflage uniforms
2 as well. There may have been Serb policemen amongst
3 them here and there, because Serb policemen had grey
4 camouflage uniforms.
5 Q. You said when you -- what part of the
6 building did you go into when you got into the school
8 A. I sat down in the part of the building which
9 was to the left side of one of the entrances.
10 Q. What sort of room was this?
11 A. It was a gymnasium.
12 Q. You say when you arrived it was half full.
13 Could you give us a rough estimate of how many people
14 "half full" was?
15 A. Well, it was full. At least 700 or 800
16 people must have been there.
17 Q. When you first got into the gym, did you see
18 any Serb soldiers inside of the gym? No?
19 A. No, they were not there. They were only
20 standing at the entrance.
21 MR. McCLOSKEY: Could we show the witness --
22 we have four exhibits, 19/3, 19/2, 19/5, and 19/8. If
23 we could show him those four exhibits in that order,
24 19/3 first.
25 Q. You've had a chance to look at some
1 photographs of a school before coming to testify today;
2 is that right?
3 A. Yes, that's right.
4 MR. McCLOSKEY: If we could start with 19/3
5 on the ELMO.
6 Q. If you could take a look at this picture.
7 It's a wintertime picture so it's a little different.
8 But do you recognise the building that's depicted in
9 that picture?
10 A. Yes, I do.
11 Q. With the pointer, can you point out, if you
12 see it, the area where you entered the building.
13 A. I think it was roughly here [indicates].
14 This is the gym [indicates], and this is an additional
15 adjacent building, and this is where we entered. We
16 got to this smaller building.
17 MR. McCLOSKEY: Okay. For the record, when
18 he pointed to the gym, it was the large building in the
19 back. And there is a smaller building in front that he
20 also made reference to and he said they entered in the
21 area where there appears to be a circle.
22 Q. If you could now look at 19/2. Do you
23 recognise this photo?
24 A. Yes, I do. This is also the gym. This is
25 the small building with the door in it [indicates].
1 Q. Do you see the area where you exited from the
3 A. It's here [indicates].
4 MR. McCLOSKEY: Indicating the circle on the
6 Q. All right. Could you now look at 19/5. Do
7 you recognise this picture?
8 A. Yes, I do. This is the inside of the gym
9 [indicates]. This is one of the walls with windows on
10 it [indicates], and pillars.
11 Q. What, in particular, about this photo do you
12 recognise from your experience that day in the gym?
13 A. I recognise the place by these windows and by
14 the way the inside of the gym looks, because the
15 picture was taken inside.
16 MR. McCLOSKEY: If we could hold off on that
17 last photo for a minute.
18 Q. Now, when you arrived inside the gymnasium,
19 where did you go? Actually, let me stop there and ask
20 you a question before that. I'm sorry.
21 You said that prior to going inside the
22 gymnasium, they made you take off your coat and put it
23 in a pile of clothes. Did you see the soldiers
24 requiring anybody else to take off coats or clothes and
25 put it in this pile?
1 A. I didn't see it. I didn't have time to
3 Q. How big of a pile of clothes was it where you
4 put your jacket?
5 A. It was quite big, maybe enough for a
6 passenger vehicle trailer roughly.
7 Q. When you got inside the gymnasium, where did
8 they put you?
9 A. I sat left to the entrance, near the opening
10 where they took us out of the hall later on.
11 Q. What happened when you were put in this gym
12 with all these other people?
13 A. When we all entered the hall and no one else
14 was coming in, we sat there for about two or three
15 hours, perhaps, and then some soldiers came and we were
16 ordered to keep silent. So we stopped talking.
17 Then one of those men at the door, I don't
18 know who it was, he ordered four rows at the end of the
19 hall to get up. These were mostly elderly men. Then
20 they ordered them to turn around to the right and face
21 the wall. This went on roughly until they reached my
22 part, and they told us to turn our backs to the exit
23 and to face the wall next to us. Then one of the
24 soldiers said, "These people must not be killed." Then
25 this other Serb soldier said, "And who says so?" And
1 then this soldier --
2 Q. I'm sorry, let me interrupt you one second.
3 Who said "These people must not be killed"?
4 A. One of us prisoners.
5 Q. Okay. Then what happened after he said that?
6 A. Then the Serb soldier said, "And who said
7 so?" Then this man repeated what he said. He said,
8 "We'll see," and he told him to get out. The man went
9 out. We heard a shot. The man started screaming.
10 Another shot was heard, and the man fell quiet.
11 Then they took out another man from the other
12 end of the gym. Again, we heard shots and that was
14 Q. Do you know why they took out the second man?
15 A. I don't know.
16 Q. Okay. Let me go back to the time that you
17 were first put inside the gymnasium with the other
18 people. Your truckload of men, were they put in the
19 gym with you, the people that you arrived to the school
21 A. Yes, they were.
22 Q. So did people continue to arrive inside the
23 gymnasium after your group was put in the group or was
24 your group the last group?
25 A. Our group wasn't the last group. There were
1 others coming in, but when they had all come in, then
2 this, what I just told you, happened.
3 Q. How long after you first arrived did Muslim
4 men continue to be brought into the school, into the
6 A. This may have lasted five or ten or fifteen
7 minutes. The vehicles came one after another. It
8 didn't take hours.
9 Q. How full did the gym get when the process of
10 bringing Muslim men in finally finished?
11 A. It was full. Maybe there would have been two
12 metres that were empty where the four boys were
14 Q. Can you give us an estimate of about how many
15 Muslim men were crowded inside this gym that day?
16 A. According to my estimate, about 2.000.
17 Q. How were you arranged? Were you sitting or
18 standing or lying down?
19 A. We were sitting, but our knees were touching
20 and so were our shoulders, next to one another.
21 Q. During this process that they were bringing
22 in more Muslim men into the gym, could you see any Serb
23 soldiers inside the gym?
24 A. They didn't enter the gym; they only stood at
25 the door. And sometimes they would shoot into the wall
1 or the ceiling of the gym.
2 Q. Do you know why they would sometimes shoot
3 into the wall or the ceiling?
4 A. Because it was very warm, people were
5 demanding water. They couldn't bring in a lot of
6 water; they brought us only a little. So people were
7 making noises.
8 Q. Did you get any food while you were inside
9 this gym?
10 A. No, we didn't. Only water.
11 Q. Did you get enough water?
12 A. No.
13 Q. Was there any place to use the toilet?
14 A. Yes, there was a bucket that was used as a
15 toilet in the right-hand corner.
16 Q. You've told us about the man that made the
17 comment about don't kill people, and that he was taken
18 out. What happened after that?
19 A. After that they stopped bringing us water.
20 And then the same thing continued, the same situation.
21 The Serb soldiers were at the door. People were
22 addressing them "Soldiers", but they would answer,
23 "We're not soldiers; we are Karadzic's young
24 Chetniks," because they were very young.
25 Q. Could you make out anything from their
1 uniforms, anything special about them or anything
2 different, the Serb soldiers?
3 A. No. Most of them were bareheaded. They had
4 camouflage uniforms like the other Serb soldiers.
5 Q. Then what happened?
6 A. After that, at the opening to the left, there
7 were two Serb soldiers standing there and a Serb woman
8 in uniform. They brought a pile of rags with which
9 they tied our eyes.
10 Q. Can you tell me, do you recall about what
11 time they first brought this pile of rags?
12 A. I don't remember, but I think it was shortly
13 after these Serb officers, or whatever, had arrived, I
14 don't know, those who had ordered those
15 rearrangements. There were these pieces of cloth; they
16 were about 60 centimetres long, five or six centimetres
17 wide; they were mostly patterned so you couldn't see
18 through them.
19 Q. How many were there, or how big a pile of
20 rags were there?
21 A. Like a sack full, shall we say, if you were
22 to pour the contents out of a sack on the ground.
23 Q. Did it look like it would be enough to
24 blindfold everybody in the gym?
25 A. Probably. Most probably.
1 MR. McCLOSKEY: Could we show the witness
2 Exhibit 19/8.
3 Q. Could you take a look at that photograph and
4 tell us if you recognise anything in there.
5 A. I recognise it. This is the exit
6 [indicates]; this is the hall [indicates].
7 MR. McCLOSKEY: When he said "This is the
8 exit," he pointed to the doorway where number 2 is
9 marked with an arrow.
10 Q. Now, when you say "That's the exit" --
11 A. Yes.
12 Q. -- is that where the Serb soldiers were
13 standing, and the woman you mentioned earlier?
14 A. Yes.
15 Q. What occurred when these soldiers and the
16 woman soldier were standing by that exit and they
17 brought in all these strips of cloth?
18 A. Then they assigned one to blindfold the
20 Q. Assigned one. Who? A Serb or a Muslim?
21 A. A Muslim.
22 Q. Then what happened?
23 A. Then what happened was that once we were
24 blindfolded we had to leave this room and form a letter
25 "L". This woman of Serb ethnicity, in a camouflage
1 uniform like any other soldier, would give us each a
2 glass or a cupful of water while we were there
4 Q. Did you see people get blindfolded in front
5 of you that left through this exit?
6 A. I did.
7 Q. Did they come back?
8 A. No.
9 Q. Could you tell where they were going?
10 A. People asked, "Where are you taking these
11 people?" and they said, "We're taking them to the
12 Bijeljina Logor, to Bijeljina, to a camp," but it
13 wasn't a camp.
14 Q. How long did it take until it was your turn
15 to get blindfolded and go out this exit?
16 A. At least three hours, if not more.
17 Q. After you were blindfolded and given the
18 water, what happened to you?
19 A. We got into a Tamic brand truck, with signs
20 either of the police or the army. I could see through
21 the blindfold. They were Cyrillic registration plates;
22 they were not civilian registration plates.
23 Q. How well were you able to see through the
25 A. One could see about 50 per cent and more,
1 because they weren't so strict about us moving the
2 blindfold off our eyes for a while.
3 Q. Can you describe to the Court what a TAM
4 truck is and what this TAM truck looked like?
5 A. It's a small truck, of two and a half tonnes
6 carrying capacity, manufactured in Slovenia, during the
7 former Yugoslavia.
8 Q. What does the back of the truck look like?
9 A. It has sides of some 40 to 50 centimetres
10 which can be closed, and there was canvas over it.
11 Q. Was there any place to sit?
12 A. There were two benches. When the benches
13 were full, then people sat in between the two benches.
14 Q. Where was this truck parked in relation to
15 where the school exit was?
16 A. Next to the room where they were blindfolding
17 us. There was a kind of obstacle in front of the
19 Q. Were you taken directly from the room onto
20 the truck?
21 A. Yes, directly.
22 Q. Could you tell how many other Muslim men were
23 put in the back of this truck with you?
24 A. There were up to 30, maybe more, because
25 eight to ten men could sit on the benches and the space
1 in between is broader than the benches themselves
2 so ...
3 Q. So did they put men in the spaces in between
4 the benches?
5 A. Yes. Yes.
6 Q. How could you tell that if you were
8 A. When we were in the truck, we took off the
9 blindfolds because we believed we were going to
10 Bijeljina. We thought they wouldn't mistreat us. And
11 when the engine got started again, we put back our
13 Q. Were there any Serb soldiers in the back of
14 this truck with you, crowded full of Muslim men?
15 A. I didn't see any.
16 Q. Can you tell us where the truck went, as far
17 as you could make out?
18 A. The truck drove for a very short while.
19 According to my judgement, it took a left turn to
20 a macadam road, because we could tell by the shaking in
21 the truck.
22 Q. It took a left turn from the macadam road
23 onto a bumpier road?
24 A. No, from the asphalt road onto the macadam
1 Q. The macadam road is bumpier than the asphalt
3 A. Yes.
4 Q. What happened when you got on the macadam
6 A. When we got there the truck stopped, and we
7 immediately heard people talking behind our backs. We
8 noticed some dead people as we were looking down
9 towards the ground. Through the cloth we could see
10 some dead people.
11 Q. Could you just tell us what you yourself were
12 able to see, looking down through your blindfold, as
13 you were getting off the truck.
14 A. I personally saw a dead man. I'm only
15 talking about myself; I'm not saying what other people
16 saw. I saw this dead man in front of me.
17 Q. What happened next?
18 A. Then they lined us up and they started with
19 bursts of fire from my right-hand side, and then men
20 were falling to the left. Men brought me down, so that
21 a man covered this part of my face [indicates], and he
22 fell before me and my arm was over his chest. That was
23 probably the last shot fired in a standing position.
24 Q. Were you hit?
25 A. No.
1 Q. Was there anybody on top of you or near you?
2 A. Yes, this one who was on top of me, because
3 on my back there was a bloodstain from this man who was
4 on top of me, and the blood was dripping from him onto
6 Q. Did you feel him die, or did he die
8 A. I didn't. But one man, I don't know whether
9 he was in my group or a group after me, he said,
10 "Finish me off," and then this Serb soldier said,
11 "Slowly. Slowly."
12 Q. What else happened as you were lying there
13 amongst this carnage?
14 A. When we had all fallen to the ground, then
15 one of them came and fired single shots at the people
16 who were probably moving. Then a stone injured me
17 slightly that probably jumped off of the road. It was
18 a small injury and it didn't hurt. If it had been a
19 bullet, it would have been more painful.
20 Q. Then what happened?
21 A. Then those Serb soldiers were shouting,
22 "Let's take their watches off their hands so we can
23 get beer instead," but another one said, "Don't," and
24 they didn't. And I didn't have a watch anyway.
25 Q. Then what happened?
1 A. Then another truck came, and again you only
2 heard shots, and people were probably falling but there
3 weren't many cries or screams. So we come to almost
5 Q. Were you able to see the arrival of other
6 trucks or were you still blindfolded at this point?
7 A. No, I still had the blindfold, and I was
8 lying on my stomach.
9 Q. Did you look up at all at this point, when
10 the other trucks started arriving?
11 A. I didn't. I didn't dare because I didn't
12 know what was behind my back. I didn't dare move.
13 Q. Do you know how long this process, where
14 trucks arrived and you could hear gunfire, how long
15 that kept going?
16 A. It went on late into the night, but the exact
17 hour I'm not able to tell. But it went on into the
19 MR. McCLOSKEY: Mr. President, the story, of
20 course, goes on a little further. Do you wish to
21 continue the story tomorrow or try to go further
23 JUDGE RODRIGUES: [Interpretation] How much
24 more time do you need, roughly, Mr. McCloskey, to
25 finish with this witness?
1 MR. McCLOSKEY: Fifteen minutes, maybe
3 JUDGE RODRIGUES: [Interpretation] Very well.
4 In that case, we will finish for today and we'll resume
5 tomorrow at 9.30.
6 I think the parties already have a proposed
7 timetable for our Status Conference for Thursday.
8 Therefore, I'd like you to look at that proposal
10 I'm telling the Defence that we have
11 considered your motion. We're going to have a month
12 and a half now, and then after that we will have more
13 time. And I think that will correspond to the amount
14 of time you have requested. But in any case we will
15 reconsider that at the Status Conference on Thursday,
16 and all I'm asking is that you look at that proposal
18 Therefore, Witness, you are going to stay
19 tomorrow, when we will resume.
20 So we will resume the hearing tomorrow at
22 --- Whereupon the hearing adjourned at
23 2.34 p.m., to be reconvened on
24 Wednesday, the 12th day of April, 2000,
25 the 9.30 a.m.