1 Friday, 14th April 2000
2 [Open session]
3 [The witness entered court]
4 --- Upon commencing at 9.33 a.m.
5 [The accused entered court]
6 JUDGE RODRIGUES: [Interpretation] Good
7 morning, ladies and gentlemen; good morning to the
8 interpreters. I can hear you too. Thank you. The
9 technical booth, the legal assistants, the Prosecution,
10 the Defence, the court reporters, General Krstic. Good
11 morning to you all. I also wish the public good
13 We already have a witness in the courtroom.
14 I think it is Witness P. You're now going to read the
15 solemn declaration that the usher is going to give
16 you. Please go ahead.
17 THE WITNESS: [Interpretation] I solemnly
18 declare that I will speak the truth, the whole truth,
19 and nothing but the truth.
20 THE WITNESS: WITNESS P
21 [Witness answered through interpreter]
22 JUDGE RODRIGUES: [Interpretation] Please be
23 seated. Are you comfortable, Witness P?
24 THE WITNESS: I'm fine, thank you.
25 JUDGE RODRIGUES: [Interpretation] Have you
1 had a good rest?
2 THE WITNESS: Yes.
3 JUDGE RODRIGUES: [Interpretation] So please
4 be at ease. I think it is Mr. Harmon who is going to
5 put questions to you, so for the moment you will be
6 answering questions put to you by the Prosecutor.
7 Mr. Harmon, you have the floor.
8 Excuse me. Yes, there is a minor matter that
9 we have to attend to. Witness P, the registrar is
10 going to show you a piece of paper with your name
11 written on it. Look at it, please, and tell us, simply
12 by saying yes or no, whether that is indeed your name.
13 THE WITNESS: Yes.
14 JUDGE RODRIGUES: [Interpretation] So it is
15 your name indeed.
16 THE WITNESS: Yes.
17 JUDGE RODRIGUES: [Interpretation] Fine. So,
18 Mr. Harmon, you have the floor now.
19 MR. HARMON: Good morning, Mr. President,
20 Your Honours; good morning, counsel; good morning,
21 Witness P.
22 Mr. President, before I begin my examination
23 of Witness P, I just want to inform Your Honours that
24 after Witness P we have one additional witness to call
25 for today, and at the end of the testimony of the
1 second witness we would like to introduce some
2 documents. The introduction of those documents will
3 not take more than 15 minutes. So we can schedule the
4 day accordingly. I bring that to Your Honours'
5 attention and I will now commence my examination of
6 Witness P.
7 JUDGE RODRIGUES: [Interpretation] Yes. Allow
8 me to say to you that all the witnesses are very
10 MR. HARMON: Thank you.
11 Examined by Mr. Harmon:
12 Q. Witness P, could you tell us how old you are?
13 A. I'm 40.
14 Q. And are you a Muslim by faith?
15 A. Yes.
16 Q. Before the creation of the UN safe area of
17 Srebrenica, were you a member of the Territorial
19 A. Yes.
20 Q. Were you wounded?
21 A. I was wounded on the 16th of June, 1992, by
22 orders of the army command, or rather the Territorial
23 Defence. I was appointed to working on the collection
24 of humanitarian aid in the local community.
25 Q. So following your injury you were released
1 from the Territorial Defence?
2 A. Yes.
3 Q. At the time of the fall of the enclave in
4 July of 1995, were you a member of the Bosnian Muslim
6 A. I was not.
7 Q. Now, I'd like to focus your attention on the
8 fall of the enclave in July of 1995, specifically on
9 the 11th of July, 1995. At that point in time were you
10 married and did you have children?
11 A. Yes. I was married and had four children.
12 Q. And could you tell the Judges what happened
13 on the 11th of July that caused you and your family to
14 go in different directions?
15 A. We simply received orders from the civilian
16 structures that we had -- all of us had to go to the
17 enclave of Srebrenica. Our assignment was that all of
18 us should go towards Susnjari, especially the men,
19 whereas the men [sic] and women went to UNPROFOR, to
20 Potocari. We got to a hill called Lehovici, where we
21 split up. So all the women and children went to the
22 battalion compound in Potocari and the men towards
24 Q. Why was there a distinction between where the
25 women went and where the men went?
1 A. Simply we didn't dare. We didn't dare go to
2 Potocari. We couldn't trust them. So only the women
3 and children dared go to Potocari.
4 Q. When you say "we couldn't trust them," who
5 are you referring to as "them"?
6 A. The Serbs, because when they captured the
7 enclave, they controlled the UN. They took their
8 vehicles. They occupied the enclave. So we didn't
9 dare go to Potocari.
10 Q. Now, Susnjari, how many men gathered -- men
11 and boys gathered at that location, approximately?
12 A. The figure ranged between thirteen and
13 fifteen thousand, according to the municipal
14 authorities. The figure could not be established, but
15 I think it was between thirteen and fifteen thousand.
16 Q. Do you know the range of ages of those males
17 who had gathered at Susnjari?
18 A. From 16 to 50 or 60 maybe. Though there were
19 some women, or rather girls, who followed their
20 boyfriends there, men. A smaller number of women,
21 maybe some 200 or 300.
22 Q. Are you able to estimate the number of men
23 amongst that group who were armed?
24 A. Well, about one third had weapons in that
1 Q. Witness P, did you have a weapon?
2 A. No, I did not.
3 Q. Now, I understand that the people in that
4 group of approximately 15.000 people left the enclave
5 in a column; is that correct?
6 A. Yes. The column was formed. The order was
7 that we had to pass through Serb lines. So it was
8 about 7.200 kilometers to free territory, to Tuzla, so
9 we had to break through the lines. And the column was
10 formed at the very entrance to the place Buljim, so
11 this column was some ten kilometers long.
12 Q. And in which direction did the column
14 A. It advanced towards Konjevic Polje. We
15 passed Nova Kasaba and then on towards Tuzla.
16 Q. Now, Witness P, I'm not going to ask you
17 questions about your experiences in the woods --
18 perhaps the Judges would like to inquire about that,
19 perhaps counsel will inquire about that -- but I want
20 to fast-forward the experiences that you had to the
21 13th of July, when there was a decision taken by you
22 and by others to surrender to the Bosnian Serb army.
23 Can you tell the Judges, did you surrender, and can you
24 tell the Judges why you did?
25 A. Yes. My group -- a relative of mine was
1 seriously wounded, my cousin, and there was a small
2 group left of some 30 men. The night between the 12th
3 and the 13th we were cut off from the big column. We
4 were in a stream. It was foggy. We didn't know where
5 we were.
6 In the morning there was heavy shelling.
7 Shells were falling around us. There was an
8 ultimatum. They were calling us out on the loudspeaker
9 that we had to surrender, that we should carry the
10 wounded, that we should be exchanged, according to the
11 Geneva Conventions, that no one would be heard. There
12 was a lot of hesitation amongst us whether we should
13 try to pull out or to surrender to the Serb soldiers at
14 Kravica. And after a time they said they would begin
15 the countdown, and the order was to collect the
16 wounded. A number of people were killing themselves,
17 committing suicide. They didn't want to surrender.
18 When we carried down the wounded to Kravica, a column
19 was formed towards Konjevic Polje.
20 Q. Now, you said a number of people committed
21 suicide. Did you see people commit suicide, and do you
22 know why they did commit suicide?
23 A. Yes. Yes, I did see it. I don't know.
24 There were poisons that were being thrown, poisonous
25 gases, and people lost control. They knew more or less
1 what lay in store for them, that they would be killed
2 or put into camps. And I saw two brothers. I don't
3 know their names. First they embraced each other.
4 They had an automatic rifle. There was a scream. They
5 opened a burst of fire to one another. Then there was
6 another group of people that threw a bomb into the
7 group, and then four or five of them were wounded.
8 Q. Now, Witness P, I'm going to ask you to talk
9 just a little bit slower, because the interpreters need
10 to follow your testimony.
11 A. Yes, I'll do that.
12 JUDGE RIAD: Excuse me now the group of
13 people who threw the bomb they were from the group of
14 Muslims or the group of Serbs?
15 MR. HARMON:
16 Q. Did the people that threw the bomb that you
17 just testified about, were they Muslims committing
18 suicide or were they Serbs killing Muslims?
19 A. I think it was Muslims who were killing
20 themselves. I heard that they may have been Serbs
21 too. At that moment, I couldn't distinguish one from
22 the other. They were all mixed together.
23 JUDGE RIAD: And the poisonous gases, they
24 were thrown by the Muslims to commit suicide?
25 A. No, it was the shells with poisonous gases.
1 I could feel it myself, my eyes were stinging and one
2 was very thirsty and one could feel it on one's own
4 MR. HARMON:
5 Q. Now, Witness P, how many people along with
6 you went down to surrender on the 13th of July?
7 A. I said that there may have been some 30 men
8 in my group; I didn't count them. We had four or five
9 wounded. And on the asphalt road, we came across a
10 large group that had surrendered at Konjevic Polje,
11 there were 300 or so people and they had some 20
13 THE INTERPRETER: Could we ask the witness to
14 move away from the microphone, please.
15 MR. HARMON:
16 Q. I've been asked by the interpreters if you
17 can move a little bit away from the microphone.
18 Now, Witness P, when you surrendered to the
19 Bosnian Serb soldiers. Can you describe their
20 appearance, how they were dressed?
21 A. They were wearing camouflage uniforms in dark
22 blue, dark blue camouflage uniforms.
23 Q. Did you see any people in dark green
24 camouflage uniforms?
25 A. Let me see. At that moment, I didn't really
1 distinguish. We were all frightened. I know that they
2 all had camouflage uniforms. Whether they were lighter
3 in colour or darker in colour, I really couldn't tell.
4 Q. Now, do you know the difference between
5 police camouflage uniforms and army camouflage
7 A. At the time, I didn't, but later I saw on
8 television that there was a difference, but at that
9 moment, I really can't remember whether there was any
11 Q. All right. Tell the Judges what happened
12 after you surrendered; where did you go?
13 A. When we carried down the group of wounded to
14 Konjevic Polje, this group of mine, between 250 and 300
16 The order was to lay down the wounded at the
17 cross roads at Konjevic Polje. One of the Serbs told
18 us that they would take over the care of the wounded.
19 They put us up in a hangar which used to be a kind of
20 shopping area and some people started bringing water,
21 but it wasn't enough. There were only two or three
22 bucket fulls of water.
23 We stayed there for some 20 minutes and then
24 the order came to get on to trucks. I ran out and I
25 saw three or four trucks. I don't remember exactly
1 whether there were three or four. They were parked at
2 the very crossroads at Konjevic Polje.
3 The trucks were facing Milici and Nova
4 Kasaba. The trucks were covered with canvas. I
5 couldn't see, and I don't remember the licence plates
6 nor whom they belonged to but I think they were
7 civilian trucks. They had canvas covers, and I think
8 they belonged to the Boksit company, I think. I'm not
9 sure. And we had to climb on to the trucks and the
10 truck I was in started towards Nova Kasaba.
11 Then we passed a sports field that used to be
12 used before the war, and the order was to get off the
13 bus, the truck, I'm sorry. When we started getting off
14 to our right-hand side, I saw a group of Serb soldiers
15 who were waiting for us there.
16 The order was that all the equipment that we
17 had on us, except for money and gold, which they had
18 taken from us at the very beginning in Kravica, that we
19 had to throw those things on to a big pile. And there
20 was a big pile of bags and backpacks and there were
21 some poplar trees there, and we got off the truck in a
22 line and entered this stadium.
23 The stadium was full of men. According to my
24 estimate, there were between 2.500 to 3.000 men and
25 they were all sitting there in a -- within the
1 compound. And my group that got off the trucks, we
2 formed a new row there in the playground, sports field.
3 MR. HARMON: Now, let me have Prosecutor's
4 Exhibit 12/4 and place this on the ELMO.
5 Q. Witness P, I'm going to ask you if you can
6 identify this location that's depicted in this image.
7 Do you recognise that?
8 A. Yes.
9 Q. What is that?
10 A. This is the stadium at Nova Kasaba. This is
11 the goal [indicates]. And we stopped here somewhere
12 next to the trees. This is the road to Konjevic Polje
13 to Nova Kasaba, and this is where I entered the stadium
14 [indicates], the sports field.
15 MR. HARMON: Indicating for the record that
16 the entry into the stadium was midway along the line of
17 trees that boarders the road that goes from the top of
18 the image to the bottom of the image.
19 Q. Now, this stadium, this football field, is
20 the location where you said there were thousands of men
21 on it; is that correct?
22 A. Yes, yes, yes.
23 MR. HARMON: I'm finished with that image.
24 Thank you very much.
25 Q. Can you tell the Judges, was the football
1 pitch -- how many men were on the pitch and how much of
2 the area of the football field was covered by those
4 A. I didn't quite understand your question. You
5 mean the Bosniaks?
6 Q. Let me ask it again. Did the Bosnian Muslim
7 men cover the entire football pitch, half of the pitch,
8 a quarter of the pitch?
9 A. I think that the whole pitch was covered.
10 Q. Now, did you see Bosnian Serb soldiers in and
11 around the Muslim men who were detained at the football
13 A. Bosnian Serb soldiers, about 15 to 20 of them
14 were waiting for us at the very entrance gates armed
15 with rifles and they gave us orders. They swore at us
16 and ordered us to enter the pitch. Within the pitch
17 itself, around us who were sitting there, there were
18 Serb soldiers with their guns pointed at us. They were
19 swearing and giving us orders.
20 Q. Can you estimate the number of soldiers that
21 you saw around you and the other men at the football
23 A. I can't give you an exact estimate because,
24 after all, it was a long time ago, but there were 15 to
25 20 at the very entrance. As for the total, in any
1 case, there were many in the field, at least 100 or
2 so. But that may not be the correct figure.
3 Q. Do you remember how they were dressed?
4 A. Also they had camouflage uniforms on. On one
5 soldier, I couldn't notice any rank. He may have had
6 insignia, but they all had camouflage uniforms.
7 Q. Now, continue with your -- describing your
8 experiences at the football field, please.
9 A. So when my group entered and when we sat
10 down, after some 15 or 20 minutes behind my back I saw
11 an APC of olive-green colour arriving, and I saw
12 several soldiers around the personnel carrier. And
13 then a big man came out of the APC, some 30 to 40
14 metres away from me. And when he passed by me, he
15 turned around and asked whether we recognised him. I
16 knew him from the media and he introduced himself. He
17 said that he was the commander of the Serb army, that
18 he was General Ratko Mladic.
19 He was a heavy man with a short cut,
20 well-shaved with some receding hairlines in a
21 short-sleeved shirt. And when he stood in front of us,
22 I don't remember whether it was a podium or a couple of
23 steps, I don't know.
24 He started insulting and cursing us. "Where
25 is your state? What are you dying for? Where is your
1 Alija? Where is Haris Silajdzic? Where are your
2 leading commanders? Naser Oric and Zulfo Tursunovic.
3 You are laying down your lives and you've left your
4 women and children for us to care for them."
5 And there were other such insulting words and
6 then the -- at the end he said, "Your authorities in
7 Tuzla don't want you. So we will put you up. Our
8 troops will give you water and food, and then we'll see
9 whether we'll send you to Krajina, to Fikret Abdic or
10 to the Bijeljina camp to the Batkovici camp in
12 Then orders came for us to get up, to get on
13 to the trucks. I was towards the end of the field, and
14 we headed towards the trucks. I also saw the trucks
15 waiting on the road, three or four trucks, and I think
16 there was a bus belonging to Boksit Trans from Milici.
17 They were waiting on the road in front of the exit from
18 the playing field.
19 My group of men who -- the group that was
20 moving with me, when we were going through the gates,
21 someone said that we should pick up the bags. And Serb
22 soldiers were guarding the gates and the bags. One of
23 the group of Serb soldiers said to us, "You won't need
24 that any longer." Probably they were thinking of what
25 they were going to do. And so we got on to the trucks
2 Q. Let me stop you right there for a moment,
3 Witness P, and ask you two questions.
4 Do you remember approximately what time of
5 the day it was when you and others started to board the
7 A. I think it was about 1700 hours or 5.00 in
8 the afternoon. Somewhere around 5.00, between 5.00 and
9 6.00 in the afternoon.
10 Q. Was the statement made by the Bosnian Serb
11 soldier that you wouldn't need your bags anymore made
12 at about that same time?
13 A. Yes. As we were leaving the football pitch
14 and about to climb on to the trucks, I heard one of the
15 Serb soldiers saying when one of our men wanted to pick
16 up his bag. I heard him telling him, "You won't need
17 that bag anymore."
18 Q. My last question about this part of your
19 experience: Did you receive any food and any water
20 while you were at the football pitch?
21 A. Never. Far from it. I don't know whether
22 anyone asked for any water, but none was distributed
24 Q. I interrupted you, Witness P, when you were
25 recounting your story about getting on to the truck.
1 Would you please carry on from that point in time.
2 A. Yes. So we climbed on to the truck. I don't
3 know how many trucks there were that became full at
4 that point. My truck started out right away. There
5 was an order for the trucks to move. So we went in the
6 direction of Konjevic Polje, that is along the same
7 road we had used to come there, to get there.
8 When we reached the junction with Konjevic
9 Polje, the truck turned right again in the direction of
10 Bratunac. And then we arrived in Kravica. I knew
11 Kravica very well because I had passed through Kravica
12 on a number of occasions before the war. And we
13 stopped near a supermarket.
14 My truck -- well in my truck, we happened to
15 count ourselves, and there were 119 people on my
16 truck. We were sitting on each other's laps on the
17 floor, on the bed of the truck with our legs crossed.
18 I was towards the rear part of the truck which was
19 covered by canvas. Those were very large canvases, and
20 at the back of the truck, you could see through because
21 there was a half a metre opening at that point.
22 So I told you I was sitting in the back of
23 the truck. And as the truck was turning right, I saw
24 that there were two trucks behind us. All of them were
25 facing the direction of Bratunac.
1 It was getting dark at that point, and people
2 were getting nervous. The Serb soldiers who were
3 guarding the trucks, who were standing guard around the
4 trucks started mistreating people, hitting them with
5 rifle butts through the canvas of the trucks. They
6 would hit people who sat next to the side of the truck
7 and they went on torturing them.
8 Then they asked about people from specific
9 villages from around the area of Srebrenica, the
10 villages of Glogova, Osmac and other villages. I don't
11 know why they asked for people from those villages.
12 If anyone stood up, they would take him out.
13 We spent the whole night on the trucks and we could
14 hear screams, moaning, cries for help. Screams again.
15 People shouting, "Please, don't beat me. Don't kill
16 me. Don't butcher me." It was so terrible, it was
17 so -- we couldn't take it anymore. I know that five
18 people were taken off my truck during that night. I
19 didn't see them being killed there on the spot, but
20 they didn't come back to the truck. I don't know their
21 names. And bursts of gunfire could be heard throughout
22 the night, coming from around the trucks, and the
23 screams of people, and this lasted all night long.
24 Q. Witness P, were there two other trucks
25 parked --
1 THE REGISTRAR: [Interpretation] Sorry to
2 interrupt you, Mr. Harmon, but I think there is a
3 problem with the transcript.
4 [Technical difficulty]
5 --- Break taken at 10.08 a.m.
6 --- On resuming at 10.21 a.m.
7 JUDGE RODRIGUES: [Interpretation] We shall
8 resume, Mr. Harmon. You may continue, please.
9 MR. HARMON:
10 Q. Witness P, the technical problem has been
11 resolved and we'll continue with your testimony.
12 Now --
13 A. Thank you.
14 Q. I have placed on the ELMO, to your right, a
15 map, and I'd like you to take a look at that map. And
16 if you could use the pointer, first of all, could you
17 point to the location where you were detained at the
18 football field.
19 A. At the football field, this was here, between
20 Nova Kasaba and Konjevic Polje [indicates].
21 Q. And you were taken in a truck to a different
22 location, where you spent the night, and you've just
23 been describing your experiences at that location.
24 Could you point to that location for the Judges,
1 A. So we went back towards Konjevic Polje, and
2 then towards Sandici and Kravica [indicates]. And this
3 was all along the road towards Bratunac. And this is
4 where we spent the night, on the trucks.
5 MR. HARMON: Indicating, for the record, the
6 pointer is on the village of Kravica.
7 Thank you, Witness P.
8 Thank you, Mr. Usher. I'm finished with that
10 Q. Now Witness P, focusing your attention on the
11 night of the 13th and the early morning hours of the
12 14th, while you were in the truck, did you receive any
13 water? Did you receive any food?
14 A. While we were in the truck, during the
15 morning we got only one bucket of water. I don't know
16 who it was who brought the water, but it was hardly a
17 drop for all of us. You can image. It was only one
18 jerrycan of water, and we were 119. We didn't get any
19 food either.
20 Q. Now, do I understand your testimony correctly
21 that in addition to your truck that was at that
22 location in Kravica, there were two other trucks
24 A. I could see behind my truck two additional
25 trucks. Whether there were any other trucks, I don't
1 know. I couldn't guarantee. I know that there were
2 two more trucks, so in total there would have been
3 three trucks, including mine. I don't know whether
4 there were any trucks ahead of us. That I couldn't see
5 because of the canvases.
6 Q. Can you describe the type of uniform being
7 worn by the Bosnian Serb soldiers who were in and
8 around your truck on the night of the 13th and the
9 early morning hours of the 14th?
10 A. I said that they all had a camouflage
11 uniform. To be perfectly honest, I couldn't tell the
12 difference. I wasn't familiar with that. And then we
13 were in great fear. We had been beaten and we didn't
14 dare look outside. People were cursing at us all the
15 time. They were mistreating us. And I know that there
16 was one young man who did not cross over. A Serb
17 soldier put a gun, the barrel of his gun, in his
18 mouth. And the situation was terrible. It was so
19 hot. It was stuffy. People didn't have any water, any
20 food. And somebody tried and asked for water. It was
21 total chaos.
22 And at one point we could hear screams. It
23 was complete madness. We could hear curses, and this
24 soldier cursed his balija mother and he put a barrel of
25 his gun into his mouth. I don't know this man. And he
1 did not reach the free territory. But the soldier told
2 me, "I will kill you and ten other people if I hear
3 another word being uttered in the truck."
4 And then everything went silent, and then
5 perhaps after 20 minutes or half an hour, people
6 started screaming again, asking for water, for help,
7 and I could see people drinking their own urine, trying
8 to moisten their lips with their own urine. So you can
9 image how it was, and it was all in terrible heat under
10 the canvas.
11 Q. Can you estimate how hot it was?
12 A. The outside temperature must have been around
13 28 or 30 degrees, so I don't know how hot it would have
14 been under a canvas. I don't know what the temperature
15 would be.
16 Q. How long did you remain at that location in
17 Kravica before you were transported to a different
19 A. At Kravica, on the 14th of July, when it
20 dawned, mistreatment started again, and we spent the
21 whole day in the truck again. And sometime in the
22 afternoon -- nobody had a watch. It had all been taken
23 away from us on the first day when we surrendered.
24 Nobody had any watch, therefore. But I know that it
25 must have been in the afternoon, between 2.00 and 3.00
1 in the afternoon.
2 Q. Where did you go?
3 A. At that point I heard somebody say that we
4 were going to Batkovic, that the trucks were leaving
5 for the Batkovic camp. And the trucks that had been
6 facing Bratunac turned around and started back towards
7 Konjevic Polje.
8 Q. And after the trucks reached Konjevic Polje,
9 in which direction did they travel?
10 A. So my truck continued right, in the direction
11 of Zvornik, and I could see, driving right behind us,
12 maybe some 10 meters away from us, started moving as
13 well. This truck was escorted by two Serb soldiers
14 with rifles, who -- one of them was sitting next to the
15 driver and the other one was also in the cabin of the
16 truck and he was holding his rifle out through the
17 window. It was pointing out. And we had been told
18 earlier on in Kravica that should anyone try to jump
19 out of the truck, that they would kill ten people. So
20 I know that my truck was moving in the direction of
22 We reached Zvornik. I knew the place very
23 well. But we passed through and continued after
24 Zvornik, and this is where women and children started
25 throwing rocks and stones on the buses.
1 We continued then towards Karakaj, towards
2 the aluminum factory in Karakaj. That area was no
3 longer familiar to me, but we didn't travel for very
4 long, and at one point the truck turned left. It was
5 already evening. We didn't travel for very long, maybe
6 only for about 15 minutes after Karakaj, after the
8 The truck therefore turned right, and we
9 could see the trucks stopping, coming to a halt. I
10 could see that there was a schoolyard in the area, like
11 a small playground.
12 Q. Witness P, let me stop you there for a
14 MR. HARMON: And if we could have 1/E/1 again
15 placed on the ELMO, the small map.
16 Q. And I'd just like you to indicate on this
17 small map the direction of travel that you took from
18 Kravica up to the area past Zvornik. And I think the
19 map will have to be opened up. And just use the
20 pointer, please.
21 A. Kravica [indicates], Konjevic Polje
22 [indicates], then we go down the river to the right of
23 Konjevic Polje, we come to Zvornik, Karakaj, and
24 somewhere there, to the left from Karakaj, we came to
25 the school. Between the Dam and Karakaj, that is where
1 the school was.
2 Q. Thank you very much.
3 MR. HARMON: And for the record, I think it's
4 fairly clear from his description the route he took
5 between Konjevic Polje and the Drina River. He crossed
6 the Drinjaca River. The rest I think is very clear.
7 He progressed up along the Drina River, past Zvornik,
8 to Karakaj, and left to an area near Petkovci.
9 Q. Thank you very much, Witness P.
10 MR. HARMON: And I'm finished with the
11 exhibit, Mr. Usher.
12 Q. Now, how long did it take you to travel from
13 Kravica to the school that you've just described?
14 A. Well, let me see. When we travelled by
15 public transport, it took about an hour, an hour and a
16 half to reach Zvornik. So this was a little bit
17 further, so about an hour and a half.
18 Q. Will you tell the Judges what happened to you
19 and to the other men once you arrived at the playground
20 at the school?
21 A. When we arrived at the playground of the
22 school, I heard sporadic shooting. Then there was
23 noise, cursing, yelling. And suddenly my truck
24 stopped, and when it stopped I saw two other trucks in
25 addition to mine, facing forward at the school
2 The order was that we jump off the trucks,
3 one by one, and as we jumped off, the order was to put
4 our hands up behind our heads and to chant aloud, "Long
5 live the Serb Republic" and "Srebrenica is Serb," and
6 maybe a few other words that I haven't remembered. And
7 as we were jumping out of the trucks and running, Serb
8 soldiers, in my estimate, some 20 or so, between the
9 truck and the school, formed two lines. And as we ran
10 between them, I said that we had to run and chant those
11 words. And usually everyone got hit, some with a rifle
12 butt on the back. Some were kicked, some were
13 slapped. And then we ran towards the school.
14 Towards the school there were some steps,
15 five or six steps going down, so that the first level
16 was lower than the yard itself. There was a double
17 door, and we ran into the school, into a corridor.
18 There was a short hall. And again there were soldiers
19 there who were hitting us and beating us, and they
20 directed us to the right, up some steps leading
21 upstairs. There were several steps and then there's a
22 kind of landing and then the steps turned left to the
23 second floor. When I reached the second floor, as I
24 was running I could see that there was an iron railing
25 in the corridor, and the classrooms were lined one next
1 to another.
2 I know that I entered classroom number 3. 1,
3 2, 3. Whether there was another classroom further on,
4 I'm not sure, but I think there was some other rooms
5 further down. When we entered the classroom, I saw
6 that it was a school, and on the left-hand side of this
7 classroom there was a blackboard, and on the floor were
8 some vinyl tiles, those that are glued on. There were
9 no school desks. All the windows were closed. And it
10 was stuffy, because we had travelled under the canvas
11 in the trucks. And as soon as I entered I saw two men
12 who had been badly beaten up and covered in blood. At
13 first glance I thought they were dead. I knew one of
14 them in person. He's Munib Admovic, who was very badly
15 beaten. I could describe him. He had a cap and a
16 jacket. I thought he was dead.
17 So we all sat down in rows. We had to form
18 those rows from the windows forward. The windows could
19 not be opened. There were two soldiers standing at the
20 doorway all the time, and they told us that we musn't
21 open the windows, that we must sit there, that we would
22 be given food and water. And so it went on until the
23 classroom was full.
24 As soon as it was filled up, other soldiers
25 started barging in, demanding money. They gave us 15
1 or 20 minutes, otherwise 20 would be killed, if we
2 didn't collect a certain sum of money. I don't know
3 how much they said. They would close the door and go
4 out, and say, "Not a word." The men were tired as a
5 result of high temperatures. They didn't have any
6 water, and they started yelling again, and again they
7 would come through the door, take people out, and one
8 could hear bursts of fire and shooting around the
9 school. No one dared look through the window to see
10 what was happening outside.
11 Suddenly a young man tried to look out, and
12 someone shot him, and he was wounded in that
13 classroom. They said, "If anyone had money left in
14 Srebrenica, that they had hidden, let him tell us and
15 we would take a car and go to Srebrenica, and that man
16 would be saved and transported to Tuzla." However,
17 nobody said they had any money, because this was the
18 third time they were searching us thoroughly and taking
19 everything away.
20 Suddenly, a relative, a neighbour of mine,
21 asked for water. However, he was turned back. A
22 second time when he went to look for water, he walked
23 out the door and he never came back. We could hear
24 fire all the time. Darkness was beginning to fall. I
25 personally didn't feel well. I was having problems. I
1 was feeling dizzy. I somehow got close to the window
2 to get some air, and in my estimate, there were about
3 200 men in that classroom.
4 And what happened, I don't really know
5 myself. Suddenly when I came to a little, I could see
6 that there were only a few men left in the classroom,
7 15 to 20, and I could see on those tiles blood and
8 water, or rather urine, and then I saw Munib Admovic,
9 who was trying to get up, and I asked him, "What has
10 happened?" And he couldn't give me an answer.
11 Shortly after that two came in from the
12 outside, two soldiers, and gave orders, "The next four
13 now." And I saw that I had to get up. I and Kadrija
14 Becirevic, who was with me, and two other men, I don't
15 know. We went out together. When we reached the
16 corridor in front of that classroom, next to the iron
17 railing, there were four to five Serb soldiers in
18 uniforms as well, and they ordered us to take off
19 everything, to strip. And I saw a whole pile of
20 clothing and footwear and documents, ID cards, medical
21 ID cards, driving licences and that sort of thing. I
22 took off my shoes, my socks. I only had my vest on,
23 and they let me keep that on. We had to turn out the
24 pockets of our trousers, every little piece of paper,
25 so make sure there was nothing left. What was the
1 reason for this, I don't know.
2 And so we had to stand against this iron
3 railing and the order was to put our hands behind our
4 backs which is what I did. And I saw next to those
5 soldiers a ball of string or rather rope. And I saw
6 him cutting pieces of that rope and tying my hands
7 twice around. There may be pictures somewhere how they
8 tied me up. And he was a big man. He was fair. I
9 don't know him. He just asked me where I was from.
10 When I told him where I came from, he slapped me, he
11 cursed my balija mother, and he pushed me opposite
12 classroom number two.
13 Classroom number two was open, the door was
14 open then, and there was no light on. When I fell, I
15 fell on a friend of mine. He hasn't come either. They
16 were all tied up in that classroom. I couldn't say
17 much, I just asked him, "What is happening?" He
18 couldn't give me an answer. I knew then that the end
19 was approaching.
20 Some 15 or 20 minutes later until all these
21 men had come out and were tied up, I heard the order,
22 somebody yelling, "Send me ten." And the man at the
23 door said, "Get out, ten of you."
24 And I was near the door, and as a group we
25 ran out with our hands tied down the steps. And when I
1 started down the steps, I saw in that corridor or I
2 could feel under my bare feet that there was blood.
3 And in the hallway at the bottom of the steps, three to
4 four men lying dead in the hallway of the school.
5 In front of the school there was a truck. It
6 was already night-time, I don't know what time it was,
7 but I think it was after midnight. And the truck was
8 standing there, the back part facing the entrance to
9 the school. The back side was down.
10 And so with our hands tied, barefooted, naked
11 to the waist had to climb into the truck which was
12 covered with a canvas. What type of truck it was, I
13 don't know, whether it was a military or a civilian
14 vehicle because it was dark.
15 The truck was filled quickly, they would say,
16 "Ten of you," then, "Twenty of you." Then this one
17 down there would call to the one upstairs. And when we
18 climbed into the truck, it was packed full. The order
19 was that we should sit down. We couldn't sit down when
20 it was packed.
21 Again, they cursed us, our balija mothers.
22 They said, "Haris Siladzic and Alija would receive you
23 dead and wounded." They were probably implying some
24 sort of exchange.
25 And again, a burst of fire at our feet and
1 then this relative, Kadrija Becirovic, said to me,
2 "I've been hit." And I only know that he dropped down
3 amongst us. I know nothing more about him. And then
4 the truck started. It was dark.
5 Q. Let me interrupt you before we go on to the
6 next part of your testimony.
7 MR. HARMON: If I could show the witness five
8 exhibits; 21/1, 21/3, 21/4, 21/5 and 21/7.
9 Q. I'm going to show you a series of pictures
10 that you've seen before in my office. Let me ask you
11 this, Witness P, did you return to the location of that
12 school with investigators from the Office of the
14 A. Yes.
15 Q. And you identified that school as being the
16 location where you were detained; is that correct?
17 A. Yes.
18 Q. I'm going to show you some pictures, a series
19 of pictures starting with 21/1. I'm going to ask you
20 if you can identify the buildings that are in that
21 particular exhibit. Can you identify the buildings in
22 that exhibit?
23 First of all, do you see a large parking lot
24 on the left side of the image? Now, your pointer is on
25 a building. Can you identify that particular
1 building? If not we'll go to the next exhibit.
2 MR. HARMON: Let's go to Prosecutor's Exhibit
3 21/3, please.
4 A. I really can't find my way, somehow.
5 Q. All right. We'll go to the next exhibit.
6 MR. HARMON: Can we go to 21/3, please.
7 Q. Now, does this clarify the location for you?
8 A. This is the playground. Yes. The school,
9 the entrance to the school. And this is the route we
11 MR. HARMON: Indicating, for the record,
12 there is a flat area where the witness now has his
13 pointer which is the playground.
14 A. That is where the trucks were [indicates].
15 MR. HARMON: The building in front of a
16 playground is the school where he was detained.
17 A. This is the entrance [indicates].
18 MR. HARMON: Can we now turn to Prosecutor's
19 Exhibit 21/4.
20 Q. Do you recognise this picture?
21 A. Yes.
22 Q. What is it?
23 A. The steps that I mentioned going down the
24 five or six that lead to the entrance to the school.
25 Q. All right.
1 A. The double door that I mentioned a moment
3 MR. HARMON: The witness pointed to the
4 double doors to the right side of the building. Thank
5 you. Could we turn to 21/5, please.
6 Q. Do you recognise this picture, Witness P?
7 A. Yes. The steps, as I said, the landing and
8 then the -- go upstairs and the iron rails. This is
9 where we were; one, two, three.
10 Q. Let me turn to the last picture in
11 Prosecutor's Exhibit 21/7 and ask you if you can
12 identify this location?
13 A. Yes. As I said, the vinyl tiles that I
14 mentioned that are glued on, and to the left, a
15 blackboard. This is the classroom, the entrance
16 [indicates], and in the door, the chimney stack for a
17 stove with a hole in it.
18 Q. This is the location where you were detained
19 prior to being taken out and put back on the truck?
20 A. Yes, yes. I was here somewhere near the
21 blackboard [indicates]. Later, I moved closer to the
22 window. You can't see the window in this picture. So
23 I was here somewhere [indicates].
24 MR. HARMON: When the witness indicates
25 "here", he's referring to a place directly under the
1 blackboard. Thank you very much, Mr. Usher.
2 Q. Now, we'll continue with your testimony,
3 Witness P. You said you and other men had boarded a
4 truck. Can you recall approximately how many men were
5 in your truck? You said it was packed?
6 A. After all, it was night-time, nor could
7 anyone count, so I don't know the figure. But imagine,
8 100 or so men at least. It was a big truck I think.
9 Q. Would you continue, please, with your
10 testimony, describing the events once the truck started
11 on its next leg of the journey.
12 A. We had climbed onto the truck after the
13 shooting, and the truck's engine started. As soon as
14 it started moving from the school, I saw immediately
15 that it was a bumpy road, and we were swaying left and
16 right and hitting each other because our hands were
17 tied. We were standing up.
18 The truck didn't travel for long, maybe 10 or
19 15 minutes. I don't know what time it was. I know it
20 was after midnight. And then suddenly the truck
21 stopped somewhere. At first glance, I could just see
22 that there was a little light, that there was some sort
23 of light reaching us.
24 And so as soon as we stopped there, we heard
25 heavy bursts of fire, noise, yells. I just heard
1 someone say, "Come down ten. Come on five." And we
2 had to run off the truck. How I got off, I don't know
3 myself. Whether there was any assistance, some way to
4 get off, but we were jumping off and we were all
6 And when we got there and it was lighted, I
7 saw a very big field of men lying dead who had
8 previously been killed. They were all facing -- their
9 faces were on the ground and they were all tied up. So
10 I and this group of mine were told to form a new row,
11 somebody was giving us the command, the orders.
12 And so we went to the area where we were shot
13 at with our hands tied and barefooted. I saw that the
14 path was rocky. I was barefooted, I didn't really know
15 where we were. I didn't know the location.
16 So we formed a new row. We went to the end.
17 And as we were passing at great speed, of course, I saw
18 a group to my right of Serb soldiers in uniform, they
19 were. And on their heads, they had something black,
20 whether it was socks or something so you couldn't see
21 their faces. They were pointing their guns at us and I
22 just heard one say, "Fall to the ground." That was the
24 After that, I really don't know what
25 happened. Behind my backs, I just heard strong bursts
1 of fire. They were shooting at our backs, at our
2 heads. From a distance of seven to ten metres, there
3 was this group of soldiers shooting.
4 I fell over bodies of those who had been
5 executed before me. As I fell, I had some kind of a
6 premonition that I might be saved. I tried to tuck my
7 head between the legs of those who had been killed
8 before me. I don't know, myself, how I managed to do
9 that. I could hear fragments and shrapnel and stones
10 hitting me at my arms and legs, but I realised I hadn't
11 been wounded yet.
12 But then suddenly, something hot seemed to
13 have been poured on my face. And as my hands were tied
14 behind my back, I couldn't do anything. I kept digging
15 my head down among the dead. How long this lasted, I
16 can't remember. The shooting, the bursts of fire, I
17 was probably unconscious again.
18 And suddenly, I heard some voices, individual
19 shots being fired and they were calling each other by
20 name. One said, "Simo and Dragan, come here." And
21 open brief bursts of fire into their heads. There must
22 have been some men alive and indeed there were. And so
23 they opened fire at them.
24 He came close to me. I heard them searching
25 the rows. And then, again, they cursed balija mothers
1 and one said, "You should see what he looks like. He's
2 like a skeleton." He was probably implying the chest
3 of this man. And he said, "If I had seen him in broad
4 daylight I would have been afraid of him."
5 And I heard these Serb soldiers exchanging
6 these words amongst themselves. I was lying down among
7 the dead with my hands tied behind my back. I heard
8 the steps. He kicked me here with his boot, with his
9 leg and he said, "He's dead."
10 After that, what happened with me, these were
11 moments after which I suddenly came to. I really
12 didn't know what had happened. I felt I was
13 suffocating. I was lying with my face down, with my
14 hands behind my back. And as those men were falling,
15 someone had fallen on my neck. And I didn't have any
16 air to breathe. I tried to pull myself out, pull my
17 head out from among the bodies. I could hear moans and
18 movements, so someone was still alive. And somehow --
19 as I said, my hands were tied. I couldn't pull free
20 with my fingers.
21 I heard a voice, a man saying the following
22 words, he was whispering, "My friends, let's move
23 down. They'll kill us. I am alive too." I plucked up
24 some courage, and I said to him, "If you can, come on,
25 let's try and escape."
1 And then he somehow managed to get some five
2 or six metres behind me in another row. He tried to
3 reach me. He said, "You have double ropes around your
4 hands and I can't untie you." I was whispering to him,
5 "Can I untie you?"
6 So he crawled up to me and I managed to pull
7 his hands free. And he said, "Let's run." You could
8 hear a machine approaching. We could see the lights of
9 the machine and the sound of this vehicle moving and he
10 said, "They'll kill us all here."
11 And I was still tied up, he helped me get up
12 and barefooted, covered in blood, stripped to the
13 waist. I still didn't know where he had been wounded.
14 We are treading over those dead bodies.
15 And down there we saw a kind of thicket, some
16 woods, and we thought we could reach it though the
17 grass was high and they would be able to see us
18 moving. But we had no choice. And only did we manage
19 the reach the wood when we caught sight of a big
20 concrete ditch that was leading somewhere. We didn't
21 know the area.
22 At the bottom of the ditch we saw a bit of
23 water. This was water with a muddy sediment. We tried
24 to reach that water to freshen up and for him to try
25 and untie me.
1 And as we were going towards this ditch to
2 our right, or rather to our left, a vehicle was
3 approaching. We didn't know what kind of vehicle. I
4 just concluded that it was a tractor with a trailer.
5 We heard it bumping over the macadam and as we reached
6 the ditch, I said to this person, take two stones. And
7 he found two rocks to try and cut the rope.
8 So I leaned my hands against the rock and
9 with those two rocks, he cut through the ropes. When
10 he did that, my hands were freed. I saw that I had
11 been scratched on the head. I was bloody. This other
12 person was wounded more seriously than me. I had this
13 vest on me. I took it off and bandaged his wound.
14 We found a bit of water so we washed up a
15 little. And we decided we would stay there until dawn
16 came. This must have been just before dawn, the
17 moments before night and day.
18 And behind us, on the field where we had been
19 shot at, we could hear strong fire again, noise and the
20 noise made by the machine. We heard the thuds as they
21 were unloading. We couldn't see from the ditch what
22 was actually happening.
23 As soon as daylight came, we decided to leave
24 the area, though we didn't know where we were. We
25 passed through a small wood. We found some mushrooms,
1 some leaves, something to eat.
2 And we saw a guard house, a small hut above
3 us. And in that hut, a machine was parked. It was a
4 bulldozer, a large bulldozer, that pushes the material
5 in front of it with a shovel and there was a man with a
6 rifle near that hut. Whether he had a uniform, I don't
7 know, but he was probably a guard working for that
8 company left over from before.
9 So we didn't dare go ahead in that direction,
10 so we retraced our steps, went back to the same ditch
11 where we had been in the morning. We continued to hear
12 explosions, the work of the machine, but we didn't know
13 what was happening, so we were back in the ditch, and
14 to the left of that ditch we saw a Bosniak village that
15 had been burned down. We saw the walls still
16 remaining, the chimneys that had been toppled and we
17 decided we would go to that village to try and find
18 some fruit and water to freshen up. We were barefooted
19 and wounded.
20 So after we had crossed the ditch, we came up
21 on a macadam road which was passing along the Dam. So
22 we crossed that macadam road. I was the first one to
23 cross it, and then I motioned to him to cross it as
24 well, because there were no vehicles. And this is
25 where we refreshed ourselves a little bit. We found
1 some water and we found some fruit.
2 We must have been some 150 or 200 meters from
3 the area where they were loading machines. So we stood
4 there watching. We didn't dare move. We were simply
5 lying in some brambles. We didn't know what to do.
6 The loader arrived that morning, the one with
7 a bucket, and it was loading dead bodies onto a
8 tractor. I know that it was a tractor. It was a large
9 type of tractor with very big wheels on the back and
10 smaller wheels on the front, and it had a trailer as
11 well. So we could see it scoop up between 10 and 15
12 bodies with its bucket, and then it threw the bodies
13 onto the tractor.
14 The tractor that was transporting the bodies
15 would leave in a direction, but we couldn't follow it
16 for very long, because at one point it turned off. All
17 we could observe was that it was coming back very
18 soon. The journey would probably last about 20
19 minutes, and after 20 minutes it would come back. So
20 meanwhile the loader with the bucket, with the shovel,
21 would be waiting for the truck to come back.
22 We could hear shots during that time. We
23 didn't know whether they were still killing people,
24 finishing them off, but shots could be heard, at any
25 rate. And we could hear them yell at each other, shout
1 at each other. And this is where we stayed throughout
2 the day. It was the 15th of July.
3 It was getting dark and we knew that we could
4 no longer stay there, so we -- from where we were
5 standing, we could see some water. We didn't know
6 where we were. But once we were in this village, we
7 could see a very large lake. At first I thought it was
8 the Drina River, but later on I found out that it was
9 an artificial lake that belonged to the aluminum
10 factory, would discharge waters.
11 So there was a ditch leading to the Dam where
12 we had been. I'm not sure that they threw bodies into
13 the lake, but I think that they threw them somewhere in
14 the vicinity of the Dam. We couldn't see the tractor.
15 It would turn off behind the Dam and disappear from
16 sight. But it would come back very soon.
17 So we spent the whole day there, waiting, and
18 at one point we saw the TV relay at Majevica, which was
19 in the direction of Tuzla. So I told this young man
20 that we should leave, that we should go in that
21 direction, and we actually started out in the direction
22 of the industrial area of Karakaj. The area was
23 inhabited, so we didn't dare come out. We didn't dare
24 cross the area. We were just trying to follow the
25 relay, the TV transmitter.
1 Q. Let me interrupt you there for just a moment
2 and let me ask you just a couple of questions to
3 clarify your testimony. When you looked back from your
4 position away from the killing field, can you estimate
5 how many bodies were laying on that field?
6 A. Well, I didn't make any estimates at the
7 time, but judging by the features of the terrain and
8 the number of people in the school, it must have been
9 between 1.500 and 2.000 people.
10 Q. Now, you also said that you observed some
11 heavy construction-type equipment. One was a bulldozer
12 with a scoop.
13 A. Yes.
14 Q. Are you familiar with construction equipment?
15 A. Yes, very much so. I knew these types of
16 construction machines. I had worked with them. There
17 was a bulldozer with "Caterpillar" which had a kind of
18 blade at the front. It was not moving, that machine,
19 the bulldozer, whereas a loader that was standing next
20 to the bodies was. And there was a third machine, a
21 tractor which had a trailer and which transported the
23 Q. Can you identify more specifically the
24 bulldozer with the scoop, the type of vehicle that was?
25 A. Well, there are several types: number 8, 9,
1 7. I believe it was the type number 7, with
2 Caterpillar, with tracks. As regards the loader, this
3 type of machine, I believe it was the ULT machine. I
4 used to work with the same type of machines. And they
5 were produced -- they were manufactured in Kragujevac
6 before the war. Now they're importing them. They are
7 of various types: 160 and 200. I believe that that one
8 was ULT 160. It was orange in colour and it had a
9 scoop in front of it.
10 Q. Now, you also were taken to the location of
11 the killing field with investigators from the Office of
12 the Prosecutor and confirmed that being the location
13 where you and others had been taken for the execution;
14 is that correct?
15 A. Yes.
16 Q. Let me show you four exhibits and ask you if
17 you can confirm that the images depict the location --
18 A. I'm sorry. There's one thing that I forgot
19 to mention. When we got out, when we reached the
20 village, from my vantage point I could see the Dam and
21 I could see two very high pillars with floodlights
22 which were on during the night. They were throwing
23 light onto the area, onto the plateau where we had been
24 shot at.
25 Q. Thank you for that addition. I'm going to
1 show you four exhibits, and what I'd like you to do is
2 merely confirm whether this is the location where the
3 executions took place.
4 MR. HARMON: If I could start first of all,
5 Mr. Usher, with a panorama, which is Prosecutor's
6 Exhibit 22/3, and if that could be shown to the witness
7 first and then placed on the ELMO.
8 A. This is easier for me, this one. This is the
10 Q. You need to place that on the ELMO so -- now,
11 using the pointer, could you just -- first of all, is
12 this the location where the killings took place,
13 Witness P?
14 A. Yes. Yes, it is. So this is the road
15 [indicates] and this is where the ditch was, the Dam
16 [indicates]. This is a kind of protection wall
17 [indicates]. And this is the location.
18 Q. Would you point to the actual location where
19 the killings took place in this particular exhibit,
20 which is 22/3.
21 A. [Indicates]
22 MR. HARMON: Indicating, for the record, an
23 area that is below the number 100 and to the right of
24 the area 50, and further to the right, beyond the
25 actual rectangle.
1 A. I know this pile of rocks in the shape of a
2 pyramid. This is where I was that night. And later
3 on, when we came with the investigators, I saw it
4 again. This is the pile of rocks [indicates]. And
5 this is the area where we were [indicates]. And it was
6 from there that we went down into the ditch.
7 MR. HARMON: There is a pile of rocks
8 indicated -- or shown on the diagram --
9 A. Yes.
10 MR. HARMON: -- to the right of the large red
11 rectangle --
12 Q. Mr. Witness --
13 A. And this is the wall [indicates].
14 Q. I need to describe where you're pointing, so
15 if you would just remain silent while I have an
16 opportunity to describe the area. Then if you have
17 additional comments, I'll permit you to make them.
18 MR. HARMON: The witness pointed to a pile of
19 rocks which is located to the right of the red
20 rectangle, and it's evident in the upper part of the
21 flat surface area.
22 Q. Do you have anything else to inform the
23 Judges about this particular exhibit, Witness P?
24 A. I recognise this wall. I remember it very
25 well. It is a kind of support wall made of rocks. It
1 is designed to support the Dam, the embankment.
2 MR. HARMON: Indicating the pile of rocks
3 that's in the lower right-hand corner of that
4 Prosecutor's Exhibit.
5 Now we'll turn to the next Exhibit,
6 Mr. Usher, which is 22/4.
7 Q. And I'm going to ask you, very quickly, is
8 this the cement culvert that you described in your
10 A. Yes. This is the concrete ditch. This is
11 where we climbed down and this is where we took
12 shelter, hid ourselves.
13 Q. What is the building in the upper right-hand
14 corner of Prosecutor's Exhibit 22/4?
15 A. This is the guardhouse which we saw, and
16 another structure next to it. The bulldozer was here,
17 and these are the pillars where the floodlights were.
18 MR. HARMON: Indicating the bulldozer was
19 between the house and the floodlights, which are
20 indicated with a circle on the upper right-hand corner
21 of the exhibit.
22 Q. Now we will turn to the next exhibit very
23 quickly, 22/6. Is this also a picture of the cement
24 culvert through which you and your companion found
1 A. Yes.
2 Q. All right. Now if we could turn to
3 Prosecutor's Exhibit 22/7. Do you recognise what's
4 depicted in Prosecutor's Exhibit 22/7?
5 A. Yes, I do. This is the road, the path
6 leading to the Dam, and this is where we had been shot
7 at [indicates].
8 MR. HARMON: Indicating the red oval on the
9 right-hand side of the image.
10 Q. Now, you said at some point in time, Witness
11 P, that you left the killing field and you took shelter
12 in an area near some buildings that were nearby.
13 A. Yes. This would have been here, in this area
14 [indicates]. There was a village there.
15 MR. HARMON: Indicating to the left-hand side
16 of the road, the perpendicular road that comes from the
17 top of the image down toward the Dam, to the left of
19 Q. Now, let me --
20 MR. HARMON: I'm finished with those exhibits
21 now, Mr. Usher.
22 Q. And Witness P, thank you very much for
23 identifying them.
24 Lastly, my last question --
25 A. Thank you too.
1 Q. -- did you and did your companion ultimately
2 arrive on the Bosnian-held territory,
3 Bosnian-Muslim-held territory, on the 18th of July?
4 A. Yes, in the afternoon of the 18th of July.
5 Q. Witness P, I've concluded my examination.
6 Thank you very much.
7 A. Thank you.
8 MR. HARMON: Mr. President, I've concluded.
9 JUDGE RODRIGUES: [Interpretation] Thank you
10 very much, Mr. Harmon. I think that it would be a good
11 idea to have a short break, perhaps a 10-minute break,
12 and later there would be a longer break, around half
13 past 12.00. At this point we will have a only a
14 10-minute break. I should like to ask the Defence to
15 try and ask very direct and precise questions for the
16 cross-examination. A 10-minute break.
17 --- Break taken at 11.23 a.m.
18 --- On resuming at 11.34 a.m.
19 JUDGE RODRIGUES: [Interpretation] Witness P,
20 you're now going to answer questions that will be put
21 to you by Mr. Petrusic who is representing the Defence
23 Mr. Petrusic, you have the floor.
24 MR. PETRUSIC: [Interpretation] Good morning
25 Your Honours, good morning counsel.
1 Cross-examined by Mr.Petrusic:
2 Q. Good morning Witness P.
3 MR. PETRUSIC: [Interpretation] In accordance
4 with your suggestion, Mr. President, I will try and ask
5 my questions in a specific manner.
6 Q. Witness P, on the 11th of July, when you went
7 to Susnjari, did you know that the members of the VRS
8 had confiscated personnel carriers from the United
10 A. Yes, I did. I did know.
11 Q. I believe the witness has answered. We do
12 not need any further clarification in respect of this.
13 So when you started out from Susnjari towards
14 Konjevic Polje towards the territory of Tuzla, you said
15 that at one point the Serb soldiers mixed with you.
16 A. Yes.
17 Q. The Serb soldiers threw hand grenades which,
18 as far as I understand, contained some poisonous
20 A. Yes.
21 Q. Could you tell us, briefly, what kind of
22 consequences did those poisonous gases have?
23 A. Well, we became very thirsty and my eyes were
24 smarting and there were tears in our eyes.
25 Q. The fact that the Serb soldiers mixed with
1 you and that those grenades were thrown, can we
2 therefore conclude that the Serb soldiers were at the
3 same territory the same night?
4 A. No, when they threw grenades it was on the
5 first night it was only on the following day that the
6 Serb soldiers mixed with the Bosnian soldiers and
7 civilians who remained in the forest.
8 Q. It was on the 12th of July then?
9 A. No, it was on the 13th. The ambush was on
10 the 12th of July in the evening and --
11 Q. I apologise. Were there any opposing views
12 amongst the representatives of the Muslim population as
13 regards the situation in which you had found
14 yourselves, whether you should surrender or continue
15 with the break-through?
16 A. Could you please repeat your question? I
17 don't quite understand what you mean by "opposing
19 Q. Well, were there any different views as to
20 what should be done?
21 A. You mean amongst the Bosnian population?
22 Q. Yes.
23 A. Well, yes, people were trying to reach the
24 right decision. Some people wanted to surrender, some
25 were in favour of continuing.
1 Q. In view of that, were there any conflicts?
2 A. Well, most probably there were conflicts
4 Q. At Kasaba at the football field, General
5 Mladic spoke to you?
6 A. Yes.
7 Q. Did General Mladic mention at that point that
8 the units with dogs were at that location?
9 A. Yes, he did. He said that there were some
10 special units there with dogs and dog handlers, and
11 that every inch of the forest would be covered by them
12 and nobody would be able to cross the asphalt road.
13 Q. After that, you left for Kravica by trucks?
14 A. Yes.
15 Q. The Serb soldiers called out people from
16 Glogova, Kravica?
17 A. Not from Kravica.
18 Q. No, from Kamenica, I'm sorry, Osmac?
19 A. Yes.
20 Q. And Zedansko?
21 A. Yes.
22 Q. And those people would actually come out?
23 A. Well, yes, if they were from those villages.
24 But people didn't dare speak up. But those who did
25 were taken out.
1 Q. Do you know what was the reason for that, why
2 did they call people from those specific villages?
3 A. I don't know. Maybe they were their
4 neighbours, they were perhaps looking for their
5 neighbours, people from their area. I don't know.
6 Q. Did they mention Kravica, did they look for
7 people from Kravica?
8 A. No, not from Kravica. It wouldn't have been
9 possible. I don't understand what you mean.
10 Q. While they were calling people out, while
11 they were looking for specific people, people from
12 specific villages, did they also mention Kravica? And
13 my question to you is: Did they ask who had
14 participated in the take-over in Kravica?
15 A. I didn't hear that.
16 MR. PETRUSIC: [Interpretation]
17 Mr. President, I should like to show the witness, very
18 briefly again, the statement that he gave to the
19 investigators of the Tribunal on the 14th, the 15th,
20 the 16th of August of 1995.
21 THE REGISTRAR [Interpretation] Exhibit
23 MR. PETRUSIC: [Interpretation]
24 Q. On page five of the statement given on the
25 14th of August, 1995, second passage, the second
1 passage from the bottom, there is a portion of
2 highlighted text. The last sentence of the passage
3 reads as follows, "The Serbs asked who had participated
4 in the take over of Kravica when it fell under BH
6 A. I don't remember. I don't know how this was
8 Q. You signed this statement. Did you sign this
10 MR. HARMON: Mr. President, may I interrupt?
11 D-18 is a redacted statement so the signature of this
12 witness has been removed. We're prepared to stipulate
13 that the witness did, in fact, sign this statement.
14 JUDGE RODRIGUES: [Interpretation] Thank you
15 very much for your remark, Mr. Harmon. I, myself, have
16 realised that the witness is having some difficulties
17 as to his signature.
18 Mr. Petrusic, could you ask your question in
19 a different way? Could you ask him whether he signed
20 the statement, not whether he can see the signature on
21 the statement.
22 MR. PETRUSIC: [Interpretation]
23 Q. Witness P, your signature has been redacted
24 from the statement so we cannot see it. So my question
25 to you is whether this is, indeed, your statement, the
1 one that you gave to the Tribunal's investigator on the
2 14th, the 15th and the 16th of August, 1995?
3 A. I believe it is. I cannot tell you the exact
4 date the statement was given but I think this is my
6 Q. When you arrived in the school, the school
7 was a two-storey building, was it not?
8 A. Yes.
9 Q. Was only the first floor filled with people?
10 A. I believe that it was the first floor and the
11 ground floor. This is what I could tell judging from
12 the voices of the people, I believe it was full.
13 Q. How many trucks arrived in your group?
14 A. I said that there had been three trucks. Two
15 that were at the football field plus my truck. I don't
16 know if there were any trucks later on or before.
17 Q. Let us go back to Kravica and then I will
18 finish with my cross-examination. Was there any reason
19 why the Bosnian Serb soldiers would be interested for
20 that place, in particular?
21 A. I don't know.
22 MR. PETRUSIC: [Interpretation]
23 Mr. President, I have no other questions to ask of this
25 Q. Witness P, thank you very much.
1 JUDGE RODRIGUES: [Interpretation]
2 Mr. Petrusic, thank you very much.
3 Mr. Harmon, do you have any additional
5 MR. HARMON: I do not, Mr. President. Thank
7 JUDGE RODRIGUES: [Interpretation] Thank you,
8 Mr. Harmon.
9 Judge Riad.
10 JUDGE RIAD: Thank you, Mr. President. I
11 have a few questions.
12 Good morning, Witness P.
13 A. Good morning.
14 JUDGE RIAD: Let me just try to clarify some
15 points you mentioned from the beginning. You spoke of
16 the column of almost ten kilometres when you were
17 fleeing away and before you surrendered. And you said
18 that one-third had weapons; is that right? One-third
19 of you in the column had weapons.
20 Did you use these weapons, these weapons?
21 Had they been used against the Serbs while you were
22 fleeing? Was there exchange of fire, some kind of
23 fighting or were you just running away?
24 A. There were no combats until the ambush. The
25 people who had weapons were at the front of the column
1 and I was somewhere in the middle of the column. And I
2 know that there had been no fighting before the ambush,
3 but then after I had been captured, I don't know what
5 JUDGE RIAD: And when you were captured, you
6 were captured because they announced, as you said, they
7 asked you to surrender and that you will be exchanged;
8 is that right, that you will be safe?
9 But in spite of that, in spite of their
10 reassurance, some committed suicide. What promoted
11 this reaction if they knew that they would be
12 exchanged? Did the Serbs give them this assurance?
13 A. Well, I think that they simply didn't
14 believe. They didn't dare to believe in their
15 guarantees, that is, that they would be exchanged,
16 because they were killing people. They didn't pay any
17 attention to the age, regardless of whether it was an
18 old man or a child.
19 JUDGE RIAD: So there was killing before that
20 and you could not trust them. That was the feeling you
21 had, that already there was no reason -- there was
22 their precedents of killing?
23 A. Yes.
24 JUDGE RIAD: And when was that, with your
1 A. Yes.
2 JUDGE RIAD: But your group had started.
3 There was no killing before that. What gave them this
4 conviction that they would not -- that they be killed,
6 A. I said that there had been an ambush, and a
7 lot of dead bodies were scattered around the forest and
8 people simply couldn't believe that. They were afraid
9 of ending up in their hands. Thousands of people must
10 have remained in the forest, so they couldn't trust
11 them anymore when it comes to the surrender.
12 JUDGE RIAD: It was the ambush. Before that,
13 was there any media announcing or threatening, in the
14 media anything which gave them this conviction?
15 A. Yes. Throughout the war people were getting
16 killed, and there was an order, a command, that we
17 should go through the woods. Somebody had issued an
18 order to that effect. People didn't dare. I don't
19 know. They just didn't trust them. They went to the
20 woods. A lot of people got killed in the woods and a
21 lot of people killed themselves in the woods, because
22 they were afraid of ending up in their hands.
23 JUDGE RIAD: You were living in Srebrenica
24 before the 11th of July?
25 A. Yes.
1 JUDGE RIAD: And could you listen, could you
2 hear Serb radio and Serb television?
3 A. No. No. We didn't have electricity at all.
4 JUDGE RIAD: Now, at a certain stage, and I
5 follow the question the Defence counsel asked you,
6 certain people were called because they belonged to
7 certain places. You had people coming from Osmac, they
8 were asked to come out and so on. And as you said,
9 after that you heard screams and gunfire. At a later
10 stage, the order came by numbers. They would say,
11 "Bring four people now," "Bring ten people now." Also
12 at this second stage were these ten people or four
13 people, were they more or less coming from a certain
14 place or they would be without discrimination?
15 A. You haven't understood me, Your Honour. I
16 said that they were taken out individually, one by
17 one. During the night, while I was in that truck, five
18 people were taken off my truck. I don't know where the
19 Serbs had come from. The trucks had canvases and they
20 stood guard around the trucks all the time. They were
21 working in shifts. So there would always be between 10
22 or 15 Serb soldiers near the trucks, and they were
23 taking people out. And during that night, five people
24 were taken off my truck.
25 JUDGE RIAD: All right. I then, I repeat my
1 question more precisely. When you were in classroom 1
2 and classroom 2, you would hear an order, somebody
3 saying, "Send me ten." Would he say: Send me ten from
4 this village or that village? Or he would say: Send
5 me ten just from the whole group, without
7 A. No. I was in classroom number 3. And after
8 my hands had been tied up, I was transferred to
9 classroom number 2, that is, the next-door classroom.
10 And they were not saying anything to that effect,
11 anything involving a village. I could only hear a
12 voice coming from outside the school, or from the
13 entrance I would hear words, "Send me ten of them" or
14 "Send me 20 of them." This is while I was already on
15 the truck.
16 JUDGE RIAD: Ten of them, without saying ten
17 of which village, or anyplace; just ten?
18 A. Yes. Yes.
19 JUDGE RIAD: Now, when you were asked how
20 many people had been lying in the killing field, you
21 said there would be between 1.500 and 2.000. Was there
22 enough light for you at your escape to see the extent
23 of the lying bodies, or was it too dark? I mean, on
24 what did you base your estimation?
25 A. I could make an estimate on the basis of the
1 number of people who had been in the school. There
2 were three classrooms on that floor, so there must have
3 been up to 600 people there. So I believe the same
4 number of people would have been on the ground floor.
5 And I believe that there were other classrooms as
7 As to the area itself, I was able to observe
8 it on the next morning, when we came out of the ditch,
9 and also when we reached the village, because we were
10 about 150 or 200 meters away from the spot. So I could
11 see the whole area, and the whole area, the whole
12 location was filled with dead bodies.
13 JUDGE RIAD: Thank you very much.
14 A. Thank you too, Your Honour.
15 JUDGE RODRIGUES: [Interpretation] Thank you,
16 Judge Riad.
17 Judge Wald.
18 JUDGE WALD: Witness P, you told us in the
19 beginning of your testimony that the reason that the
20 men decided to go or were given orders to go in the
21 woods toward Tuzla rather than to Potocari was because
22 they didn't trust the Serbs not to kill them. They
23 thought they wouldn't get any protection from the UN.
24 When your group surrendered to the Serbs, what changed
25 their mind? Why did they feel they would be able to
1 survive if they surrendered to the Serbs, when earlier
2 they thought they wouldn't survive if they went to
4 A. It was very simple. The groups had been cut
5 off from the rest of the column, and they had a large
6 number of wounded. And the order was that the wounded
7 should be brought down and that we should all come down
8 to the road. All the while there was a white personnel
9 carrier travelling along the asphalt road, coming from
10 the direction of Konjevic Polje -- this is what I
11 forgot to mention -- moving towards Kravica. And it
12 passed our group and they threw out two bottles of
13 water. And I think that half of the people surrendered
14 and came out onto the asphalt road because they
15 believed it was a UN personnel carrier. And I think
16 that it actually carried Serb soldiers, because they
17 didn't say anything to us; they simply threw out two
18 bottles of water when they passed by us. And again
19 they went back in the direction of Konjevic Polje.
20 JUDGE WALD: You said you had a large group
21 of wounded that you carried down at the time of
22 surrender. Had most of those wounded been wounded in
23 crossfire of an ambush, or had they been wounded just
24 by the shelling from the Serbs? I mean, had they been
25 wounded in an actual crossfire between the armed people
1 in the column and the Serbs, or just as they were
2 trying to walk along and just got shelled?
3 A. Part of the group was exposed to a shelling
4 and part of the group -- people from the group were
5 wounded in the ambush that took place on that night.
6 JUDGE WALD: During the ambush there was
7 crossfire, right, between the Muslims who were armed in
8 the column and the Serbian soldiers. Okay.
9 Now, you mentioned about this incident with
10 the poisonous gas that made the throat get thirsty and
11 the eyes sting. Are you familiar with what's known as
12 tear gas? I mean, sometimes police use it to break up
13 crowds in demonstrations. It brings tears to your
14 eyes, but it doesn't have -- so far as we know, it
15 doesn't immediately blind anybody or anything like
16 that. Was this something like tear gas, or was it
17 anything you were familiar with before?
18 A. I couldn't tell you, Your Honour. I don't
19 know. I just heard someone saying at one point that
20 poisonous gases had been thrown at us. I wasn't very
21 familiar with it. And I tried protect myself, to
22 protect my face, and I was looking for a shelter.
23 JUDGE WALD: Did this happen only once? Was
24 this just one incident of poisonous gas or did it
25 happen other times, or did you hear other people say
1 that it happened to them, even if you weren't there?
2 A. I heard it from a number of people who were
3 there, who were ambushed. I don't know what happened
4 elsewhere or later on. I'm referring to the ambush
5 that took place on the night between the 12th and the
6 13th of July. The ambush was at the location called
7 Kamenicko, called Brdo.
8 JUDGE WALD: Okay. My last question is: You
9 said that from the burnt-out Bosniak village you were
10 able to see this artificial lake near the killing
11 fields, the one where the aluminum company dumped its
12 refuse. Could you estimate the time it would take to
13 drive from the killing fields to that lake? What would
14 you guess or think it would take? How long to make the
15 drive from the killing fields to that lake?
16 JUDGE RODRIGUES: [Interpretation] Witness P,
17 just a second. I'm sorry to interrupt.
18 Mr. Visnjic, you were about to say something,
19 probably in relation to "Tihomir Blaskic." I myself
20 didn't get that as a translation or interpretation.
21 Were you going to point to that?
22 MR. VISNJIC: [Interpretation] Yes,
23 Mr. President, you're right.
24 JUDGE RODRIGUES: [Interpretation] Well, I
25 didn't hear it in the French interpretation, but on the
1 transcript I can see that there is a kind of poisonous
2 gas that is called Tihomir Blaskic, apparently.
3 Judge Wald, maybe you will have to repeat
4 your question so that we can hear the answer.
5 Thank you, Mr. Visnjic.
6 JUDGE WALD: I'm sorry. I don't know what --
7 on my transcript, I don't see what question --
8 JUDGE RODRIGUES: [Interpretation] I'm afraid
9 it has already disappeared from the screen. I don't
10 know whether it has something to do with the method
11 used by the court reporters. Maybe we should pay
12 attention to this aspect, we should be mindful of this
13 particular feature of the transcript. It had something
14 to do with a question that you asked of the witness
15 regarding tear gas which the police sometimes uses and
16 the poisonous gas that the witness was trying to
18 Mr. Harmon, you might help us, perhaps.
19 MR. HARMON: I saw the name "Tihomir Blaskic"
20 and thought it was the wrong case, but it was at a
21 point in the transcript at 20.02.12 and it was in
22 response -- this witness gave an answer, and what I
23 wrote down was: "I just heard at one point that
24 poisonous gases Tihomir Blaskic ..." and it went on.
25 So that's the point that Mr. Visnjic stood up.
1 JUDGE WALD: Shall we ask the witness -- let
2 me ask the question to the witness again, and the
3 question was that whether the witness had any idea
4 whether this poisonous gas was like the tear gas.
5 A. I think it was something like that, because
6 the rumour spread among the people that something had
7 been thrown.
8 JUDGE WALD: All right. We'll take that as
9 your answer to the question. Now, I think we're still
10 in the middle of the last -- well, okay.
11 JUDGE RODRIGUES: [Interpretation]
12 Mr. Visnjic.
13 MR. VISNJIC: [Interpretation] Mr. President,
14 I think it would be sufficient to hear the transcript.
15 The witness didn't mention Tihomir Blaskic. He used a
16 word in Serbo-Croatian that sounded like this.
17 JUDGE WALD: Okay. That's helpful to know
18 that. But we have his answer later on to the straight
19 question anyway.
20 So just to answer my last question which I
21 had asked you about, how long you would have estimated
22 it took to drive from the killing field to the Dam, the
23 artificial lake?
24 A. We could only see from the village where our
25 men were. We could see that lake and the field where
1 we were executed. We couldn't get close. It is behind
2 the hill, around a bend. You have an access road to
3 the Dam so we couldn't really see the access to that
4 lake. In my estimate, it would take 15 or 20 minutes
5 to get there and back.
6 JUDGE WALD: Okay.
7 JUDGE RODRIGUES: [Interpretation] Thank you,
8 Judge Wald. I think the question of transcript will be
9 resolved as usual. The court reporters have heard the
10 answer and will make the necessary corrections so there
11 is no point in wasting too much time. But it has been
12 registered in the transcript that there was a problem.
13 Witness P, I also have some questions for
14 you. The 13th of July, the call for surrender by Serb
15 soldiers. In that call, they mentioned Geneva
16 Conventions [Realtime transcript read in error "general
17 Eva"] could you remind us in what context they
18 mentioned the Geneva Conventions?
19 A. I think that they were guaranteeing the
20 safety of our lives and an exchange. That was at least
21 my opinion because I had a wounded relative, and when
22 they mentioned the Geneva Conventions that nobody could
23 be hurt, that we would all be exchanged. So my opinion
24 was that they would guarantee our safety, our transfer
25 to free territory either by exchange with their
1 vehicles or with the help of UNPROFOR.
2 JUDGE RODRIGUES: [Interpretation] So we have
3 another type of convention. The Geneva Conventions, I
4 think all these things have to be reviewed. We are
5 talking about the Geneva Conventions and not the
6 "general Eva conventions".
7 Another question, did they expressly use the
8 words Geneva Conventions?
9 A. Yes, I personally heard them over the loud
10 speakers saying that we would all be exchanged in
11 accordance with the Geneva Conventions.
12 JUDGE RODRIGUES: [Interpretation] My second
13 question. Nova Kasaba, the football pitch, the whole
14 pitch was covered. My question, were the people
15 sitting or standing or both?
16 A. When I arrived, everybody was sitting down.
17 My group and those who came after me, we all sat down
18 on the grass field of the pitch.
19 JUDGE RODRIGUES: [Interpretation] General
20 Mladic arrived. Did he come alone or in the company of
22 A. I just saw the APC coming and I saw certain
23 soldiers who were standing right next to the APC. At
24 that moment, I didn't see whether anyone else came out
25 with him, I don't remember. Of course there were the
1 soldiers next to him, but I do know that he, himself,
2 and alone spoke to the people there.
3 JUDGE RODRIGUES: [Interpretation] When you
4 left the football pitch, you were boarded on trucks.
5 Those trucks, were they already there when you arrived
6 or did they come after you?
7 A. I didn't see them having come there before us
8 because trucks were passing by all the time. They were
9 driving women and children from Potocari so trucks and
10 buses were passing by. Some were going towards
11 Konjevic Polje, and the others were passing towards
12 Kasaba. So I don't know whether those trucks had come
13 there from Kasaba and were waiting for us or did they
14 come from some other place specially. I just know that
15 they were empty when we came off the field and started
16 boarding them.
17 JUDGE RODRIGUES: [Interpretation] While you
18 were at the football pitch, did you see buses passing
19 in the direction of Bratunac-Konjevic Polje with the
20 women and other people?
21 A. Yes, yes, we did see trucks and buses passing
22 from Konjevic Polje towards Kasaba. And in the
23 opposite direction, there were empty buses going
24 towards Konjevic Polje probably to Potocari again to
25 fetch some more women and children.
1 JUDGE RODRIGUES: [Interpretation] Witness P,
2 I have no further questions. You have answered a large
3 number of questions put to you.
4 Is there something that you would like to say
5 and that you didn't have an opportunity to say?
6 A. First of all, I should like to thank the
7 International Community and this Tribunal that the
8 truth, at least about Srebrenica, should be proven and
9 that some kind of justice is served although that is
10 difficult to do and that everybody should be punished
11 for this preconceived genocide in Srebrenica.
12 Let us take into account merely the fact that
13 each family in Srebrenica has lost two or more family
14 members. I lost 20 family members. My brother, their
15 wives, aunts, cousins and so on.
16 So I wish once again to thank the
17 International Community and, if it can, to resolve this
18 problem of genocide and for all the perpetrators to be
20 JUDGE RODRIGUES: [Interpretation] Thank you
21 very much, Witness P, for coming.
22 You have many years before you to live. I
23 think you have a very good reason to live, and that is
24 through your actions and words, you should contribute
25 to a world avoiding a catastrophe of this kind, and I
1 say that regardless of who is responsible.
2 Whoever committed these acts regardless of
3 the ethnic group they may belong to is horrific for all
4 human beings and the human race.
5 Witness, don't move for the moment. I think
6 that we have some exhibits to deal with. We have
7 Defence exhibit D-18.
8 Mr. Harmon, I think you don't have any
9 exhibits to tender now.
10 MR. HARMON: I don't have any exhibits.
11 JUDGE RODRIGUES: [Interpretation]
12 Mr. Petrusic, then.
13 MR. PETRUSIC: [Interpretation]
14 Mr. President, the Defence would like to tender into
15 evidence Exhibit D-18, but it seems to me that the --
16 some redactions need to be made in the Serbian version
17 which the witness has, but the English version has
18 already been redacted to remove all names that might
19 reveal the identity of the witness or other protected
21 JUDGE RODRIGUES: [Interpretation] Thank you,
22 Mr. Petrusic.
23 Mr. Harmon.
24 MR. HARMON: I only have a couple comments
25 about this exhibit, but I need to go into private
1 session to do so. It will only take a couple of
3 JUDGE RODRIGUES: [Interpretation]
4 Mr. Dubuisson, shall we go into private session now,
6 Please be seated, Mr. Petrusic.
7 [Private Session]
4 [Open session]
5 JUDGE RODRIGUES: [Interpretation] I see we
6 are in open session now.
7 I think, Mr. Harmon, that it would be better
8 to have the break, which we had planned before, to have
9 it now, give the opportunity to Witness P to leave, and
10 when the Chamber comes back, the other witness will be
11 in the courtroom.
12 Will he have the same protective measures as
13 this one, Mr. Harmon?
14 MR. HARMON: He will.
15 JUDGE RODRIGUES: [Interpretation] Very well.
16 Witness P, good-bye. We wish you a safe journey home.
17 We're going to have a half hour break now and we will
18 resume work by hearing the next witness.
19 A. Thank you too, Your Honours.
20 [The witness withdrew]
21 --- Recess taken at 12.20 p.m.
22 --- On resuming at 12.56 p.m.
23 [The witness entered court]
24 JUDGE RODRIGUES: [Interpretation] Good
25 afternoon, Witness. Can you hear me? Can you hear
2 THE WITNESS: Yes.
3 JUDGE RODRIGUES: [Interpretation] You're
4 going to read the solemn declaration that the usher is
5 going to give to you, please.
6 THE WITNESS: [Interpretation] I solemnly
7 declare that I will speak the truth, the whole truth,
8 and nothing but the truth.
9 WITNESS: WITNESS Q
10 [Witness answered through interpreter]
11 JUDGE RODRIGUES: [Interpretation] You may be
12 seated, Witness. The registrar is going to show you a
13 piece of paper with your name written on it. You're
14 going to look and tell us, yes or no, if that is your
16 THE WITNESS: Yes.
17 JUDGE RODRIGUES: [Interpretation] So that is
18 indeed your name. Are you comfortable? Are you at
20 THE WITNESS: Yes.
21 JUDGE RODRIGUES: [Interpretation] You are now
22 going to answer questions which the Prosecutor, in this
23 case, Mr. McCloskey, is going to put to you.
24 Mr. McCloskey, you have the floor.
25 MR. McCLOSKEY: Thank you, Mr. President.
1 Examined by Mr. McCloskey:
2 Q. Witness, you know I'll be asking you some
3 questions, and please just do your best to answer
4 them. And if you don't know an answer, that's fine, or
5 if you can give us estimates or rough estimates about
6 certain things, just do your best. Do you understand
8 A. I'll do that.
9 Q. Okay. And how old are you?
10 A. I'm 28.
11 Q. And are you a Muslim by faith?
12 A. Yes.
13 Q. And I want to take you back to July 11th,
14 1995. Where were you living then?
15 A. Srebrenica, the village of Suceska.
16 Q. And who were you living with?
17 A. I was living with my parents and my wife.
18 Q. And what did you decide to do on July 11th?
19 A. I decided to go to Jaglic and the family to
21 Q. Why did you decide to go to Jaglic?
22 A. I didn't dare to go to Potocari.
23 Q. Why not?
24 A. Well, I was afraid they would kill me.
25 Q. The Serb soldiers that took over the town of
1 Srebrenica, you mean?
2 A. Yes.
3 Q. And about what time on July 11th did you get
4 to Jaglic?
5 A. It must have been dark already.
6 Q. Can you give us a rough estimate of how many
7 people were assembled there at that time?
8 A. Ten to fifteen thousand. A large crowd.
9 Q. And what did the crowd decide to do?
10 A. They decided to head for Tuzla.
11 Q. How did you get the word that that was the
13 A. I heard the other men talking.
14 Q. And when did you decide -- or when did you
15 actually head out with the group and go towards Tuzla?
16 A. On the 12th, in the afternoon.
17 Q. So you were near the -- farther back of the
18 column, I guess.
19 A. [No interpretation]
20 Q. So did you spend one night in the woods, and
21 then, when you got near the Nova Kasaba area, get
22 captured, on the 13th, in the morning?
23 A. Yes.
24 Q. Can you tell us about your capture, how that
25 happened? Can you just try to explain a little bit who
1 you were with and who captured you and where it
2 happened, that kind of thing?
3 A. Yes. I was with ten other men. We were
4 going to cross the asphalt road. However, Serb
5 soldiers captured us. We didn't manage to cross.
6 Q. And did anybody in the group of your ten have
7 any weapons?
8 A. Yes. One had a pistol only.
9 Q. And what happened to the pistol?
10 A. They seized it, the Serb soldiers.
11 Q. Did you get in any firefight or any exchange
12 of fire with this group of Serb soldiers, or did they
13 just surround you and capture you?
14 A. They just surrounded us and captured us.
15 Q. And what happened after that? What did the
16 Serb soldiers do with you, your belongings, and where
17 did they take you?
18 A. They took away our bags with food in them,
19 then they ordered us to put our hands behind our heads
20 and to proceed towards Nova Kasaba.
21 Q. And about what time did this happen on the
23 A. About seven o'clock in the morning.
24 Q. And where did they take you?
25 A. To the elementary school in Kasaba. I think
1 that was where the troops were, a kind of barracks, and
2 we were imprisoned there.
3 Q. Serb troops were in the barracks?
4 A. Yes.
5 Q. Can you tell how many Serbs were in the
6 barracks at that point when you were put there?
7 A. A group of some 10 to 20 people.
8 Q. And where were you put?
9 A. In a small room, like a kind of prison.
10 Q. Did you see any Dutch soldiers around these
11 barracks anywhere?
12 A. No.
13 Q. And had the VRS soldiers provided you with
14 any water or food yet at this time, when you were first
15 put into the barracks?
16 A. Yes.
17 Q. When did they give you any water? When did
18 they first give you water?
19 A. Maybe after some 20 minutes.
20 Q. Were there wounded among you when you came
21 out of the woods and were captured?
22 A. No.
23 Q. And what happened when you were in the
24 barracks, if anything?
25 A. I heard the voice of a woman crying out near
1 Jadar. The soldiers went down there and they brought
2 over another man.
3 Q. The Serb soldiers went outside the barracks
4 somewhere where you heard these noises coming from, and
5 brought a man back?
6 A. Yes.
7 Q. And this was a Muslim man?
8 A. Yes.
9 Q. And eventually were you taken somewhere else
10 that day outside of those barracks?
11 A. Yes.
12 Q. About what time were you taken outside of the
13 barracks, and where were you taken?
14 A. At 2.00, they ordered us to put our hands
15 behind our backs, to go in line one by one towards the
17 Q. And were you and your group then marched down
18 the road to the stadium?
19 A. Yes.
20 Q. When you say the stadium, what kind of a
21 place was this?
22 A. It was a football pitch.
23 Q. And were you still in Nova Kasaba?
24 A. No, a little bit further from Nova Kasaba.
25 Q. Just right outside Nova Kasaba?
1 A. Yes.
2 Q. And do you know roughly how many soldiers
3 that were guarding your group as you were walking
4 towards the football pitch?
5 A. Two to three soldiers.
6 Q. And what were they wearing?
7 A. Camouflage uniform.
8 Q. Was that the same kind of uniform the
9 soldiers that captured you were wearing?
10 MR. McCLOSKEY: I think I heard him say
11 "yes", but I didn't hear a translation.
12 THE INTERPRETER: Could the microphone be
13 placed closer to the witness, please.
14 MR. McCLOSKEY:
15 Q. Were the soldiers that captured you different
16 from the soldiers that were guarding you around the
18 A. They had the same uniforms, but they weren't
19 the same ones.
20 Q. How about the soldiers that took you to the
21 football pitch? Were those the same soldiers that were
22 guarding you at the barracks or were those different
24 A. Could you repeat the question, please?
25 Q. The soldiers that took you to the football
1 pitch, I think you said around three that walked you
2 down to the football pitch, had those soldiers been
3 guarding you at the barracks or were they new guys?
4 A. They were different soldiers.
5 Q. Do you know roughly how many soldiers were
6 guarding you at the barracks?
7 A. A group was in the barracks. There was some
8 outside as well. Ten to twenty soldiers in all.
9 Q. And when you got to the football pitch, can
10 you describe the scene there; how many people, who were
11 they, what was happening?
12 A. There were about 1.500 to 2.000 men who were
13 sitting on the field in rows surrounded by Serb
15 Q. So 1.500 to 2.000 Muslim men; is that right?
16 A. Yes.
17 Q. Can you give me an estimate of how many Serb
18 soldiers you saw around them?
19 A. There were quite a number of them. I really
20 don't know the number. There was an APC behind our
21 backs. The soldiers were all around surrounding the
22 playing field. There was no more than a metre between
23 each one of them and the next one.
24 Q. Did you see any other equipment besides this
1 A. Yes.
2 Q. What else did you see?
3 A. I saw two more APCs on the asphalt road, and
4 a UN APC from which no one came out. It was just
5 standing there.
6 Q. And were all these soldiers that were around
7 the Muslim men, were they armed?
8 A. Yes.
9 Q. And this football pitch, how much of the
10 football pitch was taken up by these Muslim men?
11 A. More than half.
12 Q. And did you see any Muslim men continue to
13 arrive while you were there at the football pitch?
14 A. Yes, I did see it.
15 Q. And in what direction were they arriving
17 A. They were coming from Konjevic Polje along
18 the asphalt road, and they brought some from the
19 woods. There was some who were wounded too. They
20 bandaged the wounded and put them to the other side.
21 Q. Who bandaged the wounded Muslims?
22 A. The Serb soldiers.
23 Q. About how many wounded Muslims did you see
24 get bandaged by the Serb soldiers?
25 A. Ten or so.
1 Q. And the arrival of the Muslim men to the
2 soccer field, were they arriving by foot or by vehicle
3 of some sort?
4 A. On foot.
5 Q. And can you tell us what you remember
6 happening while you were there at that football pitch?
7 A. The soldiers told us that General Mladic
8 would come. And a short while later he came escorted
9 by two cars and he held a speech. He told us that we
10 would all be exchanged and that they were not
11 criminals. He said that we should have all surrendered
12 because not a bird could pass through their lines as
13 there were hundreds of their lines. And he said that
14 we would go to Bratunac for lunch. And that he would
15 organise groups to collect the wounded in the woods,
16 and for the dead to be buried where their families want
17 them to be buried.
18 Then he ordered the soldiers to make a list
19 of the names of all those captured. At that moment, a
20 prisoner got up and the Serb soldiers approached. They
21 kicked him and hit him with their rifle butts. And
22 then one soldier took out his pistol and killed him.
23 And he was thrown into the other. Mladic was present.
24 He didn't respond in any way.
25 A camera was shooting the prisoners and
1 Mladic as he was delivering his speech. When the lists
2 were made, Mladic left towards Konjevic Polje.
3 Q. Did you put your name on this list?
4 A. Yes.
5 Q. And did you see others put their name on this
7 A. Yes.
8 Q. Could you tell if you were being filmed when
9 you had to put your name on the list?
10 A. No.
11 Q. When you eventually left that football pitch,
12 about what time was it?
13 A. It was close to dark, maybe an hour before
14 night fell.
15 Q. And how were you transported away from this
16 football pitch?
17 A. Buses came. They stopped. They ordered us
18 to get into the buses. When the buses were full, we
19 started towards Konjevic Polje. We passed through
20 Konjevic Polje towards Sandici. To the left, I saw a
21 group of men who were sitting down in a circle
22 surrounded by Serb soldiers.
23 Q. Was this near Sandici that you saw these men
24 sitting in a field surrounded by Serb soldiers?
25 A. Yes.
1 Q. What else did you see on your journey?
2 A. I saw near Kravica on the right a kind of
3 hangar and dead people at the entrance.
4 MR. McCLOSKEY: Can we show the witness
5 Exhibit 8/4. And can we first let him take a look at
6 that far right-hand side of the picture and then if we
7 could put that on the ELMO.
8 Q. And Witness, if you could pick up the pointer
9 and point out on the picture itself that sits on that
10 funny machine next to you where you saw the bodies.
11 A. Here [indicates].
12 MR. McCLOSKEY: And the record should
13 indicate that the witness has pointed to the centre of
14 the large opening in the centre of the photograph.
15 Q. As you were driving by, were you able to tell
16 how many bodies were there?
17 A. Four or five bodies.
18 Q. Could you look all the way in the warehouse,
19 or were these just the ones that were near the opening?
20 A. Those were bodies that were close to the
22 Q. Did you notice any damage to the building
23 that the bodies were in as you drove by it?
24 A. Yes. The traces of bullets could be seen on
25 the building.
1 Q. Did you hear anything going on around Kravica
2 while you were driving by it?
3 A. I heard shooting behind the hangar.
4 Q. Thank you. That's fine. And shortly after
5 driving by Kravica, did you arrive to Bratunac?
6 A. Yes.
7 Q. And did you stop in Bratunac?
8 A. Yes.
9 Q. And did you spend the night on the bus in
11 A. Yes.
12 Q. Do you remember what was written on the side
13 of the bus that you were in?
14 A. "Boksit Trans-Milici" was written on the bus.
15 Q. What kind of bus was it? Big bus, small
17 A. A big, double bus.
18 Q. And how full of Muslim men was it?
19 A. It was very crowded.
20 Q. On your trip from Nova Kasaba to Bratunac,
21 were there any Serb soldiers on that bus with you?
22 A. Yes.
23 Q. How many?
24 A. Two.
25 Q. Were they armed?
1 A. Yes.
2 Q. And wearing camouflage uniforms?
3 A. Yes.
4 Q. And when you got to Bratunac and stopped,
5 could you tell where you were?
6 A. I knew that that is -- they said that we were
7 going to Bratunac. I saw the town, so I assumed it was
9 Q. Do you know where you stopped, what kind of
10 buildings were around you where you stopped and spent
11 the night on that bus?
12 A. I think there was a school nearby.
13 Q. And were there other vehicles that also
14 stopped in Bratunac around the same location you were?
15 A. There were smaller cars.
16 Q. Any buses or trucks full of Muslim men at the
17 location where you were besides your bus?
18 A. There were more buses behind me.
19 Q. Could you tell how many might have been there
20 that night?
21 A. Four or five buses.
22 Q. And could you tell if they were filled with
23 Muslim men?
24 A. I couldn't see, but I think that Muslims were
1 Q. And what happened that night that you stayed
2 in this bus in Bratunac?
3 A. We heard shooting throughout the night, and
4 they would take people out of the bus who never came
5 back to the bus.
6 Q. How many people, if you know, were taken out
7 of your bus that didn't come back?
8 A. Four or five.
9 Q. And that was Serb soldiers that took them out
10 of the bus?
11 A. I think they were, because we didn't dare
12 look. Our heads were bowed down.
13 Q. Did a Serb soldier stay on your bus all night
14 guarding you?
15 A. No. They were outside.
16 Q. How many Serb soldiers were you able to see
17 outside your bus and around that area that night?
18 A. I don't know exactly, but a lot of them were
19 passing by the buses.
20 Q. More than 20, less than 20?
21 A. Fifteen to twenty.
22 Q. Okay. And the next morning, what happened?
23 That would be the morning of July 14th.
24 A. Yes. The driver got out. He had started the
25 engine and he had turned on the heating and then got
1 out. We remained in the bus. And then it was in the
2 afternoon and people were fainting because of the
3 heat. Later on a soldier arrived and told us that we
4 were going to be exchanged.
5 Q. How long were you in that bus with the heat
7 A. Two to three hours.
8 Q. Did they give you any water while the heat
9 was going on that bus on that day? Sorry, you have to
10 answer a little bit out loud. I know this is not easy,
11 but the microphone didn't pick up your answer. Were
12 you given water while the heat was going on the bus?
13 A. No.
14 Q. So finally when this soldier showed up and
15 says you're going to be exchanged, shortly after that
16 did the bus -- did your bus start to leave?
17 A. It started to leave, perhaps not right away,
18 but maybe half an hour later.
19 Q. And did your bus drive northward up towards
20 and through Zvornik and up to the area of Pilica?
21 A. Yes. First it was driving along a macadam
22 road which at one point became asphalt road. We were
23 not allowed to watch, but I noticed that it was going
24 towards Zvornik.
25 Q. And where, when you got to the Pilica area,
1 where did the bus stop, and what happened?
2 A. The bus stopped above the school, and the
3 soldiers ordered us out and told us to run up towards
4 the school, and they put us in a hall which was
5 completely crowded.
6 Q. Okay. How many soldiers were on your bus
7 trip from Bratunac to Pilica school?
8 A. You mean on the buses, in the buses, how many
9 soldiers there were?
10 Q. Yes. How many soldiers were in your bus when
11 it drove from Bratunac to the Pilica school?
12 A. Two soldiers.
13 Q. Were those soldiers you recognised from your
14 time in Bratunac, or were these two new people?
15 A. I think they were different, two new people.
16 Q. And they were armed?
17 A. Yes.
18 Q. And when you arrived at the school, how many
19 soldiers did you see outside the school and around the
20 bus that you got off of?
21 A. There were 15 to 20 soldiers.
22 Q. And how were they dressed?
23 A. In camouflage uniform. They were armed.
24 Q. And this place they took you, can you
25 describe what kind of a hall it was?
1 A. It was a kind of gymnasium that belonged to
2 the school. It had baskets for basketball.
3 Q. And when you first arrived in this gymnasium,
4 how many Muslim men were in the gymnasium before you?
5 A. Less than half. Later on the hall filled up.
6 Q. Could you tell how many buses were -- or
7 trucks were travelling along with you on your trip to
9 A. I think four to five buses.
10 Q. And could you tell if there were any Muslim
11 men in any other part of the school besides the
12 gymnasium where you were?
13 A. Yes, I noticed some people on the steps.
14 There was a very wide stairway leading to the upper
15 floor. Some were standing and some were sitting, and
16 we passed by on our way to the gymnasium.
17 Q. Okay. After you were put in the gymnasium
18 that first day at the Pilica school and it filled up
19 with people, did you volunteer to go get water?
20 A. Yes, I volunteered together with four other
21 men. We took some buckets and we went down the wide
22 stairway which was on the other side past the football
23 field. And further down, there was a tower and a water
24 point with two fountains.
25 When we got there, it was already dark and we
1 started filling up the buckets with water. At that
2 point, we heard a bus approaching the school building.
3 Later on, we heard some noise and shooting
4 and the guard ordered us back to the gymnasium as
5 quickly as possible so we went back.
6 Q. What kind of noise did you hear before you
7 heard the shooting?
8 A. I could hear people crying for help.
9 Q. And could you tell what area around the
10 school these cries of help were coming from?
11 A. Could you please repeat your question?
12 Q. Could you tell what direction or what area
13 these cries of help were coming from?
14 A. Yes, from behind the school.
15 Q. And you'd heard a vehicle arrive before
16 hearing the cries of help; is that right?
17 A. Yes. I think I could hear a bus.
18 Q. Was the sounds of that bus and the cries of
19 help from the people coming from the same general area?
20 A. Yes.
21 MR. McCLOSKEY: If we could show the witness
22 Exhibit 23/1. Could we use one that doesn't have
23 markings on it. I've got my copy of 23/1. I hope that
24 doesn't confuse things too much but, I'm sorry, I
25 didn't realise that had all those markings.
1 And should we give it another number for the
3 THE REGISTRAR [Interpretation] Yes, it will
4 be Exhibit 24/5.1.
5 MR. McCLOSKEY: All right. Well we'll take
6 care of that after the witness, I think, if that's all
8 Q. Now, Witness, if you take a look at this
9 photograph which has been placed on the ELMO. And
10 first of all, could you point with your pointer the
11 area where the bus pulled up that you were in the day
12 you arrived at the school?
13 A. The bus stopped here [indicates].
14 MR. McCLOSKEY: Indicating for the record the
15 asphalt road or the -- well, the road right in front of
16 the school.
17 Q. And where did you enter the school? Can you
18 point us out the entrance that you went in with that
20 A. Yes. This way [indicates] and then here
22 MR. McCLOSKEY: And for the record, the
23 witness went around to the left of the school building
24 and then into a side entrance near the building that is
25 perpendicular to what looks like the main building in
1 the school.
2 Q. And is that building that you've got your
3 pointer on the gym?
4 A. Here [indicates].
5 Q. Yes. Is that the gym, that's where you went
7 A. Yes.
8 Q. And can you now show us the route you took to
9 get the -- to go down and get the water where you heard
10 these screams and the shooting?
11 A. I got out here [indicates]. There are some
12 steps here. We went across the football pitch, past
13 the tower and reached this area here [indicates].
14 MR. McCLOSKEY: Okay. And for the record,
15 the witness went out the back of what appears to be the
16 back of the gym by what looks like a big concrete
17 playground, past the playground, in front of the tower
18 and down into some trees.
19 Q. Was it down by the water that you heard the
20 bus arrive and the people call for help?
21 A. Yes.
22 Q. And shortly after that is when you heard
24 A. Yes.
25 Q. How long did that shooting go on for?
1 A. Not for very long. Five to ten minutes
2 because we were taken back immediately to the
4 Q. Could you still hear the shooting when you
5 were in the gymnasium?
6 A. No.
7 Q. Do you know about what time of day it was
8 when this shooting started?
9 A. It was already dark.
10 Q. And that was the night of the 14th?
11 A. Yes.
12 Q. Can you describe what occurred in the
13 gymnasium that night, the night of the 14th, when you
14 and all the men were crowded inside that gymnasium?
15 A. Yes. It was stuffy. Two or three men died
16 there from lack of air.
17 Q. What happened to their bodies?
18 A. I think that they were taken out by our
20 Q. Was anyone given any medical treatment in
21 that gym that night?
22 A. No.
23 Q. Was the water that was brought back by you
24 and your group enough to provide everyone with enough
1 A. No.
2 Q. Did these soldiers provide anyone in that gym
3 with any food that night?
4 A. Yes. I went out. I went to the toilet, and
5 I know that when I got in, I fainted. And when I
6 recovered, when I came to, I was in the corridor. A
7 soldier gave me some pate and a piece of bread and took
8 me back to the gym.
9 Q. Did you see anybody besides yourself get any
10 food that night?
11 A. No.
12 Q. And did you spend all the next day inside the
14 A. Yes.
15 Q. That was July 15th. What happened in the
16 gym, if anything, on that day, on July 15th, with all
17 the people crowded in there?
18 A. They were taking men out. I'm sorry, I made
19 a mistake. Could I start again?
20 Q. Sure.
21 A. On that day, Serb soldiers arrived and they
22 took jewellery, watches, money from those who had
23 them. Then they came later on again. They were asking
24 for German marks, and they told us if we don't manage
25 to collect the money, that we would all be killed.
1 They came two more times, but nobody had that money.
2 MR. McCLOSKEY: We're done with the exhibit.
3 Thank you very much. I'm sorry.
4 THE INTERPRETER: The witness mentioned the
5 amount of money, but we couldn't hear him.
6 MR. McCLOSKEY:
7 Q. Witness, I'm informed that you need to speak
8 up a little bit more, and could you tell us the amount
9 of money again?
10 A. 10.000 German marks.
11 Q. Did anything come of any of that?
12 A. No. No, because nobody had that money.
13 Whatever people had had already been taken away by the
14 Serb soldiers.
15 Q. Okay. And then what happened after they
16 tried to take all the people's money and their
18 A. After that, the next night, the men were
19 being taken out from the gym. Some would come back,
20 some didn't. The next day, I noticed that there were
21 fewer of us in the gym.
22 Q. So that night, you're talking about the night
23 of July 15th and the morning of July 16th, you noticed
24 there weren't as many people in the gym; is that right?
25 A. Yes.
1 Q. When men were taken out of the gym, did you
2 hear any sounds?
3 A. No.
4 Q. And were there any soldiers inside the gym
5 guarding you during your stay there or did they stay
6 outside the gym itself?
7 A. Yes, they were at the entrance to the gym.
8 Q. Could you tell how many Serb soldiers were
9 outside the entrance of the gym and were around the
10 school area during your stay at the school?
11 A. There were two to three soldiers at the
12 entrance. There was a group of them in the corridor,
13 perhaps five to ten people. There may have been 20 of
14 them in total over there.
15 Q. Now, you spent two nights at this school, the
16 14th and the 15th. Do you know if the Serb soldiers
17 changed shifts, or was it the same group the whole time
18 you were there?
19 A. I think that they changed shifts, but I'm not
21 Q. Okay. On the morning of July 16th, what
23 A. Serb soldiers came, and one of them said that
24 some people thought that they had killed a number of
25 young men, and he said, "Let all the young men leave
1 the gym, one by one, because they will be exchanged."
2 I was next to the entrance, so I stood up and
3 got out of the gym. And as we were leaving the school
4 building, they told us to line up against a wall, put
5 our hands against our backs, and this is where our
6 hands were tied up.
7 Three buses were parked there, and we climbed
8 onto the second bus. There were three of us sitting in
9 one row of seats. And once the buses were filled up,
10 they left.
11 They started along the same road we had taken
12 when we came to the school. At one point we turned
13 right and reached a meadow. On that meadow I saw a
14 large number of dead bodies. The buses stopped on a
15 road near the meadow, and I could see a hangar there
16 and people lying about, killed.
17 Q. Why don't you tell us, continue to tell us
18 this story of what happened.
19 A. When the buses stopped, soldiers started
20 taking out groups of people who were tied up. They
21 were taking them in one column. They had to put their
22 hands behind their backs. Those were groups of ten
23 people which were taken to the area where the dead
24 bodies were, on the meadow, and this is where they were
25 killed. And then they would shoot at each one of them
1 individually, and this is what I could observe from the
3 After the first bus had emptied, it was our
4 turn. They took out two groups of people from my bus,
5 and I was in the third group of people. As we were
6 getting out of the bus, they asked if anyone had any
7 relatives abroad so that they could send the money for
8 the exchange, and some people spoke up and they were
9 then singled out. And I was taken to the meadow where
10 the bodies were.
11 They ordered us to stop, and we stopped.
12 There was a group of Serb soldiers there. They were in
13 a line and they were shooting at us from their
14 automatic rifles and from machine-guns. When they
15 opened fire, I threw myself on the ground. My hands
16 were still tied behind my back and I fell on my
17 stomach, face down. And one man fell on my head. I
18 think that he was killed on the spot. And I could feel
19 the hot blood pouring over me.
20 The shooting continued and then they ordered
21 soldiers to shoot people individually. And I could
22 hear a voice saying that they shouldn't shoot people in
23 their heads, so that their brains wouldn't spill out,
24 but rather to shoot them in their backs.
25 They shot me at my back. My hands were tied
1 on my back, but a bullet passed under my left armpit,
2 through my shirt, and it only scratched me. And I
3 remained there, lying. I could hear them ask if
4 anybody was wounded. They said that they would be
5 bandaged. And some people spoke up and then they were
6 finished off.
7 I could hear one man crying for help. He was
8 begging them to kill him. And they simply said that
9 "Let him suffer. We'll kill him later." They kept
10 bringing in groups of people on that day, also in the
11 afternoon, maybe for about four hours.
12 MR. McCLOSKEY: Could we show the witness
13 Exhibit 24/5. Excuse me. It's now 24/5/1. My
15 THE REGISTRAR: [Interpretation] At the end of
16 the transcript I will correct what was said a moment
17 ago. The previous exhibit was 23/1/1.
18 MR. McCLOSKEY: Could you move that over a
19 little bit so that black dot -- there we go.
20 Q. Now, last night in my office you had a chance
21 to look at this photograph, and could you first take
22 the pointer and point to where your bus stopped.
23 A. Here [indicates].
24 MR. McCLOSKEY: Okay. And for the record,
25 he's pointing at the road that has vehicles on it that
1 goes sort of in a -- well, it would be a north/south
2 position, perpendicular to the road that goes across
3 left and right.
4 Q. Can you show us the direction that Muslim men
5 were marched to the killing fields?
6 MR. McCLOSKEY: Okay. And for the record,
7 the witness has just shown us that they walked across a
8 big open field, over to the area of a black spot.
9 Q. Now, did you have a chance to write in that
10 black spot, or I helped you write in that black spot
11 last night?
12 A. I knew where it was. This is where the
13 execution took place. And there is more over there.
14 Q. And is that black spot roughly where you were
15 when they tried to execute you?
16 A. Yes.
17 Q. And how many soldiers did you see taking part
18 in the execution?
19 MR. McCLOSKEY: I think we're done with that
20 exhibit. Thank you.
21 A. Ten soldiers.
22 Q. And how many were taking part in the
23 escorting of the victims over to the killing fields?
24 A. Three or four soldiers.
25 Q. And you said you saw a machine-gun and
1 automatic weapons. You were a soldier for some time,
2 were you not?
3 A. Yes.
4 Q. What kind of machine-gun was that that you
5 saw in the hands of the executioner?
6 A. M-84. M-84.
7 Q. And while you were lying there, did you hear
8 a vehicle arrive and unload something?
9 A. I did. That was in the evening. We heard a
10 vehicle. It came close to me. It unloaded something
11 and went away again. Later, during the night, I saw
12 that they were the bodies of killed men that were
13 brought there.
14 Q. All right. Now, I'm going to -- we're going
15 to go a little quicker now. I'll ask you a few
16 questions which you can answer yes or no, and if you
17 feel like you need to explain them, that's okay too.
18 But did you spend the night on the killing field there?
19 A. Yes.
20 Q. And the next day you spent some time hiding
21 under a bridge?
22 A. Yes.
23 Q. And were you able to hear anything coming
24 from the direction of the killing fields while you were
25 hiding under that bridge?
1 A. Yes.
2 Q. What?
3 A. I heard the sounds of machines. I couldn't
4 see it, but I could hear it. I could hear vehicles
5 moving, nonstop, towards that place, and going back
6 again. This went on all day.
7 Q. And a short time later did you come across an
8 older man, whose name you know? But don't say who it
10 A. Yes.
11 Q. And did you and he travel together for a few
12 days and then meet another man?
13 A. Yes.
14 Q. And did that second man eventually get lost
15 from you and the older man?
16 A. Yes.
17 Q. And then did you and the older man finally
18 decide to turn yourselves in?
19 A. Yes.
20 Q. And why did you decide to do that?
21 A. We couldn't walk any further. We were
22 exhausted. We hadn't had anything to eat since our
24 Q. And after you turned yourself in, did you go
25 to a cafe where a Serb man looked after you?
1 A. Yes.
2 Q. Can you describe that?
3 A. Yes. When they captured us or rather when we
4 surrendered, a small bus, a mini bus, there were two
5 military policemen in it. They took us in and they
6 drove us to a shop. They got off, sat at a table to
7 have a drink, we stayed in the bus.
8 Then a man came up to us, gave us each a
9 packet of cigarettes and a pint of fruit juice, a litre
10 and he introduced himself but I've forgotten his name.
11 He asked us whether we were hungry. We said we were.
12 He took us to give us food to eat and he made us
13 coffee. Then they put us back on the bus and took us
14 back to Karakaj.
15 In Karakaj, there was a military truck with
16 some 20 men on it who had also been captured. I got on
17 to the truck, I got on to the truck. They put hand
18 cuffs on my hands. And we were driven to Batkovici, to
19 the camp there.
20 Q. What day, if you recall, were you finally
21 released and made free?
22 A. From the camp?
23 Q. Yes, from the camp.
24 A. On the 26th of the December, 1995.
25 MR. McCLOSKEY: I have no further questions,
1 Mr. President.
2 JUDGE RODRIGUES: [Interpretation] I think
3 that we need a break now. Perhaps a short break, 15
4 minutes. And then the Defence will ask its questions.
5 --- Recess taken at 2.05 p.m.
6 --- On resuming at 2.21 p.m.
7 JUDGE RODRIGUES: [Interpretation] Witness Q,
8 you are now going to answer questions which
9 Mr. Petrusic, the Defence attorney, will ask you,
11 Mr. Petrusic, you have the floor.
12 MR. PETRUSIC: [Interpretation] Thank you,
13 Your Honours.
14 Cross-examined by Mr. Petrusic:
15 Q. Good afternoon sir?
16 A. Good afternoon.
17 Q. You lived in Suceska from 1992 until
18 Srebrenica fell?
19 A. Yes.
20 Q. Do you know that in that location, Mr. Zulfo
21 Tursunovic lived there and was militarily active there?
22 A. Yes.
23 Q. He was one of the commanders in the military
25 A. Yes.
1 Q. Did he or somebody from his staff issue the
2 order for the able-bodied men to take the route you
4 A. No.
5 Q. The rallying of the population of that age
6 group in Susnjari, did that take place spontaneously?
7 A. What do you mean? Could you explain that to
9 Q. When I say "spontaneously", I mean that there
10 was no order issued by anyone, any individual or body
11 belonging to the military or the political leadership
12 of the area?
13 A. I don't know. I know I heard from others
14 that we were going to Jaglici, to Susnjari. I never
15 saw Zulfo, I think he must have left before then.
16 Q. Do you have any knowledge about the fact that
17 units under his command in the summer and autumn of
18 1992 and the winter of 1993 until the area was
19 proclaimed a protected zone had carried out combat
20 operations against both military forces of Republika
21 Srpska as well as the civilian population around
23 A. I don't remember.
24 Q. On the 13th of July, you were at the soccer
25 pitch in Kasaba?
1 A. Yes.
2 Q. You said that a list was made of those of you
3 present there at the playing ground?
4 A. Yes.
5 Q. Do you know, did you see who took that list?
6 A. I think it was Mladic.
7 Q. After that, you remained in the football
9 A. Yes.
10 Q. Can you tell us when you left the field to go
11 towards Bratunac?
12 A. It was in the afternoon an hour before
13 nightfall, perhaps.
14 Q. And when did you pass through Kravica, was it
16 A. Not yet. It was dusk. Night had started to
18 Q. On what side of the bus were you seated?
19 A. I was standing in the bus.
20 Q. And this warehouse, how far is it from the
22 A. Not very far.
23 Q. Can you be more precise?
24 A. I don't know exactly. I couldn't really tell
25 you how far it was.
1 Q. When from the school at Pilica, you went to
2 fetch water, you heard shots or rather shooting that
3 lasted. From that spot, could you see what was
5 A. No.
6 Q. What was happening in the schoolyard?
7 A. No, I only heard screams and shooting because
8 it was dark.
9 MR. PETRUSIC: [Interpretation]
10 Mr. President, the Defence has no further questions.
11 Q. Thank you, Witness.
12 JUDGE RODRIGUES: [Interpretation] Very well,
13 Mr. Petrusic.
14 Mr. McCloskey, have you any additional
16 MR. McCLOSKEY: No, Mr. President.
17 JUDGE RODRIGUES: [Interpretation] No, Judge
19 JUDGE RIAD: No, thank you, Mr. President.
20 JUDGE RODRIGUES: [Interpretation] Madam Wald,
22 JUDGE WALD: I have no questions either.
23 JUDGE RODRIGUES: [Interpretation] In that
24 case, Witness Q, you have finished your testimony here
25 at the International Criminal Tribunal.
1 We're very glad that you managed to survive
2 those terrible events that you were able to testify
4 We wish you a safe journey home and we hope
5 that you will have a life that will give you reason to
6 smile again. Don't move for the moment.
7 Mr. McCloskey, I think we have several
8 matters to deal with this question of Exhibit 24/5.1.
9 The exhibit submitted under that number was, in fact,
10 23/1.1, so we need to correct that.
11 MR. McCLOSKEY: Thank you, Mr. President.
12 I'm, at this point, just slightly confused about all
13 things exhibit-wise.
14 JUDGE RODRIGUES: [Interpretation] No
15 problem. Mr. Mark Dubuisson knows everything by
16 exhibits and is going to explain it to us.
17 THE REGISTRAR: [Interpretation] Exhibit
18 23/1.1 is the document shown by the Prosecutor
19 directly to the witness and it was a photograph which
20 was not annotated by Jean Ruez. It was a photograph of
21 the school.
22 And finally there is an exhibit, that is the
23 first one that needs to be corrected. The second one
24 is 24.5.1 an aerial photograph. Again, one that was
25 not numbered because 24/5 was annotated by the first
2 So 24/5.1 is an aerial photograph of the
3 execution site.
4 JUDGE RODRIGUES: [Interpretation] I also know
5 a little bit about exhibits, don't I, Mr. Dubuisson?
6 THE REGISTRAR [Interpretation] Yes, of
7 course, Mr. President.
8 JUDGE RODRIGUES: [Interpretation]
9 Mr. Petrusic, have you any objections regarding the
10 admission of these exhibits?
11 MR. PETRUSIC: [Interpretation] No,
12 Mr. President.
13 JUDGE RODRIGUES: [Interpretation] Thank you
14 very much, Mr. Petrusic.
15 So these exhibits will be admitted into
16 evidence as explained by Mr. Dubuisson and which I also
17 have confirmed.
18 I think we have to make a very short break
19 before we begin our Status Conference. So we will only
20 have a five-minute break.
21 As I was saying, we need a five-minute break
22 and we will have our Status Conference in closed
24 Mr. Harmon, you have something to say.
25 MR. HARMON: Yes, Mr. President. This
1 morning I announced that we would have two witnesses
2 and at the conclusion of the second witnesses, we would
3 like to tender some exhibits, some additional
4 documents. And if we could be permitted to do that
5 before we have the Status Conference then we can
6 conclude the presentation of our evidence in this
7 particular trial block.
8 JUDGE RODRIGUES: [Interpretation] Perhaps it
9 will be better to do that afterwards. I think it is
10 more urgent to have the Status Conference than to have
11 those documents.
12 Perhaps during the Status Conference I can
13 suggest a solution to deal with that matter. I think
14 it is more urgent to have the Status Conference than to
15 deal with those exhibits now.
16 So we're going to have only a five-minute
17 break. We will come back into the courtroom without a
19 Please, Witness, don't move because of your
20 protective measures. Good-bye, witness, therefore.
21 --- Whereupon the hearing adjourned at
22 2.33, to be followed by a Status