1 Monday, 22 May 2000

2 [Open session]

3 [The witness entered court]

4 --- Upon commencing at 9.38 a.m.

5 [The accused entered court]

6 JUDGE RIAD: Good morning. I would like to

7 greet the parties, the accused, and all our staff, as

8 well as our guests in the gallery.

9 You have been informed that Judge Rodrigues

10 is on an urgent mission and I will be presiding today.

11 As for tomorrow and after tomorrow, Judge Wald will

12 also be on an urgent mission so I will be the Presiding

13 Judge.

14 Now I would like our witness to take the

15 oath, please.

16 THE WITNESS: [Interpretation] I solemnly

17 declare that I will speak the truth, the whole truth,

18 and nothing but the truth.

19 WITNESS: DRAZEN ERDEMOVIC

20 [Witness answered through interpreter]

21 JUDGE RIAD: Please be seated.

22 Mr. Harmon, the witness is yours.

23 MR. HARMON: Yes. Good morning, Judge Riad,

24 Judge Wald. Good morning to my colleagues for the

25 Defence.

1 Examined by Mr. Harmon:

2 Q. Good morning, Mr. Erdemovic.

3 A. Good morning.

4 Q. Mr. Erdemovic, I'm going to be asking you a

5 number of questions on direct examination, and

6 following my examination you'll be asked questions by

7 my colleagues from the Defence, and following their

8 questions I'll ask you questions once again, and then

9 the Judges will have an opportunity to ask you

10 questions.

11 Let me start, Mr. Erdemovic, by asking you

12 how old you are.

13 A. I'm 28 and a half.

14 Q. Where were you born?

15 A. In Tuzla, a town called Tuzla.

16 Q. What is your ethnicity?

17 A. Croat, Bosnian Croat.

18 Q. Could you tell us about your educational

19 background.

20 A. I went to a school for mechanical

21 technicians. I'm a locksmith.

22 Q. Before the war, then, you were a locksmith;

23 is that correct?

24 A. Yes, but I hadn't been working yet.

25 Q. Now, I want to go into your history before

1 this Tribunal. I don't want to go into all of the

2 complex litigation that surrounded your case, but on

3 the 14th of January, 1998, did you enter a guilty plea

4 to one count of a violation of our Article 3, which was

5 a violation of the laws and customs of war,

6 specifically murder?

7 A. Yes.

8 Q. Was that guilty plea pursuant to a plea

9 agreement that was entered into between yourself and

10 your counsel and representatives of the Office of the

11 Prosecutor?

12 A. Yes.

13 Q. Now, the underlying facts that supported your

14 guilty plea was that you and members of your unit,

15 along with soldiers from another unit of the Bosnian

16 Serb army, did shoot and kill and did participate in

17 the execution of unarmed Muslim men at the Branjevo

18 Military Farm on the 16th of July, 1995; is that

19 correct?

20 A. Yes.

21 Q. On the 5th of March, 1998, were you sentenced

22 by a Trial Chamber of this Tribunal to serve a term of

23 five years' imprisonment?

24 A. Yes.

25 Q. Were you given credit for all of the time

1 that you had been in custody, that is, from the time of

2 March 28th, 1996 until the date of your judgement, your

3 sentencing?

4 A. Yes.

5 Q. Have you now completed your term of

6 imprisonment?

7 A. Yes.

8 Q. You are testifying today freely and

9 voluntarily; is that correct?

10 A. Yes.

11 MR. HARMON: Mr. President and Judge Wald, I

12 would ask the Court to take judicial notice of its own

13 records in this proceeding. There is an indictment and

14 a sentencing judgement. I've had an opportunity to

15 talk to my colleagues from the Defence and we discussed

16 the issue of judicial notice, pursuant to Rule 94, and

17 they have no objection to Your Honours taking such

18 notice.

19 Q. Now, Mr. Erdemovic, I'd like to focus your

20 attention on your own military background in the

21 various armies that were in the former Yugoslavia.

22 First of all, let me begin by asking you, did

23 you serve in the JNA?

24 A. I did.

25 Q. How long of a period of time were you in the

1 JNA?

2 A. I was in the JNA for a year as my regular

3 service, and then another four months in reserve

4 forces.

5 Q. When did you finally leave the JNA?

6 A. At the end of March 1992.

7 Q. After leaving the JNA, did you return to your

8 home in the Tuzla area?

9 A. Yes.

10 Q. After you were in Tuzla, were you again

11 called up by the JNA and asked to serve in the JNA?

12 A. Yes.

13 Q. Did you serve in the JNA again or did you

14 refuse?

15 A. I refused. I returned my call-up papers and

16 said that I had already spent enough time in the army.

17 Q. Did you at any point in time, then, serve in

18 the Territorial Defence in your village?

19 A. Yes.

20 Q. Describe the nature of that service. What

21 kind of service was that?

22 A. It was a service in our local community. At

23 night we would walk around the village and keep guard

24 in our village.

25 Q. Now, did you eventually join the Armija, the

1 army of the Bosnian Muslim government?

2 A. Yes. I think it was in July 1992, I got a

3 call-up to report to the barracks in Tuzla.

4 Q. Did you respond to that call-up?

5 A. I did.

6 Q. Did you serve in the Armija from July of 1992

7 until approximately October of 1992?

8 A. Yes.

9 Q. Could you describe your duties and

10 responsibilities while you were serving in the army.

11 A. I was a member of a reconnaissance unit on

12 mortars.

13 Q. Where did you serve the majority of your

14 time?

15 A. In a position above Gornja Tuzla or Upper

16 Tuzla.

17 Q. Were you on the front lines most of the time?

18 A. Yes. Yes, but as a reconnoitre.

19 Q. Now, when you came to the Tribunal initially

20 and you had a conversation with an investigator from my

21 office, Jean-Rene Ruez, did you tell him that you had

22 served in the ABiH?

23 A. No.

24 Q. Subsequently, when you testified publicly

25 under oath at the Rule 61 hearing in 1996, did you then

1 testify about your service in the ABiH?

2 A. Yes.

3 Q. Now, later did you volunteer to serve in the

4 HVO?

5 A. In the military police of the HVO, in the

6 village next to mine.

7 Q. Why did you volunteer to serve in the HVO?

8 A. Because I got a position in the military

9 police, and because I didn't want to be exposed to

10 danger on the front.

11 Q. So had you become essentially tired of

12 serving on the front lines and wanted to have a safer

13 position?

14 A. Yes.

15 Q. Now, did you serve in the HVO from October of

16 1992 until November of 1993?

17 A. Yes.

18 Q. While you were serving in the HVO, were you

19 arrested?

20 A. Yes.

21 Q. Could you briefly explain to the Trial

22 Chamber the circumstances of your arrest.

23 A. I was assisting civilians, Serbs from Tuzla,

24 to cross into territory under the control of the army

25 of Republika Srpska. In the first attempt I was not

1 arrested, but in the second attempt, with a larger

2 group of civilians who were mostly women and children,

3 I was arrested on Mount Majevica by an HVO

4 communications unit.

5 Q. Were you put in custody as a result of that

6 arrest?

7 A. Yes.

8 Q. Ultimately were you released from custody,

9 and did you return to the HVO military police to serve

10 with them?

11 A. No.

12 Q. What happened then?

13 A. When they questioned me and when I told them

14 everything, they beat me, mistreated me. They demanded

15 that I admit certain things that I did not know of,

16 some other attempts of transporting Serbs. I was

17 questioned by the army of Bosnia-Herzegovina and their

18 police, and after some time they turned me back to the

19 HVO police, and I asked the head of the HVO police to

20 let me go home to have a bath and change my uniform.

21 Q. What did you do then?

22 A. When the head of the military police released

23 me I went home, and I met a neighbour, a Serb, who

24 asked me whether I could help him to cross into the

25 territory held by the Serbs. I told him, "You know

1 that I'm arrested, and if I'm arrested again I won't

2 fare well." He told me then, and my wife was with me

3 at the time, that he would help me go to Switzerland

4 because his sons are working in Switzerland and I

5 wouldn't have to spend much time in Republika Srpska.

6 After thinking it over, I agreed to that because I

7 wanted to leave.

8 Q. Did you then leave to the Republika Srpska?

9 A. Yes.

10 Q. When did you arrive in the Republika Srpska?

11 A. On the 3rd of November, 1993.

12 Q. What did you do then?

13 A. When I reached Serb territory I was

14 questioned by the command, which was headquartered in

15 Lopare, at the foot of Mount Majevica. Regarding the

16 group I had transferred, this group had told them that

17 I had been correct towards the Serbs and that I was

18 correct with everyone. And after a day long of

19 questioning, in the evening they told me that the next

20 day I would be released, as well as my wife and those

21 two other persons who were of Croat ethnicity and who

22 were with me.

23 Q. If could you describe very briefly,

24 Mr. Erdemovic, what you did from that point on until

25 the point in time when you joined the army of the

1 Republika Srpska. I don't want to go into great

2 detail, but could you just tell the Judges in outline

3 form what you did, where you went, and how you ended up

4 in the army of the Republika Srpska.

5 A. When I reached Bijeljina, I started having

6 problems with paramilitary units, of which certain

7 people from Tuzla were members, they were Serbs, and

8 they mistreated me. And this man who promised to help

9 me go to Switzerland simply turned his back on me and

10 my wife and said, "I can't help you." I had no other

11 choice. But a Croat who was with me called up his

12 relative who was living in the Federal Republic of

13 Yugoslavia, in Titov Vrbas, and he came about a day

14 later to Bijeljina to take us to Titov Vrbas. I

15 couldn't stay in Bijeljina at that time because they

16 were threatening me. They said I had to join a

17 paramilitary unit or simply that I couldn't stay on, I

18 would be killed.

19 So my wife, the two Croats, and I, and this

20 man who came to collect us from Titov Vrbas, we they

21 went to Titov Vrbas to stay with him. That was also in

22 the month of November. After that, I can't remember

23 exactly, but I think we stayed in Titov Vrbas until

24 January, my wife and I and these two Croats. As we had

25 no money, we simply couldn't stay with these people,

1 enjoying their hospitality, as they too were not

2 well-off.

3 After a while, I think it was in January of

4 1994, police raids started in Serbia, so people who

5 were not from Serbia and who were from Bosnia had to go

6 back to Bosnia. So with my wife, I decided to go back

7 to Republika Srpska, to stay with her uncle in

8 Trebinje. We called him up from Serbia and he told us

9 to come. He knew I was a Croat, and still he said that

10 we could come. When we reached Trebinje, at the border

11 between Serbia and Republika Srpska, the police

12 identified me by my ID card, and he said, "You're not a

13 Serb. Your name is not Serbian, nor is your father's

14 name." I said I wasn't a Serb but that I was a Croat,

15 but my wife was a Serb. They let us go and told me to

16 report immediately to the police station in Foca.

17 I didn't report immediately. I went to my

18 wife's uncle's with her. I didn't report because I

19 didn't know where the police station in Foca was. It

20 was my first time in Foca. We went to a place close to

21 Foca called Miljevina, where my wife's uncle was. And

22 the next day we went to the police station, and this

23 man treated me very kindly, he wasn't arrogant or

24 anything. He said I couldn't stay in Foca because

25 there were no Croats or Muslims there, that I should go

1 back to Bijeljina. Of course I had to tell him the

2 whole story, how I got to Foca. He said I had to go

3 back to Bijeljina where I had crossed to leaving

4 Tuzla.

5 So I returned to Bijeljina. This must have

6 been the beginning of April. In Bijeljina I met a

7 friend of mine whom I knew from before, from Tuzla, he

8 was a Serb, he was a nice man. I even stayed with him

9 for a while. He was very kind. I explained everything

10 that had happened, where I had been and everything. He

11 told me I couldn't achieve any rights in Republika

12 Srpska, I wouldn't even be able to move around without

13 a permit if I was not in the army. So I decided to

14 report to the army.

15 I went to the military department in

16 Bijeljina. I had to tell them again this whole story

17 from the time I left Tuzla, and they told me that a

18 unit had been formed consisting of Croats and Muslims

19 who had crossed over from Tuzla to Bijeljina, and who

20 had also been helping Serbs. And when I asked them

21 where this unit was, they told me it wasn't far from

22 Bijeljina, a place called Dvorovi. I went there and I

23 recognised some Croats whom I had known from Tuzla,

24 from before. I spoke to them, and they told me that

25 they would help me join this unit, and after a few

1 days, I did in fact join the unit, which then was not

2 called the 10th Sabotage Detachment but was a special

3 unit of the army of Republika Srpska.

4 Q. Mr. Erdemovic, when you joined this special

5 detachment, how many men were in it?

6 A. Eight.

7 Q. Did this special unit evolve into the 10th

8 Sabotage Detachment?

9 A. Yes, in October 1994.

10 Q. Could you tell the Judges what kind of unit

11 was the 10th Sabotage Detachment.

12 A. It was a sabotage unit which would go into

13 the rear of the enemy and blow up munition warehouses,

14 artillery storages, and that sort of thing. That is

15 what we did behind the enemy lines.

16 Q. So you were an infiltration and sabotage

17 unit.

18 A. Yes.

19 Q. Now, turning our attention to July of 1995,

20 can you tell me approximately how many men were in the

21 10th Sabotage Detachment?

22 A. Do you mean the whole detachment?

23 Q. Yes.

24 A. As far as I was able to assess, there could

25 have been about 60 men. I don't know the exact

1 number.

2 Q. Now, was the 10th Sabotage Detachment

3 subordinate to the Main Staff of the Bosnian Serb army?

4 A. Yes.

5 Q. Would you describe to the Judges the

6 structure of the 10th Sabotage Detachment, how many

7 platoons there were, where they were located?

8 A. There were two platoons; one was in Bijeljina

9 and the other was in Vlasenica.

10 Q. Now, how large, how many men were in each of

11 those respective platoons?

12 A. I think in Bijeljina there were about 30

13 men. I don't know about Vlasenica. But perhaps a

14 similar number, three or four or five men less,

15 perhaps.

16 Q. Let's focus your attention on the Bijeljina

17 platoon that was part of the 10th Sabotage Detachment.

18 Of those approximately 30 men, how many of those men

19 were involved in infiltration and sabotage activities,

20 and how many of those 30 men were rear services people

21 who would support your activities?

22 A. I think that in the infiltration and sabotage

23 activities, there were about 22 men, roughly, I would

24 say. I don't know the exact number of course.

25 Q. Did the remaining men then participate in

1 rear service activities, support activities?

2 A. Yes.

3 Q. Could you tell us who the commander of the

4 Bijeljina platoon was?

5 A. It was Franc Kos.

6 Q. Did he have a nickname?

7 A. We called him Slovenac, the Slovene, or Zuco,

8 we used to call him Zuco.

9 Q. Who was the commander of the Vlasenica

10 platoon?

11 A. I only know that they called him Lule. I

12 don't know anything else.

13 Q. I'd like you to then identify some of the

14 hierarchy of the 10th Sabotage Detachment as you knew

15 it in July of 1995. Could you please tell us, from the

16 highest levels working down to the level of Franc Kos

17 and Lule, what was the reporting chain of command?

18 A. As far as I know, in first place there was

19 Colonel Salapura from the Main Staff, the intelligence

20 centre, he was there from the beginning when there were

21 eight of us, and later on as well. Under him, I think

22 I got to know in March 1995, Major Pecanac. Underneath

23 Pecanac, there was Milorad Pelemis; he was First

24 Lieutenant. Underneath Pelemis, there was Radoslav

25 Kremenovic, who was a First Lieutenant who came to the

1 unit in 1995; sometime in February, I don't know

2 exactly. Underneath Kremenovic, there was Slovenac in

3 Bijeljina who was the platoon commander, and Lule in

4 Vlasenica.

5 Q. Thank you. Now, you participated in some

6 sabotage and infiltration activities, as did other

7 members of your unit. When your unit travelled to an

8 area in the Republika Srpska that was under the command

9 of, say, the Drina Corps or a brigade, what was the

10 procedure, if any, to notify the other members of the

11 VRS that you were going to be operating in and out of

12 their territory? Could you tell the Judges, please.

13 A. I know for certain what the situation was

14 like at Mount Majevica, and that was the zone of

15 responsibility of the Majevica Brigade. Before we

16 would start out from Bijeljina, the commander, or

17 leader, would have to inform the command which was in

18 that area of responsibility that we were coming, and

19 what time we would be coming. I don't know that -- I

20 know that they didn't speak of the actual operations

21 that would take place in that territory, and when I say

22 "The zone of responsibility," it is a broader area.

23 So they would be informed of our arrival and that we

24 would have to undertake operations in that zone of

25 responsibility. They didn't actually say what

1 operations we would be undertaking, but we had to

2 inform them because otherwise we could not pass into

3 their zone of responsibility and move around if the

4 command had not been informed.

5 Q. So informing them was, in part, to ensure

6 your own safety; is that correct?

7 A. Yes, both our safety and theirs.

8 Q. Now, when you conducted these operations,

9 these sabotage and infiltration operations, normally

10 did you conduct them with members of your unit alone,

11 or were they joint operations? When I say "joint

12 operations," Mr. Erdemovic, I'm talking about

13 operations with members of, say, a brigade or another

14 company? What was the routine, the normal

15 modis operandi?

16 A. In the areas where we knew for certain where

17 we were supposed to pass and what we were supposed to

18 do, we worked alone. But there were operations, for

19 example, when we entered through an underground pit

20 between Bratunac and Srebrenica, then we were led by a

21 group which was from Bratunac because we didn't know

22 this mine very well, and there were several corridors

23 and we might have lost our way had we done it alone.

24 Q. In the operation that you just testified

25 about, when members of the 10th Sabotage Detachment

1 went into a mine, because they were unfamiliar with the

2 various tunnels, they received assistance from people

3 from the brigade who had been miners and were familiar

4 with the mine routes; is that correct?

5 A. Yes.

6 Q. But other than give you guidance in the

7 mines, those people didn't participate in the

8 operation; is that correct?

9 A. That's correct.

10 Q. Now, I want to focus your attention now to

11 the attack on Srebrenica itself that took place in July

12 of 1995, and, particularly, I want to focus your

13 attention on the role of the 10th Sabotage Detachment

14 in that attack.

15 Could you tell the Judges on what date your

16 unit, the 10th Sabotage Detachment, deployed to the

17 area of Srebrenica?

18 A. On the 10th of July, 1995.

19 Q. And --

20 A. In the evening hours.

21 Q. From whom did you receive your deployment

22 orders?

23 A. In the morning we received orders from the

24 commander of the platoon, Franc Kos, in Bijeljina, that

25 we should prepare to move into action.

1 Q. Then you arrived on the night of the 10th, is

2 that correct, in the Srebrenica area.

3 A. Yes. Yes, but we weren't told beforehand

4 where we would be going until we actually got there.

5 Q. How many members of your platoon were

6 deployed to the area of Srebrenica to participate in

7 the assault on Srebrenica?

8 A. I think between 15 and 20. I'm not quite

9 sure of the exact number. That's what I think.

10 Q. Did you, in fact, commence an assault on

11 Srebrenica on the 11th of July?

12 A. Yes.

13 Q. Did you receive any special instructions

14 prior to the assault from any of your superior

15 officers?

16 A. Yes. In the morning of the 11th, Pelemis

17 came and told us that in no case should be fire at

18 civilians and that we should send the civilians off to

19 the football stadium at Srebrenica. He told us on the

20 occasion that the resistance would probably be strong

21 and that at the first mosque would be the first

22 resistance, that is to say, at the entrance into town.

23 Q. Now, when you participated in the assault,

24 did you do this only with members of your unit, the

25 10th Sabotage Detachment, or did you participate in the

1 operation with a unit that was part of the Drina Corps?

2 A. Pelemis said that we would be joined by some

3 15 men, I think about 15 men, from the Drina Wolves.

4 Q. Did you know the Drina Wolves were part of

5 the Drina Corps?

6 A. Yes.

7 Q. Now, you told us earlier in your testimony

8 that normally the 10th Sabotage Detachment operated

9 exclusively with its own men. On this occasion, on the

10 assault on Srebrenica, you're telling us that you

11 worked with another unit, part of the Drina Corps. Is

12 that correct?

13 A. Yes. And this seemed to us to be a little

14 unusual because we were used to working on our own.

15 But another thing that seemed strange to me and unusual

16 was that we were not a unit to take control of the

17 town. We were intended for sabotage operations.

18 Q. So your normal mission for your unit had

19 changed from sabotage to one of being part of the

20 invading or the assaulting force; is that correct?

21 A. Yes.

22 Q. Now, what was the objective of your group's

23 operation? Were you informed of what your objective

24 was and what the Drina Wolves, who were working with

25 you, what was their objective?

1 A. Pelemis told us that it was our objective to

2 enter the town first with these people, and when he

3 told us that he said that, "On your left-hand side," I

4 can't quite remember who would be on the left and

5 right, but I know that he mentioned Sekovici, Bratunac,

6 Milici, Vlasenica, so that once we descend into town

7 they would descend too from the surrounding hills.

8 Q. When you say Sekovici, Vlasenica, Milici, and

9 Bratunac, are you referring to the brigades from

10 Sekovici, Vlasenica, Milici, and Bratunac?

11 A. He said units. He didn't use the word

12 brigade.

13 Q. So units from those --

14 A. Yes.

15 Q. -- I take it units from those brigades would

16 follow your penetration into Srebrenica, and after

17 there had been penetration by your group and the Drina

18 Wolves, then the brigade groups would follow; is that

19 how I understand your testimony?

20 A. Yes.

21 Q. Who was the commander, to your knowledge, of

22 the Drina Wolves?

23 A. I just know that his nickname was Legenda,

24 legend.

25 Q. Who was the leader of the group of the 10th

1 Sabotage Detachment that went with you in the direction

2 of Srebrenica? Was it Lieutenant Pelemis?

3 A. Yes.

4 Q. To your knowledge, did Legenda also

5 participate in the assault on Srebrenica?

6 A. Yes.

7 Q. To your knowledge, did he and Lieutenant

8 Pelemis communicate in order to coordinate their

9 efforts?

10 A. Yes, because at one point Pelemis, that is to

11 say, Legenda was to our left -- on raised ground to our

12 left. At one moment Pelemis told us that we should set

13 fire to the first thing next to us. For the artillery,

14 the tank, and heavy machine-guns, to shoot at the

15 surrounding hills and not at us, so that they could

16 know the point where we had reached.

17 MR. HARMON: If I could have the assistance

18 of the usher, and if the usher could place on the ELMO

19 for the witness Prosecutor's Exhibit 4A, which is a

20 map.

21 I'm not getting the image on my monitor. I

22 don't know if Your Honours are getting the image. It

23 appears that the ELMO is not working, and we're going

24 to need the ELMO throughout the testimony of

25 Mr. Erdemovic. Perhaps we can have the assistance of

1 the technical people to see if this monitor could be

2 made functional today.

3 JUDGE RIAD: It's being taken care of.

4 MR. HARMON: It is? Okay.

5 JUDGE RIAD: Mr. Harmon, could you proceed

6 with your questioning in the meantime?

7 MR. HARMON: I'm going to quickly start to

8 get to the point where he's going to need some exhibits

9 to illustrate his testimony.

10 Q. I'll ask you some questions. Mr. Erdemovic,

11 let me ask you, you had been informed by Lieutenant

12 Pelemis that your group and the Drina Wolves could

13 anticipate heavy resistance. Did you, in fact, get

14 heavy resistance?

15 A. No.

16 Q. Can you describe to the Judges the manner in

17 which your group divided? How many different groups of

18 10th Sabotage and Drina Wolves were there that advanced

19 onto Srebrenica?

20 A. There were four groups in our detachment.

21 The Drina Wolves, I don't know.

22 Q. All right. But your group, consisting of

23 Drina Wolves and 10th Sabotage Detachment soldiers,

24 divided into four groups and advanced in the direction

25 of the town of Srebrenica; is that correct?

1 A. Yes.

2 Q. Now, I had asked that Prosecutor's Exhibit

3 4A, which is a map, be placed on the ELMO because I

4 wanted you to illustrate and inform the Judges the

5 direction in which you approached Srebrenica. Without

6 that map, perhaps you can just describe, did you

7 approach the town of Srebrenica from the south of the

8 town?

9 MR. HARMON: Oh, here it's working finally.

10 Now, if we could have that so the town of Srebrenica is

11 shown on the ELMO. There we go. Move it up a little,

12 please. That's fine right there.

13 Q. Now, using the pointer, Mr. Erdemovic, could

14 you illustrate to the Judges the direction which your

15 four groups took in the assault on Srebrenica?

16 A. This direction here [indicates], towards the

17 centre of town.

18 MR. HARMON: Indicating, for the record,

19 Mr. Erdemovic placed the pointer initially at the

20 juncture of the hairpin turn and moved it toward the

21 top of the exhibit, in the direction of Srebrenica.

22 Q. So you moved from the south of the town,

23 toward the centre of town; is that correct?

24 A. Yes.

25 MR. HARMON: Now, if I could have

1 Prosecutor's Exhibit 4/4 placed on the ELMO.

2 Q. Did you, in fact, Mr. Erdemovic, reach the

3 centre of town?

4 A. I don't know for sure whether it was the

5 centre of town, but that's what I assumed at the time.

6 Q. Let me show you Prosecutor's Exhibit 4/4, and

7 this is a photograph of part of the town of

8 Srebrenica. Is this the location that you considered

9 or thought was the centre of town?

10 A. Yes, here [indicates], that is the location.

11 Q. Was there a mosque in the general vicinity

12 where you have just pointed?

13 A. Yes, here [indicates].

14 MR. HARMON: Indicating, for the record, it

15 looks like a platform with a circle in the middle of it

16 that is directly located in the centre of the picture.

17 Q. Was that mosque that you observed on the

18 morning of -- on the 11th of July, was it intact? Was

19 it standing?

20 A. Yes.

21 Q. When you entered the town, had you passed

22 another mosque?

23 A. Yes, at the beginning, when we moved off. It

24 wasn't far from the beginning.

25 Q. Was that mosque standing as well?

1 A. Yes.

2 Q. Now, when you arrived in the location that

3 you've pointed on Prosecutor's Exhibit 4/4, could you

4 tell the Judges what happened?

5 A. When we arrived there, a civilian, wearing

6 civilian clothing, surrendered and said, "I was never

7 in the army." He was about 30 years old, tall; he

8 wasn't fat, as far as I could see, he was thin.

9 Q. To whom had he surrendered?

10 A. Because we were the first to descend into

11 town, he surrendered to us.

12 Q. Now, did it appear to you that -- other than

13 that one individual that you saw, was the town

14 abandoned?

15 A. Yes. But we called people to come out of

16 their houses and to move in front of us, towards the

17 stadium. People did come out, I don't know how many,

18 but most of them were elderly people who found it

19 difficult to walk.

20 Q. Now, let's continue focusing on this young

21 man who had surrendered. What happened to him?

22 A. Later on, when we had already got there, the

23 units descended from the surrounding hills and one

24 particular group started to mistreat that young man, to

25 beat him with rifles, with their fists, kick him and so

1 on. And after that, perhaps a minute or two after all

2 of that abuse, Pelemis ordered one of the soldiers to

3 go and slit that man's throat.

4 Q. Did, in fact -- first of all, can you

5 identify the man who was ordered to go slit the

6 captive's throat?

7 A. Yes.

8 Q. What was his name?

9 A. Zoran. Zoran, nicknamed Maljic, from

10 Vlasenica. I don't know his family name.

11 Q. Did Zoran follow the order of Lieutenant

12 Pelemis and slit this young man's throat?

13 A. Yes.

14 Q. Did you see that?

15 A. Yes.

16 Q. Can you use the pointer, please, again

17 referring to Prosecutor's Exhibit 4/4, and point where

18 in this picture the execution occurred?

19 A. Here [indicates], in between these two

20 buildings here [indicates].

21 MR. HARMON: Indicating two buildings that

22 are on the left-hand side of the exhibit, slightly

23 above a curve in the road that appears in the centre of

24 Prosecutor's Exhibit 4/4.

25 Q. All right. That's fine. Thank you,

1 Mr. Erdemovic.

2 Now, what happened? Did that man's body

3 remain in the location where it had dropped?

4 A. Yes. It remained there on the pavement.

5 MR. HARMON: Now, I'm going to ask the usher

6 to please bring two exhibits: Prosecutor's Exhibit

7 28/17 and Prosecutor's Exhibit 147.

8 Q. Do you know why Lieutenant Pelemis gave the

9 order to Maljic to kill this man, particularly since he

10 had earlier given an order that no civilians were to be

11 hurt?

12 A. I really don't know why but I think it was

13 because he was -- because he was fit for military

14 service. That's what I think, but I don't know

15 exactly. I'm not aware of the actual reason. It

16 looked a little strange, particularly in view of the

17 fact that he had told us not to touch anybody, and

18 after having said that he ordered us to slit this man's

19 throat.

20 Q. All right. We're going to start with one

21 exhibit. I'm still waiting for another exhibit.

22 MR. HARMON: Mr. Usher, could you place that

23 on the ELMO, please.

24 Q. Let me ask you, this photograph has two

25 individuals marked, one with the number 1 and one with

1 the number 2. Do you see Zoran Maljic, the man who

2 executed the Muslim civilian who was in the custody of

3 your unit? And could you point him out, please?

4 A. Yes [indicates].

5 MR. HARMON: Indicating, for the record, in

6 Prosecutor's Exhibit 147, the man with the number 2 on

7 his shoulder.

8 Q. Now, in that same picture there is a man with

9 the number 1 marked on his shoulder. Do you see that

10 man, Mr. Erdemovic, and can you identify him for the

11 Trial Chamber?

12 A. Yes. That is the leader of the platoon from

13 Bijeljina, Franc Kos [indicates].

14 Q. All right.

15 MR. HARMON: Perhaps we can use my exhibit.

16 I can use the next exhibit.

17 Q. Let me show you what is Prosecutor's Exhibit

18 28/17, and I ask that that be placed on the ELMO,

19 please. Now, Mr. Erdemovic, you've mentioned

20 Lieutenant Pelemis who gave the order to execute the

21 young man in Srebrenica. Do you see him in this

22 particular picture? Can you point him out, please?

23 A. [Indicates]

24 MR. HARMON: Indicating, for the record, the

25 man on the right-hand side of that picture being

1 Lieutenant Pelemis.

2 Q. Thank you, Mr. Erdemovic. Thank you,

3 Mr. Usher, that's all I need.

4 Now, after this young man was executed,

5 Mr. Erdemovic, were you given an order by Lieutenant

6 Pelemis to do anything?

7 A. Yes. He told us to go back. At the time I

8 didn't know it was the southern part of the town of

9 Srebrenica. Anyway, he told us to go back to where we

10 had come from and to provide security at the entrance

11 of the town. He told this to me and other members of

12 my unit.

13 On the way back he told me to report to him

14 when General Mladic reaches the town, General Mladic

15 and the others.

16 Q. So at the point of town when you were in the

17 centre, General Mladic, General Krstic, and General

18 Zivanovic had not arrived in town yet; is that

19 correct?

20 A. Yes.

21 Q. Did you follow Lieutenant Pelemis' order, and

22 did you go to the entrance of the town in the south and

23 did you set up a position?

24 A. Yes.

25 Q. Were you with other members of your unit?

1 A. Yes.

2 Q. Now, I forgot to ask you one question, and

3 that is this: Going back to the beginning of the

4 assault, when your unit started the assault on

5 Srebrenica, approximately what time was that?

6 A. I can't say now exactly. But when NATO bombs

7 dropped, I think, two bombs, a man from our unit looked

8 at his wristwatch and said that it was about ten past

9 eleven, I think. We had already reached the first

10 mosque in town by that time.

11 Q. Now, let me take you back to the location

12 where you were at the southern entrance of the town,

13 waiting for the arrival of General Mladic. Your

14 instructions were to notify Lieutenant Pelemis that

15 General Mladic had passed your point. How were you to

16 do that? How were you to communicate with Lieutenant

17 Pelemis?

18 A. With a radio link, a Motorola. We called it

19 the 1000.

20 MR. HARMON: Now I'm going to play for Your

21 Honours a film, which will be Prosecutor's Exhibit

22 148.

23 Q. Mr. Erdemovic, you've seen this film before.

24 I'm going to ask you a number of questions about it

25 after you've had an opportunity to see this. This is a

1 film that was taken outside of the town of Srebrenica,

2 on the 11th of July, 1995.

3 MR. HARMON: So if we could dim the lights,

4 please, and if we could play Prosecutor's Exhibit 148.

5 Unfortunately, Mr. President and Your Honours, I have

6 no transcript for this film. One will follow.

7 [Videotape played]

8 JUDGE RIAD: [Interpretation] Mr. Dubuisson,

9 perhaps the next time we have a film one should dim the

10 rights a little.

11 MR. HARMON:

12 Q. Mr. Erdemovic, the location where that film

13 was taken, specifically where the Dutch UNPROFOR APC

14 was on its side, was that at a location that was

15 outside of the town and away from the location where

16 you had set up your checkpoint, pursuant to the order

17 of Lieutenant Pelemis?

18 A. Yes.

19 MR. HARMON: Now, if I could have

20 Prosecutor's Exhibits 152, 153, 154, 155, 156, and 157

21 given to the usher, we're going to show those in

22 order. They are new exhibits.

23 Q. In the meantime, Mr. Erdemovic, having seen

24 that film, did you see on that film a number of members

25 of the 10th Sabotage Detachment present in the area

1 where General Krstic was, where General Mladic was,

2 where Colonel Pandurevic was and other representatives

3 of the VRS army? Could you members of the 10th

4 Sabotage Detachment there?

5 A. Yes. Yes, I saw three members of the 10th

6 Sabotage Battalion.

7 Q. I'm going to show you a series of exhibits.

8 We're going to start with Prosecutor's Exhibit 152.

9 MR. HARMON: All of these exhibits, Judge

10 Riad and Judge Wald, are still images taken from the

11 video we have just seen. They are not of the best

12 quality but they are the best quality we could obtain.

13 Q. Let me ask you, then, placing Prosecutor's

14 Exhibit 152 on the ELMO, there are three individuals

15 with yellow dots, 1, 2, and 3. Did you, in looking at

16 this film, have the ability to identify the individuals

17 1, 2, and 3 as being members of your unit?

18 A. Yes.

19 Q. So all three of these individuals are members

20 of the 10th Sabotage Detachment; is that correct?

21 A. Yes, the 10th Sabotage Detachment, belonging

22 to the Vlasenica platoon.

23 Q. Let's start with number 1. Can you identify

24 the man who is number 1?

25 A. He was a liaison officer, a signals officer,

1 but I just know his name was Bujo. That was his

2 nickname, actually.

3 Q. Do you remember the name of the man who is

4 number 2?

5 A. No.

6 Q. But you know him to be a member of the 10th

7 Sabotage Detachment?

8 A. Yes. He worked in the signals section.

9 Q. And number 3, can you identify him, please?

10 A. Yes. He was also in the Vlasenica

11 platoon formally, but sometimes he drove our commander

12 Milorad Pelemis.

13 Q. What is his name?

14 A. Cico.

15 MR. HARMON: We can turn to the next exhibit,

16 Mr. Usher, that is Prosecutor's Exhibit 153.

17 Q. The man with the yellow dot on his chest, is

18 he a member of the 10th Sabotage Detachment,

19 Mr. Erdemovic?

20 A. Yes. His name is Bujo, and on the previous

21 picture he was marked with the number 1.

22 Q. Now, in some of these images you'll see

23 people with ribbons on their sides. Could you tell,

24 first of all, the Chamber, did members of the 10th

25 Sabotage Detachment receive ribbons before they started

1 the assault and what the purpose of those ribbons was?

2 A. In the morning, when we were about to enter

3 town, we would receive red ribbons which we attached on

4 our left shoulder, some maybe on the right. I don't

5 know. But anyway we had to have those red ribbons so

6 that we could be identified amongst the different

7 units.

8 Q. Let's turn to the next image, which is 154.

9 There are two individuals on Prosecutor's Exhibit 154

10 with a yellow dot on them, 1 and 2. Are both of those

11 members of the 10th Sabotage Detachment?

12 A. Yes.

13 Q. Now, even though one of these individuals has

14 his back to us in this image, were you able to identify

15 that individual in the film?

16 A. Yes. It is Cico, the man nicknamed Cico.

17 Q. Were members of the 10th Sabotage Detachment

18 normally issued blue helmets?

19 A. No.

20 Q. Is that helmet that Cico is wearing a UN

21 helmet?

22 A. Yes.

23 Q. Now, the individual marked number 1 on this

24 exhibit, a member of the 10th Sabotage Detachment, do

25 you know his name?

1 A. Yes, he is a member of the 10th Sabotage

2 Detachment. He worked in the signals department but I

3 don't know his first or last name or his nickname.

4 Q. All right. Now we'll turn to the next image,

5 which is Prosecutor's Exhibit 155. There is a man with

6 a yellow dot.

7 MR. HARMON: If you could move that image

8 over, please, Mr. Usher, so you can see the complete

9 image of that man. If you could move it up, please.

10 Q. Now, the man with the yellow dot is wearing,

11 it looks like a grey T-shirt and green camouflage

12 pants. Is that the normal outfit for the 10th Sabotage

13 Detachment?

14 A. No.

15 Q. What is the normal uniform worn by the

16 members of the 10th Sabotage Detachment?

17 A. We wore a black uniform, the uniform worn by

18 the army of Republika Srpska, and uniforms worn by the

19 army of Bosnia-Herzegovina and by the Croatian Defence

20 Council.

21 Q. But in terms of this operation that took

22 place on the 11th of July, were members of the 10th

23 Sabotage Detachment dressed in black, and were they

24 also dressed in camouflage uniforms of the army of

25 Republika Srpska?

1 A. Most were dressed in black uniforms but some

2 had camouflage uniforms as well.

3 Q. Now, let's focus -- let me focus your

4 attention on the man in this photograph holding, it

5 looks like, a blue helmet and has a blue beret under

6 his belt and has a yellow dot on his chest. Can you

7 tell the Judges, first of all, is he a member of the

8 10th Sabotage Detachment, and can you identify him by

9 name?

10 A. Yes. He is a member of the 10th Sabotage

11 Detachment. His name is Cico, or rather his nickname.

12 I'm not sure whether it was his name or nickname, but

13 that's how they called him.

14 MR. HARMON: Let us turn now to the next

15 exhibit, which is Prosecutor's Exhibit 156, another

16 still image taken from the video we've just seen. And

17 in the upper right-hand corner, Your Honours, is the

18 accused.

19 Q. Let me ask you to direct your attention to

20 the man in the middle with the yellow dot. Is that man

21 a member of the 10th Sabotage Detachment?

22 A. Yes.

23 Q. What is his name?

24 A. His name is Zoran Stupar. He comes from the

25 Vlasenica detachment.

1 Q. Finally in this series of exhibits, let me

2 turn your attention to Prosecutor's Exhibit 157. In

3 this image is the accused and General Mladic and other

4 representatives of the Bosnian Serb army. Do you

5 recognise any of these people, and did you recognise

6 any of these people on the 11th of July?

7 A. I recognised on that day only General

8 Mladic. I didn't know the other people, and I never

9 met Mr. Krstic. The same applies to the person on

10 Mladic's right-hand side, I never met him, but I heard

11 of the surname Pandurevic in the Drina unit. But I had

12 never heard of Mr. Krstic, nor did I ever see him.

13 Q. All right.

14 MR. HARMON: I'm finished with this series of

15 exhibits, Mr. Usher.

16 Q. Let's return to your testimony.

17 Mr. Erdemovic, before I showed you this series of

18 exhibits, you told us you'd gone up to a particular

19 location and you were to inform Lieutenant Pelemis of

20 the arrival of General Mladic. Did they, in fact, did

21 General Mladic and other vehicles pass your location on

22 the 11th --

23 A. Yes.

24 Q. -- I'm sorry. On the 12th of July. I'm

25 sorry. On the 11th of July.

1 A. Yes.

2 Q. Approximately what time?

3 A. I didn't have a watch so I don't know

4 exactly, but when we reached the centre of town, then

5 after that -- after the raid, the bombing raid, maybe

6 two or three hours later.

7 Q. Now, on the film that we have just seen,

8 there was -- part of the images were of three vehicles

9 descending a road, one of which contained General

10 Mladic.

11 A. Yes.

12 Q. On the 11th of July, at your location did you

13 see those vehicles and did those vehicles pass your

14 location?

15 A. Yes.

16 Q. Now, were those vehicles then driving in the

17 direction of the centre -- toward the centre of the

18 town of Srebrenica?

19 A. Yes. They went in that direction.

20 MR. HARMON: Now, Mr. President and Judge

21 Wald, I'm not sure when you want to take a break, but I

22 have only a few more minutes of this particular line of

23 examination, and if we could --

24 JUDGE RIAD: Would 11.00 be all right with

25 you, Mr. Harmon?

1 MR. HARMON: That would be fine.

2 JUDGE RIAD: We will have a break for 20

3 minutes.

4 MR. HARMON: I'm going to show Your Honours,

5 it would be my next exhibit, Prosecutor's Exhibit 145.

6 There are going to be two clips in this exhibit. It's

7 a very short film; it lasts about 50 seconds with the

8 total of the two, so one has to watch fairly quickly.

9 If we could then dim the lights and if we could play

10 Prosecutor's Exhibit 145.

11 [Videotape played]

12 MR. HARMON: Now we'll show the second film.

13 That should continue, please.

14 JUDGE RIAD: How will we know what is being

15 said?

16 MR. HARMON: I will submit a transcript.

17 JUDGE RIAD: Thank you.

18 MR. HARMON: You have to go back on that

19 portion of the film, please. It may be just as easy to

20 start and show the whole thing again. Both segments

21 last 51 seconds.

22 [Videotape played]

23 MR. HARMON: I think that's fine, Judge

24 Riad. As I said, it was a very short film.

25 Q. I'm going to ask you now, Mr. Erdemovic.

1 You've seen that film in my office. Is the location of

2 where that film was taken, is that in the town of

3 Srebrenica?

4 A. Yes, between the position that I was at and

5 the very centre of town, or rather what I assumed was

6 the centre of town.

7 Q. Now, in that film that you saw, did you see

8 members of the 10th Sabotage Detachment?

9 A. Yes.

10 Q. If I could show you, with the assistance of

11 the usher, Prosecutor's Exhibit 158, please.

12 MR. HARMON: If that could be placed on the

13 ELMO. In this exhibit, Mr. Erdemovic, there are three

14 individuals marked with yellow dots, 1, 2, and 3. The

15 accused is on the left-hand side of this image. Are

16 the individuals marked with 1, 2, and 3 members of the

17 10th Sabotage Detachment?

18 A. Yes.

19 Q. Could you identify them by name, starting

20 with individual 1 and working toward individual number

21 3?

22 A. Number 1 is Velimir Popovic from the

23 Bijeljina platoon. Number 2 is a man from the

24 Vlasenica platoon whom I didn't want to mention in my

25 earlier testimony, and if it is not absolutely

1 essential, I would rather not today either. I didn't

2 want to mention his name.

3 Q. All right. Well, unless I have -- but you

4 know him to be a member of the 10th Sabotage

5 Detachment; is that correct?

6 A. Yes.

7 Q. If the Defence ask you a question or if the

8 Judges ask you to identify him, you will be required to

9 identify him by name, Mr. Erdemovic.

10 Let's move on to the number 3, please. Who

11 is the individual with the number 3 marked on his body?

12 A. Stanko Savanovic from the Bijeljina platoon,

13 a member of the 10th Sabotage Detachment.

14 Q. Now, I'd like to focus your attention if you

15 would, Mr. Erdemovic, just briefly, on the man with the

16 number 2, and on the left-hand shoulder of that

17 individual there is a ribbon. Is that the kind of

18 ribbon that you said was placed on the shoulders of the

19 individuals who participated in the assault on

20 Srebrenica?

21 A. I can see there is a ribbon but I cannot see

22 that it is red. But I assume that that is the ribbon.

23 Q. Below the ribbon there's a patch, an

24 insignia, on the man's left arm. Do you recognise that

25 patch?

1 A. Yes. It is the patch of the 10th Sabotage

2 Detachment.

3 Q. Lastly, turning your attention to number 3,

4 the individual marked with the number 3, he's wearing a

5 camouflage uniform, not a black uniform. Do you know

6 why he was dressed --

7 A. Yes.

8 Q. -- differently from your other colleagues in

9 the 10th Sabotage Detachment?

10 A. I think in the morning, when we set off from

11 Bijeljina, he was wearing that uniform and that is how

12 he remained. Whether he had a reserve uniform in his

13 bag or not, a black uniform or some other uniform such

14 as that of the army of Bosnia-Herzegovina and of the

15 HVO.

16 Q. Mr. Erdemovic, thank you very much.

17 MR. HARMON: Judge Riad, I'm at a point where

18 it would be convenient to break.

19 JUDGE RIAD: Mr. Harmon, how long do you

20 foresee your examination-in-chief?

21 MR. HARMON: Approximately, two more hours.

22 JUDGE RIAD: Two more hours. We'll have a

23 break of 20 minutes now and then another break at

24 12.40. We have to adjourn at 14.10 today. So at 11.20

25 we'll be back here. Thank you very much.

1 --- Recess taken at 11.00 a.m.

2 --- On resuming at 11.20 a.m.

3 JUDGE RIAD: Mr. Harmon, you can proceed.

4 MR. HARMON: Thank you, Your Honour. If you

5 could move that exhibit down just a little bit, please,

6 Mr. Usher. Down a little more. A little more,

7 please. That's fine right there.

8 Q. Mr. Erdemovic, just before we took the break,

9 you had been testifying about Prosecutor's Exhibit 158,

10 and I wanted to ask you, are you familiar with this

11 specific location where this image was taken?

12 A. Yes.

13 Q. Now, sometime after General Mladic drove by

14 you, your position, with the other vehicles, did you go

15 down to this specific location that is found in

16 Prosecutor's Exhibit 158?

17 A. Yes.

18 Q. At that particular location, when you went

19 down there, did you find members of the 10th Sabotage

20 Detachment present?

21 A. Yes.

22 Q. Were they with a man who you did not know?

23 A. Yes.

24 Q. Before I get into what you observed and what

25 you heard at that location, can you identify the

1 members of the 10th Sabotage Detachment who you found

2 at this particular location?

3 A. Under number 1, Velimir Popovic. Under

4 number 2, an individual whom I did not wish to mention

5 in my previous testimony, I didn't want to mention his

6 name and I don't wish to mention his name today either

7 and involve him in everything.

8 Q. Continue, please.

9 A. Under number 3 is Stanko Savanovic.

10 Q. Did you see any other members of your

11 detachment at that location when you went down there?

12 A. Yes.

13 Q. Who else?

14 A. Opposite on the pavement, Koljevrat Dragan

15 was sitting down, and somebody else was with him. I

16 don't remember exactly who.

17 Q. Would you describe to the Judges what you saw

18 when you went down to this position, what you heard.

19 A. When I got to this position, I saw Velimir

20 Popovic, under number 1, the individual wearing number

21 2, and I didn't mention his name, and under number 3,

22 Stanko Savanovic. Opposite was Dragan Koljevrat, and

23 they were all members of the unit. With them there was

24 just one individual whom I didn't know.

25 When I asked who the man was, Stanko

1 Savanovic said that it was the commander of the Drina

2 Corps by the name of Zivanovic. And then the man with

3 number 2 on him, whose name I did not mention, said

4 he's not a general, he's not a commander, he's --

5 THE INTERPRETER: Could the witness repeat

6 that word, please.

7 A. -- he was drunk. And there was a jerrycan

8 with some alcohol, and it was tied to the battery of

9 the car. The man I did not know, I saw a hand launcher

10 which I had not seen before, of the type I hadn't seen,

11 and he said, "Who's that?" And Savanovic said, "I

12 found it in a house here." And I gave it to the

13 General -- I asked why he had given it to the General

14 and he said, "Because he's going to retire soon."

15 MR. HARMON:

16 Q. Now, what were these men drinking?

17 A. They were drinking, we call it in Bosnian,

18 Slivovitz.

19 THE INTERPRETER: Which is plum brandy.

20 MR. HARMON:

21 Q. Out of what kind of container were they

22 drinking from?

23 A. They were drinking from a plastic jerrycan.

24 MR. HARMON: Now, I'd like to have

25 Prosecutor's Exhibit 28/4 placed on the ELMO.

1 JUDGE RIAD: Mr. Harmon, the interpreters did

2 not hear the grade of Stanko Zivanovic. They said he

3 was not a general, he was not a commander, and it was

4 left open, an empty space there.

5 MR. HARMON:

6 Q. Could you repeat, Mr. Erdemovic, what was

7 said about Zivanovic?

8 JUDGE RIAD: Stanko Zivanovic.

9 A. He said he was the commander -- Zivanovic

10 said that he was the commander of the Drina Corps, and

11 to that the individual under number 2 answered that --

12 he said, "He's not a commander but he's an alcoholic,"

13 and everybody laughed at that and I did too.

14 MR. HARMON:

15 Q. What was the reason that was given to you why

16 the rocket launcher was given to this man?

17 A. Because he was going to be retired soon.

18 Q. Now, I have placed on the ELMO Prosecutor's

19 Exhibit 28/4. Do you see the man Zivanovic, who was

20 drinking at the barricade with you and other members of

21 the 10th Sabotage Detachment, in this particular

22 exhibit?

23 A. [Indicates]

24 MR. HARMON: Indicating, for the record, the

25 second individual from the right-hand side of the

1 image. Thank you, Mr. Erdemovic, and thank you,

2 Mr. Usher. I have finished with that exhibit.

3 Q. Mr. Erdemovic, I'm going to turn your

4 attention now to the 12th of July. Can you tell us

5 approximately what time you and members of your unit

6 left Srebrenica and returned to Vlasenica?

7 A. I think that it was around noon, that is to

8 say, in the morning hours, between 10.00 and 12.00.

9 That's when we left Srebrenica.

10 Q. Prior to leaving, where had you and members

11 of your unit been billeted?

12 A. Could you tell me what you mean by "where"?

13 Do you mean where we spent the night?

14 Q. Where you spent the night and where you spent

15 the morning hours of the 12th.

16 A. We spent the night on the southern side,

17 where I was located, where we provided security to the

18 entrance into town. There were two houses there; one

19 was a large house and the other one was a little

20 smaller.

21 Q. Did you and did members of your group remain

22 together until your departure on the morning of the

23 12th of July?

24 A. Yes.

25 Q. Now, at any time on the 12th of July,

1 Mr. Erdemovic, did you or did members of your unit

2 enter the town of Potocari?

3 A. No.

4 MR. HARMON: If I could have the usher's

5 assistance once again, please, if we could use

6 Prosecutor's Exhibit 1/E/1 which is an A3-sized map,

7 and if that could be placed on the ELMO.

8 Q. I'm going to ask you to look at this map,

9 Mr. Erdemovic, and I'm going to ask you to use the

10 pointer and indicate for the Judges the location where

11 you were and where you went and the route of your

12 travel. And if we could move that up on the ELMO,

13 please. That's fine right there.

14 Could you use the pointer, Mr. Erdemovic, and

15 just follow the line along your route of travel when

16 you returned to Vlasenica.

17 A. We went this away [indicates], towards

18 Milici, roundabout over Rudnik, and that was an open

19 pit mine, I think here [indicates], this part of the

20 mine. I don't know the territory very well but I think

21 it was. And when we passed by, there was some

22 machinery there and this sort of mining equipment. So

23 from Srebrenica we went along this route [indicates],

24 the roundabout route to Milici, and from Milici we

25 continued on to Vlasenica.

1 MR. HARMON: Indicating for the record, they

2 travelled south from Srebrenica, passed Zeleni Jadar,

3 up the road towards Milici and then over towards

4 Vlasenica. Thank you very much, Mr. Erdemovic.

5 Mr. Usher, I've finished with that exhibit.

6 Q. Now, did you return to your base in Bijeljina

7 or did you remain in Vlasenica on the 12th of July?

8 A. We remained in Vlasenica.

9 Q. Why didn't you go to Bijeljina?

10 A. I don't know.

11 Q. Now, I'm going to focus your attention,

12 Mr. Erdemovic, on the time frame between the 13th of

13 July and the 15th of July, and I don't want to go into

14 great detail but I'd like you to tell the Judges in

15 summary form where you and where certain members of

16 your unit went and why you went to that particular

17 location.

18 A. On the 12th, when we returned to Vlasenica,

19 we were late because our truck -- there was something

20 wrong with our truck and our unit was already there.

21 When we came to Vlasenica, at midnight on the 12th, we

22 learned that Pelemis had overturned, that is to say,

23 the commander of the unit Pelemis had overturned with

24 an APC not far from Vlasenica and our own base. Our

25 own base was on the road leading from Vlasenica to

1 Kladanj, the Vlasenica-Kladanj road. On that occasion,

2 a soldier had lost his life, and he was Dragan

3 Koljevrat and he was from Trebinje by birth.

4 On the 13th, in the morning when we got up, a

5 man who was in charge of the rear for our unit came up

6 to me and said that I was to attend the funeral, along

7 with some others, because I was a good friend of his

8 and I was the leader of his group at one point in

9 Bijeljina. And that was on the morning of the 13th.

10 We went to Trebinje, I myself, the individual who drove

11 the vehicle, and it was the driver under number 2, and

12 five or six others. I don't remember exactly who they

13 were but I think that's more or less how it was.

14 So we left on the 13th to Trebinje, and as

15 the journey was a long one, we had to pass by --

16 roundabout Sarajevo and the road had been destroyed by

17 the war. We had to go through the forests, and we

18 arrived in Trebinje on the 14th, in the morning, in the

19 early morning hours, perhaps 4.00 or 5.00 a.m., I'm not

20 quite sure. But that particular day we spent in

21 Trebinje. The funeral was on the 14th, so that in the

22 late afternoon hours, towards evening, we went towards

23 Vlasenica, and because the road was so bad we arrived

24 there on the 15th in the morning, once again at 5.00,

25 6.00, or 7.00 a.m., thereabouts. I don't know exactly

1 but it was the early hours of the morning.

2 And of course because we had spent the night

3 of the 10th outside our house, and on the 11th and 12th

4 I didn't get much sleep because we were travelling

5 around until midnight, and the next day, the 13th, I

6 attended the funeral; on the 14th, I was at the

7 funeral; on the 15th, the whole night I spent

8 travelling, so that on the night of the 15th, me and

9 all the others who were with me slept for the most part

10 of the day, until the late afternoon, 5.00 or 6.00,

11 perhaps.

12 Q. Now, in relation to Vlasenica, where is

13 Trebinje?

14 A. Trebinje is situated south, southwards in

15 Herzegovina, in the vicinity of the town of Dubrovnik,

16 which is in the Republic of Croatia.

17 Q. All right. Mr. Erdemovic, we're now going to

18 turn our attention to the 16th of July. On the 16th of

19 July, did you and did members of your unit receive a

20 new assignment?

21 A. Yes, we did.

22 Q. From whom did you receive the assignment?

23 A. Brano Gojkovic came and told us, told me,

24 Franc Kos, and Zoran Goronja that we should prepare for

25 our assignment. And when he asked him who said that we

1 should go, he said that the order had been issued by

2 Pelemis.

3 Q. Now, how many people were --

4 MR. HARMON: We've lost the English

5 translation.

6 THE INTERPRETER: Can you hear the English?

7 MR. HARMON: I can hear the English.

8 JUDGE RIAD: Judge Wald is bilingual. It's

9 okay.

10 MR. HARMON:

11 Q. How many members of the 10th Sabotage

12 Detachment received an assignment on this morning of

13 the 16th?

14 A. Eight.

15 Q. Can you name the eight individuals who went

16 on this particular assignment?

17 A. Brano Gojkovic, Aleksandar Cvetkovic, who

18 drove the vehicle that we were in, it was our unit's

19 van; Golijan Vlastimir; Franc Kos; Zoran Goronja;

20 Stanko Savanovic; and myself.

21 Q. You mentioned Marko Boskic.

22 A. Sorry. Sorry. Yes, there was him too.

23 Q. Now, these individuals were some members of

24 the Bijeljina platoon and some of the Vlasenica

25 platoon; is that correct?

1 A. Yes.

2 Q. Could you name the individuals in this

3 assignment who were part of the Vlasenica platoon?

4 A. Brano Gojkovic, Aleksandar Cvetkovic, and

5 Vlastimir Golijan.

6 Q. And the other members of this group were

7 members of your platoon; correct?

8 A. Yes.

9 Q. Who was the leader of this group?

10 A. Brano organised everything for us to pack,

11 take all the equipment necessary for the operation. He

12 was the leader.

13 Q. Now, was the purpose of the operation

14 explained to you while you were in Vlasenica?

15 A. No. We were only told that we were going

16 into an operation of some kind.

17 Q. Where did you go from Vlasenica?

18 A. From Vlasenica we went in the general

19 direction of Zvornik, and we stopped in Zvornik.

20 MR. HARMON: If I could have Prosecutor's

21 Exhibits 170, 171, and 172 placed on the ELMO.

22 Q. I'll wait until they are distributed to the

23 Judges before I ask you some questions about these.

24 Let's start, Mr. Erdemovic, with Prosecutor's

25 Exhibit 170. You said you went to Zvornik. Can you

1 identify the location in Prosecutor's Exhibit 170 as

2 being the location where you went?

3 A. Yes.

4 Q. Let me show you the next two exhibits.

5 Exhibit 171, is this another view of the location where

6 you went?

7 A. Yes.

8 MR. HARMON: Lastly, 172, if that could be

9 placed on the ELMO.

10 Q. Is that also the location where you and other

11 members of your unit went in Zvornik?

12 A. Yes, it was in the compound there. I don't

13 know how many buildings like this were there, but I do

14 know that that was the location.

15 MR. HARMON: Mr. Usher, if we could go back

16 to 171, please. That's fine.

17 Q. Now, Mr. Erdemovic, tell the Judges what

18 happened when you arrived at this location.

19 A. When we arrived here, in front of this ramp

20 [indicates], the ramp was opened up for us and our

21 vehicle entered. Only Brano got out of the car, and

22 the driver, and they went off in this administrative

23 building, reception area. And there were two military

24 policemen at the reception area. In front of these

25 buildings here [indicates], there were quite a number

1 of military policemen. Perhaps there were other forms

2 of police as well, perhaps civilian, but all I know is

3 that there were a lot of military policemen.

4 MR. HARMON: Now, the reception area, for the

5 record, the witness pointed to the structure on the far

6 right, in the foreground. And when he said there were

7 a lot of military policemen present, he was pointing to

8 the smaller building in the background that's directly

9 behind the gate that is open.

10 Q. Now, what did Brano Gojkovic do? Do you know

11 what he did when he went into this building? Did you

12 go with him, or did he go in there alone?

13 A. No. We all stayed in the van. Just he and

14 Cvetkovic went inside, and that was the driver of the

15 vehicle.

16 Q. Why don't you tell us what happened at that

17 location?

18 A. While we were sitting in the van, I don't

19 remember exactly whether I heard it over the radio or

20 on a Motorola, but it was stated that the Muslims that

21 broke through towards Tuzla had confiscated a vehicle

22 with heavy machine-guns on it and that they had taken

23 several policemen from Doboj prisoners. I don't know

24 if they were civilian policemen that these Muslims had

25 captured or whether they were military policemen.

1 After a few moments had gone by, from this

2 building, Brano Gojkovic, Aleksandar Cvetkovic, and a

3 Lieutenant Colonel whose name I didn't know, and two

4 policemen, came out. They had patches with the

5 "Military Police Drina Corps" on them. They came out

6 of the building.

7 Q. Now, did you see the insignia that said

8 "Drina Corps Military Policemen" on the two policemen

9 who came out with Brano Gojkovic?

10 A. Yes.

11 Q. And you said a Lieutenant Colonel came out as

12 well. How do you know that the individual who came out

13 with two military policemen from the Drina Corps was a

14 Lieutenant Colonel?

15 A. He had insignia denoting officer rank on his

16 chest. That individual had the insignia of officer

17 rank, with the rank he actually was, on his chest, on

18 the left-hand side.

19 Q. And that rank, again, was Lieutenant Colonel;

20 is that correct?

21 A. Yes, it is.

22 Q. Now, Mr. Erdemovic, after these men came out,

23 what happened?

24 A. Brano came. We had opened the door of the

25 van, and you would open it sideways, with a sideways

1 motion. He told us to shut the door. And when we

2 asked him where they were going, he said that we would

3 be escorting the Lieutenant Colonel who was in front of

4 us, in an Opel Kadett vehicle in front of us.

5 Q. Would Brano be escorting? The way I

6 understood your testimony, the way it was interpreted

7 to me, Brano would be escorting the Lieutenant

8 Colonel. Was it the other way around; in fact, the

9 Lieutenant Colonel would be escorting members of your

10 unit to a location?

11 A. No. Our vehicle followed the Lieutenant

12 Colonel and those two policemen who were in front of

13 us, in the Opel Kadett car in front of us.

14 Q. Where did you go?

15 A. We went in the direction of Zvornik, from

16 Zvornik towards Bijeljina. And not long afterwards we

17 turned off the road, the Zvornik-Bijeljina road, we

18 turned left onto a macadamised road surface -- it

19 wasn't an asphalt road -- and we arrived at a farm.

20 MR. HARMON: Could I have Prosecutor's

21 Exhibit 24/7, which is a large panorama, placed on the

22 ELMO.

23 Q. I'm going to show you this image,

24 Mr. Erdemovic, and ask you if the location that's shown

25 on Prosecutor's Exhibit is the farm where you arrived.

1 MR. HARMON: If you could place that on the

2 ELMO, if you could, Mr. Usher, and if you could move it

3 slowly across the ELMO so the people in the audience

4 could also see this location.

5 A. Yes.

6 Q. So this is the location that's depicted in

7 this panorama where you, the two Drina Corps military

8 policemen, the Lieutenant Colonel, and your group

9 arrived. By the way, did the Lieutenant Colonel have

10 any insignia on his uniform -- was he wearing a

11 uniform, in the first place?

12 A. Yes.

13 Q. What kind of a uniform was he wearing?

14 A. He had the uniform of the Army of Republika

15 Srpska. I don't remember about his pants, but I know

16 that his shirt was a summer shirt.

17 Q. Did he have any kind of insignia denoting

18 what particular unit he was a member of?

19 A. No.

20 Q. Now, after you arrived at this farm, what

21 happened?

22 A. The Lieutenant Colonel and the two policemen

23 got out of the car. The Lieutenant Colonel went into

24 this building here [indicates], where some men were

25 there, that I didn't know who they were. I think it

1 was an office belonging to those people who were

2 working there.

3 Q. How long did he stay in there?

4 A. Not long. Maybe two or three minutes.

5 Q. What happened then?

6 A. After that they all went; all those people

7 who were there moved away. Only the guard remained.

8 Q. When you say "all those people," you mean all

9 the people who were working at the farm?

10 A. Yes. They were on the farm. Whether they

11 were all working there, I don't know.

12 Q. How many people who had been present at the

13 farm remained after these other people left?

14 A. Just one.

15 Q. What happened then?

16 A. After that, when they had all left, the

17 Lieutenant Colonel was talking to Brano and I heard him

18 say that buses would be coming.

19 Q. Please continue.

20 A. As soon as he said that, it wasn't long after

21 that, he left with these two policemen in a car. Then

22 Brano came back to us and told us that buses would come

23 with civilians from Srebrenica on them. And I and some

24 others started objecting, saying, "What are we going to

25 do there?" And he said that we would have to execute

1 those people.

2 In the course of this debate, the first bus

3 was already arriving. This may have been 20 minutes

4 later or half an hour later. So the first buses came

5 in about half an hour, as he had said.

6 When the first bus arrived -- I know about

7 myself; I don't know exactly about the others, what

8 they said -- I said that I did not want to do that,

9 that I cannot do that, that that is not the task of our

10 unit. Brano told me then, "If you won't do it, stand

11 up with them or give them your rifle, and you will see

12 whether they will shoot you."

13 Q. Please continue.

14 A. When the first bus arrived, it parked here

15 [indicates]. It parked here [indicates], where we see

16 the green tractor-trailer.

17 MR. HARMON: Which is, for the record, near a

18 building that appears to have many openings in it and

19 appears to be the building that is on the farthest

20 right of the panorama. So there's a green

21 tractor-trailer on the left-hand side of that building,

22 in between a larger building that's a farmhouse with a

23 red tile roof.

24 Q. So that's the location where the buses

25 parked. Would you continue with your testimony,

1 please, Mr. Erdemovic.

2 A. When the first bus arrived, Brano told us

3 that we had to deploy in a line from this garage here

4 [indicates], from this building, in a straight line,

5 perhaps 100 metres long. I don't know exactly.

6 Q. You mean 100 metres away from the building

7 that has the openings and the tree next to it? You had

8 to deploy 100 metres past that building; is that

9 correct?

10 A. Yes.

11 Q. Into an open field?

12 A. Yes.

13 Q. All right. Please continue, Mr. Erdemovic.

14 A. Then I saw two policemen taking men out, men

15 who were in the bus, and these two men were probably

16 the security for the transport of these men, and they

17 reached Brano and Vlastimir Golijan. And the first

18 group of people were brought behind this garage down

19 there, maybe 100 metres away, maybe more, but roughly

20 to such a position. Then Brano told us to form a

21 line. The men in front of us were ordered to turn

22 their backs. When those men turned their backs to us,

23 we shot at them. We were given orders to shoot.

24 Q. Did Brano also shoot?

25 A. Yes.

1 Q. Did all of the members of your unit, the ten

2 people who had been sent over there, did they all

3 shoot?

4 A. Yes.

5 Q. All right. Continue, please.

6 Actually, Mr. Erdemovic, let me ask you some

7 questions at this point in time. Did the buses that

8 you saw coming to the Branjevo Farm, did they have any

9 kind of markings on them that you could identify?

10 A. There were markings of "Centrotrans Sarajevo"

11 and "Drinatrans Zvornik," transportation companies.

12 Q. After this first group of ten prisoners was

13 executed, what happened, Mr. Erdemovic?

14 A. Brano and Vlastimir Golijan, we again formed

15 a line to secure the path, and Brano and Golijan went

16 for the next group of people.

17 Q. What happened then?

18 A. The second group was brought, and they were

19 lined up immediately behind those first group. Our

20 backs were turned to the garage and we were moving in

21 the direction of the garage. And that is how groups

22 were brought in: Men again turned their backs to us

23 and we shot that group of people who were in front of

24 us.

25 Q. And then I take it another group was brought

1 for execution, and they were executed as well?

2 A. Yes.

3 Q. And is that how the scene repeated itself

4 throughout the day?

5 A. Yes, only I have to say that the last group

6 of the first bus, or at the beginning of the second

7 bus, I know that Aleksandar Cvetkovic and Brano had the

8 idea to speed up the execution so that we could use a

9 machine-gun, an M-84.

10 Q. What happened with that M-84 machine-gun?

11 A. Then Aleksandar Cvetkovic took this

12 machine-gun, positioned it, and started shooting at the

13 group of ten. However, because the ammunition was what

14 it was, the people were just mutilated and wounded, and

15 they begged to be finished off.

16 Q. Please continue.

17 A. Then a hot argument ensued between me, Brano,

18 Slovenac, Goronja, and Aco, because some people could

19 no longer listen to those men pleading to be killed,

20 and we were saying if they have to die, why couldn't

21 they die decently, peacefully, rather than being

22 mutilated and hit and insulted and hurt? And then they

23 put away that M-84 machine-gun.

24 Q. Now, Mr. Erdemovic, were any of these men who

25 were brought down to be executed blindfolded, did they

1 have their hands tied, or do you recall?

2 A. I can only remember that in the first bus

3 they were blindfolded and their hands were tied, as far

4 as I can remember.

5 Q. Now, the policemen who escorted these buses

6 of prisoners who were being brought to the execution

7 field, could you see any insignia on those policemen?

8 A. Yes. They were the same insignia as were

9 worn by the previous two policemen who came with that

10 Lieutenant Colonel.

11 Q. What did that insignia say?

12 A. The military police of the Drina Corps.

13 Q. Now, could you describe to the Judges the

14 role that these Drina Corps military policemen had in

15 the execution process that was taking place on the 16th

16 of July?

17 A. In the course of the transport, they probably

18 guarded the prisoners and escorted them in buses. When

19 they reached the farm, they took out ten men at a

20 time.

21 Q. So they segregated the groups of ten that

22 were passed on to members of your unit, and then those

23 men were walked to the execution field and murdered,

24 and then another ten individuals had been selected by

25 the members of the Drina Corps military police, taken

1 off the buses, and were waiting to be transported to

2 the execution field. Is that how it worked?

3 A. Yes.

4 Q. Now, approximately how many buses arrived at

5 the Branjevo farm on the 16th of July, as best as you

6 can recall?

7 A. As far as I can recall, because those were

8 terrible moments for me, I think between 15 and 20.

9 Q. What time did the executions start in the

10 morning of the 16th of July?

11 A. I think around 10.00.

12 Q. What time did they end on that same day?

13 A. 3.00 or 4.00 in the afternoon.

14 Q. Now, how many people do you estimate,

15 Mr. Erdemovic, were executed at the Branjevo farm on

16 the 16th of July?

17 A. I think about 1.000, 1.200.

18 Q. Your unit, the members of the 10th -- all of

19 the members who went on this assignment, including

20 Brano, participated in those executions, did they not?

21 A. Yes.

22 Q. At some point in time, Mr. Erdemovic, did you

23 have a conversation with one of the victims and attempt

24 to spare him from the fate that awaited him?

25 A. Yes. That man, as soon as he got off the

1 bus, started saying that he had helped some Serbs to

2 get out of Srebrenica and reach the Federal Republic of

3 Yugoslavia, and he was showing some pieces of paper

4 with the telephone numbers of those people. I took him

5 aside and told him, "Come here." He did. I started

6 talking to him. We spoke about what had happened in

7 Srebrenica. I let him light a cigarette. As there was

8 a tap, a water tap not far, and I think I also gave him

9 some water to drink.

10 I was sorry and I wanted to save that man and

11 others, but I selected him because he said that he had

12 saved Serbs in Srebrenica and helped them to reach the

13 territory of the Federal Republic of Yugoslavia, and I

14 thought that I might save him thanks to that. However,

15 not long afterwards, Vlastimir Golijan came, he took

16 the man, and then Brano came too. And I said, "Why

17 don't we investigate and see whether this man actually

18 did what he said," to save him, and they said as one

19 that they didn't want to have any witnesses.

20 Q. Was that man executed?

21 A. Yes. I think Vlastimir Golijan killed him.

22 Q. Now, Mr. Erdemovic, did you see Brano

23 Gojkovic order the bus drivers, who were transporting

24 these prisoners to the Branjevo farm, to do anything?

25 A. Yes. After the second bus, or the first -- I

1 don't know exactly -- they started drinking and the

2 spirits started to have their effect. And then

3 Vlastimir and Brano were saying that the drivers could

4 also be witnesses, and I know that one of the drivers

5 did shoot at a man and Brano gave him a gun to do

6 that. He shot at a man.

7 Q. Shot at him or killed him?

8 A. He shot at him. Now, whether that man died

9 straight away, I don't know, I can't remember, I can't

10 say. But he did shoot at him.

11 Q. Mr. Erdemovic, did the 10th Sabotage Unit

12 members who had gone to this farm kill all the 1.000 to

13 1.200 people, or did another military unit arrive at

14 the Branjevo farm arrive at some point during the day

15 and participate in the executions?

16 A. All the members of the 10th Sabotage

17 Detachment did not participate in these executions.

18 About -- between 1.00 and 2.00, members came from

19 Bratunac, so that I heard when somebody said that

20 people from Bratunac had come to assist. And they took

21 over the killing of those people, in the same way as

22 our group had done, only they recognised some of those

23 people and they took it out on them.

24 I think that one of the men from Bratunac was

25 a native of Srebrenica and he recognised some. I

1 remember he recognised the butcher from Srebrenica, and

2 I know that he said, "You're a good man, but I have to

3 kill you. I know that you were not a nationalist."

4 Q. Before we explore that, I want to correct a

5 part of the record that is in the transcript. The

6 record says at 12:09:01, "All of the members of the

7 10th Sabotage Detachment did not participate in these

8 executions." I understood your testimony to be that

9 all of the members of the 10th Sabotage Detachment did

10 participate in executions but didn't participate in

11 killing all of the people who had been executed on the

12 16th of July. Is that correct?

13 A. Yes, yes.

14 Q. Okay. Now --

15 JUDGE RIAD: Mr. Harmon, just a second. He

16 said, "The people who came from Bratunac." He said

17 "people". Were there also military people or --

18 MR. HARMON: I was going to get to that,

19 Judge Riad, and I'll explore that.

20 Q. I'd like to explore now the identities of

21 these people who came from Bratunac. First of all,

22 Mr. Erdemovic, how were they dressed?

23 A. They were, as far as I could remember, all

24 dressed in uniforms of the army of Republika Srpska.

25 Only one was wearing a uniform that I would see and

1 that I recognised as being the uniform of the American

2 army.

3 Q. Who was it who said, "The men from Bratunac

4 have arrived"?

5 A. I think it was Brano, but I'm not certain. I

6 think possibly it was him, because I saw him first

7 shake hands with them. Some people recognised each

8 other. Aleksandar Cvetkovic was there, and I saw that

9 they knew each other from before.

10 Q. Now, did it appear to you that the men from

11 Bratunac knew some of the people who had been brought

12 from Srebrenica?

13 A. Yes.

14 Q. In fact, you recounted at least one

15 conversation between one of the men who was from

16 Bratunac and the butcher from Srebrenica; is that

17 correct?

18 A. Yes.

19 Q. Did you conclude, based on your observations

20 of the interactions between the men from Bratunac and

21 the victims from Srebrenica, that these were local

22 people who knew each other?

23 A. Yes.

24 Q. Can you describe to the Judges how the people

25 from Bratunac acted toward the victims from

1 Srebrenica.

2 A. They beat them from steel rods. They kicked

3 them, they hit them. They forced them to pray in the

4 Muslim way. They simply took it out on them. They

5 humiliated them.

6 Q. In addition to the conversation between the

7 man who knew the butcher, did it appear that other

8 members of the Bratunac group knew other victims who

9 were from Srebrenica?

10 A. Yes.

11 MR. HARMON: Now, I'm going to ask that the

12 three next exhibits, Prosecutor's Exhibit 173, 174, and

13 175, be shown to the witness, placed on the ELMO, and

14 distributed to the Judges, please.

15 Q. Mr. Erdemovic, can you identify, in this

16 image that was taken in Potocari, one of the

17 individuals from Bratunac who was present and

18 participated in the execution at the Branjevo Military

19 Farm on the 16th of July, 1995?

20 A. This one here [indicates].

21 Q. Can you point to his face, please.

22 A. [Witness complies]

23 MR. HARMON: Indicating, for the record, in

24 Prosecutor's Exhibit 173, the man who is on the far

25 left-hand side of the image. He has a bandana on his

1 head.

2 Q. Could you turn to the next exhibit, please,

3 174? Do you see one of the men who participated in the

4 executions at the Branjevo Military Farm on the 16th of

5 July in this particular image?

6 A. Yes. This one [indicates].

7 Q. Is that the man who appeared in the previous

8 image?

9 A. Yes.

10 MR. HARMON: Indicating, on Prosecutor's

11 Exhibit 174, a man on the far right-hand side of the

12 image, wearing a camouflage uniform and wearing a

13 bandana on his head.

14 Q. Lastly, let me show you Prosecutor's Exhibit

15 175. Do you recognise the man in Prosecutor's 175?

16 A. Yes.

17 Q. Who is that man?

18 A. He's the same man who was at the farm that

19 day, only in this case he's in civilian clothes. But I

20 remember him well.

21 Q. He's the same man who was wearing a bandana

22 in Prosecutor's Exhibit 173 and 174; is that correct?

23 A. Yes.

24 MR. HARMON: I'm finished with those

25 exhibits, Mr. Usher. Thank you.

1 Q. Now, after the arrival of the men from

2 Bratunac, did members of your unit also participate in

3 the continued killings that were taking place at the

4 farm?

5 A. I can't say regarding everyone, but I know

6 that four men did not continue to participate.

7 Q. Who were those four men who did not continue

8 to participate?

9 A. Myself, Franc Kos, Marko Boskic, and Zoran

10 Goronja.

11 MR. HARMON: Could I please have Prosecutor's

12 Exhibit 158 placed back on the ELMO.

13 Q. Did one member of your unit, Mr. Erdemovic,

14 brag to you how many men he had killed at the Branjevo

15 Military Farm?

16 A. Yes. It is Stanko Savanovic, number 3. He

17 said that he had killed between 200 and 300 men, that

18 he had counted them.

19 Q. So the man who is marked number 3 in that

20 exhibit was a participant in the execution squad with

21 you, and he told you that he had killed between 250 and

22 300 of these individuals; correct?

23 A. Yes.

24 MR. HARMON: All right. Thank you very

25 much. I'm finished with that exhibit.

1 Q. Mr. Erdemovic, what was the age range of the

2 people who were murdered at the Branjevo Military Farm?

3 A. As far as I could tell, between 17 and 60 or

4 70.

5 Q. How were these people dressed?

6 A. They were all in civilian clothes, except for

7 one who had camouflage pants.

8 Q. Did any of these people offer resistance of

9 any kind to the execution squad or to the Branjevo --

10 I'm sorry, the Bratunac Brigade soldiers who were

11 present?

12 A. Yes, one man. I think when they had just

13 arrived, he started running, trying to escape, and they

14 caught up with him and killed him.

15 Q. Now, were Drina Corps military policemen

16 escorting each and every bus that came to the execution

17 fields?

18 A. Yes.

19 Q. Now, while the last bus was coming to the

20 execution field, did anyone else appear with that bus

21 at or about the time of the arrival of that bus?

22 A. Could you repeat the question once again,

23 please?

24 Q. I'll ask it a different way. Did the

25 Lieutenant Colonel who had escorted you to the Branjevo

1 farm return with anybody else later in the afternoon?

2 A. Yes. He came at the end, when these men from

3 Bratunac were emptying the last bus.

4 Q. And he was present when these executions --

5 the last bus of people were being executed?

6 A. Yes.

7 Q. Was he accompanied by anybody else when he

8 came to the farm?

9 A. There were those men who were there before,

10 those two military policemen who were there when we

11 headed for the Branjevo farm.

12 Q. Tell the Judges what happened when he arrived

13 at the Branjevo Military Farm.

14 A. We were sitting down against the wall of the

15 building on the farm that I showed you on the picture.

16 Then these men from Bratunac were still taking people

17 and killing them. Brano, Savanovic, and Cvetkovic were

18 close to the bus, I think. The Lieutenant Colonel went

19 towards them, over there. We were talking, and just

20 then somebody asked the guard where the people would be

21 buried, and he said they would be buried there, and he

22 also said that people had been buried there before.

23 Now, I don't know whether he meant before the Second

24 World War, before this war, what exactly he meant.

25 Not long after that, this Lieutenant Colonel

1 and Brano came, Aleksandar Cvetkovic, Savanovic, and he

2 said that we had to go to the nearby club where there

3 were 500 Muslims from Srebrenica who wanted to break

4 down the door. Four of us said that we wouldn't go

5 there to do that, that we'd had enough, that we were

6 nobody's killing machines. Brano said, "Why?" We just

7 said we didn't want to do any more, that enough is

8 enough. And then the Lieutenant Colonel turned around

9 and went towards those men from Bratunac, and after a

10 minute or two, or five -- I don't know -- they got into

11 their vehicles and left. And we were still at the

12 farm. There was the machine-gun and all the weapons.

13 When we were loading it into the van, we heard the

14 sound of gunfire coming from that direction.

15 Q. Coming from which direction?

16 A. From the direction -- well, you see, the

17 farm, when you're coming from Zvornik, you come across

18 that farm, the Zvornik-Bijeljina road. You first reach

19 the farm and then this place on the road to Bijeljina.

20 Q. Let me ask you: Did all of the men who had

21 participated in the killings at the Branjevo farm leave

22 the farm to go to another location where people had to

23 be killed?

24 A. The people from Bratunac went straight away.

25 But Brano told us in the car that that Lieutenant

1 Colonel had said that we ought to attend a meeting at a

2 cafe in that place.

3 Q. Before we get into the next set of killings,

4 I want to just ask you: How many men from Bratunac

5 were there who had arrived to participate in the

6 killings and then went to another location to continue

7 with the killings?

8 A. Perhaps ten, perhaps more, perhaps one or two

9 men less. I don't really know.

10 Q. Before we leave the Branjevo farm, I'd like

11 you to take a look at another exhibit, which is

12 Prosecutor's Exhibit 24/2, which is an aerial image

13 that has markings on it. I ask that that be placed on

14 the ELMO.

15 Mr. Erdemovic, you've seen this picture in my

16 office before?

17 A. Yes.

18 Q. Now, this is an aerial image of the Branjevo

19 farm; is that correct?

20 A. Yes.

21 Q. Does this show the location where the people

22 who had been executed fell?

23 A. Yes.

24 Q. Does this image accurately reflect the

25 location of the buildings and the bodies from the

1 executions on the 16th of July, 1995?

2 A. Yes. I remember this building [indicates]

3 and this other one [indicates]. I don't remember this

4 one so well [indicates] but I do remember this one and

5 the one over here [indicates]. I recognise that that

6 is the farm and the place where the people were taken

7 from the buses.

8 Q. Now, are there other locations where people

9 were executed beside the area with the large oval that

10 says "Bodies"?

11 A. Yes. I think these people from Bratunac,

12 those first people were taken off here [indicates],

13 this area here [indicates].

14 MR. HARMON: Indicating for the record the

15 area to the left of the word that says "Bodies," in

16 between -- slightly above the word that says "Wheel."

17 In that area, there were additional bodies. All

18 right.

19 Q. Mr. Erdemovic, thank you. I'm finished with

20 this particular exhibit.

21 Let's turn our attention back now,

22 Mr. Erdemovic, to the departure of the people from --

23 the soldiers from Bratunac who left and went to a

24 particular location. As you were leaving, you said you

25 could hear shooting; is that correct?

1 A. Yes.

2 Q. How soon after the departure of the soldiers

3 from Bratunac was it that you left the Branjevo farm?

4 A. Perhaps some 10 minutes later, perhaps 15,

5 thereabouts; 10 to 15 minutes.

6 Q. Where did you go?

7 A. We went in the direction of Pilica, the place

8 of Pilica, which is where that cafe was located, the

9 coffee bar where we were to have a meeting with that

10 Lieutenant Colonel that Brano told us about.

11 Q. Describe the scene to the Judges as you

12 entered this particular village where a cafe was

13 located.

14 A. When you come from the Zvornik direction, the

15 cafe is on the right-hand side. It is the

16 Zvornik-Bijeljina road. The cafe is on the right-hand

17 side, at a place called Pilica, and I think that is at

18 the entrance to Pilica itself. Opposite the cafe was

19 this other place, and when we came in front of the

20 cafe, in front of this building on the other side, we

21 saw people lying down on the ground, lying around on

22 the ground, and you could hear shots.

23 Q. Could you hear detonations from grenades as

24 well?

25 A. Afterwards, when we'd already entered the

1 cafe you could hear detonations.

2 Q. I'm going to show you a number of exhibits

3 and ask you to identify the various locations that you

4 are going to be testifying about. If we could start

5 first of all with Prosecutor's Exhibit 25/15, and then

6 we will turn to 25/2, 25/5, and 25/7.

7 While we're getting those exhibits,

8 Mr. Erdemovic, how far apart was the cafe from the

9 location where shooting was taking place?

10 A. I would say about 70 to 100 metres. I can't

11 say exactly.

12 Q. We're going to start by placing on the ELMO,

13 Mr. Erdemovic, Prosecutor's Exhibit 25/15. You

14 mentioned the cafe. Does this picture show the cafe

15 where you and other members of the 10th Sabotage

16 Detachment went after you left the Branjevo Military

17 Farm?

18 A. Yes.

19 Q. Is this the cafe -- and did you remain in

20 this cafe while killings took place at a location

21 across the road?

22 A. Yes.

23 Q. Did you remain in that cafe until the

24 killings that took place across the road finished?

25 A. Yes.

1 Q. Now, if we could turn to the next exhibit,

2 25/2. Mr. Erdemovic, can you point out to the

3 Judges -- first of all, you've seen this picture in my

4 office prior to testifying; is that correct?

5 A. Yes.

6 Q. Can you point out to the Judges first the

7 cafe, where you and other members of your squad were

8 sitting, and then point out the location where the

9 killings were taking place.

10 A. [Indicates]

11 MR. HARMON: Indicating, first of all, the

12 building that has the sign "Cafe" above it.

13 Q. Where did the killings take place?

14 A. [Indicates]

15 MR. HARMON: Indicating the cultural hall to

16 the bottom part of the image.

17 Q. Mr. Erdemovic, let's take a look at the next

18 picture, please, which is Prosecutor's Exhibit 25/5.

19 What is this building?

20 A. This reminds me of that hall in Pilica.

21 Q. All right. Is this the location -- what

22 happened at this location, Mr. Erdemovic?

23 A. Over here [indicates], I can't show you

24 exactly, but somewhere here to the right [indicates],

25 when we arrived, upon our arrival in front of the cafe

1 with the vehicle, that's where the bodies were lying

2 down on the ground, and shots were heard inside over

3 there, but I didn't go there.

4 Q. All right. Let's turn to our last exhibit,

5 which is 25/7.

6 MR. HARMON: I'm sorry. There should be one

7 more exhibit. We should have 25/2, 25/5, and 25/7.

8 There should be three exhibits. Mr. Usher, what is the

9 number on that exhibit, please?

10 THE USHER: 25/5.

11 MR. HARMON: If we could turn to 25/5, then.

12 Q. I want to lastly show you this picture. Can

13 you show to the Judges, Mr. Erdemovic, first of all,

14 the location where the killings took place?

15 A. This building here [indicates].

16 MR. HARMON: Indicating, for the record, the

17 building that's above the two buses that appear in the

18 middle of the picture.

19 Q. And where is the cafe located where you and

20 other members of your unit were sitting when the

21 killings were taking place?

22 A. Here [indicates].

23 MR. HARMON: Indicating the building in the

24 lower right-hand corner. You can only see the roof

25 portion of that building.

1 Q. Mr. Erdemovic, when you were sitting in the

2 cafe, was there something at the location where the two

3 buses that appear in the middle of this image?

4 A. As far as I remember, that's where the

5 checkpoint of the civilian police was located.

6 Q. Now we've set the scene for the rest of your

7 testimony, Mr. Erdemovic. Would you tell the Judges,

8 then, what happened when you got to the cafe, who was

9 there, what you saw, and what you heard.

10 A. When we arrived at the cafe -- when you go

11 in, when you enter the cafe, at the entrance, on the

12 right-hand side, I called this -- these were little

13 separate places to sit, and on the right-hand side,

14 this Lieutenant Colonel was sitting down with another

15 military policeman. I didn't see the other one.

16 Q. Please continue.

17 A. We all went inside. I and Franc Kos sat

18 right next to -- sat at the table on the left-hand

19 side, by the door. All the others went off, Brano,

20 Vlastimir, Aco, Boskic, Goronja. And the Lieutenant

21 Colonel said, that is, he called the man working there

22 and told him to bring drinks. I and Slovenac, as far

23 as I remember, had some coffee, the others were, I

24 think, drinking brandy, and they were talking. I

25 didn't listen to what they were saying. You could

1 still hear the shooting, and the detonations were heard

2 at that point in that building.

3 Q. "That building" being the building across the

4 street.

5 A. Yes, that's right.

6 Q. How long did you remain there -- I'm sorry.

7 How long while you were there did you continue to hear

8 shots and detonations coming from the building across

9 the street?

10 A. Not long. Between 15 and 20 minutes,

11 perhaps.

12 Q. All right. Now, after 15 or 20 minutes, what

13 happened, Mr. Erdemovic?

14 A. First of all, that man came, the one that I

15 have already showed you with the bandana on his head,

16 from Bratunac, he came inside and said that everything

17 was over, and then the others came in as well. And

18 they talked to the Lieutenant Colonel for a while, and

19 then we said that we wanted to go home. And not long

20 after that we got up, got into our vehicle, and went

21 off. And I remember that the Lieutenant Colonel just

22 said, "Those who survived survived."

23 Q. I take it at this second execution site,

24 which was in this town, no members of the 10th Sabotage

25 Detachment participated in those killings; is that

1 correct?

2 A. No. That's correct.

3 Q. The killings that took place at this

4 particular location were committed, as far as you could

5 see, by the men from Bratunac, who were dressed in the

6 military uniform of the army of the Republika Srpska;

7 is that correct?

8 A. Yes.

9 Q. Now, Mr. Erdemovic, you said you wanted to --

10 you asked to leave. Did you, in fact, then leave the

11 location of the cafe shortly after the killings that

12 had taken place across the street occurred?

13 A. Yes. We went in the direction of Vlasenica.

14 Q. Did all of the members of the execution squad

15 from the 10th Sabotage Detachment return to Vlasenica?

16 A. Yes.

17 Q. Do you know where the men from Bratunac went?

18 A. No.

19 Q. Do you know where the Lieutenant Colonel

20 went?

21 A. No.

22 Q. Do you know where the military policemen from

23 the Drina Corps went?

24 A. No.

25 Q. All right. Now, after your return to

1 Vlasenica, did you eventually return back to your base

2 in Bijeljina?

3 A. Yes. When we returned, not much time went

4 by, they said a bus would come to take us to Bijeljina,

5 and that's what in fact happened.

6 Q. Mr. Erdemovic, after these killings took

7 place, you remained with members of your unit, first of

8 all, in Vlasenica briefly, and then in Bijeljina, and

9 you had an opportunity to converse with other members

10 of your unit. Is that correct?

11 A. Yes.

12 Q. Now, did you hear at any time, in your

13 conversations with your colleagues, that members of the

14 10th Sabotage Detachment had participated in the

15 separation of men from women and children in Potocari

16 that occurred on the 11th and the 12th of July? Did

17 you ever hear anything from any of your colleagues that

18 they had participated in that?

19 A. No.

20 Q. Did you ever hear, Mr. Erdemovic, in talking

21 to your colleagues, that members of the 10th Sabotage

22 Detachment had participated in the detention of men in

23 Potocari, in Bratunac at various locations, at the Luke

24 school near Kladanj, in the Petkovci school, or the

25 Grbavci school, or the Pilica school, or the Rocevic

1 school?

2 A. No.

3 Q. So you never heard any of your colleagues

4 talking about that.

5 A. No. But some of these places, I heard of

6 them for the first time later on, when your

7 investigators questioned me.

8 Q. All right. Now, since your group was a

9 reconnaissance group, Mr. Erdemovic, did you ever hear

10 that members of the 10th Sabotage Detachment

11 reconnoitred to find suitable detention facilities

12 where Bosnian Muslims from Srebrenica were detained

13 prior to being executed?

14 A. As far as I know, no.

15 Q. Did you ever hear that members of your unit

16 participated in being guards or providing security for

17 Bosnian Muslim prisoners who were detained at various

18 sites prior to their execution?

19 A. No.

20 Q. Did you ever hear that members of the 10th

21 Sabotage Detachment participated in mass executions at

22 the Kravica warehouse, at Orahovac, at a dam, or at a

23 location Kozluk?

24 A. No.

25 Q. Did you ever hear, Mr. Erdemovic, that

1 members of the 10th Sabotage Detachment participated in

2 the burial or the operation of heavy equipment of

3 victims from massacres that took place at the Branjevo

4 Military Farm, at the Kravica warehouse, at Orahovac,

5 at the Dam, or at Kozluk?

6 A. No.

7 Q. Mr. Erdemovic, to your knowledge, I take it

8 that your understanding was that your unit participated

9 in the executions only at the Branjevo Military Farm;

10 is that correct?

11 A. Yes. And I heard later on, when I left

12 hospital, because after Srebrenica I was wounded and I

13 was in a hospital in Bijeljina, first of all, and then

14 at the military academy hospital, I heard rumours going

15 around that individuals had been in the Nova Kasaba.

16 Q. All right. But you didn't hear any rumours

17 about those people participating in executions at Nova

18 Kasaba, did you?

19 A. No.

20 Q. All right. Mr. Erdemovic, thank you very

21 much.

22 MR. HARMON: Judge Riad, Judge Wald, I've

23 concluded my direct examination of Mr. Erdemovic. I

24 have no further questions.

25 JUDGE RIAD: You said you had two hours. So

1 you've concluded.

2 MR. HARMON: I have concluded.

3 JUDGE RIAD: I would like very much to

4 express my admiration.

5 We will adjourn for 20 minutes and resume at

6 1.00.

7 Mr. Erdemovic, you know from your experience

8 that now the Defence counsel will ask you some

9 questions. I would like to seize this opportunity to

10 tell you that the Bench appreciates very much you're

11 coming to testify.

12 We are adjourned until 1.00.

13 --- Recess taken at 12.40 p.m.

14 --- On resuming at 1.00 p.m.

15 JUDGE RIAD: Mr. Visnjic or Mr. Petrusic.

16 THE INTERPRETER: Microphone, Your Honour.

17 JUDGE RIAD: Yes. Please proceed. Good

18 afternoon.

19 MR. PETRUSIC: [Interpretation] Good

20 afternoon, Your Honours, my learned colleagues of the

21 Prosecution.

22 Cross-examined by Mr. Petrusic:

23 Q. Good afternoon, Mr. Erdemovic.

24 Mr. Erdemovic, can we say that you became a

25 member of the Republika Srpska army in Dvorovi?

1 A. Yes.

2 Q. Did you then sign an agreement with the army

3 of Republika Srpska as to your membership in the army?

4 A. Not then but afterwards. Well, when Pelemis

5 joined in October 1994.

6 Q. Can you tell us something about that contract

7 or agreement.

8 A. I read it out, I had it in my hands, and it

9 was between me, as a member of the 10th Sabotage

10 Detachment, and the Main Staff, as far as I know, of

11 the army of Republika Srpska.

12 Q. So that contract was between you and the Main

13 Staff of the army of Republika Srpska, to make matters

14 quite clear.

15 A. Yes.

16 Q. So we can say that you were a professional

17 soldier of the army of Republika Srpska, were you not?

18 A. Yes, by signing that contract or agreement,

19 you could put it that way, yes.

20 Q. Mr. Erdemovic, I should now like to ask you

21 some technical questions. We're speaking the same

22 language, you and I, so please make pauses between the

23 question and the answer.

24 A. Yes, I will do so. I apologise.

25 Q. Mr. Erdemovic, do you know whether the other

1 members, and I'm speaking of the Drina Corps

2 specifically, individual brigades, Milicka, Bratunac,

3 Bircka, Zvornicka Brigades, whether their soldiers had

4 the same kind of contract with the army?

5 A. I'm not aware of that. I don't know.

6 Q. Can we say that the command structure of your

7 unit with respect to superiority was made up of the

8 following hierarchy: We had Colonel Salapura as the

9 top man, top officer; then we had Major Pecanac; then

10 we had First Lieutenant Pelemis and Kremenovic, whom I

11 think was in charge of the rear for your detachment;

12 followed by two platoon leaders, Lule of the Vlasenicki

13 and Franc Kos of the Bijeljina platoon.

14 A. That is all correct. But Kremenovic was not

15 in charge of the rear, he was Pelemis' deputy.

16 Q. Can we then say that at the top of that

17 pyramid, according to this chain of command, was the

18 Main Staff of the army of Republika Srpska?

19 A. Yes, the intelligence staff of the army of

20 Republika Srpska.

21 Q. And by the same token, the Main Staff of the

22 Republika Srpska army.

23 A. Yes, that's right.

24 Q. In a military hierarchy of this type, in the

25 command sense or in actual, practical terms, or in any

1 other sense, you didn't have any links with the Drina

2 command; is that correct?

3 A. Yes, that is correct. Yes, it is correct.

4 Q. When you went on assignment to the zones of

5 responsibility of other corps, in addition to

6 information at the command level saying that you would

7 be passing through, you continued to be under your

8 command; that is, your platoon was under the command of

9 Mr. Pelemis, was it not?

10 I can't see an answer on the transcript.

11 A. The answer is yes.

12 Q. So nobody else was able to issue orders to

13 you except for your command.

14 A. Yes, that is correct.

15 Q. Mr. Erdemovic, can it be said that you didn't

16 have your own area of responsibility, in fact?

17 A. Yes.

18 Q. When other units joined you in your

19 operations, in the particular case of the mine near

20 Srebrenica, did the members of that unit come under

21 your command, the same command as you?

22 A. They were not directly under our command, but

23 they were attached to us just to show us the way.

24 Q. So their command could not issue orders to

25 you.

1 A. No. No.

2 Q. And could your command issue orders to them?

3 A. Well, if they were attached to us for that

4 occasion, then probably our commander could issue

5 orders to those men who were attached to us.

6 Q. This relationship, at what level did it

7 function? At the level of Pelemis command or a higher

8 level?

9 A. I only know that if Pelemis was with us, then

10 he could command those men. If it was someone else,

11 then he would be the one. Now whether there was a link

12 between Salapura, Major Pecanac, and the brigade

13 command, of the people who were attached to us, I

14 really don't know.

15 Q. Mr. Erdemovic, I think you said, and please

16 correct me if I'm wrong, that on the 10th of July you

17 headed from Bijeljina, towards Zvornik, towards

18 Bratunac.

19 A. Yes.

20 Q. And you arrived in Bratunac.

21 A. Yes.

22 Q. How many members of the 10th Sabotage

23 Detachment were boarded onto, I suppose, some trucks or

24 buses in Bijeljina?

25 A. Between 15 and 20, into a small bus. I don't

1 know exactly now but between 15 and 20. That is what I

2 think.

3 Q. You reached Bratunac on the 10th. What time

4 of day was it, roughly?

5 A. Well, maybe 2.00 in the afternoon. I don't

6 know exactly.

7 Q. Could you please describe your movements from

8 Bratunac to the position in Srebrenica?

9 A. I don't know the area well but I know that we

10 went a roundabout away through woods and over hills. I

11 know it was a difficult route for us to take. Our

12 group and the group from Vlasenica were led by two

13 three-barrelled guns belonging to the former JNA.

14 Q. Was there a total of 15 of you, including you

15 and the group from Vlasenica, or was the Vlasenica

16 group independent?

17 A. No. You asked me, "How many of you started

18 from Bijeljina" and I said between 15 and 20. But when

19 we got to Bratunac, shortly after that these men from

20 Vlasenica came.

21 Q. How many of them arrived?

22 A. I don't know. I think there was a total --

23 when we left on the 11th [sic] for Srebrenica, there

24 must have been about 30 of us, but I don't know

25 exactly.

1 Q. You reached the area above Srebrenica on the

2 10th, in the evening. Were you then under Pelemis'

3 command?

4 A. Yes.

5 Q. Both platoons.

6 A. Yes.

7 Q. In the morning, on the 11th of July, who gave

8 you orders to go to Srebrenica, into the town itself?

9 A. Milorad Pelemis, the commander of our unit.

10 Q. Mr. Erdemovic, were there with you members of

11 the regular units of the Drina Corps? I mean members

12 of the Milici, Bratunac, Zvornik, and Vlasenica

13 Brigades.

14 A. There were about 15 men from the Drina Wolves

15 which, as far as I know, were billeted in Zvornik, and

16 they came under Pelemis' command because he went into

17 town with us then. They were attached to our unit.

18 Q. You were divided into several groups. Can

19 you tell us how many?

20 A. As far as I know, our unit was divided into

21 four groups.

22 Q. Were members of the Drina Wolves with you in

23 those groups?

24 A. No, they were not mixed up with us in those

25 groups.

1 Q. So they were not under Pelemis' command

2 either.

3 A. Well, judging by the way Pelemis spoke to us,

4 I gathered that Pelemis could give them an order.

5 Q. Those members of the Drina Wolves, did they

6 have their leader?

7 A. Yes.

8 Q. At that location?

9 A. The leader of the group was certainly with

10 them, the Drina Wolves.

11 Q. Do you know who that leader was?

12 A. No.

13 Q. If I understand you correctly, it's not

14 Legenda.

15 A. No, Legenda was not there.

16 Q. In your examination-in-chief you mentioned

17 the order that you should guide the population towards

18 the football stadium.

19 A. Yes. Pelemis told us -- people asked, "What

20 if we come across civilians?" He said that we should

21 direct the civilians to go in front of us towards the

22 football stadium.

23 Q. So you didn't come across civilians, rather,

24 your group didn't.

25 A. Yes, we came across a couple. Throughout

1 that period there may have been 200 civilians that we

2 came across, elderly people, women, people who couldn't

3 move quickly.

4 Q. Did you see them go to the football pitch?

5 A. They went in front of us so I didn't see

6 that.

7 Q. Do you know that that football pitch, viewed

8 from Srebrenica, is in the direction of Potocari?

9 A. At the time I didn't know. I do now.

10 Q. So you know the location where it is now.

11 A. Yes, today I know.

12 Q. Could you conclude today that they went in

13 the direction of Potocari?

14 A. When I reached the centre of town, what I

15 thought was the centre of town, I think they took the

16 road towards Potocari.

17 Q. After a certain amount of time, after the

18 bombing raids by NATO forces, you were given orders to

19 withdraw to one of the checkpoints at the entrance to

20 Srebrenica, on the southern side.

21 A. When we reached this second mosque, upon

22 entering Srebrenica, Pelemis said that everything was

23 finished and that members of various units were coming

24 down from the hills -- I don't know exactly which units

25 they belonged to, but they were coming down -- and

1 Pelemis said we shouldn't move forward any more but

2 that we should go back to where we had started out from

3 entering the town, and to guard the entrance to the

4 town.

5 On the way there he told us to inform him

6 when General Mladic and the others arrived. He didn't

7 say who the others would be. I just remember him

8 mentioning General Mladic.

9 Q. The road that you took on the way back, is

10 that the road that General Mladic came along?

11 A. Three vehicles came. First was a Mercedes

12 belonging to the former JNA. Mladic was sitting in

13 front, and I didn't recognise the other persons.

14 Q. From the position where you were at that

15 checkpoint, could you see how many troops had entered

16 the town?

17 A. I don't know how many, I can't say now, but

18 in my estimate there must have been 500 or 700 soldiers

19 maybe.

20 Q. And they passed by your checkpoint?

21 A. No. No, they were coming down from the

22 surrounding hills. And before the vehicles that passed

23 were two APCs, a self-propelled and a Praga, as far as

24 I can remember, but not many troops passed that

25 checkpoint.

1 Q. At that checkpoint you spent the night.

2 A. Not at the checkpoint itself. It was not a

3 checkpoint. We were protecting the entrance to the

4 town. I learnt here that this was the southern side of

5 Srebrenica. Yes, we spent the night there in houses, a

6 big house, I remember, and a smaller house.

7 Q. The order for movement the next day, the 12th

8 of July, between 10.00 and 12.00, came from Pelemis.

9 A. No. A man who sometimes drove Pelemis, under

10 the name of Zoran Stupar, came and said that that

11 Pelemis had ordered us to move towards Vlasenica. We

12 were already supposed to go and search this mine, one

13 at the entrance to Srebrenica and the other coming out

14 at the Bratunac side, and we were informed that we

15 should go to Vlasenica.

16 Q. So Stupar is conveying Pelemis' orders to

17 you.

18 A. Yes.

19 Q. And Pelemis previously had issued orders that

20 you should search the mine.

21 A. When we got down into town, after a few

22 minutes a man came, I think his name was Garic, from

23 Vlasenica, and the mine was in his area. He asked

24 Pelemis, as we knew the mine, that we should work

25 there. We should have done that the next day but we

1 didn't. I don't know why.

2 Q. Let us go back for a moment to the 11th

3 again. Your comrade from the detachment, I think the

4 young man whose funeral you attended later, when he

5 described General Zivanovic as a drunk, when he said,

6 "He's not a General, he's not a commander, he's a

7 drunk," did he mean "pijano," meaning drunk, did he

8 mean a person who is frequently drunk? Is that what

9 the term implies?

10 A. That is what it sounded like to me, and since

11 I saw him drinking brandy from the jerrycan, that is

12 how we describe a man who drinks.

13 Q. So he wanted to describe him as a person

14 prone to alcohol, and thereby that he shouldn't have

15 the role he has as a commander.

16 A. Yes, that's what it sounded like.

17 Q. Mr. Erdemovic, how many members of the 10th

18 Detachment left Srebrenica and went towards Vlasenica?

19 A. As far as I can remember, all the members of

20 the unit, on the 12th, left.

21 Q. Therefore, some 30 of you.

22 A. Yes. May I just say, we didn't see Pelemis

23 when we left Srebrenica, we met him on the way

24 somewhere, towards the south, where there was this

25 former UNPROFOR checkpoint, south of Srebrenica. We

1 found him, Cico, and another two soldiers there, who

2 were with an APC that you saw on the video clip which

3 they had seized from UNPROFOR.

4 Q. So your group went south of Srebrenica,

5 Zeleni Jadar, that is, the mine, Milici, and then the

6 road goes on to Vlasenica.

7 A. I don't know that area too well, but when we

8 passed I could see that there were open cast mines. So

9 possibly those were mines.

10 Q. But regardless of your knowledge or not of

11 the area, there's no doubt that you went to the south

12 of Srebrenica, in the direction of Vlasenica.

13 On that road, did you see members of the

14 Drina Corps?

15 A. No.

16 Q. On the 16th of July you left Vlasenica via

17 Zvornik, towards the farm, and then you saw a certain

18 number of members of the police.

19 A. Yes.

20 Q. Do you know under whose command they were?

21 A. I just saw the emblem. It said, "The

22 Military Police of the Drina Corps." I don't know

23 exactly under whose command they were. The name of the

24 person or his rank, I don't know.

25 Q. Do you know how units of the Drina Corps were

1 deployed at the time in their area of responsibility,

2 on the 16th of July?

3 A. No.

4 Q. Do you know that at the time another

5 operation was under way?

6 A. I heard that over the radio, that the

7 Muslims, who were going from Srebrenica, were breaking

8 through towards Tuzla and that they had managed to

9 capture a Praga or a self-propelled gun, and several

10 policemen from Doboj. I don't know whether they were

11 civilian police or military police, or whether they

12 were really from Doboj. But that is what I heard.

13 Q. Do you know, and had you heard that on the

14 16th of July there were other combat operations in

15 Zepa?

16 A. No.

17 Q. You came across a Lieutenant Colonel in

18 Zvornik?

19 A. Yes.

20 Q. Could you describe him, please.

21 A. He was tall, I would say about a metre and 90

22 centimetres, heavily built. He had a rather big head.

23 He had -- I don't know how to put it. It was very

24 sunny that day, very hot, and he had a cap. As far as

25 I could remember, he had greying hair and a receding

1 hairline.

2 MR. PETRUSIC: [Interpretation] I beg your

3 pardon, Mr. President.

4 Q. Excuse me, Mr. Erdemovic. Are you sure,

5 Mr. Erdemovic, that he had the rank of Lieutenant

6 Colonel?

7 A. Yes.

8 MR. PETRUSIC: [Interpretation] Mr. President,

9 with your permission, I should like to show 28/15,

10 Prosecution Exhibit, on the ELMO for identification

11 purposes.

12 Q. Mr. Erdemovic, the officer whose head has a

13 circle around it in red marker, is that the person you

14 saw?

15 A. No.

16 Q. Thank you. Members of this unit, or rather

17 the soldiers who came to the farm from Bratunac, as you

18 said, did they tell you that they were from Bratunac,

19 or did they specify the unit they belonged to?

20 A. I heard this when Brano, I think it was Brano

21 who said, "Men from Bratunac are coming to assist." I

22 don't know exactly whether they were from Bratunac, nor

23 did I talk to them.

24 Q. So it was not stated that members of such and

25 such a brigade were coming, but simply men from

1 Bratunac.

2 A. Yes.

3 Q. Mr. Erdemovic, when all this was over in

4 Branjevo and Pilica, you returned to Vlasenica.

5 A. Yes.

6 Q. So eight of you went to Branjevo and Pilica

7 and eight of you returned.

8 A. Yes.

9 Q. Where were the members of the 10th Sabotage

10 Detachment from the 12th until the 16th, when you

11 returned?

12 A. I'm afraid I didn't understand the question.

13 Q. Mr. Erdemovic, there were 30 of you who

14 reached Srebrenica. From Srebrenica you all returned,

15 with the exception of this young man who got killed,

16 you got to Vlasenica. From Vlasenica, eight of you

17 went to Branjevo and Pilica. Where were the others,

18 the other members of the detachment, in the meantime?

19 A. I have to explain. I don't know where they

20 were on the 13th, 14th, and 15th, when I went to the

21 funeral. On the 16th, as far as I remember, they all

22 stayed behind me in Vlasenica, and when we returned to

23 Vlasenica we saw them all there, because a few minutes

24 after that we went to Bijeljina.

25 Q. You stayed at the VMA, the military medical

1 clinic in Belgrade, when you were being treated for

2 your injuries, and you said that you heard some things

3 there. Did you hear anything about the movements of

4 the 10th Sabotage Detachment at that time?

5 A. I definitely heard about the case of Nova

6 Kasaba.

7 Q. What did you hear?

8 A. I heard that these persons from my unit were

9 there, and this was recounted by somebody -- to my wife

10 and she passed it on to me, that Velimir Popovic, Brano

11 Gojkovic, Milorad Pelemis, that they were in Nova

12 Kasaba, that they took a man, a young boy, who reported

13 and said that he had 100.000 German marks in a house in

14 Srebrenica, that they took him there, he found the

15 money, and that they killed him. And when I came home,

16 I heard the same story from Marko Boskic, telling some

17 people.

18 Q. Is that all that you heard about the

19 movements of the members of the 10th Sabotage

20 Detachment during the time when you were not with the

21 rest of them?

22 A. I heard later, my wife told me again, that

23 they had gone looking for gold. I don't know about

24 that for sure, but I think this could be true, because

25 Marko Boskic told the same story a second time.

1 Q. Mr. Erdemovic, do you know which unit was

2 located in Nova Kasaba?

3 A. No.

4 MR. PETRUSIC: [Interpretation] Your Honours,

5 I have finished my cross-examination.

6 Mr. Erdemovic, thank you.

7 JUDGE RIAD: Thank you very much,

8 Mr. Petrusic.

9 Mr. Erdemovic, first Mr. Harmon, would you

10 like to ask some questions? Thank you.

11 MR. HARMON: I have only a couple of

12 questions.

13 Re-examined by Mr. Harmon:

14 Q. Mr. Erdemovic, you were asked by my colleague

15 questions about the joint operation between your unit

16 and the Drina Wolves that took place in the direction

17 of Srebrenica on the 11th of July.

18 My first question relates to an answer you

19 gave in my direct examination. You identified the

20 leader of the Drina Wolves as a man named Legenda. Do

21 you remember that answer? You have to answer aloud.

22 A. Yes. Yes.

23 Q. Now, members of the Drina Wolves -- did it

24 appear to you, when you were making the assault on

25 Srebrenica, that members of your unit were working

1 together with members of the Drina Wolves in making the

2 assault in the direction of Srebrenica?

3 A. It appeared to me that they were working in

4 cohorts, that Pelemis did have contacts with Legenda,

5 which he probably did have in actual fact.

6 Q. To your knowledge, did Legenda -- let me ask

7 that question differently. To your knowledge, was

8 Legenda a participant in the operations that were being

9 directed against Srebrenica?

10 A. Yes, I saw that on the pictures, the video

11 first, and later on you showed me a photograph and I

12 identified it as being Legenda.

13 Q. I want to focus your attention back to the

14 time when you were participating in this operation,

15 that is, the 11th of July. Were you aware that

16 Lieutenant Pelemis was in communications with Legenda?

17 A. Well, I did know because Pelemis said that we

18 should set fire to the first thing we came across on

19 the left, on the right. There was a haystack next to

20 me and I should set the haystack on fire. He said that

21 we should set it alight so as not to be hit by the

22 artillery and Praga and those heavy machine-guns that

23 were positioned up on the hill. And I do know that

24 that was done -- that Legenda, in fact, was at that

25 elevation point.

1 Q. So Legenda was at a location near Srebrenica

2 where he could cover your operations with some kind of

3 heavy fire if necessary; is that correct?

4 A. Yes. Yes, that's correct. And I also know

5 because of another example. When a bomb was thrown, we

6 heard over the radio, our signals officers had said

7 that a tank had been damaged, and the vehicle, a

8 vehicle of the commander of the Drina Wolves, Legenda.

9 A bomb fell on that hill where that communication line

10 was located, and Legenda himself.

11 Q. Are you talking about a NATO bomb that fell?

12 A. Yes.

13 Q. And did the NATO bomb hit a location, as far

14 as you're aware, that was near a vehicle that was

15 operated or owned by or used by Legenda?

16 A. Yes.

17 Q. Thank you very much, Mr. Erdemovic.

18 MR. HARMON: Thank you, Your Honours. I have

19 no additional questions.

20 JUDGE RIAD: Thank you, Mr. Harmon.

21 Judge Wald, would you like to ask your

22 questions?

23 JUDGE WALD: Thank you.

24 Questioned by the Court:

25 JUDGE WALD: Mr. Erdemovic, as your unit was

1 moving into Srebrenica on the 11th, I think you

2 testified on direct that you didn't meet much

3 resistance, but I wanted to make sure I understood

4 correctly. Is that right? In other words, was there

5 resistance from Muslim forces or other forces as you

6 moved into the centre of Srebrenica?

7 A. No. There was -- well, I can't say there

8 wasn't any resistance. You could hear shots shooting,

9 but there was no great resistance of any kind.

10 JUDGE WALD: All right. Now, did your unit,

11 during that same movement into the centre of

12 Srebrenica, did your unit, or later on any of the other

13 units which came down into the town, engage in setting

14 any of the houses on fire or individual searches of the

15 houses that were in the area?

16 A. As far as I remember, only one house was

17 burnt and it was at the entrance, when you enter the

18 town from the south side. It was close to the mosque,

19 and it was when the NATO planes had already thrown

20 their bomb. And of course the members did take part in

21 the search -- in searching the houses and buildings in

22 the town of Srebrenica.

23 JUDGE WALD: At that time was anything done

24 during the period that your unit was in Srebrenica to

25 the mosques, either one?

1 A. No. Only from the first mosque, the flag had

2 been lowered, taken off the mosque.

3 JUDGE WALD: Okay. Moving on to Branjevo.

4 You said that in the course of the afternoon, something

5 between 1.000 to 1.200 people, you estimated, were

6 killed. Were the bodies just left as each unit of

7 ten -- as each group of ten was brought to be

8 executed? Were the bodies of those that were already

9 executed just left there, or during the period you were

10 there, did any kind of loading and carrying away of the

11 bodies, putting them on trucks, et cetera, take place?

12 A. No.

13 JUDGE WALD: So in other words, as each new

14 group of ten came up to be executed, they were brought

15 up to the place where they could see all the bodies of

16 the people who had been previously executed just lying

17 there; is that right?

18 A. Yes.

19 JUDGE WALD: Incidentally, were the drivers

20 of the buses that brought the victims to the Branjevo

21 Farm, you mentioned that at one point it was said, "We

22 don't want them to be witnesses," were they civilians?

23 Were they police, military, what? The drivers of the

24 buses that brought the victims.

25 A. I only know that they drove civilian buses.

1 Whether they were members of the military or not, I

2 can't answer that.

3 JUDGE WALD: So you don't remember whether

4 they wore any kind of distinguishing uniform or just

5 civilian clothes?

6 A. I don't remember.

7 JUDGE WALD: Now, when you got to Pilica, you

8 showed us where the cafe was and it was across the

9 state from the Pilica Dom where the detainees were kept

10 inside. Now, this was, I gather, in the middle of the

11 afternoon. Were there any other people around in the

12 area? This is the middle of town, as I understand it.

13 Besides the group that was with you in the cafe and the

14 people who were inside the Dom across the street, there

15 were no ordinary townspeople around?

16 A. Well, there were people there. Between these

17 two buildings there was a checkpoint of the civilian

18 police, and people did pass by in cars. And right next

19 to the hall, there were houses, inhabited ones. Yes,

20 there were civilians.

21 JUDGE WALD: So there were some people around

22 on the streets while this was happening.

23 A. Yes. Yes. Traffic was passing.

24 JUDGE WALD: You told us, I believe, that you

25 heard the shots, and later detonations, inside the

1 Pilica Cultural Dom across the street. Did you see

2 people attempting to escape or being shot outside the

3 Dom, in front of the Dom, or did you just hear the

4 sounds that were going on inside, while you were in the

5 cafe?

6 A. When we arrived at the cafe, and when we

7 turned off from the main road to get in front of the

8 cafe to park the car, I saw people in front lying on

9 the ground. While I was in the cafe itself, I heard

10 shooting and bombs.

11 JUDGE WALD: But did you actually yourself

12 see anybody being shot and fall in front of the Pilica

13 Dom?

14 A. No.

15 JUDGE WALD: Okay. My last question. You

16 and some of your colleagues from the 10th Unit were

17 brought to Pilica, and then you say you went into the

18 cafe and you sat down, you waited, and soon somebody

19 came and said words to the effect that, "Well, it's

20 over, and those who have survived have survived." Did

21 anybody ever explain why they brought you there if all

22 you were going to do is sit in the cafe and watch from

23 across the street?

24 A. Well, I couldn't see what was actually

25 happening across the street. Nobody had told me

1 anything, told me why. We were just told that there

2 was to be a meeting of some kind, but as I noticed,

3 there wasn't any meeting. A man from Bratunac came and

4 said that everything was over, that it was finished.

5 When he came and said this, the Lieutenant Colonel got

6 up and said, "Those who have stayed alive have stayed

7 alive." I don't know why he said that.

8 JUDGE WALD: My last question would be:

9 Roughly what is your estimated number of the bodies

10 that you actually saw outside the Pilica Dom?

11 A. I can't say with any certainty, but perhaps

12 10 or 15. I don't know exactly.

13 JUDGE WALD: Thank you.

14 JUDGE RIAD: Thank you, Judge Wald.

15 Mr. Erdemovic, I would like just to follow

16 with you a little bit some of the phases of these

17 unfortunate events.

18 You said when you came into Srebrenica, at

19 first they met a civilian who pleaded that he was not

20 in the army and still Mr. Pelemis ordered to slit his

21 throat. That was just at the beginning. What was the

22 purpose, really, of that?

23 A. Well, it happened, as far as I was able to

24 see, in Srebrenica, in the centre of town, where the

25 second mosque was located. What the purpose was of

1 that killing I could only assume. I assume that it was

2 because perhaps he was of an age for the army, an age

3 for military service. I don't know, actually, what the

4 purpose was.

5 JUDGE RIAD: Was it to intimidate the

6 people? I mean, just a sign to show them what's going

7 to happen to them? What was the reason?

8 A. I cannot say that. I just cannot say.

9 JUDGE RIAD: It was in front of all the

10 people. It was in broad daylight.

11 A. Yes, it was. It happened in front of the

12 soldiers. There were no civilians there.

13 JUDGE RIAD: There were no civilians. Now,

14 then they called on the people to move to the stadium.

15 Were men and women included, or was it just for the

16 men?

17 A. From the very beginning, when we moved into

18 town, we called out to people, if there was anybody in

19 the house to come out, because the houses would be

20 searched, and we were told that we weren't allowed to

21 fire at civilians. So we called out to any civilians

22 there, to come out of their houses and to move towards

23 the stadium. This was at the entrance to the town.

24 JUDGE RIAD: All the people, you called on

25 all the people of Srebrenica to move to the stadium.

1 A. Yes, from all the houses, if there was

2 anybody in the houses, but there were only some 200

3 people, in my assessment, who came out of those

4 houses. They were invalids, elderly people who found

5 it difficult to walk, elderly women.

6 JUDGE RIAD: And they moved to the stadium

7 too?

8 A. They were moving in front of us. I don't

9 know where the stadium was or if it existed.

10 JUDGE RIAD: Were they included in the

11 execution? These people who you said were old, the

12 infirm, those who could not walk, they also went to the

13 buses, to the execution?

14 A. I don't know that. I didn't see it.

15 JUDGE RIAD: You didn't see that. But what

16 kind of people were being executed then, exactly? Any

17 women between them, to start with?

18 A. No.

19 JUDGE RIAD: Any old people?

20 A. I already said that they were between the

21 ages of 17 and 60 or 70 years of age.

22 JUDGE RIAD: Between 17 and 70. Those who

23 were not between 17 and 70, what happened to them?

24 A. I don't know.

25 JUDGE RIAD: But you were there.

1 A. Please could you explain your question. I

2 know I was there but --

3 JUDGE RIAD: What happened to the people who

4 were not executed? Were they left to stay at their

5 homes? What happened to them? If everybody had to go

6 to the stadium, was there any separation, or did

7 everybody have the same fate?

8 A. All those people who had remained in their

9 houses when we entered the town, they were told to come

10 out and move in front of us in the direction of the

11 football stadium in Srebrenica. But I never reached

12 that stadium, nor did I actually see this separation,

13 the separation of these people, the individuals there.

14 I just said that I know that the people that were

15 brought to the farm were between the ages of 17 and

16 70.

17 JUDGE RIAD: You mentioned also that Stanko

18 Savanovic was bragging that he killed between 200 and

19 300 men, and the squadron, the killing squad, was about

20 eight people. You who were killing, you were eight?

21 A. Yes.

22 JUDGE RIAD: If you count, then I think that

23 reach -- was it a competition of who would kill more?

24 A. Well, that was it. Actually, he did it --

25 some people, after the first shooting, would fall down

1 but they were not actually dead, and later on he would

2 finish them on with his pistol.

3 JUDGE RIAD: There was also shooting, as you

4 said, by machine-guns and people were not killed, they

5 were hurt and some of them were not killed. Were they

6 all finished after this?

7 A. Yes. Yes, and Stanko Savanovic did most of

8 that.

9 JUDGE RIAD: There were no survivors, because

10 you said the Lieutenant Colonel said, "Those who

11 survived have survived." Were there some survivors, in

12 your opinion?

13 A. I can't say now whether there were or

14 weren't. I didn't examine all the people to be able to

15 ascertain that.

16 JUDGE RIAD: I think you mentioned something

17 about -- when you mentioned about the cafe, you said

18 after 15 minutes you were in the cafe and a man came

19 and said everything was over. What did you understand

20 from that?

21 A. Well, that the execution in the Dom was over,

22 and I didn't hear any more shooting after he had said

23 that.

24 JUDGE RIAD: So it was clear that he was

25 speaking of the execution.

1 A. Well, to me it was clear that he was speaking

2 of the execution because nothing else could have been

3 over, finished.

4 JUDGE RIAD: Do you have an idea of who was

5 in the Dom?

6 A. When that Lieutenant Colonel came towards the

7 end, when everything was drawing to a conclusion at the

8 Pilica farm, he said that there were 500 Muslims from

9 Srebrenica who wanted to break through, so that I

10 concluded that they were Muslims from Srebrenica.

11 JUDGE RIAD: Mr. Erdemovic, thank you very

12 much. Your testimony is over, and I repeat that we

13 appreciate your coming. Thank you very much. You will

14 now go out.

15 THE WITNESS: [Interpretation] May I just ask

16 a question of the President.

17 JUDGE RIAD: Yes. And also I will request

18 that if you have anything to add, you are welcome to

19 add it, whether it's a question or whether it's any

20 statement.

21 THE WITNESS: [Interpretation] I should like

22 to say that everything that occurred in Srebrenica,

23 that against Mr. -- that is to say, General, against

24 the General, I don't know him and I don't know that he

25 issued any orders. And I should like to thank his

1 Defence counsel for their correct and proper conduct

2 towards me.

3 JUDGE RIAD: Would you like to say anything

4 else in general about your experience?

5 THE WITNESS: [Interpretation] I hope that it

6 is not repeated ever again to anyone. That it doesn't

7 happen to anyone ever again, that is my greatest wish.

8 JUDGE RIAD: We share very much this wish.

9 Thank you very much, Mr. Erdemovic.

10 [The witness withdrew]

11 JUDGE RIAD: Mr. Harmon, we have ten minutes

12 to go. You can use them the way you like.

13 MR. HARMON: I would first like,

14 Mr. President, Judge Riad, and Judge Wald, to introduce

15 the exhibits that have been testified about by

16 Mr. Erdemovic, and if I could move into evidence, then,

17 the following exhibits: 28/17, which is a photograph;

18 a film, which was Prosecutor's Exhibit 145; 147, which

19 was a photograph; 148, which was a film; 152 through

20 157, which were photographs; 158 as well, which was a

21 photograph; Prosecutor's Exhibit 28/4; and Prosecutor's

22 Exhibits 170 through 175, which were photographs.

23 JUDGE RIAD: Thank you, Mr. Harmon.

24 I assume that the Defence counsel has no

25 objection.

1 MR. PETRUSIC: [Interpretation] No,

2 Mr. President.

3 JUDGE RIAD: Thank you.

4 MR. HARMON: We have no additional evidence

5 today, Judge Riad.

6 JUDGE RIAD: As I've mentioned before,

7 tomorrow I will be the Presiding Judge, and we'll

8 resume exactly our testimonies in the same way. So

9 we'll start tomorrow at 9.30.

10 The hearing is adjourned.

11 --- Whereupon the hearing adjourned at

12 2.03 p.m., to be reconvened on Tuesday,

13 the 23rd day of May, 2000, at 9.30 a.m.

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