Tribunal Criminal Tribunal for the Former Yugoslavia

Page 4720

1 Tuesday, 5 September 2000

2 [Open session]

3 --- Upon commencing at 10.20 a.m.

4 [The accused entered court]

5 JUDGE RODRIGUES: [Interpretation] You may be seated.

6 Good morning, ladies and gentlemen; good morning, technicians,

7 interpreters; good morning to our legal officers, Madam Registrar; good

8 morning, Mr. Keegan, counsel for the Prosecution; good morning, counsel

9 for Defence; good morning to the accused.

10 We are beginning with a slight delay this morning, and we should

11 like to apologise for that. We discussed the issue with the registrar,

12 and we told her that we can accept such a situation to occur once but

13 several times is simply not admissible.

14 As regards the Prosecution, I should like to know what the

15 situation regarding witnesses is for this week, please.

16 MR. KEEGAN: Yes, Your Honour. We have witnesses either here

17 present or on their way sufficient to cover the remainder of the week. It

18 will be Witnesses J, K, O, Mr. Mesanovic, and Mr. Mesan.

19 JUDGE RODRIGUES: [Interpretation] I asked you that because I

20 wanted to know if we have to compensate for the time that we lost this

21 morning. We will see how things will unfold during this week, because I

22 don't like to prolong the sessions because I am fully aware of the fact

23 that we all have other commitments. But we are always concerned about the

24 witnesses. If the witnesses are here, they have to be heard so that they

25 don't have to come back once again.

Page 4721

1 So we will see how things go during the week, and we will then see

2 if we have to compensate for the time that we lost this morning in order

3 to assure a full respect for the situation the witnesses find themselves

4 in.

5 So you have the floor now, Mr. Keegan. You're about to call your

6 next witness, Witness J, I suppose.

7 MR. KEEGAN: Correct, Your Honour. We would call Witness J.

8 While we are waiting for the witness to be brought in, Your

9 Honour, there is one short application I would like to raise with the

10 Trial Chamber.

11 JUDGE RODRIGUES: [Interpretation] If I understand you correctly,

12 Mr. Keegan, you have a request to make before we proceed?

13 MR. KEEGAN: Yes, Your Honour, while we're waiting for the

14 witness.

15 JUDGE RODRIGUES: [Interpretation] Excuse me. Just a second.

16 Yes. And I can also see Mr. Jovan Simic on his feet. He also apparently

17 has something to tell us. I don't know what it is, but can I first give

18 the floor to Mr. Simic, Mr. Keegan?

19 MR. KEEGAN: Certainly, Your Honour.

20 JUDGE RODRIGUES: [Interpretation] I don't know if that has

21 anything to do with the state of health of Mr. Prcac.

22 Mr. Simic, you have the floor, and I should like you to tell us

23 something about the health of Mr. Prcac, your client.

24 MR. J. SIMIC: [Interpretation] Thank you, Your Honour. Mr. Prcac

25 was sick on Friday, as we all know. His blood pressure was 180/120. The

Page 4722

1 situation has somewhat stabilised itself.

2 Yesterday we paid him a visit and he was feeling rather well. He

3 wasn't sure, but he said that he would do his best and try to appear at

4 the hearing.

5 I had no possibility to have contact with Mr. Prcac this morning

6 because, as far as I'm informed, the transport from the detention unit was

7 late. So I didn't have an opportunity to speak to him this morning, and I

8 thought it would be a good idea for me to find out what his situation is

9 at this moment and to see if he needs any special care.

10 JUDGE RODRIGUES: [Interpretation] Yes. Mr. Simic, you may speak

11 to Mr. Prcac. You can do it now. I don't know how much time you need.

12 Two or three minutes? Is that going to be enough or would you like to

13 have a break?

14 MR. J. SIMIC: [Interpretation] Yes, that will be enough, Your

15 Honour.

16 JUDGE RODRIGUES: [Interpretation] Yes, please, Mr. Simic.

17 Mr. Keegan.

18 MR. KEEGAN: Yes, Your Honour. I believe we can deal with the

19 application that the Prosecution has since I have spoken to the Defence

20 and there is no objection to the application. So perhaps we could do that

21 while Mr. Simic is speaking with his client.

22 JUDGE RODRIGUES: [Interpretation] Yes, but I should like to

23 address one thing at a time. We will take our time and then we will hear

24 your application. We need to have a respect for the accused here.

25 Yes, Mr. Simic.

Page 4723

1 MR. J. SIMIC: [Interpretation] Your Honour, I know that this is

2 somewhat unusual, but accused wanted to address the Chamber and to explain

3 himself, what his situation is. He -- once again, he didn't receive the

4 right medication, so he wanted to advise you of that problem.

5 JUDGE RODRIGUES: [Interpretation] Yes. Mr. Usher, could you help

6 with Mr. Prcac with the microphone so that he can take the floor.

7 Yes, Mr. Prcac.

8 THE ACCUSED PRCAC: [Interpretation] Your Honours, I'm really

9 thankful to you. I was given adequate assistance on Friday. I almost

10 fainted; I had very severe headache; I was losing my sight. The situation

11 persisted on Saturday and Sunday. I spent those days in bed, but I

12 received some medication and things changed for the better. However, I

13 have a problem which I have to draw your attention to, and I will try to

14 be as brief as possible.

15 This morning I expected that one of the guards would bring me the

16 medication, but he wasn't there. So I went to see him, and I asked him to

17 give me one of the three medications that I received. I realised that

18 there was no medication in my safe. I was supposed to receive one

19 particular medication this morning but I didn't. He said that he would

20 intervene, and I waited.

21 He indeed made a telephone call, and he came to me later on, and

22 he said that a doctor would come and that he would take care of

23 everything. However, I was left there waiting. Then he came again and he

24 brought me half a tablet, which I take every morning, but he failed to

25 bring me Lexotanil, which I also have to take. He brought me Diazepam,

Page 4724

1 which is a different type of medication, which I didn't take, and I was

2 surprised.

3 So I asked him what it was all about. I took the tablet so that I

4 would bring it here and take it at 12.00, because I have to take

5 medication here while I'm at the Tribunal. So I thought I would bring the

6 tablet with me.

7 In the meantime, a nurse appeared, and she has been causing

8 trouble regarding that medication -- that is what I heard -- and that she

9 was somewhat responsible for the situation I now find myself in. My

10 health has considerably worsened.

11 Dr. Vera Petrovic told me that I had to take medication and that

12 with appropriate medication I would have no problems. She even advised

13 Mr. Falke of that problem of mine, and they agreed on the medication that

14 I'm supposed to take.

15 While I was waiting to be taken here, a policeman came and he took

16 the Diazepam tablet with him. He took it back, and I heard the nurse talk

17 to him, and I was simply standing there waiting for the tablet to arrive.

18 I also have to say that I didn't receive the right medication last night,

19 because I also suffer from insomnia.

20 So I am really surprised at such things happening in the past

21 several days.

22 I don't have any problems here in the courtroom or during the

23 transport from the detention unit. The biggest problem for me is the

24 waiting time. I have to spend a considerable amount of time waiting in a

25 room which doesn't have enough oxygen, and because of that I have severe

Page 4725

1 headaches and I feel as if I would faint at any moment.

2 So I should like to appeal to you, Your Honours, to see if

3 anything can be done with the Registry maybe for me to help me. I don't

4 know if it's possible for me to be taken, to be transported first, because

5 sometimes I have to wait for one hour, an hour and a half, or even two

6 hours, and that is the main problem.

7 I really apologise for taking your time, but I wanted to advise

8 you of this problem. Thank you very much.

9 JUDGE RODRIGUES: [Interpretation] Thank you, Mr. Prcac. Madam

10 Clerk, could you please look into the matter and see what the situation is

11 and what measures can be taken so that Mr. Prcac receives appropriate

12 medication at appropriate time according to his prescriptions. Could you

13 please take care of that?

14 THE REGISTRAR: Yes, the Registry is concerned about the

15 situation, and we'll do some investigation on these matters.

16 JUDGE RODRIGUES: [Interpretation] Will you please advise us of the

17 results of your investigation?

18 THE REGISTRAR: Yes, for sure.

19 JUDGE RODRIGUES: [Interpretation] Thank you.

20 Mr. Simic, is there anything else that you wish to add?

21 MR. J. SIMIC: [Interpretation] No, Your Honour.

22 JUDGE RODRIGUES: [Interpretation] Thank you very much for drawing

23 our attention to this problem.

24 Mr. Keegan, the application, let us hear you.

25 MR. KEEGAN: Yes, thank you, Your Honour. The application

Page 4726

1 actually relates to the next witness, Witness K, who, upon arrival and

2 viewing the courtroom, immediately requested to give her evidence --

3 JUDGE RODRIGUES: [Interpretation] I'm sorry, I don't want the

4 witness to be brought in yet. [No interpretation] It's necessary to wait

5 a moment to introduce the witnesses, please, so we are discussing now,

6 because I wouldn't like to have the witnesses inside and while we are

7 discussing. Okay?

8 [Interpretation] Sorry for this interruption, Mr. Keegan. Please

9 continue.

10 MR. KEEGAN: Thank you, Your Honour. She, of course, had

11 protective measures, including confidentiality, voice and image

12 distortion, but upon viewing the courtroom, immediately requested a

13 complete closed session based upon her concerns which were the foundation

14 for the request for confidentiality measures to begin with.

15 I have discussed this matter with counsel for the Defence. There

16 is no objection to the request based upon the following understanding;

17 that is, the first option which we explored with the witness was to

18 determine whether or not we could bifurcate her testimony in such a way

19 that only the most sensitive parts were in closed session, and the

20 remainder would be in the open session but with the confidentiality

21 measures already granted. We went to the extent of actually breaking out

22 her testimony to determine what that would look like.

23 After doing so, it appeared that in fact what would remain in

24 public session was in fact a very small amount; and in addition, given the

25 circumstances of her particular arrest and the events which she was a

Page 4727

1 victim to or witness of in the camps, they would, in effect, identify her

2 such that her concerns would not be allayed by having that part in open

3 session, albeit with the other confidentiality measures.

4 So having undertaken that examination and having discussed it with

5 the Defence, they don't object based on that understanding of the factual

6 situation as presented to them by the Prosecution. So for this particular

7 witness, it's my understanding there is no objection with respect to this

8 request.

9 JUDGE RODRIGUES: [Interpretation] I will give the floor to the

10 Defence; however, first I have a question for you, ones that we already

11 asked. The witness without the protective measures, do you think that she

12 or he will accept to testify, or not?

13 MR. KEEGAN: Yes, I'm sorry, Your Honour. The witness indicated

14 she would not be willing to testify absent closed session protections.

15 JUDGE RODRIGUES: [Interpretation] Thank you. Let me hear the

16 witness -- the Defence, please, Mr. Krstan Simic or Mr. O'Sullivan.

17 Yes, Mr. O'Sullivan, please let us hear you.

18 MR. O'SULLIVAN: Thank you, Your Honour. We have nothing to add

19 to what Mr. Keegan said. What he described to you is in fact the results

20 of the discussions we had regarding this witness, based on the

21 Prosecution's discussions with the witness and the structure and nature of

22 her testimony. So we support this application.

23 JUDGE RODRIGUES: [Interpretation] Thank you very much,

24 Mr. O'Sullivan.

25 In view of the application made by the Prosecutor and the fact

Page 4728

1 that the Defence does not object, and in view of the interests of justice,

2 the Chamber will grant the application for protective measures made by the

3 Prosecutor. Witness K will therefore testify in closed session.

4 Mr. Usher, we need the witness now.

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20 [Open session]

21 JUDGE RODRIGUES: [Interpretation] We are already in open session,

22 Mr. Keegan. Please continue.

23 MR. KEEGAN: Thank you, Your Honour.

24 Q. Witness J, after the attack on Prijedor on 30 May, was your

25 neighbourhood then cleansed?

 

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Page 4733

1 A. The attack on Prijedor was on the 30th of May, and it began with

2 arrests taking place in my neighbourhood. People were being taken away,

3 and rumours were spreading that in Prijedor and around Prijedor,

4 concentration camps existed.

5 Q. Now, how was it that people in your neighbourhood were arrested?

6 What actually happened?

7 A. Their houses and apartments were stormed, and they were taken off

8 in an unknown direction. Armed people would come to their doors.

9 Q. Did you have an occasion to see what type of uniforms these armed

10 people were wearing?

11 A. There were different types of uniform, camouflage uniforms, police

12 uniforms, the uniforms worn by the former Yugoslav People's Army in the

13 traditional olive-green colour with different insignia. For the most

14 part, they were Serbian insignia with the four "S" sign and the kokarda

15 type of cap.

16 Q. And you were not arrested on that day?

17 A. No.

18 Q. Between the 30th of May and the 9th of June, were there any other

19 attacks on the Prijedor town that you're aware of?

20 A. No.

21 Q. During that same time frame, 30 May to 9 June, what was life like

22 in the area of town where you lived?

23 A. For the non-Serb population, life was very difficult, hard. Our

24 movements were restricted. If you went to buy anything in a shop, you had

25 to wear white bands. On the windows of our houses and apartments we had

Page 4734

1 to hang out white flags.

2 Q. Were you listening to the radio or watching television during that

3 time frame?

4 A. Yes. I listened to the local radio station, Radio Prijedor,

5 mostly, which was in Serb hands, and journalists of Serb ethnicity worked

6 at that radio station.

7 Q. What were the reports that were broadcast on the radio saying?

8 A. We were cautioned that our movements were restricted, and

9 precisely what I said a few moments ago, that we had to carry white

10 armbands and that we had to hang out white flags on the windows of our

11 houses and apartments, that the Serbs had taken over complete control and

12 that they were controlling all power and authority in the town of

13 Prijedor.

14 Q. During that time frame, would you hear shooting and explosions

15 going on in the area of the town?

16 A. Yes. Very often you could hear shooting, both during the day and

17 at night. Looting was going on of the non-Serb population and their

18 houses. People were evicted from their houses and apartments, and

19 citizens of Serb ethnicity took their place in them.

20 Q. The explosions that you could hear, were you able to tell what it

21 was that was the target of these explosions?

22 A. The Muslim and Croatian houses and apartments.

23 Q. How were your neighbours who were of Serb ethnicity conducting

24 their daily lives during that same time frame?

25 A. They lived quite a normal life. They went to work regularly, they

Page 4735

1 went shopping, they walked around town.

2 Q. Did you see any children out playing in your area?

3 A. Yes. The Serb children played quite normally.

4 Q. Now, on the day that you reported to the SUP, what happened?

5 A. I went early in the morning, after I had received the message from

6 my brother. I went to the SUP building. In front of the building, I saw

7 a lot of armed individuals.

8 I said that I had come to report, as I was told to do in the

9 message that I received, that I was to report to Ranko Mijic. They told

10 me that I should wait and that they will check that out.

11 Q. What was the answer that you received?

12 A. After some time had gone by, I received an answer telling me that

13 he was busy and couldn't receive me.

14 Q. Were you forced then to wait out in front of the building?

15 A. Yes.

16 Q. Did a bus pull up in front of the building?

17 A. Yes, a bus turned up in front of the SUP building. The door to

18 the SUP building opened, and armed persons wearing uniforms started

19 leaving the building and boarding the bus.

20 Q. Were you also put on the same bus?

21 A. Yes. A man wearing a uniform and armed told me that I had to

22 board the bus as well.

23 Q. At that time did they tell you where the bus was going or why you

24 had to get on it?

25 A. No.

Page 4736

1 Q. Now, these armed men who you say came out of the SUP and got on

2 the bus, did you recognise any of them?

3 A. Some of them, yes.

4 Q. And who among that group did you recognise?

5 A. I recognised Dragan Radakovic, Ilija Bjelic, Zare Tejic, Nenad

6 Tomcic, Nenad Babic, Goran Novic, Rade Knezevic, Vukasin Knezevic.

7 Q. Do you know what those men did before the war? What was their

8 profession?

9 A. Yes, I do. They were inspectors in the MUP.

10 Q. In addition to inspectors, did any of those individuals also have

11 other jobs or other professions?

12 A. Yes. Dragan Radakovic never worked in the SUP. He was my art

13 teacher in elementary school. Later on, he worked in the national park of

14 Kozara.

15 Q. Were there any other individuals who had been teachers among this

16 group?

17 A. I know that he was a teacher, and as far as I know, Rade Knezevic

18 was retired and was reactivated when the Serbs took control.

19 Q. Do you know a man named Miroslav Zoric?

20 A. Yes, I do. I forgot to mention him a moment ago. He was

21 professor at the technical school, and he was also on that bus and was

22 wearing a uniform and carrying a weapon. Later on, during my stay at the

23 camp, I was to learn that he too was an inspector in the camp.

24 Q. Now, all of these men who you have named, do you know their ethnic

25 group?

Page 4737

1 A. They were all Serbs.

2 Q. Did all of these men have a position or role in the Omarska camp

3 that you became aware of?

4 A. Yes. They were investigators or inspectors, and they interrogated

5 the people who were detained in the camp.

6 Q. Where did this bus go once you left the SUP?

7 A. The bus went off in the direction of the main road running from

8 Prijedor to Banja Luka.

9 Q. Now, were you familiar with that road?

10 A. Yes, I knew it very well.

11 Q. And were you familiar with the villages and areas that are along

12 that road as you go towards Banja Luka?

13 A. Yes.

14 Q. Were you familiar with what ethnic groups lived in those villages?

15 A. Yes.

16 Q. As you were driving along that new road heading from Prijedor

17 towards Banja Luka, was there anything that you noticed in particular?

18 A. Yes.

19 Q. What was that?

20 A. I noticed that the villages inhabited by Muslims were destroyed,

21 that some houses were still burning.

22 Q. In addition to the destroyed houses or the burning houses, did you

23 notice other things?

24 A. I noticed in some of the houses that had not been completely

25 destroyed, people wearing uniforms, the Serb army pulling out some things

Page 4738

1 from the houses and loading them up onto trucks and tractors.

2 Q. Now, do you recall the names of the villages or the areas where

3 you saw these destroyed houses and where you saw the soldiers taking the

4 things out of the houses and loading them onto the trucks?

5 A. Yes. Kozarusa, Kozarac, Kamicani, Kevljani.

6 Q. Are you familiar with the village of Jakupovici?

7 A. Yeah.

8 Q. And what did you notice in that village? Was it about the same as

9 the others?

10 A. Yes, it was completely the same.

11 Q. Now, did you notice any villages where there was no destruction at

12 all?

13 A. Yes. They were Orlovci, Garevci, Lamovita, and Omarska.

14 Q. Did the bus eventually arrive in Omarska?

15 A. Yes.

16 Q. And had you been to the mine complex before this?

17 A. Not to that place. I had been to the village of Omarska but not

18 to that particular spot. I'd never been there before the war.

19 Q. So when you arrived in this complex, mine complex, what did you

20 notice?

21 A. I was shocked from seeing the sight that stood before me. I saw

22 many people on a sort of asphalt ground, sitting down in the heat. I saw

23 a room that seemed to be very small for such a large number of people. I

24 knew quite a number of those people as my fellow townsmen.

25 Q. Now, when you say that you knew quite a number of those people,

Page 4739

1 which area are you referring to, the asphalt area or the room where you

2 saw people?

3 A. Both areas. I'm thinking of both areas.

4 Q. Now, this room where you saw people being held that you

5 recognised, what building in the complex was that room in?

6 A. In the administration building.

7 Q. And the asphalt area that you referred to where you saw the men

8 sitting in the sun, did you later learn what that area was called?

9 A. Yes; the pista.

10 Q. When you were taken off the bus in the Omarska camp, where were

11 you taken?

12 A. I was taken to the administration building, to the reception

13 office of the administration building, which was up on the floor above.

14 Q. Who was in that office that you were taken to?

15 A. In the office there was Zeljko Meakic, Miroslav Kvocka, and

16 Milojica Kos, nicknamed Krle.

17 Q. Was there anyone else in the room?

18 A. Yes. One of the prisoners whom they had brought in together with

19 me on that same day, and I knew him personally. His name was Ibrahim

20 Causevic.

21 Q. You've named Zeljko Meakic, Miroslav Kvocka, and Milojica Kos.

22 Did you know any of those men from before?

23 A. I knew Zeljko Meakic by sight. I knew he was a policeman. I

24 didn't know Milojica Kos before, but I knew Miroslav Kvocka best.

25 Q. How did you know him from before?

Page 4740

1 A. His sister worked with me, and I grew up with his wife.

2 Q. And indeed, had you ever visited his family house in Omarska

3 village?

4 A. Yes.

5 Q. Now, in addition to those three men, was there anyone else who was

6 part of the camp staff who was in that room on the first day?

7 A. Perhaps there was a guard present, but I really can't remember.

8 Q. Did you later learn what role those three men played in the camp?

9 A. Yes.

10 Q. Zeljko Meakic, what role did you come to learn he played?

11 A. Zeljko Meakic was the camp commander of Omarska.

12 Q. And how did you learn that?

13 A. During my stay in the camp, I learnt of this. People talked about

14 it. The guards talked about it. It was no secret.

15 Q. Did you ever see Meakic having dealings with the guards?

16 A. Yes.

17 Q. Did you ever have an occasion to see him issue orders or

18 directions to the guards?

19 A. Yes.

20 Q. And what did those orders -- what were those orders generally

21 about?

22 A. He would usually assign them to places around the camp. When they

23 came to work, they would report to him in his office up there, and he

24 would make a tour of the camp together with them.

25 Q. Did you observe how the guards acted towards Zeljko Meakic, or how

Page 4741

1 they treated him?

2 A. They referred to him as towards a superior.

3 Q. Did you ever have an occasion to see Meakic meet any visitors to

4 the camp?

5 A. Yes.

6 Q. Did Meakic act as the leader of the delegation or the staff of the

7 Omarska camp when those visitors came?

8 A. Yes.

9 Q. Do you recall or did you know who any of the visitors were?

10 A. Yes, I do remember well. It was during my stay, I think it was

11 sometime in July, a high ranking delegation came to visit the Omarska camp

12 from Banja Luka and Prijedor. It was composed of high ranking politicians

13 and military personnel.

14 Q. Do you recall the name of any of those individuals in that high

15 ranking delegation?

16 A. Yes. I did see them very well from the restaurant. They were

17 escorted by a transporter, Radislav Brdanin, Stojan Zupljanin, Radisav

18 Vukic, Simo Drljaca, Momir Talic.

19 Q. And how did Meakic greet this delegation; did you see that?

20 A. Yes, I saw that. Meakic had his formal uniform on, a blue one,

21 with a special cap on his head. He greeted them, he placed his hand on

22 his forehead, and he bowed to the official delegation.

23 Q. When you say that he placed his hand on his forehead, do you mean

24 by that he saluted them?

25 A. That's what I assume.

Page 4742

1 Q. Now, Miroslav Kvocka, what role did he play in the camp?

2 A. Miroslav Kvocka was Zeljko Meakic's deputy, that is to say, the

3 Deputy Commander of the Omarska camp.

4 Q. And how did you come to know that?

5 A. Well, it was no secret. People talked about it, the guards talked

6 about it, and you could tell by his conduct.

7 Q. First, what do you mean that the guards talked about it? What

8 would you hear the guards say?

9 A. Well, they would say, "I have to ask the deputy, I'm going to see

10 the deputy, I'm going to see Kvocka," that kind of thing.

11 Q. And what do you mean that you could tell by his conduct?

12 A. Well, yes. Miroslav Kvocka would usually sit in the same office

13 with Zeljko Meakic. He would go round the camp, he would position guards

14 in the camp compound and so on. Meakic and him would take turns usually.

15 When Meakic was off duty, Kvocka would take his place in his office.

16 Q. Did you ever see or hear Kvocka issuing instructions to the

17 guards?

18 A. Yes.

19 Q. And what was the nature of those instructions?

20 A. He acted like a superior and would tell the guards where to go.

21 He would say, "Go to that section." He would give them their schedule.

22 They liked him and always listened to the orders or instructions he gave

23 them. I never heard anybody refuse to act upon his word.

24 Q. Did you have occasion to observe how the guards treated Miroslav

25 Kvocka; that is, how did they act towards him?

Page 4743

1 A. With respect; as you would towards your superior.

2 Q. Now, to the best of your knowledge, was Miroslav Kvocka in the

3 Omarska camp for the entire time that you were held there?

4 A. No.

5 Q. How long did he act as the deputy commander in the camp after you

6 arrived?

7 A. I really cannot tell you the exact dates, but he was there until

8 the month of July.

9 Q. Do you recall when during the month of July?

10 A. I believe until the 2nd half of July.

11 Q. During the time that you were in the camp, did you ever observe

12 Miroslav Kvocka bring packages for prisoners?

13 A. Yes.

14 Q. On how many occasions do you recall seeing him bring packages?

15 A. I saw him on two or three occasions.

16 Q. Did he ever bring any packages for you?

17 A. Yes.

18 Q. On how many occasions did he do that?

19 A. Once.

20 Q. Do you recall what was in the package?

21 A. There were several pieces of clothing, some coffee, and some

22 cigarettes.

23 Q. Were you told who the package came from?

24 A. He told me that he thought that the package had been sent by his

25 mother-in-law.

Page 4744

1 Q. Do you recall the names of any of the other prisoners whom

2 Miroslav Kvocka brought packages for?

3 A. Yes, I do. When I went there to take the package as he was

4 getting it out of his car, I saw Said or Sead Burazerovic, nicknamed

5 Braco, to whom he had also brought a package together to mine.

6 Q. Are you aware of how Miroslav Kvocka knew this other prisoner?

7 A. They were neighbours. They used to live together at Pecani, I

8 think in the same apartment block. But I think it was at the Pecani

9 residence area and that they used to be neighbours.

10 Q. To your knowledge, did anyone replace Miroslav Kvocka in the camp

11 as deputy commander?

12 A. Yes. Miroslav left -- he could no longer be seen in the camp --

13 and he was replaced by Drago Prcac.

14 Q. Did you know Drago Prcac before the war?

15 A. Yes.

16 Q. How did you know him?

17 A. He used to work at the SUP (redacted)

18 (redacted)

19 Q. How did you come to know that he took over from Miroslav Kvocka?

20 A. This was openly discussed. The guards said that Miroslav went to

21 another position and that Drago Prcac came. Then he was in the same

22 office, and he did the same kind of work as Miroslav did.

23 Q. What do you mean when you say, "he did the same kind of work"?

24 A. Well, first of all, he was in the same office. When Meakic would

25 leave or when he was absent, Drago Prcac was there. He was giving

Page 4745

1 assignments to the guards, he was giving instructions or orders to them,

2 and he would tour the camp together with them. He carried some kind of

3 lists very often, things like that.

4 Q. When you saw him carrying these lists, did you ever see him

5 reading out the names from the list or hear him reading out the names from

6 the list?

7 A. Yes.

8 Q. What would happen with those individuals once their names were

9 read out?

10 A. Usually I would never see them again in the restaurant.

11 Q. Did you ever have occasion to see him reading out names of people

12 who were taken for interrogation?

13 A. Yes. Yes.

14 Q. Now, you mentioned Milojica Kos. Did he have any nickname in the

15 camp?

16 A. Yes. They called him Krle.

17 Q. Now, you indicated that you did not know him from before. How was

18 it that you came to learn his name?

19 A. I think he himself mentioned his name, and the guards referred to

20 him as such, but most often they would call him by his nickname.

21 Q. Do you know what his role in the camp was?

22 A. According to what I was able to conclude while I was there, he was

23 a shift leader in the camp.

24 Q. Now, how were you able to determine that?

25 A. I was able to determine that because when the guards would come

Page 4746

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Page 4747

1 for duty, they would report to him. They would go and talk to him. Then

2 he would often be sitting in the same administration office where the

3 commander or his deputy would sit.

4 Q. How many shifts of guards were there in the camp?

5 A. Again, according to what I could tell, there were three shifts.

6 Q. When did these guard shifts change over?

7 A. Usually they would come in the morning around maybe 7.00 or

8 thereabouts, and they would stay until the afternoon. One shift would

9 stay until the afternoon and then the other shift would come and then a

10 third one. They had a kind of schedule.

11 Q. Do you know the names of the other shift leaders?

12 A. Yes, I did.

13 Q. Who were they?

14 A. Mladen Radic; Momcilo Gruban, Ckalja; and Milojica Kos, Krle.

15 Q. Now, Mladen Radic, Krkan, did you know him from before?

16 A. I knew him only by sight.

17 Q. Where had you seen him before the time you were in the camp?

18 A. At the police building. I know that he was a policeman. He was a

19 policeman even before I was taken to the camp.

20 Q. And Momcilo Gruban, Ckalja, did you know him from before?

21 A. No. I had never seen him before.

22 Q. How did you learn his name?

23 A. Because of the way people would refer to him. It was not a

24 secret. Names were not a secret at the camp. The guards would use the

25 names, or some superior officers.

Page 4748

1 Q. Now, what led you to conclude that Mladen Radic, Krkan, was a

2 shift commander?

3 A. Mladjo was there at the camp all the time during my stay in the

4 camp, and I found him at the camp when I got there. He would often be

5 sitting in the main office, the admission, the reception office, where I was

6 initially brought to the camp. He would give assignments to the guards.

7 They would report to him when they came to take over duty for their

8 shift. He would be walking around the camp with them.

9 Q. Did you have an occasion to observe how the guards treated or

10 acted towards Krkan?

11 A. With respect. Yes, with respect, as to a superior.

12 Q. Was that the same situation for Ckalja, Momcilo Gruban?

13 A. Yes.

14 Q. Now, you referred to when the shifts changed over, when they

15 reported. Did you observe that there was any type of actual official

16 changeover between the two shifts?

17 A. Yes.

18 Q. Generally, how would that occur? What would you see happen?

19 A. A group of the guards whose shift was about to end would be

20 standing in a group, and then a shift leader would come, and they would

21 take over the following group and give them their assignments.

22 Q. On these occasions, do you recall seeing all three of the

23 individuals whom you've named as shift leaders be present and take part in

24 these changeovers.

25 A. Almost all the time.

Page 4749

1 Q. On those occasions when you saw them, was it your opinion that

2 they were in charge of appointing the guards and giving the instructions

3 on how the shifts were to be operated?

4 A. I think yes.

5 MR. KEEGAN: Your Honour, would that be a convenient moment?

6 JUDGE RODRIGUES: [Interpretation] Yes, this is a convenient

7 moment, Mr. Keegan. Thank you very much.

8 Mr. Usher, could you please help the witness leave the courtroom.

9 We're going to have a break now. We will resume around noon.

10 --- Recess taken at 11.29 a.m.

11 --- On resuming at 12.10 p.m.

12 JUDGE RODRIGUES: [Interpretation] Please be seated.

13 Madam Registrar, could you please brief us of the results of the

14 measures that you have taken regarding the events that were told to us by

15 Mr. Prcac this morning.

16 THE REGISTRAR: The Registry has been looking into these matters,

17 and we will take whatever measure we can to avoid such things happen

18 again. As well, we would like to report the result to you, to Your

19 Honours, by tomorrow.

20 JUDGE RODRIGUES: [Interpretation] Very well, thank you. The

21 Chamber should like to have information about the situation that has been

22 described to us, and I hope that we will have the results tomorrow.

23 Mr. Usher, could you please bring the witness in to the courtroom

24 now so that we can resume with the examination.

25 Mr. Keegan, you may continue.

Page 4750

1 MR. KEEGAN: Thank you, Your Honour.

2 Q. Witness J, prior to the break you were speaking of the shift

3 commanders in the camp. Did you come to learn the names of the guards on

4 those shifts?

5 A. Yes, I learnt some of their names and surnames.

6 Q. Do you recall the names of any of the guards on Krkan's shift?

7 A. Yes, I remember some of them. There was Zivko Marmat; then there

8 was Milutin Popovic, nicknamed Pop. I remember the two of them best.

9 Q. Why is it that you remember the two of them best?

10 A. Because they were very aggressive.

11 Q. And what do you mean by aggressive?

12 A. I saw them beating the prisoners often when they came to the

13 restaurant to have their one meal, the meal that was handed out there in

14 the restaurant. They would beat them during the meal when they entered

15 the restaurant. They would shout at them, verbally abuse them.

16 Q. Were there any guards with the surname Kvocka in the camp that you

17 are aware of?

18 A. Yes. Yes, there were several with the surname Kvocka.

19 Q. How did you learn their name?

20 A. They would be addressed by other guards by that surname, and they

21 would refer to each other as well.

22 Q. Do you recall what positions or areas in the camp that they used

23 to work?

24 A. For the most part, inside in the restaurant and around the

25 restaurant.

Page 4751

1 Q. Do you recall a man who was part of the camp staff who had the

2 nickname Brk?

3 A. Yes, I remember him very well. His name was Milorad Tadic, and

4 his nickname was Brk.

5 Q. What was his role in the camp?

6 A. As far as I was able to see, he was a sort of personal escort or

7 bodyguard to the camp commander, Zeljko Meakic, and he would drive him

8 often in a green Mercedes. He would act as his driver, Zeljko's driver;

9 although Zeljko would often drive that green Mercedes himself, the

10 Mercedes that brought him to the camp.

11 Q. What did this Brk look like? Can you describe him?

12 A. Yes, I can. He was short build. When I say short, according to

13 my own criteria, a short man is somebody who is shorter than 170

14 centimetres, for example. He was of normal weight. He was dark and had

15 dark eyes and dark hair.

16 Q. Did you ever see him involved in beating or abusing any prisoners?

17 A. Yes, I did see him on one occasion.

18 Q. And what was he doing?

19 A. He was making a prisoner cross the pista completely naked, and he

20 beat him with an object of some kind which seemed to me to be like a whip.

21 Q. Did you know who the prisoner was? Did you recognise him?

22 A. No, I didn't.

23 Q. Did Brk ever threaten the women in the restaurant?

24 A. Yes. On one occasion he wanted to shoot us and took us out to

25 shoot us.

Page 4752

1 Q. Can you explain what happened, please?

2 A. He came into the restaurant and shouted out loud and shouted at

3 the women. He accused us that we had given the prisoners more bread than

4 was permitted, and he said that for doing that, we should be made to pay.

5 Q. And what did he tell you to do?

6 A. He said that we should turn towards the wall and lift up our

7 hands, and that he would shoot us because of what we had done.

8 Q. How long did he make you remain in that position?

9 A. Well, perhaps it wasn't long. I would say it was around 40

10 minutes, but it seemed a whole lifetime to me.

11 Q. And what did he then do?

12 A. Then he laughed and said, "Well, this is just a warning this

13 time," but if we did the same thing next time, we knew what we could

14 expect.

15 Q. And when Brk told you to face the wall and said he was going to

16 shoot you, at that time did you believe he was serious?

17 A. Of course, because the tone of his voice made us realise that he

18 was quite serious. At no time did I ever think that he was just joking.

19 Q. Were there other guards in the restaurant area when that happened?

20 A. Yes, there were.

21 Q. And did any of them say anything or do anything?

22 A. No.

23 Q. How often did interrogations take place in the camp?

24 A. Interrogations in the camp took place daily.

25 Q. Where were those interrogations conducted?

Page 4753

1 A. In the administration building, which was within the composition

2 of the restaurant building but up on the story above.

3 Q. Did you have occasion to go into the rooms where the

4 interrogations were conducted?

5 A. Yes, the same day that I was brought to the camp.

6 Q. Other than the time when you were interrogated, did you go into

7 the rooms where the prisoners were interrogated?

8 A. Yes.

9 Q. When would you go into those rooms?

10 A. In the evening, after having completed the work duty that we had,

11 that we women had in the restaurant.

12 Q. What condition would those rooms be in?

13 A. Every time we got to that room, we would be shocked to see blood

14 in the room. There was blood on the floor, there were traces of torn

15 clothing. There was blood not only on the floor but on the walls as

16 well.

17 Q. Did you ever find any types of batons or other weapons in those

18 rooms?

19 A. Yes, we did come across things of that kind several times. I

20 think twice, as far as I remember, in my room, we found these various

21 devices, which I can only assume were to beat and torture people who were

22 brought there for interrogation.

23 Q. Why do you assume that those batons and things were used to beat

24 and torture people brought for interrogation?

25 A. Because there were traces of blood on them.

Page 4754

1 Q. What would you do with these batons and other things that you

2 found?

3 A. We would hand them over to the main office, the person on duty in

4 the main office, the commander or his deputy.

5 Q. Besides finding weapons in the room, did you ever find any other

6 materials in the room such as documents?

7 A. Yes, lists with the names of prisoners on them.

8 Q. Do you remember any of the names that you found on those lists?

9 Did any of them stand out to you?

10 A. I only saw the first page because I was frightened to look

11 further. I wanted to get rid of those things as soon as possible. Saw

12 clearly a name of a woman prisoner who was in the room with me, Sifeta

13 Susic, and I also saw the name of the mayor who was a prisoner in the

14 camp, Muhamed Cehajic.

15 Q. What did the women do with these lists when they found them?

16 A. We would hand them over straight away to the commander or his

17 deputy.

18 Q. Did the women have to clean these rooms, interrogation rooms?

19 A. Yes, they did, because in the evening we lay there. So we had to

20 clear up the blood and everything else to be able to spend the night

21 there.

22 Q. Now, during the day, would you be able to hear any sounds coming

23 from these interrogations, down in the restaurant?

24 A. Yes. That was the reality in which we lived. We had to spend the

25 whole day in the restaurant handing out that one meal a day to the

Page 4755

1 prisoners, cleaning, and we would hear screams, the screams of people

2 coming from the offices where the interrogations were conducted. We heard

3 the blows that reverberated, and their entreaties, their cries, their

4 moans and groans.

5 Q. You indicated that you were interrogated in the camp.

6 A. Yes, as soon as I was brought there on the 9th of June, 1992, the

7 first day.

8 Q. Do you recall who the interrogators were that questioned you?

9 A. Yes, I remember them well. They were Nenad Babic and Nenad

10 Tomcic.

11 Q. Did those two interrogators have nicknames or how were they

12 referred to?

13 A. Neso.

14 Q. What types of questions did they ask you?

15 A. We talked. They asked me whether I knew that their referendum

16 that was proclaimed for a sovereign, independent Bosnia-Herzegovina had

17 been falsified, was a forgery.

18 Q. Did they make any allegations about you?

19 A. Yes. They asked me where I went of late, whom I had occasion to

20 meet. They mentioned Nedzad Seric, the man, who until the Serbs could

21 control, was the president of the court. And also they asked me about

22 Omer Kerenovic, Esad Mehmedagic.

23 Q. Were you beaten during your interrogation?

24 A. No.

25 Q. Did you see any weapons visible during the time you were

Page 4756

1 interrogated?

2 A. Yes. Throughout the time I was sitting in the chair and making my

3 statement or, rather, answering the questions they asked me, a sniper was

4 directed at me. Whether it was a sniper or machine-gun, I really don't

5 know much about weapons, but this weapon was directed at me throughout my

6 interrogation.

7 Q. Now, you indicated the interrogators raised the issue of

8 referendum. Did they accuse you of having something to do with that

9 referendum?

10 A. They thought that I had something to do with it, because I was

11 able to deduce this from the questions they asked me. They thought that I

12 took part in the implementation of that referendum.

13 Q. Had you taken part in the implementation of the referendum?

14 A. No.

15 Q. Now, you referred to this as a referendum on the issue of

16 sovereignty for Bosnia-Herzegovina. When was that referendum held, do you

17 recall?

18 A. The referendum was held and the citizens of Bosnia-Herzegovina --

19 I think it was proclaimed in 1991, and the citizens of Bosnia-Herzegovina

20 went out to referendum, I think sometime at the end of February or

21 beginning of March 1992.

22 Q. Do you recall the result of the vote?

23 A. Yes, I do.

24 Q. What was that?

25 A. Sixty-four per cent of the electoral body, that is to say, in

Page 4757

1 translation, the citizens of Bosnia-Herzegovina, said they wanted to live

2 in an independent, sovereign, and autonomous Bosnia-Herzegovina. They

3 came out in favour of that.

4 Q. During the time of the referendum, do you recall hearing public

5 statements regarding the position of the SDS party on that referendum?

6 A. Yes. The SDS called upon the citizens of Serb ethnicity to

7 boycott the referendum.

8 Q. Earlier you named the inspectors who conducted interrogations in

9 the camp who had accompanied you on the bus. In addition to those that

10 you named, were there other inspectors who worked in the camp?

11 A. Yes.

12 Q. Do you recall some of their names?

13 A. I do.

14 Q. And who were they?

15 A. Drago Meakic, Obrad Despotovic, and an inspector who I had never

16 seen before that. I think that his name was Mile or Milan, but his

17 surname was Hrvacanin.

18 Q. Do you know what area they came from or where they came?

19 A. They came in their own cars. They would come to the camp every

20 day. They didn't take the bus with the other inspectors. I think that

21 they came from a village which is located near Omarska, and the name of

22 that village is Petrov Gaj.

23 Q. Now, in addition to those interrogators who were from the local

24 area, were there interrogators who came from outside the Prijedor

25 municipality?

Page 4758

1 A. Yes, from Banja Luka.

2 Q. Do you remember the name of any of those individuals who came from

3 Banja Luka?

4 A. I remember just the nickname of one of them. His nickname was

5 Patak, but I don't know his name or surname.

6 Q. Did you ever have a conversation with Mladjo Radic, Krkan, about

7 the inspectors and whether or not they could help you?

8 A. Yes.

9 Q. And what, if anything, did he say to you, that is Krkan? What did

10 he say to you about that?

11 A. On one occasion when Mladjo called me into his office, he said

12 that he could help me, that he knew one of the inspectors who came from

13 western Slavonia, that is, a portion of Croatia, and that he was a

14 high-ranking military officer and was now an inspector at Omarska, and

15 that he could help me.

16 Q. Did Krkan tell you what this help would cost you, what you would

17 have to do in return?

18 A. Yes. I would have to have sexual intercourse with him.

19 Q. And when you say "with him," who do you mean? With who?

20 A. I mean Krkan.

21 Q. In your professional training and your education, did you receive

22 instruction regarding the public Security Service in the former

23 Yugoslavia, that is, its structures, its responsibilities, and its

24 operations?

25 A. Yes.

Page 4759

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Page 4760

1 Q. And during your years of professional experience in the Prijedor

2 area, did you have frequent contact with the public Security Service and

3 its operations in Prijedor?

4 A. Yes.

5 Q. Now, having regard to your training and your professional

6 experience and in terms of your experience in the Omarska camp, I'd like

7 to ask you the following questions: What do you believe the role of the

8 inspectors was in the camp? What was their purpose?

9 A. They came to the camp often, that is to say, every day, as I

10 said. I apologise, every day. They would take statements, make minutes

11 and reports on the basis of what we were charged of.

12 Q. And when you say "charged of," what do you mean by that? What was

13 the purpose of these reports?

14 A. Well, charged. None of us knew why we were -- what we were

15 accused of, and I didn't know either; but from my talk with the

16 interrogators, I was able to conclude what -- why I was there.

17 Q. And were you able to form an opinion as to what they were going to

18 do with that information or what the purpose of these talks were, these

19 interrogations?

20 A. Well, for the possible liquidation of people.

21 Q. And did you ever have an occasion to see what you learnt, that the

22 allegations made during these interrogations were subsequently published?

23 A. Yes.

24 Q. Were they used as a justification for what occurred in the

25 Prijedor area?

Page 4761

1 A. Certainly, yes.

2 Q. Based on your experience and your training, did you form an

3 opinion as to the authority of these inspectors in comparison to the camp

4 command staff? What was the relationship there?

5 A. As I saw it, I think the relationship was one of equality. They

6 were associates in the work they were doing, on a footing of equality.

7 Q. In your opinion, were these two sections, if you will, two groups,

8 inspectors on the one hand and the camp staff on the other, were they

9 performing different functions within the same organisation?

10 A. Yes. I think so, yes.

11 Q. Based on your experience and in light of your training, what was

12 your opinion as regards the authority of the camp commander and the deputy

13 commanders with respect to the guards who worked and others who worked in

14 the camp?

15 A. It was a hierarchy. At the top of the pyramid was the commander,

16 underneath him was his deputy, below him shift commander, and then the

17 guards at the bottom of that pyramid.

18 Q. And in your opinion, did the commander and the deputy commanders

19 have the authority to order the shift commanders and the guards below them

20 to do or not to do certain actions, acts?

21 A. Yes, of course they did.

22 Q. Was this structure which you observed in the camp with the guards,

23 to the camp commander and the guards, similar to the structure that you

24 were familiar with within the public Security Service in non-wartime

25 settings?

Page 4762

1 A. Yes, yes.

2 Q. And is it your opinion that there was an obligation on those who

3 were at the bottom of this hierarchy, if you will, to obey the orders of

4 those who were superior to them?

5 A. Yes, of course.

6 Q. Now, based on your training and experience, what was the basic

7 purpose and obligation of a member of the public Security Service in

8 Bosnia and Herzegovina? What were they there for? What was their

9 principle?

10 A. Well, to protect the state, the system. The police was there,

11 too. The state security system and the police, to see that law and order

12 was enforced.

13 Q. Did they have an obligation to protect the citizens of

14 Bosnia-Herzegovina?

15 A. Of course they did, yes.

16 Q. Did they have an obligation to prevent a crime if they saw one

17 being committed?

18 A. Yes.

19 Q. During the time that you were in the camp, did you hear any

20 information, comments, regarding a Crisis Staff and its relationship with

21 the Omarska camp?

22 A. Yes, I heard a kind of Crisis Staff being mentioned.

23 Q. And what did you hear about that?

24 A. I had heard about it even before my arrival there. A Crisis Staff

25 would often be mentioned on the local radio station.

Page 4763

1 Q. And with respect to the prisoners who were in the Omarska camp,

2 did you hear any conversations as to what role or what authority the

3 Crisis Staff may have had with respect to those prisoners?

4 A. This is only my assumption, but it was mentioned that the Crisis

5 Staff was also in charge of providing certain information, and that the

6 information gathered during those interrogations at the camp would be then

7 supplied to the Crisis Staff. But those were the rumours, and I don't

8 know whether they were correct.

9 Q. And where did you hear that information?

10 A. In the restaurant.

11 Q. From the restaurant, could you see when new prisoners arrived?

12 A. Yes.

13 Q. And what would happen when new prisoners arrived in the camp?

14 A. When new prisoners arrived in the camp, usually all of the guards

15 who happened to be on the shift would approach the group of detainees in

16 question. They would start beating them, hitting them, verbally abusing

17 them. They also searched their clothes. They would ask them to empty

18 their pockets in case they had any....

19 Q. When new prisoners arrived, did you see any of those prisoners

20 being taken to the "white house"?

21 A. Yes.

22 Q. And what would you see happen as those prisoners were being taken

23 to the "white house"?

24 A. They would be beaten all the way to the "white house" by those who

25 were escorting them.

Page 4764

1 Q. Now, on any of these occasions when new prisoners arrived and were

2 being beaten, did you ever see Miroslav Kvocka, Dragoljub Prcac, Krkan, or

3 Krle present when the beatings occurred?

4 A. Yes, very often.

5 Q. Do you recall where they would be when the beatings occurred?

6 A. Out there in the vicinity.

7 Q. Did you ever see any of those four individuals, Kvocka, Prcac,

8 Krkan, or Krle, take any steps to prevent the beatings that were going on?

9 A. No, I never saw them prevent anything.

10 Q. Do you recall occasions when Kvocka, Prcac, Krkan, or Krle would

11 be present in the restaurant building or, indeed, in the camp when you

12 heard those screams coming from the interrogation rooms on the first floor

13 of the administration building?

14 A. Yes. They could clearly hear it from the office where they were

15 sitting. They could hear it better than us in the restaurant.

16 Q. How do you know that they would be upstairs in their office?

17 A. They would come from upstairs from the office. They would walk

18 around the compound, stop by the restaurant.

19 Q. Are you aware of any beatings that Krle directly participated in

20 or was present at?

21 A. Yes.

22 Q. Can you describe what happened there?

23 A. Yes, I can. Sometime in the evening -- it must have been around

24 11.00 -- during my stay there, I believe it was in the month of July but I

25 cannot recall the exact date, I heard the voice of Zivko Marmat, and the

Page 4765

1 voice of Krle, Zdravko Govedar as well. I heard them screaming and

2 shouting upstairs, on the upper floor. They were asking for Silvije Saric

3 to be brought upstairs together with Abdulah Puskar.

4 Q. What could you hear happen once those men arrived on the first

5 floor?

6 A. Somebody opened the door to the room where I was, and I could hear

7 terrible blows reverberating. I could hear Silvije Saric and Abdulah

8 Puskar begging them not to beat them. I could hear them cry and moan.

9 Q. During the time that you could hear these beatings, these blows,

10 could you hear Krle say anything?

11 A. He was yelling, he was shouting something. I don't know exactly

12 what. Then one of them -- I don't know which one -- verbally abused

13 Silvije Saric. I mentioned the part of Croatian Democratic Union, whose

14 president he was. They were shouting at Abdulah Puskar, "Professor, who

15 are you going to grade now?" because he was a teacher by profession.

16 Q. Silvije Saric, what had he done before the war?

17 A. Silvije Saric used to work at the post office in Prijedor. He was

18 a legal officer by occupation and he was president of the Croatian

19 Democratic Union, a political party.

20 Q. And the Croatian Democratic Union, is that known by the moniker

21 H-D-Z, HDZ?

22 A. Yes.

23 Q. Now, after this meeting, did you ever see either of those two men,

24 Silvije Saric or Abdulah Puskar, again?

25 A. This lasted until late into the night, and I never saw them in the

Page 4766

1 restaurant again.

2 Q. Now, how is it that you could recognise Krle's voice that night?

3 A. I came to learn his voice very well while I was in the camp

4 because he was always very loud.

5 Q. What do you mean that "he was always very loud"?

6 A. He would always talk in a highly pitched voice.

7 Q. When you say "highly pitched," do you mean loud or squeaky voice?

8 A. I mean loud, very loud.

9 Q. Do you recall seeing a man named Rizah Hadzalic in the camp?

10 A. Yes.

11 Q. What, if anything, happened to him?

12 A. His name is Rizah Hadzalic, and his nickname is Rizo. One day, I

13 saw a man lying down on the pista amongst numerous detainees. Standing

14 right above him was a guard wearing a camouflage uniform. Unfortunately,

15 I don't remember his nickname or surname. He was rather short, with blue

16 eyes and blonde hair. I would see him very often in the camp. He would

17 often wear particular glasses that looked like two mirrors, and they would

18 reflect colours in the sunlight.

19 So this man was standing above the individual in question. He was

20 kicking him with his heavy military boots and hitting him with a rifle

21 butt. He also jumped on him, all over his body.

22 Q. After this, did this guard eventually leave this man lying on the

23 pista?

24 A. Yes.

25 Q. What happened after that? Did anyone come over to that prisoner?

Page 4767

1 A. Yes. After that, I saw Dr. Esad Sadikovic, who lifted the man's

2 hand, and he was trying to take his pulse. He then lifted his head and

3 put him back down on the ground again. He put his arms next to his body

4 and closed his eyes. At the moment when he lifted him, when he lifted his

5 body, I could clearly see that it was Rizo Hadzalic, Rizah Hadzalic called

6 Rizo.

7 Q. Now, prior to the beating that you saw, to your knowledge had

8 there been another beating already -- had that already taken place?

9 A. I don't know. I don't remember.

10 Q. Did Dr. Sadikovic later talk to you about Rizo?

11 A. Yes, he did. He told me that he had passed away, that he was no

12 longer alive.

13 Q. Did he tell you what caused the death?

14 A. Torture, beatings.

15 Q. Were any of the women who you stayed with ever assaulted in the

16 restaurant?

17 A. Yes.

18 Q. Who was that?

19 A. Mugbila Besirevic.

20 Q. What happened to Mugbila?

21 A. On one occasion while we were working at the restaurant, handing

22 out the food to the prisoners, Mugbila was sitting down at a table which

23 was located inside the restaurant. The women who would not be serving the

24 food on that day or would not be working that day would usually sit at

25 that table.

Page 4768

1 Then a man came into the restaurant. He was wearing a camouflage

2 uniform, and I had not seen him in the camp prior to that so I didn't know

3 who he was.

4 He went straight to Mugbila, and I noticed that he was wearing a

5 cap with a cockade on it. He approached Mugbila, and he started shouting

6 at her and hitting her. He said, "You're the one that used to work in the

7 bank in Prijedor, and you're the one who sent the computers and the money

8 that belonged to the bank in Prijedor to the Muslims in the area of

9 Zazine." At that moment, he pulled out a knife from his boot and he

10 carved a cross on her forehead and she started to bleed.

11 Mugbila remained sitting there, motionless. We were in a state of

12 shock because of the sight.

13 Q. Now, I want to address two things. First, the English translation

14 came across on the transcript as he pulled out a knife from his boot -- it

15 was corrected, I'm sorry. It originally said "his forehead," but I now

16 see the transcript says "her forehead."

17 The transcript also says that that man who pulled out the knife

18 was wearing a cockade on his hat. Did you mean to say "cockade" or

19 something else?

20 A. Well, he cannot actually wear it on his head, but on his cap. He

21 had a kind of cap which had a cockade or the Serbian kokarda on it. And

22 he pulled out a knife and he carved it on her cheek, on Mugbila's cheek, a

23 cross.

24 Q. So the cap had the kokarda symbol on it?

25 A. Yes.

Page 4769

1 Q. Now, were there guards, camp guards, in the restaurant at that

2 time?

3 A. Yes, all of those who were on duty that day.

4 Q. Did any of them do anything to prevent this man from cutting

5 Mugbila or to take him into custody, to apprehend him after it happened?

6 A. No. Nobody even came close or said anything, nor did anyone help

7 Mugbila in any way.

8 Q. Was there another occasion when a woman was assaulted in the

9 restaurant?

10 A. Yes.

11 Q. And what happened on that occasion?

12 A. On one occasion while we were in the restaurant, a man with a

13 weapon came, and he went to my colleague, Munevera Mesic. She was sitting

14 on a chair at a desk -- at a table, rather, and he unbuttoned her shirt,

15 and he uncovered one of her breasts. And he took out a knife, and he --

16 with his knife, he went over her breast.

17 Q. And at that point, what did you believe he was going to do?

18 A. I believed that he was going to cut it off with that knife.

19 Q. And what happened?

20 A. He was obviously having good time doing that, so he went on like

21 that for several minutes. I don't know exactly how long. I was shocked.

22 But at one point he gave up, and he was laughing at that.

23 Q. And again, were there guards present in the restaurant?

24 A. Yes. The guards were always there; we were never alone.

25 Q. And did any of them take any action to stop this man or to take

Page 4770

1 him into custody after the fact?

2 A. No, no. They laughed. They were obviously having good time,

3 having fun.

4 Q. Did you ever see dead bodies in the camp?

5 A. Yes, on a daily basis.

6 Q. Where would you see these dead bodies?

7 A. We would start the day with counting the dead who were in front of

8 the "white house," to the sides of the "white house." The bodies were

9 strewn along the meadow, along the lawn, and we would count the dead every

10 morning.

11 Q. And did you ever recognise any of those dead bodies?

12 A. Yes. Once I recognised a man whom I knew personally. His name

13 was Mehmedalija Sarajlic.

14 Q. And how could you tell that he was dead?

15 A. They were thrown onto a truck.

16 Q. And during the time that you saw Mehmedalija Sarajlic out there,

17 did he give any signs of life whatsoever?

18 A. No, he didn't.

19 Q. And how were these bodies taken away?

20 A. The bodies would be thrown onto a TAM truck. It was a yellow

21 truck. So they would be loading them onto a truck and then driving them

22 somewhere.

23 Q. Did you ever see Miroslav Kvocka, Dragoljub Prcac, Krkan, or Krle

24 walk by the dead bodies who were in the grass near the "white house"?

25 A. Yes, of course. Very often.

Page 4771

1 Q. Did you ever see or hear of any of those four individuals making

2 inquiries about how those prisoners had died or taking any steps to

3 discipline anyone for the killings?

4 A. No. I never heard of any such thing, that they would have taken

5 any steps.

6 Q. Did you ever see any of those four individuals, Kvocka, Prcac,

7 Krkan, or Krle, make inquiries about any of the beatings or other abuse of

8 prisoners which you saw in the camp, or to take any action to discipline

9 anyone for any of that abuse which you saw or were a victim of yourself?

10 A. No, never.

11 Q. You referred to the women who were kept in the administration

12 building with you. Besides those women, were there any other women in the

13 camp that you were aware of?

14 A. Yes.

15 Q. And who was that?

16 A. There was a woman by the name of Hajra Hadzic and who spent

17 most -- all of the time she was there in the "white house."

18 Q. And did you have occasion to see Hajra Hadzic when she came to the

19 restaurant for meals?

20 A. Yes.

21 Q. And what was --

22 A. She would come in a group together with the men from the "white

23 house."

24 Q. And what was her condition when you saw her?

25 A. She appeared to be very exhausted; she was pale.

Page 4772

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Page 4773

1 Q. Did you ever see her suffer any abuse while you were in the camp

2 outside near the "white house"?

3 A. Yes.

4 Q. And what happened?

5 A. On one occasion, they were bathing men with a water hose in front

6 of the "white house." They were all naked, and Hajra was amongst them.

7 Q. Now, when you say they were bathing the men, what do you mean,

8 they were bathing them with this hose? What kind of hose were they

9 using? What were they doing?

10 A. It was not a real bathing; they were simply hosing them down. It

11 was a very thick water hose which they would usually use for washing

12 trucks or the pista. It has a very strong jet that comes out and a very

13 strong pressure. So I saw them using that same water hose in front of the

14 "white house" to wash the detainees, including Hajra, and all of them

15 were naked.

16 Q. And what would happen to the detainees when they were hit by this

17 strong pressure from the water?

18 A. Some of them were staggering. Some fell down on the grass because

19 they were very exhausted, and the pressure of the water was very strong,

20 so many of them fell down on the ground.

21 MR. KEEGAN: Your Honour, I'm a little confused about how we

22 should proceed, given the odd schedule today. I'm about to move into a

23 new area. I believe I probably have another 30 to 40 minutes with this

24 witness. I would at least like to finish the direct today, if not start

25 the cross-examination. Is there a possibility we'll go a little longer

Page 4774

1 today, and if so, when would you like to take a break schedule?

2 JUDGE RODRIGUES: [Interpretation] Perhaps we should divide the

3 time that remains until 2.30. We should have a break now, perhaps a

4 half-hour break, and then after that we will have more or less 50 minutes

5 to complete the examination.

6 So we're going to have a half-hour break at this point, and I

7 should like to ask the usher to pull down the blinds and help the witness

8 out of the courtroom. Thank you.

9 Witness, could you remain seated, please.

10 We will have a break now, half-hour break.

11 --- Recess taken at 1.12 p.m.

12 --- On resuming at 1.43 p.m.

13 JUDGE RODRIGUES: [Interpretation] Please be seated.

14 Mr. Keegan, we will continue with the examination of the witness.

15 Please go on.

16 MR. KEEGAN:

17 Q. Witness J, were women in the administration building called out at

18 nights?

19 A. Yes.

20 Q. And how often?

21 A. Very often. I would probably be exaggerating if I told you every

22 night, but it was very often during my stay there.

23 Q. Do you recall the names of some of those women who were called

24 out?

25 A. Yes, I do. Edna Dautovic, Mina Ceric, Seada Curak nicknamed Dada,

Page 4775

1 Sedija Menkovic called Dika, Velida Mahmuljin, Tesma Elezovic, Sabiha

2 Obradovic, Fikreta Sarajlic, and Nadzija Nadza Fazic.

3 Q. From the other room, do you recall any of the names of women who

4 were called out?

5 A. Yes. Jadranka Cigelj, (redacted).

6 Q. Who would call these women out?

7 A. A guard would call them out or Mladjo Radic, called Krkan.

8 Q. Can you remember any of the other commander or deputy commanders

9 or anyone else also calling women out?

10 A. Not deputy commanders, but I know that Edna Dautovic was called

11 out by Zivko Marmat, that Jadranka Papes and Edna Dautovic were called by

12 Mirko Babic.

13 Q. What about Zeljko Meakic? Do you recall him calling anybody out?

14 A. Yes, he did. Jadranka Papes.

15 Q. Anyone else besides Jadranka?

16 A. Edna Dautovic as well.

17 Q. And Jadranka Cigelj, did he call her out?

18 A. Yes. She was in the other room. She wasn't with me.

19 Q. Who did Krkan call out?

20 A. Myself on one occasion.

21 Q. And anyone else do you recall him calling out?

22 A. He called out Velida Mahmuljin, Mina Ceric, Tesma Elezovic, Seada

23 Curak, Sabiha Obradovic.

24 Q. What would these women look like when they came back?

25 A. They would appear to be absent, absent-minded. They wouldn't

Page 4776

1 speak. They were silent.

2 Q. Did you ever ask them what happened to them?

3 A. No, never.

4 Q. Now, you indicated that Krkan called you out once.

5 A. Yes, he did.

6 Q. What happened on that occasion?

7 A. He took me to the office where he would usually be sitting, the

8 same office I referred to where the camp commander would be and where I

9 was initially taken when I was brought to the camp.

10 Q. What time of the day was this?

11 A. It was sometime during the afternoon or, rather, towards the

12 evening when we were coming back from our duty in the restaurant, in the

13 evening.

14 Q. Do you recall approximately when the date -- datewise when this

15 was in the camp?

16 A. No, I don't remember exactly.

17 Q. What did Krkan say to you?

18 A. We talked, and he told me or, rather, according to what he was

19 saying, I realised that we, the detainees, were put into some kind of

20 categories which were indicating the gravity of the accusation made

21 against us. There were lesser accusations or more serious ones.

22 He told me that he knew one of the inspectors who was a

23 high-ranking military official and was currently deployed at the camp,

24 that he was from Slavonia, that he was a very strict man, and that through

25 him he could see to it that I was put in a less serious category, because

Page 4777

1 according to what he was saying, the charges against me appear to be very

2 serious and that what I was accused of was indeed very serious.

3 Q. And what did he tell you that you would have to do to protect

4 yourself?

5 A. That I should be fair towards him, that in return for that

6 assistance, for that service, that he would ask for a counter-service to

7 be made.

8 Q. And what was that counter-service supposed to be?

9 A. Well, I was supposed to have sexual intercourse with him, to sleep

10 with him. That is, at least, what I understood, and later on he behaved

11 that way.

12 Q. And during the time he was telling you this, was he doing

13 anything?

14 A. Yes, he did. He pushed me against a wall, and he started touching

15 me on my breasts and on my bottom.

16 Q. And what were you saying to him in return when he was doing this

17 to you?

18 A. I was pleading with him to let me go, not to touch me, but he was

19 very rough. He was pushing against me, and I was breathless. I was

20 trying to tell him that I was menstruating, that he should let me go.

21 Q. When you told him that you were menstruating, did he say anything

22 to you?

23 A. He said that that was what each one of us told him.

24 Q. When you say "each one of us," what do you mean by that? What was

25 he referring to?

Page 4778

1 A. He was referring to women. That was my conclusion. He didn't

2 mention any names, though.

3 Q. Did he say anything about the other women to you?

4 A. Not to me, not on that occasion. He just said that that was the

5 way all of us were trying to avoid what he wanted.

6 Q. Now, during the time that this was going on, where was he touching

7 you on your body?

8 A. On my breasts and on my genitals. He pulled up my skirt, he

9 unbuttoned his trousers, and he took out his penis.

10 Q. And did he attempt to have intercourse with you at that time?

11 A. Yes.

12 Q. And did he penetrate you with his penis?

13 A. No.

14 Q. Did he ejaculate on you?

15 A. Yes, he did on my thighs and on my skirt, which was rolled up.

16 Q. During this entire time, were you attempting to get away from him?

17 A. I was attempting to get away from him, but I was pushed against

18 the wall by him very hard. He was very rough.

19 Q. Was he throughout this time physically grabbing various parts of

20 your body, including your breasts?

21 A. Yes, he was.

22 Q. And your genitals?

23 A. Yes.

24 Q. Did you sustain any injuries as a result of this? Did you have

25 any bruising or cuts?

Page 4779

1 A. Yes, I did. My skin is very sensitive, and I discovered bruises

2 after that on my body.

3 Q. And after he ejaculated on your legs and on your clothes, did he

4 release you?

5 A. Yes.

6 Q. Did he say anything to you once he released you?

7 A. Yes, he did. He said that the two of us should do it in a proper

8 way, in a different way.

9 Q. Did he tell you how that could be arranged?

10 A. Yes. He said that I should open the doors to my room, and that

11 once when he's on duty, he would come and pick me up and that we would go

12 to a room somewhere, and that we would -- he would take a mattress and

13 that we would be able do it properly and not like this.

14 Q. After you left the office, did you return to your sleeping room?

15 A. I went to the toilet, to the sink in the bathroom. I washed

16 myself a little, and I went to the room.

17 Q. When you returned to your room, did you tell anybody what had

18 happened to you?

19 A. No, I didn't. I said that I had been working, cleaning something.

20 Q. Were you assaulted by anyone else in the camp?

21 A. Yes.

22 Q. And who was that?

23 A. It was Nedeljko Grabovac called "Kapitan," Captain.

24 Q. And do you know what position, if any, he had in the camp?

25 A. I don't know. He came suddenly, and he stayed there for a week or

Page 4780

1 ten days, and after that he was no longer in the camp. And until that

2 time, I hadn't seen him there.

3 Q. Do you have any idea of what part of your stay in the camp this

4 was, what the approximate date was?

5 A. According to my recollection, it took place sometime in July 1992.

6 Q. How was this man introduced to you?

7 A. They introduced him by his nickname, "Kapitan".

8 Q. What did the man wear when you saw him in the camp?

9 A. He was wearing an olive drab uniform, the same kind that was worn

10 by the members of the former JNA. He had epaulettes with some gold and

11 stars on it. I really don't know much about ranks, but according to the

12 stars, I figured that he must have some kind of rank in the military.

13 Q. Now, what happened on the occasion that he assaulted you? How

14 were you first called out?

15 A. He said that I should make them some coffee.

16 Q. And did you in fact go to an office to make coffee?

17 A. Yes, I did. I went to the same office, the reception office where

18 the commander of the camp and his deputy would be sitting.

19 Q. Do you recall who was in that office?

20 A. Yes, I remember very well. Zivko Marmat and Milojica Kos, called

21 Krle, were there.

22 Q. And did you make coffee for those men?

23 A. Yes, I made some coffee.

24 Q. And what happened after you had the -- what happened after they

25 had the coffee?

Page 4781

1 A. I also had coffee with them. Milojica Kos and Zivko Marmat left,

2 and the Captain and myself were left alone in the room.

3 Q. And what happened once when you left alone in the room?

4 A. I wanted to wash the dishes after we'd had coffee, and I was about

5 to get up, but he told me to come back. And he told me that he liked me,

6 that I was his type of woman, and he started touching me.

7 Q. Where was he touching you?

8 A. He was touching me on my genitals.

9 Q. And did you say anything to him when he began to do this to you?

10 A. I told him -- actually, I was pleading with him to let me go, that

11 I was feeling sick, that I was not okay, that my health was not good, that

12 I felt like throwing up.

13 Q. Did he say anything to you when you said that to him?

14 A. He said that we women always had a problem with that, that we

15 always wanted to avoid that under that pretext that we were not feeling

16 well, that we women in the camp were doing fine; whereas other Serbian

17 women who are in the citizen -- in the cities under the Muslim control

18 were being raped.

19 Q. Did he continue to grab your body and to touch you?

20 A. Yes, he continued.

21 Q. Did he pull up the shirt that you were wearing?

22 A. Yes. He pulled up my skirt and my shirt, and he took off my

23 knickers, lowered them down.

24 Q. Was he grabbing your breasts?

25 A. Yes, he was.

Page 4782

1 Q. Did he also take out his penis?

2 A. Yes, he did.

3 Q. Did he, at that time, attempt to rape you?

4 A. Yes, he did.

5 Q. Did he penetrate your vagina?

6 A. No, he didn't.

7 Q. Did he ejaculate?

8 A. Yes, he did.

9 Q. Was that, again, on your legs?

10 A. Yes. It was on my thighs and on my legs.

11 Q. And after he ejaculated, did he let you go?

12 A. Yes, he did.

13 Q. Throughout this assault, were you attempting to get away?

14 A. Yes, of course. All the time I was trying to get away, pleading

15 with him to let me go, but he said that he can also act differently if I

16 should continue that way, that he can also be rough, much rougher than he

17 was on that occasion.

18 Q. Was he already using force and being rough with you?

19 A. Yes, he was rough. He was squeezing me very hard, and I was

20 afraid after he told me that, that he could act differently, because I

21 thought that he would beat me up or even kill me.

22 Q. Did you sustain any injuries, any bruising or cuts, as a result of

23 this assault?

24 A. No, I didn't sustain any cuts, only bruising.

25 Q. And where was the bruising?

Page 4783

1 A. On my thighs and on my breasts.

2 Q. Where did you go after he released you?

3 A. I went towards the toilet in the bathroom. I washed myself a

4 little. There was a sink there with some water in it. I cleaned myself a

5 little. I was trying to compose myself enough that I went to the room.

6 Q. On this occasion, did you tell anyone in the room what had

7 happened to you?

8 A. No, I didn't. I told them I had to make some coffee and I had

9 drunk coffee.

10 Q. Did you ever report either one of these assaults to the deputy

11 commander or the commander of the camp?

12 A. No. No.

13 Q. Why not?

14 A. I didn't dare. I was convinced that nobody would believe me, and

15 that, because of that, I would fare even worse.

16 Q. During the time that you were in Omarska, did you see a man named

17 Zoran Zigic?

18 A. Yes.

19 Q. Did you know him prior to seeing him in Omarska camp?

20 A. I knew him just by sight.

21 Q. And where had you seen him?

22 A. I would see him around town, in the town of Prijedor. I knew that

23 he was a taxi driver for a time by profession.

24 Q. Do you recall approximately when you saw him in the Omarska camp?

25 A. I think it was the day after I arrived in Omarksa, which is to say

Page 4784

1 the 10th of June, 1992.

2 Q. What do you recall him doing when you saw him at the camp?

3 A. He was standing in front of the restaurant on the pista. He was

4 shouting. He was calling people's names and surnames out and asking the

5 guards where those people were. He mentioned some names like the name of

6 (redacted).

7 Q. Do you remember the names of other people?

8 A. (redacted).

9 Q. Was there anyone from the camp command present in the area when

10 Zigic was calling out these names?

11 A. Yes.

12 Q. Who was that?

13 A. The commander and his deputy were there, and it was Krkan's shift

14 on duty that day.

15 Q. When you say the "deputy," who is it you're referring to?

16 A. I'm thinking of Miroslav Kvocka.

17 Q. Did you see what happened after Zigic called these men out?

18 A. He was looking for them. He was calling them out, their names and

19 surnames, and I asked the man who worked in the kitchen with us, he was

20 one of the prisoners, Adnan Ago Agic, I asked him what was going on and

21 who the man was, and he said, "It's the taxi driver. Do you know him?" I

22 said, "Well" -- I was just very frightened from all the screaming. So I

23 went to the toilet, which was within the composition of the restaurant,

24 and I stayed in the toilet for some time.

25 Q. Did you see those three men that you have named -- (redacted)

Page 4785

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Page 4786

1 (redacted)-- after this day?

2 A. No. I didn't see them for a long time in the restaurant. They

3 did not come for the meal for some time.

4 Q. When they did finally come for a meal, do you recall what they

5 looked like?

6 A. Their faces were completely distorted. They were swollen and they

7 were covered in bruises.

8 Q. Do you recall what Zigic was wearing that day that you saw him in

9 the camp?

10 A. He was wearing a camouflage uniform and a red beret on his head.

11 Q. When did you leave Omarska camp?

12 A. On the 3rd of August, 1992.

13 Q. And where were you taken?

14 A. To Trnopolje, to another camp.

15 Q. During the time that you were in Trnopolje, did you see any of the

16 people from the Omarska camp that you've talked about here today, the

17 guards, the command staff, or others?

18 A. I saw Zoran Zigic again.

19 Q. What did you see him do in Trnopolje?

20 A. He came in a car of some kind, and he was looking for a man. He

21 asked where that man was, whether anybody knew. The man's name was Edin

22 Ganic.

23 Q. Did you hear what Zigic wanted with him? Did you hear why he

24 wanted Ganic?

25 A. He mentioned some kind of motor, that he needed him for that.

Page 4787

1 Q. For a motor?

2 A. Yes.

3 Q. Did he refer to any particular type of vehicle or just a motor?

4 A. Well, like a motorbike, a type of vehicle.

5 Q. A motorbike.

6 A. Yes.

7 Q. Did you ever see Zigic trying to assault somebody in Trnopolje

8 camp?

9 A. Yes, I did see him, in front of our room. He stood stride

10 opposite a man and took a knife out to stab him with.

11 Q. And did he stab the man?

12 A. He did not.

13 Q. Did the guards at Trnopolje do anything?

14 A. No. He came and greeted the prisoners out loud, and the greeting

15 was "God be with you, you Turks," and the answer the prisoners would give

16 would be, "God bless you too."

17 Q. Are you aware whether Zigic ever came to look for women from

18 Omarska?

19 A. Yes. He did ask the man in charge of standing guard over us in

20 the room where we were in Omarska where the women were.

21 Q. What do you recall him asking the man who was guarding the women?

22 A. He asked where they were, where the whores were. He used a sort

23 of abusive term of that kind. "Where are they in Omarska?" "Where have

24 they been put up, these tarts," or, "whores."

25 Q. And what did this guard do?

Page 4788

1 A. He did not allow him to go into the room we were in. And he was

2 armed. I learnt from one of my girlfriends that his name was Spiric

3 Radenko and that he was a neighbour of hers, that man who prevented Zigic

4 from entering the room that we were put up in at the camp.

5 Q. Do you recall what that man, the guard, said to Zigic or what he

6 did to prevent him?

7 A. He cocked his weapon at him and forbid him to enter. And he said

8 that while he was on guard there, Zigic would not be able to enter the

9 room we were located in.

10 Q. And what did Zigic do then?

11 A. Zigic left. He walked around looking for this man, Edin Ganic,

12 whom I saw was there; he was wearing a plaster cast. But he wasn't in our

13 own room, he was in some other room close by. And he contacted the Red

14 Cross there. He was with Kuruzovic, Slobodan, the commander of the camp,

15 and the other man working in the Serbian Red Cross. So he walked around

16 there.

17 Q. You indicated "he" was wearing a plaster cast. Who was wearing

18 the cast?

19 A. I mean Edin Ganic. He was lying there in one of the rooms. I saw

20 him. Azra Blazevic pointed him out to me. She worked there. She was on

21 the medical team there.

22 Q. Now, when you saw Zigic in Trnopolje, do you recall what he was

23 wearing?

24 A. He also wore a camouflage uniform and a red beret on his head and

25 arms as well, weapons.

Page 4789

1 Q. What happened when you left Trnopolje?

2 A. I went to Prijedor.

3 Q. Did you go back to your old apartment?

4 A. No. My apartment had already been taken over by a woman, a Serb

5 woman. (redacted)

6 Q. Did you visit your apartment?

7 A. Yes. She met me once in our neighbourhood where my apartment was

8 located, and she invited me in for a cup of coffee.

9 Q. And when she invited you in, what did she serve you the coffee in?

10 A. She served coffee out of my dishes.

11 Q. And what was she wearing?

12 A. She was wearing my clothes. At the entrance to the apartment, her

13 name and surname was written up on the door.

14 Q. Were you allowed to take any of the property from your apartment?

15 A. No. The things were all the same. I just asked her if I could

16 take some of my family photographs with me, and I managed to take a few

17 photographs along with me, back with me.

18 Q. Before you left Prijedor, were you required to sign any

19 documentation?

20 A. Yes.

21 MR. KEEGAN: Could the witness be shown what's been marked as

22 Exhibit 3/116A, and B.

23 Your Honours, given the confidentiality measures, rather than have

24 this document placed on the ELMO so that we have to go into private

25 session, I'll simply ask some questions about the document which I think

Page 4790

1 will be sufficient for explaining it for the record; and there is an

2 English translation which I believe the Judges can look on as the witness

3 describes it, unless you would prefer to go into private session so that

4 she can put the document on the ELMO, Your Honour.

5 Q. Witness J, do you recognise this document?

6 A. Yes.

7 Q. What is this document? What does it represent?

8 A. I was not able to leave town, the town of Prijedor, without this

9 document. This document meant that I was granted permission to leave

10 town, and at the same time, that I pledged all my possessions -- that I

11 was leaving behind all my possessions.

12 Q. Who signed this document; in other words, what official signed the

13 document?

14 A. It was signed by Slavko Budimir, the head of the Ministry of

15 Defence, the Prijedor department.

16 Q. Have you had any continuing health problems as a result of your

17 confinement in Omarska?

18 A. Yes. I have problems, physical and psychological problems. I

19 have kidney problems from the water that we drank in the camp, which was

20 not potable water. I have female-type problems, bleeding outside my

21 menstrual cycle, which I have had since the left the Omarska camp. I

22 suffer from depression and nightmares. I have chronical insomnia.

23 Q. Do these problems continue to this day?

24 A. Yes.

25 Q. After you left Prijedor and moved to another country, did you ever

Page 4791

1 receive a newspaper article from the Kozarski Vjesnik, the Prijedor

2 newspaper, from an acquaintance?

3 A. I did. I received an issue of the Kozarski Vjesnik newspaper from

4 a neighbour of mine and childhood friend of mine who had left Prijedor and

5 found herself on the same territory where I sought refuge.

6 MR. KEEGAN: Your Honour, could the witness be shown what has been

7 marked as Exhibit 3/117A and B.

8 Q. Witness J, do you recognise this document?

9 A. Yes.

10 Q. And what is that?

11 A. That is a local newspaper entitled "The Kozarski Vjesnik," and

12 from this I can see, and I was later able to see other portions, with a

13 series entitled "What Our Sovereign Neighbours Had In Store For Us."

14 Q. Do you recall when, approximately when this particular article was

15 written?

16 A. In 1992, in the summer. I really can't tell you the exact date.

17 Q. The transcript says in 1992. Did you mean 1993? The English

18 transcript says 1992. On the one-year anniversary of the takeover?

19 A. I think this wrote about events, the events of 1992, what had

20 happened in Prijedor. The course, the version was the version written by

21 those who had done everything that took place in Prijedor. But I received

22 it in 1993; it reached me in 1993.

23 Q. And are you named or mentioned in that article?

24 A. Yes, my name is mentioned.

25 Q. Does that article refer to the same allegations that you heard

Page 4792

1 against you when you were interrogated in the Omarska camp?

2 A. Yes. And luckily this was not printed, published, during my stay

3 in the camp; otherwise, I would not be sitting here today.

4 Q. Now, Witness J, you have referred to five individuals in your

5 testimony today: Miroslav Kvocka, Milojica Kos, Mladjo Radic, Drago

6 Prcac, and Zoran Zigic. You described briefly the basis of your knowledge

7 of those individuals.

8 I would first like to ask you to give a brief description of each

9 of those individuals as you remember them in 1992 in the camp, starting

10 with Miroslav Kvocka.

11 A. Miroslav Kvocka was of medium height, medium weight in that year

12 of 1992. He had brown hair. He was younger than me.

13 Q. And you indicated that you had known him for some ten years or so

14 prior to seeing him in the camp?

15 A. Yes.

16 Q. And what about Drago Prcac, the description of him during the time

17 that he was in the camp?

18 A. Well, he was in his fifties at the time, going gray.

19 Q. And --

20 A. Of normal bodily weight.

21 Q. And height in comparison to yourself?

22 A. Medium height, I would say. Perhaps it was a little taller than

23 me. I can't quite remember now what his height was.

24 Q. And had you known him for a period of time prior to seeing him in

25 the camp?

Page 4793

1 A. Yes, I knew him.

2 Q. And Mladjo Radic?

3 A. Mladjo Radic is approximately my own age, perhaps a year younger.

4 At that time in 1992, he was -- I can freely state this -- fat.

5 Q. And you indicated you had seen him as a member of the police for

6 some period of time, some number of years, prior to seeing him in the

7 camp?

8 A. Yes.

9 Q. Milojica Kos, you indicated you met him for the first time in the

10 camp?

11 A. Yes.

12 Q. Can you describe what he looked like during the time you saw him

13 in the camp?

14 A. Well, I remember his hairdo well. He had a fringe.

15 Q. And approximately how tall?

16 A. He was quite tall, according to my own sort of criteria. He was

17 of normal weight at that time.

18 Q. And approximately how often do you believe you saw him in the

19 camp?

20 A. Well, practically whenever he was on duty, I would happen to see

21 him.

22 Q. And finally, Zoran Zigic. You indicated you saw him once in

23 Omarska and three times -- or two times in Trnopolje camp. Can you give a

24 brief physical description of him at the time?

25 A. He had dark hair and dark eyes.

Page 4794

1 Q. And you indicated you knew him from before, from seeing him, you

2 said, in Prijedor.

3 A. Only by sight. I didn't know him well.

4 Q. And do you have any estimate for over how long of a period you had

5 seen him in Prijedor as a taxi driver?

6 A. Very rarely. Perhaps two or three times. I saw him only two or

7 three times. But as I say, I had no contact with him. But I remembered

8 his face when I saw him in Omarska.

9 Q. Now, have you seen any of those persons since leaving the Omarska

10 and Trnopolje camps in person, on TV, or otherwise in the media?

11 A. I have on television.

12 Q. And who did you see on television?

13 A. Mladen Radic, called Krkan.

14 Q. In what context did you see him on television?

15 A. I saw a film by a foreign television company which managed to film

16 the Omarska camp, but it wasn't while I was in the camp there. It was

17 after I had left Omarska.

18 Q. In that video, where did you see Mladen Radic? Where was he in

19 the camp, do you recall?

20 A. On the steps, wearing a blue police uniform, with a cap and a

21 rifle.

22 Q. That is in the glass area on the landing in the stairway?

23 A. That's right, yes.

24 Q. And that photo was of during the time when he was at the camp in

25 1992?

Page 4795

1 A. Yes. As far as I was able to see by this foreign television

2 company or perhaps CNN, I don't know, of the 5th of August it was

3 transmitted, I saw a foreign journalist in the programme, and the

4 restaurant. I was able to make out the restaurant and the pista, and

5 Zeljko Meakic on that same footage, in that same programme. Drazenko

6 Predojevic was one of the guards. He was standing in the restaurant with

7 a weapon.

8 Q. Witness J, what I'd like you to do now is to look around the

9 courtroom and determine whether or not you see any of those individuals

10 who I've referred to here in the courtroom. I'd like to tell you that if

11 you need to, you can stand up so that you may get a better look. Also, if

12 you need to, feel free to ask the Court to have any person within the

13 courtroom stand up so that you can get a better look, and then please

14 advise us whether you recognise any individuals.

15 A. I should like to get up, if I may.

16 In the back row over there, the first to my right -- and I'll

17 stand this way to better orient myself -- is Mladen Radic, called Krkan.

18 He is wearing a purple suit and white shirt.

19 Next to him is Miroslav Kvocka. Next to Miroslav Kvocka is

20 Milojica Kos, nicknamed Krle. In front of him, sitting down, is Zoran

21 Zigic. Next to him, on his right-hand side, is Drago Prcac.

22 MR. KEEGAN: Your Honour, I'd like the record to reflect a

23 positive identification.

24 JUDGE RODRIGUES: [Interpretation] Before we do that, I should like

25 to ask the accused to take their headsets off, to stand up, and to see if

Page 4796

1 the witness sees any difference. So I seek your cooperation.

2 Witness, would you look at these men once again and tell us if

3 they are indeed the people that you have just identified.

4 A. Yes. I am certain of that.

5 JUDGE RODRIGUES: [Interpretation] You may be seated. Thank you

6 for your cooperation.

7 Mr. Keegan, please continue, and I apologise for interrupting.

8 MR. KEEGAN: Thank you, Your Honour. No further questions.

9 JUDGE RODRIGUES: [Interpretation] Thank you, Mr. Keegan.

10 It is now 2.37. We cannot start the cross-examination today, but

11 I should like to ask the Defence counsel to prepare their questions, to

12 organise the cross-examination properly.

13 Witness, we're going to continue tomorrow with the

14 cross-examination, and it will be the Defence counsel putting questions to

15 you. Please have a rest, and we continue tomorrow morning at 9.30.

16 I shall now ask the usher to lower the blinds once again and

17 prepare the room for the witness's exit.

18 [The witness stands down]

19 JUDGE RODRIGUES: [Interpretation] Very well. Until tomorrow at

20 9.30. The hearing is adjourned.

21 --- Whereupon the hearing adjourned at 2.40 p.m.,

22 to be reconvened on Wednesday, the 6th day of

23 September, 2000 at 9.30 a.m.

24

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