1 Friday, 25 November 2005
2 [Open session]
3 [The accused entered court]
4 [The witness entered court]
5 --- Upon commencing at 2.18 p.m.
6 JUDGE PARKER: Good afternoon. If I could remind you of the
7 affirmation you made at the beginning of your evidence, it still
9 WITNESS: WITNESS P-016 [Resumed]
10 [Witness answered through interpreter
11 JUDGE PARKER: Mr. Borovic? Mrs. Tuma?
12 MS. TUMA: I'm sorry to interrupt but there is some information I
13 would like to bring up at the beginning of this session, please, and that
14 is concerning the witness. The witness unit has informed me that the
15 witness needs to be back in his -- in Belgrade on Monday but he is most
16 happy to come back, if so needed, later on but he has some business --
17 JUDGE PARKER: I would have thought, Mrs. Tuma, there is no
18 prospect of his evidence going beyond today. I think I can rely on
19 counsel getting through it all in a day. Including you.
20 MS. TUMA: No problem with me. It's more problem with the Defence
22 JUDGE PARKER: No problem with anybody, Mrs. Tuma. Never any
23 trouble with counsel.
24 MS. TUMA: Okay.
25 JUDGE PARKER: Yes, Mr. Borovic.
1 MR. BOROVIC: [Interpretation] Thank you.
2 Cross-examined by Mr. Borovic: [Continued]
3 MR. BOROVIC: [Interpretation] First of all, I will try to remain
4 in private session for a while and then we will be back to open session
5 for the remainder of my cross-examination. I have arranged my questions
6 in that way so that we wouldn't have to go in and out of private session
7 all the time.
8 JUDGE PARKER: [Previous translation continues] ...
9 [Private session]
11 Pages 2301-2313 redacted. Private session.
4 [Open session]
5 MR. BOROVIC: [Interpretation]
6 Q. How long were you in the (redacted)?
7 A. I was a (redacted) until or since 1991.
8 THE INTERPRETER: The interpreter is not sure which one the
9 witness said.
10 THE WITNESS: [Interpretation] But it was not something that was
11 important to me, the (redacted). My job was more important.
12 Q. Would you please be kind enough to tell us how long were you an
13 (redacted) and then how long was it when you -- since you left the
14 (redacted) and how many years did you spend as (redacted)?
15 A. Are you talking about (redacted) or how long was I in the
17 Q. How long were you (redacted)?
18 A. Well, 1991, if we calculate, I guess it's two years but, yeah,
19 this is something that can be proved very easily.
20 Q. And how long were you (redacted) altogether?
21 A. Including the accelerated service years I think it was some 20
23 Q. So if we look at all the information we have, it seems that after
24 (redacted), people who have spent 17 or more years
25 (redacted). Is it possible that
1 you were not really successful in your (redacted) and that you were
2 not (redacted)?
3 A. Well, I said that this was not of interest to me. What was of
4 more interest to me was to be promoted in this other area of work, in this
5 other branch.
6 Q. Well, were you an officer or were you this other thing? I don't
7 want to mention your profession because we are in open session now. What
8 was more important to?
9 A. Well, first of all, I was an intellectual.
10 Q. Thank you. Would you be kind enough to tell us briefly all the
11 fronts that you toured?
12 A. Yes. I can tell you all of them. And they are Knin, Drnis,
13 Zemunik, Western Slavonia, Okucani, Dragalic, Vukovar, Borovo Naselje.
14 Then Mostar, Nevesinje, Trebinje above Dubrovnik, then Sibenik, Eastern
15 Bosnia. I cannot remember them all, but I was at all of these places.
16 Q. Thank you. And can you now tell us, after how many years did you
17 decide to talk about what according to you actually happened in Vukovar?
18 How many years passed before you decided to do that?
19 A. Four years.
20 Q. Thank you. Were you really in Vukovar on the 18th and the 19th of
21 November 1991 or were you perhaps there in some other month?
22 A. I was there because there are people who saw me there.
23 Q. Thank you. When was the first time that you found out that the
24 persons who are accused here in this courtroom have been indicted before
25 The Hague Tribunal or by The Hague Tribunal? When was the first time you
1 found out about it?
2 A. Well, I said I don't remember dates. I don't remember numbers.
3 The only numbers I remember are my home phone number. I don't even know
4 the number of my mobile phone, so people laugh at me about that sometimes.
5 Q. Thank you. Do you know the number of your foreign currency
6 account by heart?
7 A. I never knew it and I will probably never remember that and,
8 however, I don't even have a foreign currency account. I only have a
9 dinar account.
10 Q. Well, you've already answered that question.
11 Since that time, did you often see the accused on television,
12 after the events in Vukovar?
13 A. No. I don't really watch television that much but I remember that
14 I saw Major Sljivancanin at the Topcider barracks on New Year's
15 celebration. (redacted)
16 I remember seeing him maybe in 1992 or 1993.
17 Q. (redacted), what profession were you in?
18 A. Well, I wasn't really choosing my work. (redacted)
19 That was among my jobs. Those were the sort of jobs that I did. I would
20 have to -- well, we would have to move into private session because then I
21 would be able to tell you.
22 Q. Thank you. There is no need to move into private session. There
23 is no need to abuse the Court. But you were actually doing some kind of
24 private work; is that correct?
25 A. Yes.
1 Q. Did you ask for the assistance of any NGO when you decided to move
2 into the private sector?
3 A. I never asked for anyone's help.
4 Q. Do you know Natasa Kandic?
5 A. I know her only from seeing her on television.
6 Q. Thank you. You said in your statement to the Prosecution and you
7 repeated that before the Trial Chamber that you arrived at the hospital at
8 the very moment when the evacuation of the Croatian soldiers had begun; is
9 that correct?
10 A. Yes, it is.
11 Q. And you said that this was in the early afternoon hours. Was this
12 around 1300 hours?
13 A. Well, the early afternoon hours. That is a little bit difficult
14 to specify but it was sometime between 13 and 1400 hours.
15 Q. Thank you. Well, if it was between 13 and 1400 hours and if we
16 add all the time period that you described here and you said that at 1600
17 hours you met up with your friend again, is that consistent with the
18 scenario, at least the time frame of the scenario that you described here?
19 A. That was no scenario. I visited very few places between the
20 hospital and the other places I went at 1600 hours. I moved in a limited
22 Q. All right. So movements of yours, when you went to the Danube,
23 that's several kilometres away, then you talked to your friends and then
24 you talked to the representatives of units that you had come across. All
25 of that took place within two hours?
1 A. No. You got some things confused. You confused the two days. I
2 went from the hospital to the park where I saw the corpses that I
3 described, and then I went back to the workers' hall and on that day that
4 were all of my movements.
5 Q. Thank you. You said that at the entrance you saw two members of
6 military police?
7 A. They were not standing at the entrance. They were standing behind
8 the first glass door.
9 Q. How did you know if they were behind the glass door through which
10 you didn't go, as you said to us yesterday? How did you then know that
11 they were military police members?
12 A. Mr. Borovic, one can see that. They were clearly visible.
13 Q. Thank you. Did you have an impression that the workers were
14 issuing orders to military policemen? You were there then, weren't you?
15 A. I wasn't interested in it then and I had no impression about it at
16 the time.
17 MR. BOROVIC: [Interpretation] The transcript does not reflect the
18 name Radic or do we need the witness to repeat it or can my word be
19 sufficient in order to correct the transcript?
20 JUDGE PARKER: That will be enough, Mr. Radic -- Mr. Borovic.
21 MR. BOROVIC: [Interpretation] Thank you.
22 Q. Was the observer from the ICRC issuing any orders to the soldiers
23 there based on what you saw?
24 A. No, Mr. Borovic. The observer just stood there as a statue
25 looking at the entrance of the hospital. He never moved.
1 Q. Thank you. These soldiers, were they armed or not?
2 A. The soldiers were armed.
3 Q. Thank you. At any point in time, did they go outside while were
4 you there or not?
5 A. They did not come outside. They only held the door open for the
6 soldiers who were carrying the wounded outside.
7 Q. Those who were carrying the wounded outside, were they also
8 military policemen?
9 A. It's hard to say. I was unable to see that. I just saw the
10 soldiers carrying wounded.
11 Q. What about the other two? You said the other two who were clearly
12 visible at the glass door. You were able to see that they were military
14 A. Well, Mr. Radic --
15 Q. I'm not Mr. Radic.
16 A. I apologise to you and to Mr. Radic, Mr. Borovic. Usually it is
17 the military policemen who are present in such situations. I know my work
18 enough in order to define that.
19 Q. So you can't claim with full certainty that those were indeed
20 military policemen, nor do you know to which unit they belonged?
21 A. As I have already said to you, I was not interested in that at the
23 Q. Sir, can you tell us what were you interested in at the time?
24 What were you looking for there?
25 A. Mr. Borovic, I was interested in the event. I was interested in
1 the wounded, in the prisoners, in the arm and in the bandages.
4 A. That was quite sufficient. Surely you don't think that I was
5 supposed to enter the hospital and question Dr. Bosanac.
6 Q. Thank you. But how on earth did you find out, did you learn, that
7 those were Croatian prisoners of war? And you ended there, you found
8 yourself there, just out of the blue? So how were you able to determine
9 that this was an evacuation of the prisoners?
10 A. Well, I deduced this logically.
11 Q. Thank you very much. How did you know that those were Croatian
13 A. Mr. Borovic, I assumed that.
14 Q. Thank you very much. When did you speak to Radic -- or, rather,
15 when you spoke to Radic, did you have an official attitude or just a
16 friendly attitude? Because allegedly you were acquaintances.
17 A. I don't know whether he recognised me, but I always have that type
18 of attitude.
19 Q. Was your attitude an official one or a friendly one?
20 A. I greeted him in the normal way.
21 Q. Thank you. It is clear that you do not wish to answer.
22 My next question.
23 MR. BOROVIC: [Interpretation] I would like to have document
24 0053-1257 shown on the screen, page 2 of that document, please.
25 Q. Can you see that on the screen? No, I apologise.
1 MR. BOROVIC: [Interpretation] Can this be removed from the screen
2 for a minute, please? Just briefly, thank you.
3 Q. Before you start pointing the things in the photograph, would
4 you please describe to us the Vukovar Hospital as it looked at the
6 A. I'm telling you, Mr. Borovic, that I approached it from the side
7 that to me looked like the in your part of the hospital. So there was a
8 path leading there.
9 Q. Excuse me, as you were approaching the hospital, did you see what
10 the hospital looked like?
11 A. I walked straight. I was in a new area, new environment. That
12 was the first time I was there. So I went to the place that had been
13 pointed out to me.
14 Q. Did you see how many storeys the building had or rather did it
15 have any storeys?
16 A. The new building had a ground floor and another floor or two.
17 Q. Do you suppose there or did you see this?
18 A. I saw this. Of course, I saw this. I knew that the building
19 looked new without --
20 Q. You mean it looked as a building that used to be new before the
22 A. No. I mean the building looked new, and I only looked at that
23 building. I wasn't interested in other buildings.
24 Q. All right.
25 MR. BOROVIC: [Interpretation] Can we now have the photograph on
1 the screen, please. Number 2, please. Thank you. That's the photograph.
2 Q. Would you now be so kind and tell us -- but first please take a
3 red marker. The usher will assist you. Thank you.
4 Can you please draw in the direction from which you approached the
6 A. Mr. Borovic, this is a peacetime photograph.
7 Q. My question is, is this what the hospital looked like in terms of
8 its size and physical appearance?
9 A. The part that I saw from one side looked like this.
10 Q. All right. If that is the case, would you then please slowly mark
11 the direction from which you approached the hospital.
12 A. I'm telling you that that was the first time I had ever visited
13 Vukovar. And if I were to see this site as it looked at the time, then
14 yes, I would be fully certain, and now I will have to do some guessing.
15 So please don't expect me to be fully accurate, because this photograph
16 shows the hospital in a different light, so to speak.
17 Q. All right. So from which street did you approach the hospital?
18 A. From the street leading to the workers' hall. That means that I
19 came from the direction of the MUP building. If I were able to see the
20 MUP building here in this photograph then I would be able to be much more
22 JUDGE PARKER: Mrs. Tuma?
23 MS. TUMA: Thank you, Your Honour. The witness said that this
24 picture has been taken in peacetime so for the Defence sake to inform the
25 witness when the photo has been taken then so he can make a correct
1 marking, so to say.
2 JUDGE PARKER: I think it's fair to say that we understand the
3 photograph was taken in 1957 after reconstruction of the hospital. 1997.
4 So that you are correct that it was a peacetime photograph but otherwise,
5 Mrs. Tuma, I think the witness is making his position quite clear.
6 MS. TUMA: Thank you.
7 JUDGE PARKER: Yes, Mr. Borovic.
8 MR. BOROVIC: [Interpretation] Thank you.
9 Q. In order not to confuse you, let me put my question in these
10 terms. You said that the size wise and the appearance wise, this is what
11 the hospital looked like at the time. So would you please now try to
12 describe from which direction you approached the hospital?
13 A. I'm doing my best. I'm trying as hard as I can, Mr. Borovic, but
14 there are trees here.
15 Q. Thank you. So you can't show that to us.
16 My second question is: Can you show to us where the MUP building
17 was in relation to the hospital?
18 A. The MUP building -- well, once again I have to tell you I don't
19 know where it begins and where it ends so if the MUP building was here --
20 Q. Don't use your fingers to show the direction in the air to us.
21 Please use the photograph.
22 A. You are asking the impossible of me, Mr. Borovic. I know where
23 things were or the buildings were when I was there but to show it now on
24 this photograph --
25 Q. Thank you. All right. So you are unable to show to us where in
1 relation to the hospital was the MUP building, in front of which you
2 parked, yes or no?
3 A. I can tell you that looking from here, it was to the left.
4 Q. What you're now pointing with your hands is absolutely of no
5 assistance to us.
6 Your Honours, you are right. I am interrupting the witness but I
7 need him to start marking it on the photograph, not pointing it in the
9 JUDGE PARKER: [Previous translation continues] ... Mr. Borovic.
10 Sit down, please, Mrs. Tuma. The witness has made clear that he
11 cannot orient himself on this photograph, that he needs to see the very
12 building you're now asking him to mark, the MUP building, before he can
13 decide from which direction he approached the hospital. He's indicated to
14 you the name of a street that he used but, beyond that, he can't tell us
15 more. So there is no point in trying to get him to mark the position of
16 the MUP hospital when he doesn't know it.
17 MR. BOROVIC: [Interpretation] Thank you, Your Honours. Could we
18 please show the witness photograph number 3?
19 Q. Do you see the picture now?
20 A. Yes.
21 Q. Can you show us on this photograph the street from which you
22 approached the hospital?
23 A. Just give me a bit of time, please. Let me rewind the tape in my
24 head, please. No. I can't recognise that area from which I approached
25 the hospital.
1 Q. All right. Thank you.
2 MR. BOROVIC: [Interpretation] In that case, I will have to delete
3 a large number of questions, since you can't recognise the area.
4 A. If I saw authentic photographs, and if I could see the photographs
5 showing the hospital from all sides, then, yes, I would be able to orient
7 Q. All right. Yesterday you said that you climbed some steps and got
8 to the glass doors; is that right?
9 A. Yes. I climbed the two steps which were not very high, but high
10 enough for me to see the hall in the hospital.
11 Q. But you said that you didn't enter the hospital and didn't know
12 who was there?
13 A. I saw Major Sljivancanin at the end of the corridor.
14 Q. Did you see any other officers except for the two we mentioned?
15 And did you recognise any of them there?
16 A. You mean in the hospital?
17 Q. I meant precisely what I asked, there at the spot.
18 A. No, I didn't see anybody else except for those whom I have
20 Q. All right. So we have two men there, Sljivancanin and Radic, and
21 nobody else; is that right?
22 A. Well, we have the monitor who was 30 metres away, as the crow
23 flies. We have two nurses who passed by next to me, Radic, and
25 Q. I didn't ask you about the nurses because they do not fall into
1 the category of soldiers or officers. That's why I didn't ask you about
3 You say that you parked by the MUP building. Did you see a sign
4 saying, "MUP, Vukovar"?
5 A. We were told by the soldiers we met there that.
6 Q. Can you please describe the MUP building?
7 A. I've already told you that that was an older building, a solid
8 one. I think it had a ground floor and two storeys. It was a long
9 building. It was quite bullet-ridden with broken windows. The cars that
10 were around it were also completely bullet-ridden.
11 Q. But it was in a solid shape except for being bullet-ridden?
12 A. Yes, that's how it impressed me at the time.
13 Q. Thank you. Can you please tell the Court and tell me, of course,
14 what was the distance between this building and the entrance outside which
15 you lingered?
16 A. If it's true what they told me at the time, that this was the MUP
17 building, then it wasn't too far from where I was standing. But in
18 situations like these, you don't think in terms of distances. It struck
19 me as being quite nearby, though.
20 Q. Could you please make an effort and try to assess the distance, in
21 terms of time and in terms of metres, perhaps?
22 A. I'm doing my best, really, but, once again, I must tell you that I
23 can speak about things that I'm not certain about or at least I can't be
24 very specific.
25 Q. Well, that's an answer, too. Thank you.
1 Near the workers' hall or the MUP building did you notice any
2 other important buildings nearby?
3 A. I noticed the bank that is were across the way from the workers'
4 hall. I assume they were banks because there were people's savings
5 account books strewn all over the street.
6 Q. I'm sorry for interrupting you. I asked whether you saw anything
7 near the hospital. So was this near the hospital?
8 A. No that was across the way from the workers' hall, near the Dunav
10 Q. What about near the hospital, only the MUP building? No other
11 buildings, nor were you told about any other important buildings being
12 near the hospital?
13 A. Well, Mr. Borovic, I asked what I wanted to know, things I wasn't
14 interested in were things that I didn't even ask about.
15 Q. Thank you. What about the condition of the other buildings around
16 the hospital? Is this perhaps something you noticed or not?
17 A. Well, in my job, you use a lot of help from different sources and
18 it's very difficult to say.
19 Q. So you don't have an answer?
20 A. Yes, I told you what the situation was that I was facing.
21 Q. What about those prisoners? At least you said they were prisoners
22 and now you no longer seem certain. You said they were rather
23 good-looking, nice and neat blue pyjamas with lovely stripes that were
25 A. Yes.
1 Q. So they were clean-shaven, their pyjamas nicely ironed?
2 A. Well, let's not push it too far. They were clean-shaven. That
3 much is true.
4 Q. Based on your information that you had brought along (redacted)
8 Q. Did you know that at the time, Vukovar had no electricity, no
9 running water?
10 A. I knew about some of those, but on account of the pace of my work,
11 I simply had no time to follow everything that was going on. I believe
12 you understand what I mean.
13 Q. Thank you. Those young men, where were they accommodated?
14 Perhaps in the ambulances, the military ambulances?
15 A. They were being carried towards the military ambulances belonging
16 to the JNA.
17 Q. Can you please describe one of these military ambulances? Would
18 that be some sort of a lorry, JNA lorry, used for medical purposes?
19 A. It looks a bit like lorries that they use for distributing bread.
20 They are olive-drab and they have a huge red cross on them.
21 Q. Well, if you will allow, why did it not cross your mind that
22 perhaps there were Serbs among those wounded? You seem to have been under
23 the impression that all of the wounded were Croats. So why was that?
24 A. You're probably not going to believe me, Mr. Borovic.
25 Q. Probably not.
1 A. But at this moment, and at any other time when there were victims
2 and casualties and wounded around, it just never occurred to me to think
3 that way.
4 Q. Thank you. So can you please give us zoom sort of final answer?
5 Why did you assert in your statement that those were Croatian soldiers and
6 prisoners on top of that? If this wasn't likely to occur to you then,
7 well, how come that it occurred to you in 1996?
8 A. I think that's a bit sarcastic on your part, Mr. Borovic. I was
9 there 15 minutes. You need to keep that in mind.
10 Q. Thank you. Can you please explain to the Chamber where those
11 medical military ambulances were? Where did they start and where did they
13 A. I can try to explain that. They were along that asphalt road,
14 roughly speaking, in that general direction, parked in a line. I'm not
15 sure how far the line extended because I'm not familiar with the layout of
16 the place.
17 Q. But I must insist. Where did this column of vehicles begin and
18 where did it end? You said it contained altogether about ten vehicles.
19 Would I be right in saying that?
20 A. Well, the specific figure may vary. I didn't see the beginning
21 but I did see the end.
22 Q. You say you didn't see the beginning. So where was the end, then,
23 if you could tell us?
24 A. I don't know, Mr. Borovic. I only saw the end.
25 Q. Thank you. Perhaps I have unduly interrupted you. You saw the
1 end. Where was the end of the column in relation to the hospital, the
2 tail end of the column? Do you or do you not know?
3 A. Of course I know, but you just wouldn't listen, would you? It was
4 at a distance of about 25 or 30 metres from where I was standing, in that
5 general direction. That's where the vehicles were parked.
6 Q. That direction, that general direction, can you be a bit more
7 specific? I have no idea what you mean.
8 A. I have a photograph of the environment in my mind now. Let's say
9 I'm here and let's say I approached the place from this side, and if
10 that's over there --
11 Q. May I interrupt you, please? In a bid to help the Chamber, too,
12 over there, over here, left and right, means nothing at all. Can you
13 please be more specific in terms of the physical realities of the place?
14 I'm sure you're capable enough of doing that for us because I think we are
15 right now on the wrong track.
16 A. Hue can you say that I'm on the wrong track? I know exactly what
17 I'm thinking about. I have this image in my mind. I came from this place
18 and I was headed for this other place and to the right of where I was
19 going is where the vehicles were parked.
20 Q. Thank you very much. I believe that's quite sufficient by way of
21 an answer.
22 Are you perhaps familiar with the fact that those wounded who were
23 evacuated from the hospital and driven off in those military ambulances,
24 that they were eventually taken to Sremska Mitrovica, do you know that?
25 A. No, I don't.
1 Q. You say you took the main street leading to the centre of town.
2 Do you know what the name is of that street?
3 A. No. I don't know its name but I know that it led all the way to
4 the workers' hall and the plateau that I spoke about, to the right of that
5 street, you could see the Dunav hotel.
7 (redacted), can we please now show Exhibit 59, and if we could please zoom
8 in on the central part where the hospital is?
9 THE INTERPRETER: Could the witness speak closer to the
10 microphone, please?
11 MR. BOROVIC: [Interpretation] What I can see on the screen is not
12 Exhibit 59. Can we please zoom in on the central part? Zoom in a little
13 more, please, if possible. Thank you.
14 Q. A question for the witness: How good are you at topography?
15 A. I took the subject a long, long time ago. There must be many
16 things I've forgotten.
17 Q. I'm asking how good are you at topography. I know you took the
18 subject as a soldier?
19 A. Yes, that's true. I did, but I was never very much into it.
20 Later on, I hardly had any opportunities to use it in practice.
21 Q. Have you ever used a topographic map in practice?
22 A. Very rarely, if ever.
23 Q. If rarely, what was the last time? What would you say?
24 A. The last time must have been back in 1976.
25 Q. Thank you very much. That should be quite sufficient for you to
1 be able to use this particular map, shouldn't it, or are you trying to
2 avoid answering my question?
3 A. Well, I'm not really positive about that. I was never very much
4 into topography.
5 JUDGE PARKER: [Previous translation continues] ... and I'd be
6 pleased if you would put one and move along. Thank you.
7 MR. BOROVIC: [Interpretation] I'll try.
8 Q. Can you indicate the workers' hall on this map?
9 A. I really -- well --
10 Q. Thank you. Can you try to indicate location of the Dunav hotel?
11 A. You should have used a different kind of map, the one used by
12 tourists and people who go sight-seeing.
13 Q. Well, but you're not going sight-seeing are you? My next question
14 is where is the hospital?
15 A. I said I was an intellectual, not a soldier.
16 Q. Well, fair enough. Okay. A question for you as an intellectual,
17 then. Where is the MUP building in this map?
18 A. That's got nothing to do with what I've just told you. What I'm
19 telling you is that you should show me a different map. This was the
20 first time I was in the area and you know what the extent of the
21 destruction was at the time, don't you?
22 Q. If I show you there arrow which says HOSP, standing for hospital,
23 and then there is this red dot, then it appears to me that now, based on
24 the red dot, you could show me the location of the MUP building, couldn't
1 JUDGE PARKER: Mr. Borovic, it doesn't matter how it appears to
2 you. If you want to ask the question whether from this map, which is to
3 my mind particularly unhelpful for the purpose you are trying to use it,
4 if you want to ask him can he identify the MUP building, ask him? I'm
5 getting very impatient at your constant use of your opinion, your
6 interjections and your comments about the performance of the witness.
7 That's not your role at this point. It's delaying and it's seeking to
8 gain an upper hand over the witness.
9 If you put a question and he can't answer it, we can appreciate
10 that he can't answer it and will form our judgement about his performance.
11 We don't need your comment to help us.
12 If you would now put any questions you want about the location of
13 buildings, but I fancy the answer you will get is no to each one of them.
14 He can't tell you. I think that's fairly clear from his evidence so far.
15 If you want to keep at it, go at it.
16 MR. BOROVIC: [Interpretation] Thank you, Your Honours. It is with
17 pleasure that I will accept your criticism. As usual, you are entirely
18 right. However, I felt that I was getting a lot of answers that were
19 quite unclear and not too helpful for the purposes of this Court, so I
20 allowed myself a little more liberty than usual. I apologise if I have
21 exaggerated in that.
22 Q. Could you please at least trace the route that he used on this
23 map, the route that he took to the hospital?
24 A. If I try to use your map, Mr. Borovic, that would be an impossible
1 Q. My next question: Does the witness know a person named Jovan
3 A. From television but not personally.
4 Q. On two occasions yesterday, you said that you had seen a
5 neuropsychiatrist, something to do with your testimony. Would you share
6 with us the reason why you went to see a specialist?
7 A. Could you please repeat the question for me?
8 Q. In answer to one of Mr. Vasic's questions yesterday, you referred
9 to a neuropsychiatrist that you had seen. You said that this
10 neuropsychiatrist gave you advice regarding the events that you had
11 experienced, and what such experiences can mean for someone who is
12 subjected to that sort of experience repeatedly. My question is: Where
13 did you see this neuropsychiatrist, one or several, and when, the ones you
14 mentioned yesterday?
15 A. There was only one specialist. (redacted)
16 Only one session. I was having nightmares and I had trouble sleeping, all
17 of which was a consequence of prolonged sojourns at the front.
18 Q. Does that mean that you were receiving medication that was
19 prescribed by there neuropsychiatrist?
20 A. No. I never was. I never used any medicine whatsoever. The
21 strongest medicine I ever used were painkillers for my headache.
22 Q. Which year was this when you went to consult a specialist and to
23 receive treatment?
24 A. I did not receive treatment, Mr. Borovic. I went to see a doctor.
25 That's all. I'm trying to be as specific as possible about this. I'm
1 trying to treat you in a fair manner. I'm really trying, but I can't say
2 the same about you, can I?
3 Q. Before we continue, we don't have you stating that you were
4 prescribed medicine but that you refused to take it, just for the sake of
6 MS. TUMA: I'm sorry, Your Honour, but I would like the Defence
7 counsel to reduce from comments about the witness such as "I'm trying to
8 treat you in a fair manner, I'm really trying." Okay. That is --
9 JUDGE PARKER: You have just --
10 MR. BOROVIC: [Interpretation] My apologies. I wasn't the one that
11 was said that. I think that was something stated by the witness, not me.
12 I apologise. As for this comment by my learned friend, this is something
13 the witness said. I wasn't the one who said it. Let's try to be fair
14 about this.
15 Q. So, Witness, which year was it that you went to see this
16 specialist, a neuropsychiatrist because you had problems with nightmares?
17 A. I had difficulty with my sleeping pattern. That was the problem.
18 That's what I meant. Can I just pause for a minute there, Your Honours,
19 please, in order to be able to better remember what exactly what happened?
20 Oh, yes. It was sometime in May 1992.
21 Q. Thank you. When were you prescribed this therapy that you refused
22 to apply? You said that these were prescribed to you by a doctor and can
23 you tell us what the therapy consisted of specifically?
24 A. I have a copy with me of the medicines. It was Bensedin and some
25 kind of mild tranquiliser; however, I never used that.
1 Q. Thank you. Did you see this specialist only once or did you go
2 back several times and do you have medical card in relation to this type
3 of therapy?
4 A. I went back once. I think, actually, once I went back for a
5 checkup and then if I can remember other than that one time and the
6 checkup, I didn't go back any more.
7 Q. And when was the first time that you talked to the psychiatrist in
9 A. Well, it was the first time in 1992.
10 Q. When in 1992?
11 A. I don't remember the exact date.
12 Q. Was that the period when you were going to the front or was that
13 already all over by then?
14 A. I really don't remember. I would have to look at my records or
15 the documents.
16 Q. Thank you. And now, can you freely provide a statement or are you
17 suffering from any problems?
18 A. No. I'm not suffering from any problems. Fortunately, it all
19 concluded very well, and before I came here to The Hague to testify, I
20 went for a medical checkup. The company that I worked for sent me for
21 this checkup and the doctors were quite satisfied with my state of health
22 in relation to my age. So I was at this medical checkup a few days ago.
23 Q. Well you say that you have your medical papers about this
24 treatment with you. If it's not too indiscreet would you be willing to
25 show them to me?
1 A. Well, no, I don't have them here with me, I have them at home.
2 Q. Well, all right. That's sufficient. Thank you very much.
3 You said that you were initiating proceedings in Strasbourg
4 because of the events in the JNA. If offered, (redacted)
5 (redacted)? At least that's what it says in the complaint.
6 A. I actually talked to the lawyer who is preparing these documents
7 only on the telephone. This is something that is also new in our
8 practice. I don't know the particulars, but we will see what we will be
9 asking for once the lawyer looks at the case. I'm not sure yet. It's a
10 little bit late to (redacted). I think that probably we will
11 be asking for some kind of financial compensation but I don't know what
12 will happen.
13 Q. If I understood you properly in your indictment at the Strasbourg
14 court you're going to ask for financial damages for what had happened to
16 A. Well, somebody has to pay because of what has been done to me, and
17 that will probably be the state that will pay.
18 Q. Thank you very much.
19 MR. BOROVIC: [Interpretation] I think that at this point I'm going
20 to finish my cross-examination of this witness, Your Honours. Thank you
21 very much?
22 JUDGE PARKER: Thank you very much, Mr. Borovic.
23 This is probably a practical time then for a break so that you
24 could have a clean start. There have been redactions so it will be ten
25 past four.
1 --- Recess taken at 3.40 p.m.
2 --- On resuming at 4.14 p.m.
3 JUDGE PARKER: Mr. Lukic -- oh, Mr. Bulatovic.
4 MR. BULATOVIC: [Interpretation] Thank you, Your Honour. We've
5 made the switch because we are going to be using the technology so we have
6 to be in this Bench, at this Bench.
7 JUDGE PARKER: You've been promoted to the front bench.
8 Cross-examined by Mr. Bulatovic:
9 Q. I'm attorney Bulatovic, the co-counsel for Major Sljivancanin, and
10 I'm going to be asking you questions. I would like you to pay attention
11 to the warnings made by my colleagues before, to avoid any
12 misunderstandings and to make it easier for the interpreters to do their
13 job properly, for your sake and for our sake, too.
14 MR. BULATOVIC: [Interpretation] Your Honours, I will try to go
15 into private session as rarely as possible. I believe that that's --
16 enough time has been spent in private session already and I will try to
17 direct my questions in such a way that this will not jeopardise the
18 identity of the witness.
19 Q. The first question is, if the witness could explain to me
20 (redacted)? What conditions does a person
21 need to meet? Are there any conditions, and if there are, what are they,
22 in order to become (redacted)? And if the witness
23 could please explain what kind of an (redacted)
25 A. (redacted) is someone who responded to an
1 advertisement (redacted). They have to pass medical checks and some
2 other tests and, if a person passes all those tests, then they will be
3 admitted. It's an institution of higher learning. It takes four years to
4 complete this education. Perhaps after two years the students can decide
5 which branches they will specialise in, and they choose that according to
6 their affinities. That's all I can say.
7 Q. Could you please tell us when does the school year begin at the
9 A. As far as I can remember, the first year begins sometime in --
10 well, on the 15th of September, but it doesn't necessarily have to be that
12 Q. Once you go through all of these requirements that are necessary
13 in order to be admitted to the (redacted) what happens and how long
14 does it take to go through this process?
15 A. Well, (redacted)
17 Q. Is there a list of those who are admitted after that to the
18 (redacted) and, if so, after how long is this (redacted)
19 A. Yes. The (redacted) perhaps 20 days or so, after
20 this process. It depends when a person was admitted to the (redacted)
22 Q. In order to apply for a place at the (redacted), as you
23 explain it, what education has to be completed before that?
24 A. A person needs to complete high school, mostly people would
25 complete the gymnasium. There were also people who graduated from some
1 technical high schools, while those who graduated at the school for
2 economics would go to the quartermaster school.
3 Q. Is there a school for (redacted) which would have
4 the same rank as a high school?
5 A. Yes. There (redacted) There are also (redacted)
6 (redacted) and, once a person completes a (redacted), they can be
7 recruited or they can be educated as (redacted) of certain
8 specific (redacted).
9 Q. Did you complete any of these schools for (redacted)
10 (redacted) before you were admitted?
11 A. No. I graduated in the classic gymnasium.
12 Q. Were there any students of the (redacted) who had previously
13 completed the school for (redacted) and then came to the
15 A. I think that in my generation, there were no such cases.
16 Q. Do you know the reason for that?
17 A. Well, no, I don't. I really am not able to give you any kind of
18 answer about that.
19 Q. During the schooling, which took a certain amount of time, did you
20 want to find out why there were no such persons, if there were no such
21 persons in your class?
22 A. No. I personally wasn't interested in finding out the reason why.
23 Q. You talked about the academy building, nice weather, windows,
24 reception area, telephone booth and so on. I'm interested to know how far
25 the school building, the academy building is from the reception area?
1 A. Well, it depends where you are looking at it from.
2 Q. If we are looking at it from the reception area?
3 A. From the reception area to the first windows, it's a distance of
4 about perhaps 100 metres as the crow flies.
5 Q. Are you familiar with the Bajnica camp museum?
6 A. Of course.
7 Q. Is it somewhere in the vicinity?
8 A. Yes. It's part of the academy and the school for land forces
10 Q. In relation to the reception area where is it located?
11 A. In location -- in relation to the reception area, it's below the
12 building which is actually part of the school.
13 Q. And this telephone booth, where is it in relation to the reception
15 A. Well, it depends. If you go from the exit or from the entrance.
16 Q. [Microphone not activated]
17 THE INTERPRETER: Microphone, please, for the counsel.
18 MR. BULATOVIC: [Interpretation]
19 Q. Excuse me, we are not talking about the entrance and the exit.
20 What I would like to know is that is it outside of the military academy
21 compound, outside of those buildings, the academy, the dorm, and so on, or
22 is it in the academy compound?
23 A. Well, this is a more precise question. It's within the compound,
24 on the left side from the duty officer's room.
25 Q. Am I to understand that this was in an enclosed area?
1 A. No. It wasn't in an enclosed area. It was out in the open.
2 Q. Can you please explain how was it when we are talking about it
3 being as part of the duty officer's room?
4 A. Well, the telephone booth is on the corner of that building.
5 Q. Is that the telephone booth -- I mean, does the telephone -- is
6 the telephone installed within a booth or not?
7 A. It's that old system where you insert coins. It's a large
8 telephone booth.
9 Q. I'm not talking about how you would use it in order -- how -- what
10 you would do in order to be able to use it. I'm just asking whether it's
11 part of a -- within a building, whether it's under some kind of roof or
12 under an awning or outside.
13 A. It was under an awning.
14 Q. You say that in your work, (redacted)
16 (redacted). Can
17 you please tell me what (redacted)
18 and, as part of your work that you undertook certain steps?
19 A. (redacted)
24 Q. Let me ask you this: Did you ever hear of the command staff
25 school for tactics?
1 A. Certainly, I did. I even know where it is located.
2 Q. I don't doubt that you as an (redacted) have to know about its
3 location but what I'm -- would like to you do is to describe that school
4 for us.
5 A. These schools, which are part of (redacted)
8 Q. All right. Can you tell us how come you only (redacted) about these
9 (redacted) when, as you told us yourself, you were an
10 expert in your work, a very competent professional who received a lot of
11 praise was commended many times, served in a (redacted), had a (redacted),
12 so can you explain to us, then, why is it that you never (redacted) about
13 the (redacted), then?
14 A. It is quite simple to explain that. The education at that level
15 is a regulated procedure, especially the graduation procedure. There is a
16 certain protocol that needs to be followed.
17 Q. Sir, I asked you for a specific answer and you gave it to me.
18 Please do not interrupt me while I'm speaking. And I'm saying this for
19 your sake, not for my sake.
20 You gave us an explanation about why, within your work, you did
21 not cover the (redacted) for tactics. You said that there was a
22 certain protocol involved in graduation ceremonies and so on. I'm
23 interested in this: In your work, did you learn about what kind of a
24 school it was, what officers were eligible to attend it and what
25 requirements they had to meet in order to be able to attend this school,
1 to enroll in it?
2 A. If this is not something that one is interested in, then one
3 doesn't need to know about that.
4 Q. Please, let us not waste our valuable time. All I'm asking you
5 is: Do you know or do you not know? If you do, then explain. If you
6 don't know, then that's fine. And then I will ask you how come you don't
7 know, you, a person who held a high office in a very reputable centre
8 involved in these kinds of matters.
9 A. Of course I know this, Mr. Bulatovic. In 90 per cent of the
10 cases, this school was attended by professionals, officers, people who had
11 previously command posts and were given the highest possible assessment,
12 and were expected to have a prosperous career following that. So, yes, I
13 know who attended that type of school.
14 Q. Did you yourself ever apply to enroll into that school?
15 A. No. I was absolutely not interested in that.
16 Q. Do you know what rank applicants to that school had to have in
17 order to enroll in it, the lowest rank?
18 A. As far as I know, and as far as I can remember, major or
19 lieutenant colonel. I think a major could enroll in that school and that
20 there were also many lieutenant colonels there.
21 Q. Could somebody enroll in that school with a rank of captain?
22 A. During the period of time that I'm familiar with, that wasn't
24 MR. BULATOVIC: [Interpretation] Your Honours, can we briefly go
25 into private session, please?
1 JUDGE PARKER: Private.
2 [Private session]
4 [Open session]
5 THE REGISTRAR: We are in open session, Your Honour.
6 MR. BULATOVIC: [Interpretation]
7 Q. Yesterday, and today as well, you spoke about your citizenship.
8 You said that you hold the citizenship of Serbia and Montenegro; is that
10 A. Yes.
11 Q. I will ask you now when did you acquire that citizenship and on
12 what basis?
13 A. That was in 1997.
14 Q. On what basis?
15 A. On the basis of the time spent in the territory of Serbia and
17 Q. Yesterday my colleagues asked you something about the
18 reorganisation of the Yugoslav People's Army, namely when it was
19 transformed into the Yugoslav army. There was a rule then that nobody
20 could be an officer of the Yugoslav army unless they were citizens of
21 Serbia and Montenegro.
22 A. That's not true.
23 Q. All right. What I just told you about, was that perhaps one of
24 the reasons that (redacted)?
25 A. That's not true.
1 Q. Do you know how the officers of the Yugoslav People's Army were
2 assigned to different duties, those who did not have the citizenship of
3 Serbia or that of Serbia and Montenegro, and how that was done after the
4 JNA ceased to exist and the Yugoslav army was founded?
5 A. I only know about the cases that are similar to mine, those who
6 had the same fate as I did, namely all of these people left the JNA.
7 Q. When you gave evidence, you mentioned a man who hailed from
8 Karlovac, whose name was Zdenko Urisk. You said that he was a
9 warehouseman. Would you please explain to me and everybody else what type
10 of contacts you had with him, where he worked as a warehouseman, in what
12 A. That was a chance meeting in front of the military schools'
13 centre. We just greeted each other. He was a Lieutenant Colonel, a very
14 capable officer. I know what posts he held earlier, because we were of
15 the same age. He asked me about my work, and I told him, and he said that
16 he was not -- he didn't have a proper job but, rather, was assigning beds
17 and blankets and so on to the refugees and so on.
18 Q. That was the military schools centre. Where did it exist? Within
19 what type of institution?
20 A. It was a special, independent institution which had within it this
21 staff command school for tactics and some other high military schools.
22 There was also the national defence school and a political school there.
23 Q. All right. Did this centre exist within the General Staff?
24 A. As far as I know, they were a separate, independent institution,
25 but most likely, just like everybody else, they were under the command of
1 the General Staff.
2 Q. If I were to tell you that this individual that you mentioned,
3 Zdenko Urisk, in 1996, worked in the military schools centre, would you
4 agree with me?
5 A. Not without verifying certain things. I would have to talk to the
7 Q. When you talked to him, and when he told you that he worked as a
8 warehouseman, when did this conversation take place?
9 A. This conversation took place -- all I could tell you was that it
10 was during the time when the families of the officers started arriving and
11 they were housed in the dormitories of officers who were students of those
12 schools. I know that it was that period of time but I couldn't be more
14 Q. Can you remember what year it was?
15 A. No, not really, Mr. Bulatovic. All I can do is speculate and I
16 don't like to do that.
17 Q. Was that before your service was terminated? Let us see if we can
18 find a reference point. Was that while you still worked or after you had
19 stopped working or several years after that?
20 A. I think this was after I had stopped working. Definitely after,
21 because I remember saying to him how it had all transpired with me.
22 Q. All right. I will now tell you that based on the information that
23 I saw while preparing for this, Zdenko Urisk worked in the main library of
24 the military schools as one of deputy heads of the library. He was a
25 major and he was assigned to a post corresponding to his rank. In 1998,
1 when reorganisation of military educational schools was conducted, he was
2 promoted to the post of a scholar, a researcher, and that that was
3 within -- and that this was within this institution. Would you say that
4 this isn't true, what I just told you?
5 A. Well, I could certainly trust you blindly, but I'm telling you
6 that I did meet Zdenko and that, at the time, this is the job that he had.
7 I don't know what happened to him afterwards.
8 Q. Will you please tell me now how you came to meet him and to hold
9 this conversation with him, that type of conversation?
10 A. Would you please clarify your question? Could you be more
12 Q. I will try to, even though you as an educated man, simply refuse
13 to understand certain things.
14 So this is what I'm saying. You're meeting a man whom you
15 basically don't know. You're meeting him for the first time and all of a
16 sudden you start talking about to him about some very private matters,
17 from your private life. I want to know is how could you trust somebody
18 whom you knew so very briefly at the time?
19 A. Mr. Bulatovic, you have to be specific. Which man do you have in
20 mind? You're saying you were talking to a man. Which man? And I'll give
21 you an answer.
22 Q. So far, I have mentioned only one man with whom you had talked.
23 His name is Zdenko Urisk. I hope you didn't forget it in the meantime.
24 A. Mr. Bulatovic, you have to understand that this is the third day
25 that I'm working under pressure, psychological pressure, and it is quite
1 natural for my concentration to drop. (redacted)
4 Q. In that case, we misunderstood each other. That is possible. So
5 after this conversation you never saw him again?
6 A. I never saw him again.
7 MR. BULATOVIC: [Interpretation] Your Honours, can we go into
8 private session, please?
9 JUDGE PARKER: Private.
10 [Private session]
11 Pages 2351-2360 redacted. Private session.
23 [Open session]
24 THE REGISTRAR: We are back in open session, Your Honour.
25 MR. BULATOVIC: [Interpretation]
1 Q. To go back now to the main events, to the events of Vukovar, there
2 was quite a lot of vagueness and misunderstanding in your answers so I
3 wanted to maybe avoid that, go into that.
4 In your statement that you gave to the Prosecution, it says as
5 follows: I'm not going to give it to you to read so that we can save
6 sometime. I'm going to read it to you and, if you have any doubts about
7 whether it really says that or not, then, of course, I'm going to give you
8 the document for you to look at. I'm reading from the B/C/S version. "I
9 arrived at Vukovar in the morning, on the 18th of November 1991, a day
10 when -- that was the day the fighting stopped between the JNA and the
11 Croatian army. That is where I stayed until the 20th of November 1991."
12 Today in response to a question by my learned friend Mr. Borovic
13 you talked about something else. You said something else. You said that
14 on the 20th you were in Sombor. That is why I would like to ask you to
15 explain to me, and we'll go in order, your movements first of all, when
16 you left Belgrade to get to Sid on the 18th or the 17th whenever you set
17 out on the trip, when you were in Sid, to give me the time, how did you
18 get to Vukovar from Sid and how long did the trip take. On the 18th, how
19 long did you stay in Vukovar, and then we can end with the 19th, with your
20 departure from the -- from Vukovar. Then we'll move to the 19th and so on
21 because I would like to clarify somethings. There are many things that
22 are not quite clear in these movements of yours so. I don't want anybody
23 to misunderstand my intentions. They are quite clear.
24 A. We left Belgrade on the 18th, in the early morning. We arrived at
25 Sid at around 11.00. We stayed there for a short while, perhaps half an
1 hour or so. And then we continued our trip to Vukovar.
2 Q. Can you explain -- can you remember perhaps which way you took?
3 A. This was my first time in that area, so I cannot give you a
4 precise answer, but it was a regular road, route, with checkpoints and the
5 driver had no problems. I was sitting next to the driver.
6 Q. If I understood you properly, the driver was a photo journalist
7 who worked for some French news agency. Don't worry, I'm not going to
8 mention the name. There are plenty of French such agencies.
9 A. Yes, that is correct. It was his vehicle.
10 Q. And what was the make of the vehicle?
11 A. I think that it was a Yugo car.
12 Q. What were the licence plates on the car?
13 A. Well, I really don't know. If I knew I would be a genius.
14 Q. You were person who was supposed to help these two people get to
15 Vukovar as quickly as possible. Did you take with you any kind of
16 documents? You were informed about the existence of checkpoints and that
17 it wasn't possible just for anybody to pass through them.
18 A. Of course. They received passes at the press centre. I had more
19 than that. As far as documents are concerned, so there were no problems.
20 Q. These passes at the press centre, did you have to fill in a form
21 to receive such a pass or they were just being distributed, issued to
22 whoever turned up?
23 A. I don't know how the head of the (redacted) worked but we
24 received the passes and they looked okay.
25 Q. According to your information and according to what you saw
1 sitting next to the driver, was the driver a person who came to that area
2 for the first time or was he someone who had been there before?
3 A. It was the first time in that area for all of us.
4 Q. You said that you came to Sid at about 11.00. You stayed there
5 briefly. How long?
6 A. About half an hour, enough to have some coffee and to complete the
8 Q. And when did you get to your destination?
9 A. In the early afternoon.
10 Q. Could you be more specific about the time?
11 A. Well, I will try. Perhaps it was sometime around 2 p.m., early
12 afternoon hours.
13 Q. Does that mean that if you came to Sid at 11, stayed there for
14 half an hour, then left Sid at around 11.30, and then you arrived at
15 Vukovar at around 2 p.m.? Is that correct?
16 A. I cannot give you a specific answer, but we did get there.
17 Q. Very well. You answered some questions by my learned friend
18 Mr. Borovic about reaching the Vukovar Hospital. You said that this
19 entrance where you saw them bringing out the wounded and that was also
20 where you saw the officers whom you mentioned, there were stairs, there
21 was a wide asphalt road, if I understood you properly, there were a few
22 steps. And you went up the stairs, looked inside, and you saw Major
23 Sljivancanin. Did I understand you correctly?
24 A. Yes, you did.
25 Q. The place where you climbed those steps, how many more steps were
1 there in front of you in order to reach a level area? Can you perhaps
2 tell us?
3 A. Well, it wasn't a very long staircase, perhaps there were two or
4 three steps more, but that was about it.
5 Q. Does that mean that when you climbed the stairs, you came to a
6 glass door?
7 A. Yes, that's correct.
8 Q. Was this door open?
9 A. No. The door was closed. It was probably an automatic door.
10 Q. How long did you stay there?
11 A. I looked inside, noticed what I saw, then I came back. I went
13 Q. And tell me this. If I understood you properly, and in order to
14 avoid any misunderstanding, through the door you saw Major Sljivancanin
15 standing further along the corridor. How far -- how long was this
16 corridor in relation to the place where you were standing?
17 A. Well, it seemed to me quite a large space but if you would like me
18 to take a guess, I think from me to the place where Major Sljivancanin and
19 those soldiers were standing, it was some 20 metres.
20 Q. Very well. And that same entrance where you were standing, as far
21 as I understood, was the same entrance that they were bringing out the
22 wounded from?
23 A. Yes.
24 Q. And all of this was sometime in the early afternoon, around
25 2 p.m.?
1 A. Yes, approximately.
2 Q. And now, this other encounter you had with Mr. Sljivancanin, which
3 you described, this was when you were near the workers' hall, the Radnicki
4 dom. I'm interested exactly where you were standing? Were you near the
5 workers' hall? Were you near the hospital when you saw Veselin
6 Sljivancanin and two escorts passing?
7 A. I was in front of the statue that you can see on the photograph
8 that we looked at.
9 Q. That was the photograph that you made on the 18th; is that
11 A. Yes.
12 Q. Could you please tell me the entrance where we were standing and
13 the statue or the sculpture, how far apart were they?
14 A. Well, I cannot give you a specific answer because I was working in
15 that time. I was working, I was using the devices that I had available.
16 So I wasn't really noticing the distances, the space.
17 Q. Could you please wait for a second? Something here doesn't quite
18 match up. You were leaving, you were going, you met two young girls, one
19 with black hair, one with brown hair, they were wearing coats, you spoke
20 with them, after that you went towards the workers' hall?
21 A. No, no. First I went to the park where there were the bodies of
22 persons who died in the hospital, and they were covered.
23 Q. Very well. And how long did you stay there?
24 A. This was interesting and I stayed there for about half an hour.
25 Q. And then after that, you went towards the workers' hall?
1 A. No. Then I looked at the civilians. There was a young mother
2 with a child and also I spent some time there.
3 Q. In relation to this first encounter -- well, let us clarify so
4 that we don't proceed like this and waste time. In relation to the first
5 encounter, when you saw Veselin Sljivancanin in that corridor, when he was
6 standing some 20 metres away from you, and this other encounter, how much
7 time passed between these two encounters, half an hour, an hour, an hour
8 and a half?
9 A. I think that if this was three, something like that, I think
10 perhaps it was an hour and 45 minutes.
11 Q. After that, you left and then you took this photograph with these
12 three people, which you then gave to Tribunal representatives; is that
14 A. Yes, it is.
15 Q. Exactly where was this photograph taken? You did talk about it
16 but I'm asking this because I have a reason for it and I will tell you
17 what the reason is.
18 A. The photograph was taken on the pavement behind the sculpture.
19 The plateau is -- leads in the direction of the Dunav hotel.
20 Q. Is the workers' hall nearby?
21 A. Yes. I was told that the workers' hall was there on the corner.
22 Q. If I am not mistaken, when you were interviewed, you said that you
23 found the workers' hall and that you recognised it?
24 A. It was the first time I saw it, and I recognised the
25 characteristic line of the building, and then later I checked to make sure
1 that that was it.
2 Q. So the photograph was not taken near or at the workers' hall?
3 A. The workers' hall is nearby, in the key it states that it's the
4 plateau in front of the Dunav hotel.
5 Q. Which -- which key? Which caption are you talking about?
6 A. The caption on the back of the photograph, the index.
7 Q. On the back of the photograph, it says, "Across from the Dunav
8 hotel, across the road." So I want to see what road it is that we are
9 talking about.
10 A. I think that I was clear. I wanted to pinpoint that from the
11 place where I was standing, it was across from the Dunav hotel. I think
12 that the sentence is clear.
13 Q. The interview with the Tribunal representatives, on this topic,
14 contains the following, (redacted)
16 that it was a sculpture there, and that we can see it on the photograph
17 and so on.
18 A. Please, Mr. Bulatovic, this is a very small area. It's a small
19 area. I had to relate to something. It's much closer, about 50 metres
20 away, the workers' hall while the Dunav hotel is a bit further off, some
21 200 to 300 metres off. So you would always relate to the building that
22 was closer.
23 Q. Well, this is what I wanted to ask you about. From this point
24 where you were standing, how far from that point is the workers' hall and
25 how far from that point is the Danube hotel in let's clarify that.
1 A. Well in my assessment but I wasn't really dealing with the
2 distances, the workers' hall was quite close, within 100 metres, while
3 erstwhile the Danube hotel, the Dunav hotel, was furthers away. In my
4 estimate it was some 3 to 400 metres away. It was quite a large plateau.
5 Q. Thank you very much. Let's come back to your arrival at the
6 hospital. When you reached the hospital and that entrance that you
7 described, as you were moving towards the hospital, did you pass by any
8 part of the hospital or did you reach the entrance of the hospital
9 immediately from the road?
10 A. From that road I came directly to the hospital entrance.
11 Q. Did you notice, as you were approaching the hospital entrance,
12 that there was any kind of a sign pointing or indicating that this was a
14 A. I didn't pay attention to such details.
15 Q. In front of the entrance, or above the entrance, did you see a Red
16 Cross flag?
17 A. I saw no such flag.
18 Q. Did you see any buildings across from that entrance, which looked
19 like health services buildings? Could you conclude that based on
21 A. No. Everything that I had within my view was that hospital.
22 Q. All right. Let us look at some other issues.
23 You said that you saw Mr. Sljivancanin for the first time -- I
24 don't mean Vukovar now. I just mean generally, in life. You saw him for
25 the first time when he was a student of the military academy. Next time
1 you saw him was in Vukovar. In between, between 1972, 1973 and 1991-1992,
2 did you ever see him, talk to him, follow his progress, his work, or
3 anything similar?
4 A. Well, naturally, during that long period of time, I saw
5 Mr. Sljivancanin many times. Whether we had ever talked, I don't remember
7 Q. Can you give us examples of places where you met him up until
9 A. I used to see him within the Marshal Tito barracks, which was
10 later renamed the Topcider barracks. I used to see him during various
11 military exercises, perhaps on some other occasions, but those were
12 accidental meetings.
13 Q. You mentioned military exercises, manoeuvres, just a bit ago?
14 A. Yes.
15 Q. You mentioned a military exercise called Pestar in which the
16 Guards Brigade participated according to your information?
17 A. Correct.
18 Q. Which year was that drill, that exercise held, the one called
20 A. I can give you an approximate time-frame, between 1986 and 1989.
21 I couldn't be more specific than that. I know it was autumn, late autumn.
22 Q. Do you know that the Guards Brigade took part -- do you know
23 whether the Guards Brigade took part in any other drill or exercise?
24 A. I moved into another area of work, and I didn't follow these
1 Q. As I understood it, you followed the developments in Territorial
2 Defence and civilian protection. That's what you said.
3 A. I did, but in a different type of a session.
4 Q. Members of Territorial Defence and civilian protection, did they
5 participate in military drills?
6 A. That's a very clear issue.
7 Q. Within your area of work, within this field mentioned in the
8 certificate, society and defence, did you write any reports about the
9 participation of Territorial Defence and civilian defence units in that
10 drill? In other words, do you know whether in this military training --
11 military drill called Pestar which was held between 1986 and 1989, these
12 units took part, the ones which you followed?
13 A. I'm not aware of that, because what I was interested in were
14 assault units and developments, and this was the topic that I followed.
15 And the drill, this military drill, was a huge one.
16 Q. All right. We don't have to go into details.
17 We covered the events of your stay in Vukovar up until the 1600
18 hours on the 18th of November. Please tell me what happened afterwards.
19 Did you go back to Sid?
20 A. No. I met up with my colleagues. We went to the end of the city,
21 to follow the evacuation of civilians.
22 Q. Who took you there?
23 A. Just like before, driver, co-driver, escort, and we asked about
24 that and we got there.
25 Q. How long did you stay there?
1 A. We spent -- we stayed there until the nightfall.
2 Q. And following that?
3 A. Following that, we went back to Sid.
4 Q. Using the same road?
5 A. It was dark. I think that for a while we travelled on the same
6 road as the convoy. We were trying to get through and it was difficult.
7 Q. Did you stay long in Sid?
8 A. We spent the night there, and then on the following day, they left
9 and I stayed on.?
10 Q. [Microphone not activated]
11 THE INTERPRETER: Microphone, please.
12 THE WITNESS: [Interpretation] It was a trophy.
13 MR. BULATOVIC: [Interpretation]
14 Q. So they didn't?
15 A. Most likely, they didn't.
16 Q. Did this permit, this pass, have a military stamp?
17 A. There was some type of a stamp on it but I remember nothing
19 Q. It was issued by the military, it was a military document?
20 A. Yes. But it was issued on a one-time basis for that day alone and
21 it wasn't valid on the following day.
22 Q. All right. So it was a one-day pass?
23 A. Yes.
24 Q. On the following day, on the 19th, where did you go from Sid and
25 where -- and when?
1 A. On the following day, at around 8.00 in the morning, I went to the
2 press centre. As I have already told you --
3 Q. You don't need to repeat because we do not want to waste time. I
4 have important things to ask you.
5 A. We took the shortest road to Borovo Naselje.
6 Q. And what is the shortest road?
7 A. The driver knew that. He was the one doing the driving.
8 Q. And then from Borovo Naselje, if I'm not mistaken, after
9 everything you did there, you went and you spoke to the navy captain; is
10 that right?
11 A. No. We stayed very briefly there, perhaps an hour, and then we
12 went back to Vukovar.
13 Q. And how long did you stay in Vukovar on the 19th and what time of
14 the day was it?
15 A. We stayed there from the afternoon -- we didn't stay very long and
16 then we went back.
17 Q. Where?
18 A. Towards Sombor. I think we travelled via Backa Palanka.
19 Q. When did you speak to the navy captain?
20 A. That was in the early afternoon hours.
21 Q. On the 19th?
22 A. On the 19th.
23 Q. On the 20th of November, you were not in Vukovar?
24 A. No. I was not. I was some place else.
25 Q. All right. You keep mentioning this other place where you were.
1 What was it?
2 A. We went to visit a unit of air defence.
3 Q. I'm interested in the location. I am into the interested in
4 military issues such as which type of a unit and so on. What place was
6 A. Sombor.
7 Q. You said that that was 40 kilometres from Vukovar.
8 A. No. First we visited that and then we went there.
9 Q. Would you please explain what is "that" and what is "there"?
10 A. That was another air force unit.
11 Q. And where was that unit, in what town?
12 A. I didn't pay attention because that was not my area of work.
13 Q. Then why did you go there?
14 A. To accompany somebody else and because I had transportation.
15 Q. And when did you return to Belgrade?
16 A. On the 20th, in the evening.
17 Q. Would you tell me, please, your next visit to Vukovar came how
18 long afterwards?
19 A. I'm not quite sure, but on that occasion, we also had a vehicle
20 and there were several of us.
21 Q. Was there a specific reason for your trip, your return trip, to
23 A. We toured some places. (redacted)
25 Q. Mr. Borovic asked you to describe the location of the MUP building
1 in relation to the hospital, the distance and so on, and you were unable
2 to show that on the photographs and on the maps shown to you. I will not
3 go back to that but I will try to rephrase that question. Since you
4 covered that distance on foot from the MUP building where you parked to
5 the hospital, you said that that was nearby, and now I'm interested in the
6 distance between the hospital and the Dunav hotel. Can you estimate that?
7 A. Mr. Bulatovic, I already attempted to do that.
8 Q. Well, just roughly. I fully appreciate your efforts. Can you be
9 more specific?
10 A. No. And I don't like to speculate.
11 Q. You gave evidence and said that you discussed with your colleagues
12 and then you said, "I don't know how to say this in English," but you said
13 that Sljivancanin went on and on and on in his conversation with the
14 representative of the International Red Cross.
15 A. Yes, that's precisely what I said.
16 Q. I will ask you whether that was the same ICRC representative as
17 the one we saw in front of the hospital?
18 A. Based on what I saw, yes, that's the same man, the same
19 representative as the one on television.
20 Q. That was on the 18th, when you saw the representative, the same
21 man, in front of the hospital. On that wall, that was just two or three
22 metres high?
23 A. Yes.
24 Q. And you said that you recognised him because two or three evenings
25 prior to that, you watched his -- him arguing with Veselin Sljivancanin?
1 A. Yes. I saw that on television.
2 Q. All right. And you saw that two or three evenings prior to that?
3 A. Yes.
4 Q. And where was that?
5 A. At home.
6 Q. All right. So you were at home with the people who live in your
7 house and, on that occasion, you commented about Sljivancanin going on and
8 on and on. You didn't comment on that when talking to your colleagues?
9 A. That's not true. That conversation took place in our office.
10 MR. BULATOVIC: [Interpretation] Your Honours, is this good time
11 for a break?
12 JUDGE PARKER: It is, Mr. Bulatovic. There have been and there
13 will be another redaction and we will resume -- Mrs. Tuma?
14 MS. TUMA: Sorry, Your Honour, but just one question, please.
15 It's concerning the planning of the next witness, if the Court intends --
16 I don't know how long this cross-examination will take.
17 JUDGE PARKER: Can you assist us at all, Mr. Bulatovic? I realise
18 you've been going very efficiently.
19 MR. BULATOVIC: [Interpretation] Your Honours, I think another 45
21 JUDGE PARKER: That gives you five minutes, Mrs. Tuma. Is that
23 MS. TUMA: That's enough for me, yes, I think so.
24 JUDGE PARKER: Try to make it 40 minutes, Mr. Bulatovic. In that
25 event, there will be another witness on Monday.
1 On Monday, we are sitting in the afternoon and then the rest of
2 the week we sit in the morning.
3 MS. TUMA: Thank you, Your Honour.
4 JUDGE PARKER: Then we must adjourn now and with the redactions it
5 will be half an hour, so ten past six.
6 --- Recess taken at 5.41 p.m.
7 --- On resuming at 6.10 p.m.
8 JUDGE PARKER: Mr. Bulatovic.
9 MR. BULATOVIC: [Interpretation] Your Honour, thank you. Can we
10 please go into private session, briefly?
11 JUDGE PARKER: Private.
12 [Private session]
13 [Open session]
14 THE REGISTRAR: We are back in open session, Your Honour.
15 MR. BULATOVIC: [Interpretation] Thank you.
16 Q. Can you please tell us the location of the Guards Brigade
18 A. What do you mean? Of course, I can.
19 Q. Briefly, please.
20 A. Topcider.
21 Q. Do you know about the Guards hall or centre?
22 A. Yes, I know that too. It's within the perimeter of the barracks.
23 Q. If I tell you that the Guards Brigade barracks is at Trebinje and
24 has nothing whatsoever to do with the barracks at Topcider, would you tend
25 to agree with me on that one?
1 A. I will agree with you because we use the term in a very general
3 Q. Thank you. You spoke about some sort of ethnic cleansing, of
4 which you, too, were a victim. You spoke about the anti-terrorist
5 platoon. Are you familiar with the following names, the first one being
6 Vehid -- Fehid Karavelic, a Muslim person?
7 A. No.
8 Q. What about the name of Adem Becirevic, another Muslim?
9 A. No.
10 Q. You spoke about that person you met, I'm not sure what you called
11 him, I think you called him Razvigor. What about the last name of
12 Dirijevic [phoen]? Does that ring a bell?
13 A. No, not right now.
14 Q. You said you met this man called Razvigor at one of the youth
15 meetings or work meetings?
16 A. Yes.
17 Q. Can you tell me which meeting or which operation -- youth work
18 operation and which year?
19 A. I said I can't be very specific about that, and it's not my style
20 to speculate.
21 Q. If speculation is not your style, can you please again repeat for
22 me your description of this man named Razvigor, when you saw him on that
23 motorbike in Vukovar? What was he wearing? Was he wearing a beard,
24 perhaps, a close description?
25 A. He was wearing a civilian jacket, military trousers, and he was
1 not wearing a cap.
2 Q. I would now like to ask you to look at a very brief portion of
3 footage and please confirm if this is the man named Razvigor who you saw
4 at Vukovar. Please have a look now.
5 [Videotape played]
6 MR. BULATOVIC: [Interpretation]
7 Q. This person on the motorbike that you can see in this footage, is
8 that Razvigor?
9 A. No. Looks nothing like the man I know.
10 Q. Thank you. Brief question: When you're off on a mission, you
11 have your camera, you said you had a Nikon with a colour film, and a
12 Praktica containing a black and white film. Do you sign for these things,
13 such as cameras and film rolls when leaving, and do you have to account
14 for these items once back?
15 A. I only signed for the film rolls.
16 Q. Who checks this, whether you're using your own film rolls or those
17 that you previously signed for?
18 A. Never occurred to us to use our own film rolls.
19 Q. My question is not about whether it occurred to you but, rather,
20 were you able or were you in a position or would you have been allowed to
21 use your own?
22 A. Yes, in theory. It's just that I myself never did that.
23 Q. Okay. You were given a task, as you said, as you testified in
24 chief, on the 23rd of November 2005, a specific task. My colleague
25 Borovic showed you this and I'm going to show you what you said on the
1 23rd of November 2005. (redacted)
10 JUDGE PARKER: It does, I think, need to be in private session,
11 Mr. Bulatovic. Thank you.
12 [Private session]
11 Page 2382 redacted. Private session.
23 [Open session]
24 THE REGISTRAR: We are in open session, Your Honour.
25 [Videotape played]
1 MR. BULATOVIC: [Interpretation]
2 Q. Did you see the video now?
3 A. Yes.
4 Q. Are these the bodies that you saw?
5 A. When I arrived, those bodies were covered by canvas or tarpaulin.
6 I think the bodies had probably been moved in the meantime.
7 Q. Do you recognise the general environment so to speak? Are these
8 the bodies that you saw covered by tarpaulin?
9 A. Yes. It looks like the same environment that I came across but
10 the question is were the bodies moved in the meantime.
11 Q. Okay. Let me ask you, when you saw the bodies, did you in any way
12 try to ascertain who had committed this crime? You saw the types of
13 injuries that could be seen, right?
14 A. Under those circumstances, that would have been impossible.
15 MR. BULATOVIC: [Interpretation] Your Honours, I move that this be
16 admitted into evidence, the footage that we have just shown. This is a
17 video clip that we received from the OTP, and the number is V0001170-1-A.
18 THE REGISTRAR: This will be Exhibit 116, Your Honour.
19 JUDGE PARKER: Thank you.
20 MR. BULATOVIC: [Interpretation]
21 Q. In order to move on to that bit where Sljivancanin was being a
22 pain in the neck, the substance of that conversation that you heard in the
23 house and what you heard from your colleagues at work, can you tell us the
24 substance? Try to paraphrase or if you know the exact course of the
1 A. It was a long time ago. I remember exactly when he spoke to the
2 representative of the International Red Cross saying stuff like, "Sir,
3 this is my country." That sort of thing. I can't remember all the
4 details. We believed he took an arrogant approach and was being very
5 arrogant to this poor man who was only there to help us and we in the
6 (redacted) had our comments. We were saying things like, well, okay
7 there were people who approved of that but --
8 Q. But the substance of the conversation, in addition to what you
9 said, sir, "this is my country," was there anything else that Sljivancanin
11 A. You're really asking a lot.
12 Q. To the best of your recollection?
13 A. Well to the best of my recollect, he said, "Sir, this is my
14 country. I -- these are our own problems." I can't just say off the back
15 like that without speculating. What I didn't like about it was the
16 arrogance that he displayed. I think he should have found a more
17 diplomatic way of going about that.
18 Q. So that seems to be the only problem.
19 A. Well, I have a personal dislike for arrogance, for arrogant
20 behaviour. I think a diplomatic approach is much better, as a rule.
21 Q. You saw that for a -- three or four days before you went to
22 Vukovar on the 18th?
23 A. I don't know how many days before but I did see it. It was on the
25 Q. Did you after that saw -- did you after that see any other video
1 showing Sljivancanin talking to that representative of the International
2 Red Cross, the same one that you saw near the hospital on the 18th?
3 A. Mr. Bulatovic, the nature of my job entailed a lot of travel.
4 Very often we didn't have time to read papers or watch TV.
5 Q. Could I ask my learned friend something? In order to refresh the
6 witness's memory, I will show you something, some footage, with the sound,
7 this is the conversation between the International Red Cross man and
8 Mr. Sljivancanin. Before that, please tell me one thing. Was there
9 anyone else there, any other officers in addition to Veselin Sljivancanin?
10 Were there any other soldiers in the vicinity. What about this
11 representative of the International Red Cross. Did he have a deputy? Was
12 he with someone? Is this something you remember?
13 A. There is just a very short clip that was shown on TV. It's hard
14 to remember.
15 Q. You said a very short clip. Can you specify how long he was going
16 on like that in terms of time and on and on and on until the cows came
17 home, as you said?
18 A. Well, it's difficult for me to specify but it did go on for quite
20 MR. BULATOVIC: [Interpretation] Can we please play the video?
21 Thank you.
22 [Videotape played]
23 MR. BULATOVIC: [Interpretation]
24 Q. Is this the same video that you saw two or three evenings before
25 you left for Vukovar on the 18th?
1 A. Yes.
2 Q. Thank you very much.
3 MR. BULATOVIC: [Interpretation] Your Honours, I would like to
4 tender this into evidence, please, this video. Again it was obtained from
5 the OTP, the number is V0001231-1-A.
6 JUDGE PARKER: It will be received.
7 THE REGISTRAR: This will be Exhibit 117, Your Honour.
8 MR. BULATOVIC: [Interpretation] Your Honour, I'm about to play
9 another video, if that's all right. It has to do with this conversation,
10 and this will complete my cross-examination of the witness. Therefore,
11 can we now please play the next video?
12 [Videotape played]
13 MR. BULATOVIC: [Interpretation]
14 Q. Do you see this frame?
15 A. Yes, I do.
16 Q. Is that part of the same footage that you saw earlier?
17 A. No. I didn't watch this part.
18 Q. Are these the same people? Is it the same location, the same
19 time, the same place?
20 A. I don't know. I was paying more attention to the actual
21 conversation than to the surroundings.
22 Q. Can you read what it says on the caption on that footage?
23 A. It states Vukovar, the 20th of November, 1991.
24 Q. Do you see a sign in the top right corner of this frame?
25 A. Yes, I do.
1 Q. And what is that sign or logo?
2 A. Could you please focus in or zoom in on it?
3 Q. Unfortunately, we are not able to do that. We can try. Can you
4 try now as we are playing the footage, if you can see?
5 A. Well, it's something like RTS, RTS, it's the TV station logo.
6 Q. If it says RTS, do you know what the RTS stands for?
7 A. Radio-television Serbia.
8 Q. And is it perhaps RTB?
9 A. Then it's Radio-television Belgrade.
10 Q. This news programme that you saw, was that perhaps broadcast by
11 RTB, Radio-television Belgrade, by that television station?
12 A. Yes, I think that that was the name of it.
13 MR. BULATOVIC: [Interpretation] Could we please move into private
14 session now?
15 JUDGE PARKER: Private.
16 [Private session]
12 [Open session]
13 JUDGE PARKER: And yes, that will be received.
14 THE REGISTRAR: We are in open session, Your Honour. And the
15 Exhibit will be number 118.
16 MR. BULATOVIC: [Interpretation] Your Honours, I have finished my
17 cross-examination. Thank you.
18 JUDGE PARKER: Thank you very much, Mr. Bulatovic.
19 Mrs. Tuma?
20 MS. TUMA: No further questions, Your Honour. Thank you.
21 JUDGE PARKER: Thank you.
22 You'll be pleased to know that that concludes the questioning so
23 that you are certainly able to get to -- back to your home by Monday, as
24 you had hoped. The Chamber would thank you for your assistance here and
25 your attendance.
1 As indicated earlier, when we thought we would be even tighter on
2 time, but as this is a Friday evening, late, we will now adjourn to resume
3 on Monday, at 2.15.
4 --- Whereupon the hearing adjourned at 6.43 p.m., to
5 be reconvened on Monday, the 28th day of November,
6 2005, at 2.15 p.m.