1 Thursday, 9 February 2006
2 [Open session]
3 [The accused entered court]
4 [The witness entered court]
5 --- Upon commencing at 9.10 a.m.
6 JUDGE PARKER: Good morning. The apologies of the Chamber for
7 arriving late. We actually received a message that the witness was
8 delayed, and so we've been waiting in our Chambers. But the message
9 turned out to be mistaken.
10 Good morning, sir. Would you please take the card that's given to
11 you now and read aloud the affirmation.
12 THE WITNESS: [Interpretation] I solemnly declare that I will speak
13 the truth, the whole truth, and nothing but the truth.
14 JUDGE PARKER: Please sit down.
15 Mr. Moore.
16 MR. MOORE: Your Honour, thank you very much. May I just deal
17 with the witness situation this morning. When the message was passed
18 through to the Bench, the witness was not here and there was no
19 interpreter here either. I thought it appropriate to pass the message
20 through so that the Bench wouldn't come and be inconvenienced. My
21 apologies if I've miscalculated slightly.
22 JUDGE PARKER: Thank you for taking precautions. Fortunately they
23 proved unnecessary.
24 MR. MOORE: May I now deal with the following witness, who is a
25 protected witness, 007.
1 Could the witness please be shown a confidential document and
2 indicate whether the names, details, and date of birth included are his
10 MR. MOORE: Thank you very much. My understanding is that this
11 witness has a pseudonym and facial distortion, but no voice distortion.
12 WITNESS: WITNESS P-007
13 [Witness answered through interpreter]
14 Examination by Mr. Moore:
15 JUDGE PARKER: This will be received under seal.
16 THE REGISTRAR: As Exhibit 183, Your Honours.
17 MR. MOORE: Thank you very much indeed.
18 Q. Witness, may we deal, please, with the evidence that you have some
19 to give. I want to deal with some preliminary matters.
20 Is it right - and I can show you the document if you need to see
21 it - that you completed an official report for the Republic of Croatia,
22 the Ministry of the Interior. That was dated the 15th of May in 1992. Do
23 you remember compiling that report?
24 A. I do. I didn't actually write the report myself. I provided a
25 verbal account to a police officer who took it down.
1 Q. Thank you very much indeed. That was some six months after the
2 event at which you're going to give evidence.
3 Secondly, it's right, is it not, that you then compiled a report
4 for the Office of the Prosecutor for this institution. That was dated the
5 19th of June, 1995. That's right, is it not?
6 A. Yes.
7 Q. That you have given evidence is what is called the Dokmanovic
8 trial. Is that right?
9 A. Yes.
10 Q. And you have additionally given evidence at the Belgrade inquiry
11 or trial, which was the 24th of May of this year. Is that right?
12 A. Yes.
13 MR. MOORE: Just to assist the Court, my learned friends, I
14 believe the date that this witness gave evidence in the Dokmanovic trial
15 was the 3rd of February of 1998.
16 Q. I'd like to, if I may, please, firstly refer to the date 1991, and
17 I think at that time you were in Vukovar. Is that correct?
18 A. Yes.
19 MR. MOORE: Your Honours, may I just go into private session for a
20 moment to clarify one matter, please?
21 JUDGE PARKER: Private.
24 [Private session]
11 Page 3991 redacted. Private session.
5 [Open session]
6 THE REGISTRAR: We are in open session, Your Honours.
7 MR. MOORE: Thank you very much.
8 Q. Did you do a military service at any time?
9 A. Yes.
10 Q. And is it right - and I think it was in 1966 - you had to serve in
11 the JNA?
12 A. Yes.
13 Q. And what part of the JNA did you serve?
14 A. I was with the infantry in Vrsac.
15 Q. And how long was your military service for?
16 A. One year.
17 Q. May we deal then, please, with the fact - I think you are a
18 married man - that you had two children. Is that right?
19 A. Yes.
20 Q. I unfortunately with deal with one of those children in due
22 And it's right, as you say, that you lived I believe in the centre
23 of Vukovar. Is that right?
24 A. Yes. Plumb in the centre.
25 Q. Thank you very much. I'd like to deal in general terms, if I may,
1 with August 1991 and what was occurring in Vukovar itself. Do you follow?
2 A. Yes.
3 Q. Can you in very general terms what happened towards the end of
4 August, how matters developed - I will use the word - militarily.
5 A. After May when the police officers in Borovo Selo had been killed,
6 the barricades were still there on all the roads leading to predominantly
7 Serb villages. You couldn't drive there or back. In the first days of
8 August, the first shells landed on the centre of Vukovar, the centre of
9 town, just in front of my house -- or rather, between my house and a
10 department store known as Zagrebacka Nama. That was when the whole thing
12 Q. And the actual firing itself, did it continue?
13 A. It began with those two shells and then it continued throughout
14 the remaining months.
15 Q. Can you tell the Court, please -- you say that you were in the
16 centre of Vukovar at that time. Did you see, if we deal perhaps just with
17 August and September for the moment, where many of those shells landed,
18 general locations?
19 A. The very centre of town and also the surrounding area.
20 Q. If I deal with what could be called the fall of shot or the fall
21 of the shells, from what you could see were they being targeted on
22 military targets or not?
23 A. No.
24 Q. Well, can you explain to the Court why you say that? Can you give
25 us a picture, please, of what was happening?
1 A. There were no military targets in the centre of Vukovar to be
2 targeted individually. It was random shelling, and the aim was to hit
3 whatever they could.
4 Q. Did you, yourself, ever see airplanes in action over Vukovar?
5 A. Yes.
6 Q. I just want you to deal with what you actually saw, not what you
7 heard. Do you understand? So would you be kind enough, please, to tell
8 us what you saw.
9 A. We were standing outside in the courtyard that day. Two planes
10 came flying across the Danube, downstream, as it were. They came down
11 towards Vukovar and suddenly there was a powerful explosion. Once we had
12 taken shelter to our left, we first heard a loud bang and then we saw
13 smoke rising not far from our own building. I realised that one of the
14 buildings attached to the Eltz palace was on fire, the one housing the
15 administration of the Vupik Vukovar company.
16 Q. Did you at any time on other occasions see what I will call
17 civilian buildings being destroyed?
18 A. Those were civilian buildings, the ones I've just mentioned.
19 Q. But in addition to that, please.
20 A. The first shells landed near my house and the Nama department
21 store. All the windows were shattered. Several minutes or perhaps hours
22 later a shell landed near the Vuka high-rise and then several shells near
23 the bridge over the Vuka. And those were the first days of shelling;
24 that's what it was like.
25 Q. In very general terms, where was what I will call the front line
1 between JNA and Croat defenders at that time? Was that around where the
2 shells were falling?
3 A. The lines held by Croat defenders were out in the suburbs and
4 around Borovo Naselje. By no means did the lines coincide in the centre
5 of town because there were no defence lines in the centre of town.
6 Q. And this shelling or bombing of the centre of town, can you tell
7 us the period when -- or periods when this shelling continued?
8 A. You could never know for sure when the shelling would begin or
9 where they would strike.
10 Q. But the question that I asked you is: Over what period did this
11 shelling occur? If we deal with August, September, November, October.
12 A. It began when the first shells fell, and then it continued
14 Q. Now, you told us that you were living in the centre of Vukovar at
15 that time. You had your home there. Did you remain in that home through
16 that period?
17 A. No.
18 Q. Well, can you tell the Court then where you went?
19 A. After the shelling started and we felt we were no longer safe in
20 our apartment, the window-panes were broken, nothing could be repaired,
21 and the shelter in my building was inadequate. It was small and it was
22 full of water. It's -- it was a cellar. So I was forced to go to
23 another, safer shelter. I went to the shelter across from the hospital at
24 an apartment building where there were three floors of apartments. The
25 ground floor was where there was a Vupik supermarket and then underneath
1 that there was a long -- or a large shelter that was the size of the
2 actual building.
3 Q. You've told us in that account that: "We no longer felt safe."
4 Why did you no longer feel safe in your home?
5 A. Because the area began to be shelled frequently.
6 Q. And can you tell us when it was you actually left your home?
7 A. Four or five days after the first shells that I described hit.
8 Q. I'd like you to look, please, at an exhibit. I think it is
9 Exhibit 156. It's the bundle of maps, and it's our map 6 which I believe
10 has changed recently because of the pixel problem. The number is
11 04626622. I wonder if that can be produced, please.
12 Now, can we blow that up slightly so that we don't need a
13 magnifying glass, something that takes in the centre of town. Yes. Thank
14 you very much. That looks helpful.
15 MR. MOORE: Your Honour, could we perhaps go into again private
16 session in relation to this matter --
17 JUDGE PARKER: Private --
18 MR. MOORE: -- because I'm going to ask the witness to mark where
19 he lives.
20 [Private session]
11 Pages 3997-4000 redacted. Private session.
9 [Open session]
10 THE REGISTRAR: We're in open session, Your Honours.
11 MR. MOORE: Thank you very much.
12 Q. I want to deal with Dr. Bosanac and Mr. Bili Vidic. Did you see
13 them when you were in the shelter?
14 A. When the negotiations started between the JNA and representatives
15 of Vukovar in which Dr. Vesna Bosanac took part, as well as Marin Vidic,
16 Bili, a few days before when they went for the first time the MUP building
17 was set on fire with a shell, and all the staff and the police officers
18 moved to our shelter because the shelter was big. The commander of the
19 police at the time, Mr. Pole Stjepan, was with them as well. I saw
20 Dr. Bosanac and Marin on two occasions when they came to speak with
21 Mr. Pole about the course the negotiations were taking and what was being
23 Q. Did you personally have any dealings with the negotiations?
24 A. No. No, I did not.
25 Q. Can I just deal with what I will call living conditions not in the
1 cellar but actually outside in Vukovar itself. Did you ever go into the
2 fresh air, into Vukovar, through this period up to November?
3 A. We would all go out once the bombing of the town of Vukovar would
4 stop. Some people would go out more frequently and some people would not
5 go out that much.
6 Q. And what was the condition of the centre of Vukovar like at that
7 time with regard to buildings?
8 A. I wasn't near the centre at the time, but around the building
9 where I was, that area, everything there was demolished. The trees were
10 bereft of leaves. Everything was knocked down. Probably the part of town
11 where I used to live before was even more damaged than where I was then.
12 Q. Prior to the conflict - and I'll use that word for August - were
13 there what I will call public wells in the Vukovar city area?
14 A. There were many public wells in Vukovar.
15 Q. And as far as you're aware, were those public wells, the location
16 of the public wells, known to the population of Vukovar? I'm not saying
17 all of them, but some of them.
18 A. Most of the wells were privately owned in private yards, so many
19 people who lived around that particular place or places would know about
20 the wells.
21 Q. And again, from your own personal knowledge, did people go to the
22 wells to obtain water through this period from September to November?
23 A. There was no other drinking water available.
24 Q. And how safe was it going to collect water from the wells?
25 A. People went to get water because they had to. They were thirsty.
1 They risked their lives to bring back water for other people and for
2 themselves, so it was not safe at all to go and get the water.
3 Q. I think it's right to say you eventually left the shelter and went
4 to the hospital. Is that right?
5 A. I think that it was the 15th of November when we heard that the
6 town defence would no longer be able to hold the defence lines. I went
7 across the road with my wife to the hospital.
8 Q. Now, I -- before we move to the hospital, I just want to deal with
9 one small area about your cellar and the people in it. Did you at any
10 time assist any of those people in the cellar to go back to their premises
11 to obtain items?
12 A. I don't remember that.
13 Q. All right. I will move on then, if I may. Do you know the type
14 of weapons that were being used or shells that were being used against
15 Vukovar area, as far as you could see?
16 A. From what I was able to see, mostly it was mortar shells. They
17 were the most frequent projectiles and they came from all sides. There
18 were also tank projectiles, gun ammunition. All kinds of weapons were
20 Q. Did you ever find shells or items that came from shells around
21 where you were?
22 A. You could still find some embedded in the asphalt near the
23 buildings where I lived or there also all over Vukovar.
24 Q. And are you able to say if these were weapons that were just
25 specifically designed or on a target or to just injure people generally?
1 A. There was no targeting; it was just random fire and the
2 projectiles fell wherever they fell.
3 Q. Let's move on to the hospital, if we may. You say you think that
4 you went there about the 15th of November. If we try and assess numbers
5 between the 15th and the 19th of November, how many people would you
6 assess were in the hospital hinterland or hospital area?
7 A. When I arrived on the 15th, there weren't too many people. There
8 were many wounded persons and the hospital staff was there. The basement
9 was full. During those five days until the 19th, the hospital filled up
10 and it was practically full. According to my estimate, there were about
11 2.500 people.
12 Q. Can you remember the JNA arriving at the hospital?
13 A. Yes. Yes, I can.
14 Q. And when do you think that was?
15 A. That was on the 19th, in the afternoon.
16 Q. And can you tell the Court about the arrival of the military
17 forces, please.
18 Q. We heard that the JNA and the rest of the forces entered Vukovar,
19 that the defenders were giving themselves up, and sometime in the
20 afternoon JNA soldiers came in front of the hospital and they entered the
21 hospital. I think there was several tanks outside in front and APCs while
22 the soldiers entered the hospital on foot?
23 Q. Are you able to say whether these were regular JNA soldiers, TO
24 soldiers, or a specific category that we use here called Chetnik? Can you
1 A. The first people or soldiers whom I saw who came to the entrance
2 hall of the hospital and were on the stairs were just regular soldiers, I
3 think, regular soldiers of the JNA.
4 JUDGE PARKER: Could you pause there please.
5 Yes, Mr. Borovic.
6 MR. BOROVIC: [Interpretation] Thank you, Your Honour.
7 I have an objection to this quite suggestive question, making a
8 difference between regular soldiers and soldiers allegedly called
9 Chetniks. There were different formations in Vukovar at the time: JNA,
10 Territorial Defence, special units, as well as Chetniks. So in future I
11 would like my colleague, in future, when he puts such questions, not to be
12 suggestive, not to put leading questions. That is the gist of my
14 JUDGE PARKER: Thank you, Mr. Borovic. It's a good point that
15 there shouldn't be leading about specific units, but I think it is
16 necessary to bring the witness to discuss the types of units, to indicate
17 that a choice needs to be made, if possible, between regular JNA troops,
18 other types of troops, and what they were. So I'm sure Mr. Moore will be
19 able to adapt to that.
20 MR. MOORE: I will. Thank you very much.
21 Q. Are you able to tell us the soldiers, what -- what category or
22 type of soldiers they were who came to the hospital?
23 A. The first soldiers that I saw, as I said, well, one of them was a
24 military officer wearing a green camouflage uniform. And there were a few
25 soldiers with him. I don't know how many there were, and these soldiers
1 were dressed in regular military uniforms.
2 Q. Do you know who that military soldier -- that military officer
4 A. Well, I knew after he introduced himself.
5 Q. Well, can you tell us his name, please?
6 A. He introduced himself as Major Sljivancanin.
7 Q. And can you give a flavour, please. You say that he came. "He
8 was wearing a green camouflage uniform." That you said "there were a few
9 soldiers with him."
10 Again, can you assist the Court whether they were regular,
11 irregular, what classification, what category?
12 A. In my opinion, these were regular soldiers of the Yugoslav
13 People's Army.
14 Q. And did Major Sljivancanin speak to you? And when I say "you," I
15 mean collectively, all of you.
16 A. He introduced himself as Major Sljivancanin and said: Now you
17 will be transported to the Velepromet warehouse where you will be
18 separated according to what was agreed.
19 Q. Did he indicate what the basis of the separation was going to be
20 at Velepromet?
21 A. No.
22 Q. Did you see Major Sljivancanin having any discussion or argument
23 with any other person who was present at the hospital that -- that day?
24 A. When the military officer said this, there was some commotion.
25 People started shoving and pushing. They couldn't bring themselves to
1 believe that this would happen, because according to what had been agreed,
2 buses were supposed to be on their way and people would be free to choose
3 where they would go next. However, the agreement was not reached
4 eventually, and Mr. Sljivancanin said people would be taken to Velepromet.
5 After that, he turned around, went down the steps outside the hospital and
6 spoke to two people wearing white uniforms. I did not hear their
7 conversation, but I heard his voice telling one of those people to go back
8 to their own country and issue orders if they like because he's in charge
10 Q. The person that he told to go back to his own country because he,
11 Sljivancanin, was in charge, had you seen that person before or not?
12 A. No, never.
13 Q. And how would you describe the tone of the way Sljivancanin dealt
14 with that person?
15 A. Quite strict.
16 Q. And a man in a -- that he was talking to, how was he reacting?
17 A. I didn't notice any reaction on his part.
18 Q. You've told us that Sljivancanin was with a group of -- you
19 considered regular soldiers. At that time, how many military personnel
20 from what I will call the JNA were around the hospital?
21 A. I wasn't able to see how many JNA soldiers were around the
22 hospital. I saw those people who were with Major Sljivancanin. However,
23 when I left the hospital, outside in the courtyard there were other JNA
24 soldiers as well as some paramilitaries who were within the hospital
1 Q. I think it's right to say that you eventually did leave the
2 hospital and go to Velepromet. Is that right?
3 A. Yes.
4 Q. Let us deal, please, with your transportation from the hospital to
5 Velepromet. Have you any idea whether it was morning, afternoon, or
6 evening when you were transported to the Velepromet area?
7 A. Afternoon.
8 Q. And what was the method of transportation? What vehicles were you
9 taken in?
10 A. I was taken there in a military truck.
11 Q. I want to deal with one small piece of evidence that you gave
12 about two minutes ago. You said that you saw other military personnel --
13 I'll just clarify for precision. One moment, please.
14 You said that you saw paramilitaries at the hospital. Did you
15 recognise any of those paramilitaries, please?
16 A. There were many people there wearing all kinds of uniforms. I
17 noticed several people whom I knew personally, people from Vukovar. I can
18 perhaps give you about five or six names that I remember.
19 Q. Well, would you be kind enough to give us those names that you
20 believe you recognised, the paramilitaries.
21 A. Darko Fot; Mico Dzankovic; the Susljik brothers, Cigo and his
22 brother Susljik; Veljko Brko [phoen], I don't know his surname. I know he
23 was a handy-man from Vukovar. Boro Kovacevic and a number of others I
24 don't know.
25 Q. How many people were actually transported with you from the
1 hospital to Velepromet?
2 A. A truckful. I'm not sure how many people that is.
3 Q. And how many trucks went to Velepromet? Were you able to see
5 A. When I came we were unloaded across the way from the warehouse in
6 Velepromet. There was a Vupik garage there and that was where they left
7 us. The trucks probably drove back to the hospital in order to fetch more
8 people and bring them back to the Vupik warehouse across the way from
10 Q. But do you know how many trucks there were? Sorry, I was
11 momentarily distracted.
12 A. I don't know the exact number. There were quite many.
13 Q. Well, let's -- let's see if we use ten as a guide. Was it more
14 than ten or less than ten, as far as you're aware?
15 A. I think more than ten.
16 Q. And do you know who was driving your truck?
17 A. A soldier.
18 Q. And were you able to see who was driving or who were driving the
19 other trucks?
20 A. Soldiers, too.
21 Q. And when you use the term "soldier," to which military section do
22 they belong?
23 A. I think this was the regular JNA.
24 Q. Now, if we just deal with your truck itself, was it just men,
25 women, children? Can you tell the Court the make-up of the people on the
2 A. Yes. On my truck there were only men.
3 Q. Then obviously the time came when you got off at Vupik. Is that
5 A. Yes.
6 Q. And what about the other trucks? Did the people get off those
7 trucks as well?
8 A. At Vupik, yes.
9 Q. And if we just deal with the light. Forget about time for a
10 moment, let's just try dealing with lighting. Was there natural light at
11 that time or not; can you remember?
12 A. Natural light.
13 Q. Yes. Was there?
14 A. I didn't hear the question. I'm sorry.
15 Q. I'm asking if you can just tell us whether there was natural light
16 at that time when you arrived at Vupik. It helps us try and assesses
17 time, you see.
18 MR. VASIC: [Interpretation] Your Honour --
19 THE WITNESS: [Interpretation] Yes, there was still natural light.
20 JUDGE PARKER: Yes, Mr. Vasic.
21 MR. VASIC: [Interpretation] My apologies. The only reason I rose
22 was because the witness has already answered this question, and I believe
23 my learned friend is asking the question again, expecting the witness to
24 perhaps change his answer. The witness has now confirmed that there was
25 still some daylight, natural light. I think the only reason these
1 questions are being asked is because there is the off-chance perhaps that
2 the witness might change his answer.
3 MR. MOORE: That was not the aim --
4 JUDGE PARKER: Mr. Moore.
5 MR. MOORE: Sorry, I beg your pardon.
6 JUDGE PARKER: Mr. Vasic, I see that the witness expressly
7 said: "I didn't not hear the question," and that is what prompted
8 Mr. Moore to again raise the question and the question whether there was
9 light or not. So I think that your objection is out of order.
10 Carry on, please --
11 MR. VASIC: [Interpretation] Your Honours, I'm sorry. Page 23,
12 line 8 --
13 JUDGE PARKER: Mr. Vasic, that's enough.
14 Mr. Moore, carry on.
15 MR. MOORE:
16 Q. Can we deal, please, with the people who got down from the truck.
17 You've told us that -- I believe you told us that there were only men in
18 your truck. Did you see the make-up of the people from the other trucks,
19 whether there were men, women, or children? Can you give us a picture,
21 A. Yes, there were women and children.
22 Q. And what happened when everybody got off the trucks at Vupik?
23 A. I don't know exactly if everybody got off the trucks at Vupik
24 while I was there, but the military officials who were there started
25 separating people on a massive scale.
1 Q. And what way did they separate the people?
2 A. As I said, there were people wearing all kinds of uniforms and
3 insignia. They came to us, and everybody did as they saw fit. They would
4 take as many people as they wanted. Nobody stood in their way.
5 Q. The question that I'm asking -- you said that they were separated.
6 Were they separated on sexual lines, ethnic lines, age lines, colour
7 lines? Can you tell us?
8 A. Before this time it was said that Croats should go to one side,
9 Serbs to the other side, and everybody else to a different side.
10 Q. And who said this, please?
11 A. I didn't hear exactly who.
12 Q. Are you able to remember, even if it wasn't who, who was in
13 control of the separation process?
14 A. There was no control exercised, or at least none that I saw.
15 Q. When you alighted at Vupik and you were separated, was there
16 anybody waiting for you?
17 A. Why would there have been? But there was a man who stepped
18 forward from this group, a native of Vukovar, by the name of Darko Fot.
19 Q. And what way was Darko Fot dressed, please; can you remember?
20 A. It's difficult for me to remember everything, and I can hardly
21 remember what he was wearing.
22 Q. Well, if you can tell us, then, please, slowly what happened when
23 you got down from the -- from the lorry. Can you tell the Court, please?
24 A. When we got off the lorry, one of my friends and I were called by
25 Darko Fot. He sent us to one side where some of the people were who had
1 already been separated. There were other people being taken away. After
2 a while we were taken across the road to the Velepromet warehouse.
3 Q. Who took you across to the Velepromet warehouse?
4 A. Darko Fot.
5 Q. And did he have anybody with him when you were taken across?
6 A. There were other soldiers there. I didn't know them.
7 Q. And how many soldiers were with Darko Fot when you were taken
9 A. I don't know. Quite many. They were all over the place. It's
10 difficult to give a figure.
11 Q. Well, try and see if you can assess. More than 20? Less than 20?
12 A. More than 20.
13 Q. And were those people armed or not?
14 A. All of them were, no exception.
15 Q. And what sort of arms did these people have?
16 A. To the extent that I could notice, they all had long fire-arms.
17 Q. Did you recognise or can you remember the names of people who were
18 armed and waiting for you before going over to the Velepromet area?
19 A. In the warehouse, more specifically in the Vupik garage and in the
20 Velepromet warehouse, there were quite a number of people from Vukovar,
21 people I knew from Vukovar or from the surrounding area.
22 Q. Were any of those people paramilitary?
23 A. All those people belonged to a variety of paramilitary groups
24 wearing all sorts of different uniforms and sporting all sorts of
25 different insignia. I can't be more specific.
1 Q. And can you remember now the names of any of those people?
2 A. I can, in fact, remember quite a few.
3 Q. Well, would you be kind enough, please, to try and remember some
4 of the names.
5 A. Yes. Kosic, his wife Inka; her brother, we called him Kesega,
6 their surname is Stankovic; Pero Krtinic; Dr. Maric; Cevo Zoric, his wife
7 used to work with my wife. I remember a number of people who were there
8 as well as those who were at the hospital.
9 Q. You made a statement on the 15th of May, 1992, six months after
10 this incident at Vukovar. You've already referred to it. Now, did you
11 check the statement to see that it was accurate?
12 A. No.
13 Q. Well, let's go through, then, the details of how the statement was
14 compiled. Can you tell us how you compiled the names or how you compiled
15 the story itself?
16 A. You're talking about the 1992 statement?
17 Q. I am.
18 A. When I came back from the hospital and from the Sremska Mitrovica
19 camp, a police officer from the Vukovar MUP came who was staying in Zagreb
20 at the time. This was in a neighbourhood called Spansko. We were staying
21 in some makeshift huts there. He came to see me and to ask me about
22 everything that had happened in Vukovar. We sat down. I told him all
23 these names that I remembered of different people, and he took the names
25 MR. MOORE: Your Honour, I would seek leave from the Court for
1 this witness to look at that document of the 15th of May, 1992, as firstly
2 a memory refreshing document to see whether, in actual fact, any of these
3 names are actually names that he can now remember, having been refreshed
4 from the document.
5 JUDGE PARKER: Yes, Mr. Moore.
6 MR. MOORE: Would the witness please be shown the document. The
7 ERN number is 03577927, concluding at 932. The B/C/S number is 02170375.
8 JUDGE PARKER: Mr. Lukic.
9 MR. LUKIC: [Interpretation] Just for the record, we do have this
10 document, but there's one thing that I'd like to check with my learned
11 friend. The original version of this document that is about to be shown
12 to the witness bears the following date: The 20th of May, 1992. I see
13 that the statement itself was taken on the 15th of May, 1992.
14 JUDGE PARKER: We should be in private session for the moment if
15 this statement is to be displayed.
16 [Private session]
11 Pages 4016-4020 redacted. Private session.
23 [Open session]
24 THE REGISTRAR: We are in open session, Your Honours.
25 JUDGE PARKER: We've reached the point where we must adjourn to
1 allow the tapes to be rewound. As there have been redactions, there will
2 need to be a half-hour break. We will continue after that. It would
3 appear as long as the front page of this document doesn't go back on the
4 screen that we can be in public session after the break, Mr. Moore.
5 MR. MOORE: Certainly.
6 --- Recess taken at 10.37 a.m.
7 --- On resuming at 11.10 a.m.
8 JUDGE PARKER: Yes, Mr. Moore.
9 MR. MOORE: Thank you very much, indeed.
10 Q. Witness, may we just move on, please, to this statement of May
11 1992. We have got to the list and the name of Darko Fot. Now, do you see
12 that on your list? Can you just read to yourself what it says about him
13 and can you confirm whether that's accurate or not from your memory now?
14 MR. MOORE: The witness spoke; I certainly didn't hear anything.
15 THE INTERPRETER: The interpreters didn't hear anything.
16 THE WITNESS: [Interpretation] That is correct.
17 MR. MOORE:
18 Q. Thank you very much. With regard to the next name, Borislav
19 Zuvanovic. Again, using the same procedure, the details there. Are they
20 accurate in relation to the uniform and the long fire-arm?
21 A. Yes, they are correct.
22 Q. The next witness -- or the next name Nenad Zigic. Is that
23 correct? Do you remember seeing him there at the Vupik Velepromet
24 collection centre?
25 A. Yes, I do remember seeing him.
1 Q. Now, you say in your statement that he was dressed in a military
2 uniform and it had a rank; the rank was major. Can you remember that or
4 A. Yes, I remember that.
5 Q. Can you tell the Court what sort of uniform he had and why it was
6 you took the view he was the rank of major?
7 A. He had a dark brown uniform with the rank's insignia of a major on
8 his shoulder.
9 Q. Can we move to the next name, Petar Velebit. Do you remember
10 seeing him there at Vupik and then in Velepromet?
11 A. Who -- he used to work with me at the former milicija, the police
12 force, and then he went to Velepromet.
13 Q. The question is: Do you remember seeing him when you got out of
14 your vehicle at Vupik and then subsequently went to Velepromet?
15 A. Yes.
16 Q. Thank you.
17 A. I saw him.
18 Q. Marko Paic?
19 A. Also.
20 Q. Again, the suggestion is in your statement he was wearing military
21 uniform and a long fire-arm. Is that right or not?
22 A. Yes, yes.
23 Q. Miso Rokvic, do you remember seeing him there?
24 A. Yes, he played the accordion in Vukovar. I also saw him there.
25 Q. Again with a fire-arm and in uniform. Is that right?
1 A. Yes.
2 Q. We have only four more other -- four more names to go through. Do
3 you know the next name? It looks like Stevan Curnic. Is that right
4 or not, because there's question marks at it.
5 A. Yes, I know.
6 Q. And what is the proper name then, please.
7 A. His name is Stevan Curnic.
8 Q. And, again, the commentary in military uniform and a long
9 fire-arm. Is that right?
10 A. Yes, that's correct.
11 Q. Stanko Vujanovic.
12 A. He was a taxi driver in Vukovar.
13 Q. Thank you. But dealing with Vupik and the Velepromet area when
14 you got out and were segregated, is this explanation, does it correspond
15 with your memory or not?
16 A. Yes, it does.
17 Q. Thank you. Stanislav Avramovic, also known as --
18 MR. BOROVIC: [Interpretation] Excuse me, Your Honour.
19 JUDGE PARKER: Mr. Borovic.
20 MR. BOROVIC: [Interpretation] Thank you, Your Honour. My learned
21 friend from the Prosecution asked, not for the first time, whether it is
22 correct what it states here in this text. For example, for Stanko
23 Vujanovic it said that he took part in guarding, denouncing, and
24 mistreating detainees. So what is correct, only what relates to the
25 uniform and the weapon or the whole text? I think that the witness denied
1 saying all of these things to the person who took the statement. So I
2 think this is something that needs to be clarified before we proceed
4 Thank you.
5 JUDGE PARKER: Mr. Moore, the point made I think is very
7 MR. MOORE: Might I submit that a witness is entitled to look at a
8 document where the indicia for reliability suggests that he is the source
9 of the documentation. If a witness --
10 JUDGE PARKER: Mr. Moore, the point is: What is it is he saying
11 to be correct? There have been clear indications that not everything
12 recorded are his words. The only express things that he's indicated is
13 that he saw the person in uniform carrying a fire-arm. There is much more
14 recorded, which is quite different from any of his evidence to date. If
15 you want any specific notice to be taken of that, it will need to be
16 explored properly.
17 MR. MOORE: Certainly.
18 JUDGE PARKER: Thank you.
19 MR. MOORE: Would Your Honour forgive me one moment.
20 [Trial Chamber confers]
21 [Prosecution counsel confer]
22 MR. MOORE: Your Honour, the way I propose to do it, and I hope it
23 meets the agreement of the Defence, is for the witness to read the
24 document, ask whether in actual fact he remembers the person as being
25 there from his present recollection, and whether the explanation given in
1 the document accords with his present recollection. And that is all I
2 would wish to establish at this time. It may well be that I would want to
3 deal with these individuals later on in his evidence, and I hope that that
4 would be an appropriate way of dealing with it.
5 JUDGE PARKER: For my part I want it to be --
6 THE INTERPRETER: Microphone, please, Your Honour.
7 JUDGE PARKER: -- clear that he agrees with everything that is
9 MR. MOORE: Certainly.
10 JUDGE PARKER: Or only part of it.
11 MR. MOORE: Certainly.
12 JUDGE PARKER: That seems to be the issue.
13 MR. MOORE: Certainly, I will do that.
14 Does my learned friend wish me to go back to the name of Zigic as
15 a starting point, which is only two names back, and that is really -- is
16 fairly close to where we resumed. I'm quite happy to resume at a
17 particular name if there's any concern about an individual.
18 I see my learned friend nodding yes, and I will do it that way
19 with the Court's leave.
20 JUDGE PARKER: Thank you.
21 MR. MOORE:
22 Q. Witness, I want you to go back, please, to the name of Nenad
23 Zigic. There is written beside his name an explanation or an account of
24 what he was supposed to have done. Can you read that out, please, and
25 tell us whether you agree if that is accurate or not. Now, can you read
1 it out, please, and tell the Court whether it is accurate or not.
2 A. "I saw Nenad Zigic in a uniform with the ranks of major. The rest
3 I did not see."
4 Q. Can we look at Petar Velebit. Now, you have a commentary. Can we
5 do the same again, please.
6 A. Once again, I say that I saw him in uniform and armed.
7 Q. There is another part that relates to another aspect about
8 defenders and civilians. Is that accurate or not?
9 A. I really don't know that. I couldn't say.
10 Q. Thank you very much. Let us move then to Marko Paic. Again,
11 there is an explanation. Firstly, did you see Marko Paic at Vupik and
13 A. Yes, I did. He was also in uniform and armed, but as for the rest
14 I didn't see that.
15 Q. Miso Rokvic, did you see him at Vupik Velepromet?
16 A. In a uniform and with weapons, yes, that is correct.
17 Q. Can we go back to Stevan Curnic. You've told us you saw him.
18 What about the other entry, please?
19 A. The same, in a uniform with weapons.
20 Q. Stanko Vujanovic you've told us you saw. Please read what is said
21 there for him and confirm whether that is accurate or not.
22 A. I repeat, once again, that I saw him in a uniform with a weapon.
23 Q. Can you remember anything else about Vujanovic?
24 A. Not right now, no.
25 Q. Stanislav Avramovic, did you see him at Vupik Velepromet?
1 A. Yes. He also was wearing a uniform and had a weapon.
2 Q. And the final one, are you able to assist with that name or not?
3 A. He was a driver. He worked at the same company that I did. He
4 also wore a uniform and had a weapon.
5 Q. Thank you. Can you just listen then to the following question.
6 You have given those names to the Court as being people who met you at
7 Vupik. What were they doing after that; can you tell us?
8 A. I don't know what they did after that. I wasn't able to be at
9 every place where they happened to be.
10 Q. Can we then deal, please, at -- when you've arrived at Vupik and
11 you've told us about the separation. You've already explained that. What
12 then happened to your group?
13 A. During the transfer from Vupik to Velepromet, we were taken to a
14 wall which is on the left side next to the Velepromet entrance. More
15 people were being brought in from all directions. After a certain amount
16 of time, not too long afterwards, I was summoned by Mico Dzankovic, a
17 former waiter in Vukovar from a group, and he told me to stand a little
18 bit to the side. A young man stood next to me - I knew him from Ilok -
19 who was a police officer in Vukovar at the time. His name was Miroslav
20 Blaskovic. Miro Dzankovic took him out from that group also and told him
21 to stand next to me next to that wall. After a certain amount of time he
22 cursed him, cursed his mother, and then he hit him on the face with the
23 barrel of his rifle. Blood started to show on his face, and then they
24 took him off somewhere, and I never saw him again.
25 Q. I want you, please, to look at a document. The number
1 is 04672780, and I believe -- well, the Defence will have copies of that.
2 Could that be put on the screen, please.
3 Now, I think it's right to say that when you came to The Hague on
4 this occasion that you brought this document with you. Isn't that right?
5 A. That's right.
6 Q. And the document itself represents the Vupik-Velepromet area. Is
7 that correct?
8 A. That's correct.
9 MR. MOORE: I wonder if it's possible for the document to be
10 enlarged? It's rather difficult on my screen to see it. I think it can't
11 be minimised to an appropriate size.
12 Q. Let us deal with the document itself. At the top of the page we
13 have got an arrow pointing to Negoslavci. Is that right?
14 A. Yes.
15 Q. And we have got at the bottom an arrow pointing to Vukovar. Is
16 that correct?
17 A. Yes, yes.
18 Q. And in between we have got a road clearly running in a north-south
19 direction between Negoslavci and Vukovar. Is that right?
20 A. That's right.
21 Q. Now, can I just deal with a general understanding and then we'll
22 move on to specifics. But did you actually compile the buildings
23 themselves? So I'm not talking about the arrow marks; I'm talking about
24 the buildings.
25 A. No.
1 Q. Well, can you just tell the Court how this document was created
2 initially? Just in very simple terms, please.
3 A. It was done for me by a friend of mine.
4 Q. And how long ago was it done for you, approximately?
5 A. About six months ago.
6 Q. Now, we have got arrows clearly drawn coming from the left-hand
7 side and then going into what seems to be the Velepromet area. Is that
8 right or not?
9 A. Yes.
10 Q. Well, let us just look to the left-hand side of the page, what I
11 will call 9.00. Have you got that?
12 A. Yes.
13 Q. Now, what is that area on the left-hand side of the page?
14 A. This is the Vupik warehouse.
15 Q. So when you talk about the Vupik warehouse, is that the warehouse
16 area where you were offloaded from the lorries?
17 A. Yes, that's right.
18 Q. Well, can you explain to us then exactly what the arrows
20 A. This is the route along which I was taken to Velepromet.
21 Q. You're talking about the arrows. Is that right?
22 A. Yes.
23 Q. Now, can you with your magic pencil and the electronic screen - I
24 don't know if it's possible or not - actually mark out the route that you
25 actually took, not the route of others, the route that you took.
1 A. [Marks].
2 Q. Can I just ask you to stop there for a moment, please. Now, your
3 marking shows you're coming in from the Vupik area, across the road, into
4 Velepromet, and then you seem to go to a location and then leave that
5 location. Now, what happened? Can you explain to the Court exactly what
6 this diagram represents?
7 A. The whole thing, you mean?
8 Q. Well, if you just tell us what it is you have drawn and explain to
9 us slowly what happened and where. So take your time and tell us as
10 thoroughly as you wish.
11 A. This is the Vupik warehouse. I was offloaded here and so were
12 they. This is where the group was formed and we were taken behind this
13 wall for the first time, roughly speaking. The next time I was taken away
14 it was to this spot that I've just marked. The third time around I was
15 taken to this spot.
16 Q. Well, thank you for that, but we just need to mark out the spots
17 that you're referring to. So let's use the magic pen again. Can you tell
18 us, using the pen, where it is that you go and where you stop. And tell
19 us then what happens there and then move on again. Would you do that?
20 And mark on the diagram, please, where you stop?
21 A. The first time around we stopped right here near the casino on our
22 way from Vupik to Velepromet. From that group of people, Mico Dzankovic
23 took me to one side and two other people, too.
24 Q. So every time that you refer to stopping, mark it with a -- let us
25 say, an X or an A. It matters not. So you stop there. Who takes you
1 there, please?
2 A. Mico Dzankovic called me to one side and led me there with a
3 number of other people. As I have already said, he --
4 Q. And who is Mico Dzankovic --
5 THE INTERPRETER: The interpreter didn't get the last part of the
6 witness's answer.
7 THE WITNESS: [Interpretation] Excuse me, can you please repeat the
9 MR. MOORE:
10 Q. And who is Mico Dzankovic?
11 A. Mico Dzankovic was a waiter before the war in Vukovar. He is from
13 Q. And what was Mico Dzankovic doing that evening with you?
14 A. He just took me to one side and put me in a different group.
15 Q. And when he put you into the different group, how many did he put
16 you -- how many were in that group?
17 A. About seven or eight persons, ten at most.
18 Q. And so where was the group? Where did it -- where was it placed?
19 A. The group was right here.
20 Q. And what was happening at that time?
21 A. You mean happening to me?
22 Q. Well, you can tell us what was happening to you and perhaps tell
23 us what was happening to others. You see, I can't tell you what to say;
24 you've got to tell the Court.
25 A. Fine. People were still being separated left and right on a
1 massive scale. This was done in an arbitrary fashion. Mico Dzankovic was
2 the one who separated me and a couple of other people from the rest, left
3 us there with about ten other people. They were still bringing other
4 people to that group. After a while, Boro Zuvanovic came for the third
5 time, called my name out, and told me to leave the group, together with
6 another man whose name I believe was Jurica. When he started leading us
7 toward the buildings over there I asked him: Boro, where are you taking
9 And he said: (redacted), just keep your mouth shut. There's going to
10 be quite a mess here. I'm taking you somewhere safe. And then we headed
11 towards this spot I've marked here.
12 Q. When you say you headed towards this spot here, can you put a C, a
13 letter C at this spot, please.
14 A. C.
15 Q. And can we mark the other spots A and B, obviously running in
17 A. [Marks].
18 Q. So with regard to A, what happened at A?
19 A. We were brought here from Vupik near the wall to Velepromet.
20 Q. And then at B?
21 A. The spot marked as B. When Mico Dzankovic took me to one side, I
22 described what happened between Mico Dzankovic and the police officer Boro
23 Draskovic [phoen].
24 Q. What was the atmosphere like in Velepromet at that time when you
25 came in?
1 A. It's very difficult to describe it verbally. There was panic and
2 fear in the air. Sounds of shooting could be heard from the moment I
3 arrived throughout. This shooting -- what should I call it? There was
4 shooting all over the place. There was celebratory fire, people firing
5 into the air, and other people firing. I didn't know why they were
6 firing. You could hear screams, women screaming for the most part, Bring
7 back my this or my that, because they were taking people away and women
8 were crying. It was a scene of utter chaos.
9 Q. I want to deal with the movement from B to C on your diagram. Do
10 you see that?
11 A. Yes, I do.
12 Q. Now, can you tell us then what occurred when you were moving
13 from B to C?
14 A. When leaving B -- or rather, when Boro Zuvanovic called me, it was
15 next to this building, I'm not sure what it is now, a small building, I
16 saw a man who passed in front of us, Mirko, also known as Capalo. He was
17 walking ahead of us holding a crooked knife in his hand, a knife with a
18 crooked tip, with blood dripping from it. In his other hand he was
19 carrying a human head. I'm 90 per cent certain that what I saw was a
20 human head. He passed in front of us and never looked back.
21 Q. Can you mark a letter D if it's possible where it was you saw this
22 man called Capalo with the knife and the head. If you can't do it, just
23 tell us whether it was in an open area or an enclosed area.
24 A. It was in an open area.
25 Q. When you saw this man Capalo with the knife and what you felt sure
1 was a head in his other hand, what did you feel?
2 A. I was horrified. I didn't have time to think about anything at
4 JUDGE PARKER: Mr. Moore, I'm just watching the time moving by on
5 this sketch that has been marked --
6 THE INTERPRETER: Microphone for the President, please.
7 JUDGE PARKER: If we don't tender it soon, we may lose the
9 MR. MOORE: I was aware of that. I was hoping to get to the
10 destination. Can I just ask this question of --
11 JUDGE PARKER: Well, if you think this -- you're getting somewhere
12 shortly, please go ahead.
13 MR. MOORE: I will. Thank you very much for that.
14 Q. And D, what was D on your map?
15 A. D.
16 Q. C, I was one ahead. I'm sorry about that. C.
17 A. C marks the spot where that small building was in front of which I
18 was brought. Me and that other person called Jurica.
19 Q. Thank you very much.
20 MR. MOORE: Perhaps if we take a photograph of that now and tender
21 that into evidence.
22 JUDGE PARKER: It will be received.
23 THE REGISTRAR: This will be Exhibit 187, Your Honours.
24 MR. MOORE:
25 Q. Prior to actually going to that small room, did you see within the
1 Velepromet area where you were walking through, did you see anyone in
2 military uniform or not?
3 A. They were all over the place. There were people all over the
4 place, but less people than I saw around the admin building.
5 Q. Let us deal then, please, with the small room that you went to.
6 Can you describe it for us.
7 A. It's a very small room with a slanting roof, if I remember
9 Q. And that -- did you go into the room?
10 A. The two of us were brought just outside that small room. A man
11 was standing there wearing camouflage uniform, very tall, with long hair
12 and a beard. Just in front of him there was a table. This man who was
13 leading us, Boro, said to him Topola: These two are mine, don't let
14 anyone get near them or touch them. And he answered: No problem there,
16 Boro left, went somewhere, and then Topola ordered me to place a
17 bag that I was holding on a heap of other bags that were lying there. I
18 was wearing a jeans jacket, somewhat long, with fur lining. He told me to
19 take it off and place that, too, on top of that heap. We did as we were
21 After that he told me to hand over my documents. I extracted all
22 the documents from my wallet and in fact handed over the entire wallet.
23 There was some money; he took the money and placed the money on the table
24 in front of him and laid the documents down under the table. I saw that
25 there were other documents under the table, too, just like mine.
1 I turned around. I was wearing a small and flimsy black jacket, and he
2 said: Take that off, too, and put it on top of that heap. I did that,
3 and I was left in a -- wearing a T-shirt, and he ordered the other man who
4 was with me to do the same thing. Since it was very cold and we were
5 freezing, I asked if I could have my leather jacket back as well as my
6 documents. And he replied: You won't be needing these anymore. After
7 some time he opened the door and told us to get in. I was the first to
8 get into the building, and he kicked Jurica on his way in. We were now
9 inside the building, and the door slammed shut behind us.
10 Q. Let us deal, if we can, please, with what you found inside the
11 building after you had been placed inside it. Were there any other people
12 in there?
13 A. Two or three candles were burning. I can't remember exactly. The
14 small building was packed with people who were there already when I
16 Q. I know it's very difficult to estimate numbers, but can you give
17 the Court an idea of numbers? More or less than 50?
18 A. I think just over 50.
19 Q. And what was the atmosphere like in that particular building?
20 A. When I came in there was a deadly silence.
21 Q. And do you know what that room or building was subsequently
23 A. Some called it the death cell. Some called it the carpenter's
24 room, which is what it was, what it was used for, as part of the
25 Velepromet company.
1 Q. When you were in the room you described it as being silent. Did
2 you hear any noises outside that caught your attention?
3 A. All we could hear while we were inside was sounds of firing.
4 Q. And how close was the firing?
5 A. One couldn't really discern or distinguish the exact spot that
6 sounds of firing were coming from.
7 Q. But did there come a time when there was firing right beside the
8 building itself?
9 A. After I came in -- well, after a certain time, it's difficult to
10 say exactly, there was firing just outside the door of that building, and
11 people were yelling things like: He's getting away. He's getting away.
12 Catch him, quickly. After a while the door opened and a young man was
13 thrown or pushed into the building. Both his legs were bleeding. I
14 recognised him. I know this young man well. His name was Dragan Lucic.
15 Q. You have described -- you have described that his legs were
16 bleeding. Did you see what had caused the injuries?
17 A. There was a doctor who wanted to dress his wounds, but he had
18 nothing to dress them with. I think his name was Josip Nadas. He bent
19 down over him, and he says he has gun-shot wounds to both his knees and
20 his ankles.
21 Q. Did you do anything to try and help Dragan Lucic?
22 A. There was nothing I could do at this point in time. Dr. Nadas was
23 trying to help. I gave him my own shirt to use to try to help the young
24 man's life and stop the bleeding; however, we failed.
25 Q. And did you speak to anybody outside the room about this?
1 A. We realised that he was bleeding profusely and that there was
2 nothing we could do. I knocked on the door of that other room, and then
3 this soldier named Topola came in and asked what was going on. And I
4 said: There is a man, he's dying, can we do anything to save him? After
5 a while, two persons came in and took Dragan away from the room.
6 Q. Did Dragan -- was Dragan ever brought back to the room?
7 A. Dragan was brought back, and there were bandages on his legs.
8 However, there was still some bleeding and Dr. Nadas did whatever he could
9 to stop that.
10 Q. Let's continue with the room. Did any other people come into that
12 A. After Dragan was brought there, the door opened and a young man
13 emerged in the door. He had long blond hair and a beard. He held a
14 bottle of some alcohol in one hand and an automatic rifle in the other.
15 He stood there in the doorway saying: At about 9.00, or half past 9.00
16 latest, you'll all be taken to be executed. He lingered there for a
17 minute or two and then left.
18 Q. Well, after he left, can you then again slowly tell us what then
20 A. Fear and panic descended upon us. We felt certain that we would
21 die. We kept looking at one another, but nobody said anything. Soon
22 after, the door opened again and a man in uniform emerged. I think he had
23 the rank of major. He had two soldiers on each side accompanying him. At
24 first we thought this was the firing-squad and they were about to shoot
1 However, this turned out to be something altogether different, to
2 our great fortune. This man came in and said: People, stand up, all of
3 you. They had been calling us Ustashas all the while, but this man was
4 the first not to use the term. He said: People, stand up. Walk in twos,
5 hold each other's hands, don't look left or right, just go out. There's a
6 bus waiting for you there. Get on the bus without looking left or right.
7 None of us could believe this at first. I was particularly
8 diffident by the way things went, that things had taken a totally
9 different turn now. We grabbed each other's hands. There was a man
10 standing next to me, Mirko Bridovic, he was an inspector in Vukovar, a
11 sanitation inspector. We slowly walked towards the bus, heads down, the
12 bus waiting for us outside. The military officer expressly ordered his
13 people: Turn around, no one is to come even close. If anyone comes
14 close, shoot them. It was at this point in time that it dawned on me that
15 we were now saved. We got on to the bus and so did the officer. He spoke
16 to the driver who was also in uniform. He said: Just drive on, park
17 somewhere along the road to Negoslavci, and pull over right behind that
18 Pinzgauer. He also told two soldiers to guard the doors, one each. He
19 said: No one is to get on this bus but me. And the soldiers complied
20 with this.
21 We set out. We left the Velepromet compound, and - I'm sorry -
22 parked behind this Pinzgauer that was parked there facing Negoslavci.
23 Q. Witness, are you all right or would you need a break?
24 A. Everything's all right. Thank you.
25 Q. And I think it's right to say then that you were taken away, is
1 that right, to safety?
2 A. That's right.
3 Q. I want to deal with one or two areas in relation to your knowledge
4 of Vukovar and the people in Vukovar. Do you know the Dosen family?
5 A. I know the Dosen family; most people in Vukovar do. His mother
6 lived in my building in the centre, where I was living, on the first
7 floor, Ms. Marija Dosen. There were three Dosen brothers, Tadija, Martin,
8 and Ivica. They had two sisters. We used to call one Seka and the other
9 one we called Crna.
10 Q. How would you describe the Dosen family before, let us say, the
11 summer of 1991? Were they a politically active family or not?
12 A. They were all employed. The eldest, Tadija, worked at the Borovo
13 company as a labourer. The second one is Martin; he worked in the
14 agricultural combine, and then later he became a professional fisherman.
15 The third brother, Ivica, worked occasionally. He wasn't permanently
16 employed. From what I know, they were not really interested in politics.
17 Q. Can we deal with them, though, whether you knew -- whether you
18 know whether they were defenders of Vukovar or not?
19 A. Yes, they were.
20 Q. Does that relate to all three brothers or not?
21 A. I know about the oldest and the youngest. I'm not sure about the
22 middle one, but I think that he was part of the defence, too.
23 Q. And as far as you're aware, how well-known as defenders were they?
24 A. They didn't behave as people who wanted to be especially known.
25 They just behaved like any other of the defenders.
1 Q. It's right to say that you were shown a list of people - the Court
2 will know it as the annex to the indictment - a list of people who are
3 described as victims at Ovcara. Do you remember seeing that document?
4 I'll just hold it up so you can see.
5 A. Yes, I remember seeing it.
6 MR. MOORE: Your Honour, forgive me for one moment, please.
7 [Prosecution counsel confer]
8 MR. MOORE: I'm told that it's saved as 00 Ovcara in e-court.
9 I've got it now showing, but there are certain markings that are not
10 terribly easy to see. Can we blow it up the first page and then we'll
11 move through it.
12 MR. MOORE: Your Honour, I've told my learned friends, so that
13 there's no misunderstanding, some of the marks here are actually mine from
14 my indictment, but I wanted for my own understanding to know what this
15 witness thought were people who were seen at the hospital when he was
16 there. So there are marks on it, but I will just deal with the Hs and I
17 will clarify that they are his.
18 Q. Witness, can you just look at this document for a moment. I think
19 it's right to say that you were asked to look at this list of people and
20 mark with the letter H those that you remember seeing at the
21 hospital. Is that right or not? Can you just answer, please.
22 A. Yes, that's correct.
23 Q. And when we look at this first page, and we'll move on, I think
24 it's right to say if we scan down the page, if that's possible to do it
25 slowly, please, that with the markings of H those are your markings of
1 people you believed to have seen at the hospital when you were there. Is
2 that right?
3 A. Yes.
4 Q. Now, can I just clarify with the witness, there is at the name of
5 Blaskovic, Miroslav, a mark of V/not hospital. That is not your marking.
6 Is that right?
7 A. All I wrote was the letter V.
8 Q. But can we just deal with the Hs for a moment. So the Hs are
9 yours. That's right, I think?
10 A. That's right, yes.
11 Q. Now, let's look at this page, and we've got Blaskovic, Miroslav.
12 There is a V opposite that. Is that your V or not, standing for
14 A. Yes, that is my V.
15 Q. And I am quite happy to go through to the next page, please, if
16 that's possible. Can that be done?
17 Again, you have got Hs running down opposite various names.
18 Again, same format. Is that your H?
19 A. Yes.
20 Q. And what does the H stand for here on this page?
21 A. It means that I saw those people at the hospital.
22 Q. Moving over to the next page, please. Thank you very much.
23 Does the same apply to those Hs?
24 A. Yes, it does.
25 Q. Can we look at the initial M and there is a V, Marijanovic. Do
1 you see that, that V there?
2 Can the registry please move on to the initial M because it does
3 go alphabetically. The next page, please. The next page, please.
4 Now, do you see the -- we've got Hs, two Hs and a V. Is that your
5 V, is that your marking?
6 A. No.
7 Q. Thank you. And the Hs?
8 A. Yes.
9 Q. Can we move on then two more pages with the first name as Magdic
10 at the very top. I see I've got a duplication here. That's a
11 duplication. And with regard to the rest of the indictment, if we go to
12 the initial J -- sorry, the initial T for Tomasic. Have we got that? Can
13 we turn to the next page, please. And again there are four Hs. Did you
14 mark those four Hs as people that you saw at the hospital?
15 A. Could you please scroll the page down. I did write that, yes.
16 Q. Thank you very much.
17 MR. MOORE: I would seek to make that an exhibit.
18 JUDGE PARKER: It will be received.
19 THE REGISTRAR: As Exhibit 188, Your Honours.
20 MR. MOORE:
21 Q. Witness, one of the names I did not refer you to was your son.
22 And I don't want to mention his name or draw attention to it in open
23 court. But I think it's right to say that your son's name is specified on
24 that list of victims of Ovcara. Is that right?
25 A. Yes, it is.
1 MR. MOORE: Now, I was not going to ask this witness how he
2 identified his son. As far as I'm aware, there is no dispute that his son
3 was exhumed at Ovcara. I'm quite prepared to do it if my learned friends
4 wish to contest it, but for my part I'm not aware that there will be any
5 contesting of this particular matter. It is sensitive to this witness,
6 and I don't wish to do it unless absolutely necessary.
7 Could I have some indications, please, if there's any dispute
9 JUDGE PARKER: Mr. Lukic.
10 MR. LUKIC: [Interpretation] We absolutely agree with the approach
11 of the Prosecutor, and then we are going to consult during the break and
12 then we will give you our positions. Now it's about close to the break,
13 so we would just like to have a little bit of time so that we can consult
14 on this amongst ourselves and then we will state our position after the
16 JUDGE PARKER: Thank you.
17 Mr. Moore, you can continue on the basis that for the moment at
18 least there is no dispute.
19 [Prosecution counsel confer]
20 MR. MOORE: At the moment I have no further questions. I was
21 going to conclude with that particular topic at the end.
22 JUDGE PARKER: Very well. Thank you very much, Mr. Moore.
23 Mr. Vasic -- Mr. Domazet. The pillar isn't getting any slimmer.
24 I'm sorry --
25 MR. DOMAZET: Yes.
1 JUDGE PARKER: -- it continues to hide you completely from me.
2 MR. DOMAZET: [Interpretation] Your Honour, I'm ready to start with
3 the cross-examination, but I would personally rather have the break now
4 because of the consultations that my colleague Mr. Lukic mentioned also.
5 And I think that then after the break I will require the whole session for
6 my cross-examination.
7 JUDGE PARKER: Very well, Mr. Domazet.
8 There are redactions, so the break will be for half an hour.
9 --- Recess taken at 12.15 p.m.
10 --- On resuming at 12.49 p.m.
11 JUDGE PARKER: Before you continue, Mr. Domazet, has there been
12 any conclusion reached about the matter raised just before the break?
13 MR. DOMAZET: [Interpretation] Yes, Your Honour. We have agreed
14 with what our learned friend, Mr. Moore, has said and we believe there is
15 no need for cross-examination on this matter.
16 JUDGE PARKER: Thank you, Mr. Domazet. I thank you and all
17 Defence counsel. We can proceed on the basis that the -- that matter is
18 not in dispute. Yes, Mr. Domazet.
19 MR. DOMAZET: [Interpretation] Thank you, Your Honour.
20 Cross-examination by Mr. Domazet:
21 Q. Good afternoon, sir. I am Vladimir Domazet, and I am the
22 co-counsel of Mr. Mrksic. I will be asking you questions on behalf of
23 Mr. Mrksic's defence. First a few questions on your career.
24 MR. DOMAZET: [Interpretation] I would like to move in to private
25 session so that nothing is made public that could reveal your identity.
1 JUDGE PARKER: Private.
2 [Private session]
11 Page 4048 redacted. Private session.
12 [Open session]
13 THE REGISTRAR: We are back in open session, Your Honours.
14 MR. DOMAZET: [Interpretation]
15 Q. I would like to ask you now about the period of 1990 and early
16 1991. As you've described it yourself, it was a period where you as a
17 long-time citizen of Vukovar, you had lived there for 30 years. Is that
19 A. Yes, it is.
20 Q. The year 1990, I'm sure you remember it by the events that were
21 going on in the former Yugoslavia at the time and that was the creation of
22 the multi-party system and the first multi-party elections. Do you
23 remember that?
24 A. Yes.
25 Q. How did the results of the first multi-party elections in Croatia
1 reflect on the situation in Vukovar itself?
2 A. For people of Serb ethnicity, I believe that it reflected
3 negatively. And as for the Croat people, I think it was reflected
5 Q. When you say that, sir, that for people of Serb ethnicity you
6 believe that it was a negative reflection, why do you say that? Why did
7 you form that opinion?
8 A. I think that those people spontaneously came out into the streets
9 and they protested the results of those elections.
10 Q. The results of the elections in Croatia were actually the victory
11 of the HDZ. Is that correct?
12 A. Yes.
13 Q. What about the local elections in Vukovar? How did they proceed
14 in this multi-party system for the first time?
15 A. I think that the HDZ party also won in Vukovar.
16 Q. Do you remember who was elected president of the Municipal
17 Assembly of Vukovar then, following the local elections?
18 A. I think that it was the late Mr. Dokmanovic.
19 Q. Do you remember or do you know which party he was a member of?
20 A. Well, I can guess. I think that he was in the SDP party.
21 Q. Was that a party headed by Mr. Racan, at one time a very prominent
22 member of the League of Communists of Yugoslavia and a member of the
24 A. Yes, that is correct.
25 Q. And that party, Racan's party, according to what you know, was
1 that a multi-ethnic party, comprising Serbs and Croats?
2 A. Yes, that is correct.
3 Q. At the time, and I'm only speaking about that period, did the
4 Serbs have their own national party in Vukovar?
5 A. I think that in Vukovar they did not.
6 Q. Do you know how long Mr. Dokmanovic, you remember that he was the
7 president of the Municipal Assembly, how long did he stay as president of
8 the Municipal Assembly?
9 A. I think it was until the end -- until the war broke out.
10 Q. Do you know why he stopped performing that function?
11 A. I'm not sure.
12 Q. Do you recall that at some point before the war broke out, there
13 was an administration imposed? Was there some other type of authority
14 imposed other than the regular authority? Was there any kind of
15 commissioner appointed?
16 A. I don't know that. I'm not quite sure about that.
17 Q. From what you said in your answers to the questions by my learned
18 friend from the Prosecution, it was clear that you know Marin Vidic, Bili.
19 Is that correct?
20 A. Yes, I know him. That is correct.
21 Q. Do you know what duties he was performing at that time just before
22 the conflict broke out?
23 A. Yes, I think that he was the one who followed after
24 Mr. Dokmanovic. He took over his duties.
25 Q. You will probably agree with me and many before you have said the
1 same, that Vukovar and its environs were a national -- a multi-ethnic
2 community. There were not only Croats and Serbs but other ethnic groups
3 as well.
4 A. Yes, that is correct. There were members of 22 ethnic groups
5 living there.
6 Q. Would you agree with me that a lot of ethnic Serbs lived in
7 Vukovar itself as well as in surrounding areas where they constituted
8 either a majority or wholly populated those areas?
9 A. Yes, I would agree with you.
10 Q. Is it true that in early 1991, following these elections and after
11 the constitutional changes in the Republic of Croatia, tensions began to
12 emerge in these relations between Serbs and Croats, first of all?
13 A. Yes, that is correct.
14 Q. Are you aware that the constitution that I mention which was
15 adopted in late 1990 changed the previous constitution, whereby Serbs as
16 an ethnic group or a nation no longer constituted an integral part of the
17 Republic of Croatia, but it was formulated in the following way, that
18 Croats were members of the Republic of Croatia and that this was, in a
19 way, something that created the initial concerns by Serbs living in
21 A. Yes, I think that is correct.
22 Q. Today you mention the tragic incident in Borovo Selo on the 2nd of
23 May, but what I'm interested in is a little bit before that because when
24 you spoke about that event you talked about the roadblocks and barricades.
25 Could you tell us actually what was beginning to happen before that?
1 A. Before that I said that ethnic Serbs, as you said, those who lived
2 in the villages where they constituted a majority, set up barricades in --
3 at the entrances to their village because -- actually, I don't know what
4 the reason was for this, but it was probably partly done out of fear
5 because of what had happened.
6 Q. Were any such barricades set up in predominantly Croat areas and
7 settlements, such as Borovo Naselje?
8 A. There was a barricade set up between Borovo Naselje and
9 Borovo Selo near the railway track. I know about that one. The only
10 barricade that was set up was near the village of Sotin, which was the
11 only predominantly Croat village in the surroundings of Vukovar.
12 Q. Although at the time you were no longer working, do you perhaps
13 happen to know, based on conversations that you had with your friends,
14 that a number of Serbs no longer reported for work in Vukovar?
15 A. Yes, I am familiar with that.
16 Q. When you spoke about what happened in Borovo Selo on the 2nd of
17 May, 1991, you said that this incident, for you, marked the beginning of
18 clashes. Can you tell me what specifically was going on in Vukovar in May
19 and June?
20 A. I can't be certain. I don't know what preceded the police being
21 dispatched to Borovo Selo, to begin with. At this point in time,
22 Vukovar's police was still a regular institution, and they were free to
23 move about all of Vukovar's different areas, including Borovo Selo. But
24 we all know what happened.
25 Q. Thank you, but I wasn't asking about the details of that
1 particular incident. I assume you don't know that much about it. What I
2 was asking is how this affected whatever happened in Vukovar in May and
4 A. This was a signal for people in Vukovar to start organising
5 themselves. They all believed, as I did myself, that this was not the end
6 of it, that this was no isolated incident, but rather a massacre.
7 Q. What specific steps were taken? You mentioned preparations of
8 some kind. What exactly did you have in mind?
9 A. People started organising for the town's defence. People started
10 obtaining weapons and, as I say, they were organising the town's defence.
11 Q. Thank you. When you say "the town's defence," preparing the
12 town's defence, what sort of preparation do you have in mind specifically?
13 A. They started setting up small groups of people in certain areas in
14 Vukovar such as Mitnica, Borovo Naselje, Luzac, and such-like. People
15 started setting up units for the town's defence.
16 Q. The setting up of these defence units and organising people, did
17 this entail obtaining weapons for these people?
18 A. It probably did.
19 Q. Can you please tell me if earlier on, perhaps in the spring of
20 that year, you heard anything about unarmed units being reviewed under the
21 aegis of the HDZ in a number of villages around Vukovar?
22 A. I am not aware of anything like that happening in Vukovar itself.
23 Q. I didn't mean Vukovar itself, but what about villages such as
24 Bogdanovci, Lovac?
25 A. I heard something about that, yes.
1 Q. Were you a member of the HDZ? I suppose not, but please correct
2 me if I'm wrong.
3 A. I was not a member of the HDZ or any party.
4 Q. That was my understanding after that answer that you just
5 provided, but I need to ask all the same because I believe these reviews
6 that I am talking about had been organised by the HDZ, of all parties.
7 So you heard people talk about this but you don't know anything
8 more about that?
9 A. No, I don't.
10 Q. Did you perhaps hear anything about people finding different other
11 ways of purchasing and obtaining weapons in their own time?
12 A. Yes. That was also something that started happening.
13 Q. Do you know when the Crisis Staff was established in Vukovar
15 A. I don't know the exact date.
16 Q. Roughly speaking in relation to the incident at Borovo Selo, how
17 soon after that?
18 A. I think quite soon after that.
19 Q. Did you personally hear from anyone about explosions, fires in
20 catering establishments and private homes during the spring and early
21 summer of 1991?
22 A. There was this one time that I saw something, but other than that
23 I heard about things happening, just like everyone else.
24 Q. Based on any conversations that you had with people about this,
25 was this another factor which contributed to the growing sense of disquiet
1 among the residents of Vukovar?
2 A. I should think so, yes.
3 Q. You mentioned August as the period when armed clashes began. Is
4 that right?
5 A. Yes.
6 Q. I suppose you know where the JNA barracks was located in Vukovar?
7 A. Yes.
8 Q. Can you tell me if the JNA were facing any problems entering or
9 leaving the barracks or travelling around the Vukovar area at all,
10 generally speaking?
11 A. Not as far as I know.
12 Q. Did you perhaps hear that columns of vehicles were stopped in
13 certain places because of check-points or barricades set up by the
14 civilian population or something like that?
15 A. No.
16 Q. What about the barracks itself, was it not under siege at one
17 point because its water, electricity supplies, as well as phone lines were
18 cut off?
19 A. I don't think so.
20 Q. Throughout this period of time, I mean until the end of November,
21 were the JNA people leaving the barracks throughout this period of time?
22 A. Not as far as I know.
23 Q. Today in answer to one of the questions asked by my learned
24 friend, you used that map of Vukovar to mark the front line, the
25 confrontation line, or whatever I should call it. You remember that,
2 A. Yes, I do.
3 Q. If necessary, we can show the map again for you to have a look.
4 But would you agree with me, sir, if I said that at this point in time the
5 JNA barracks found itself behind the front line in a way, isolated, and
6 surrounded by the defending forces, as you say?
7 A. I don't know about that. I don't know when this happened.
8 Q. Would it be of any assistance to you if we tried showing you the
9 map again?
10 A. No, I don't think that's necessary.
11 Q. Fair enough. You say that the line stayed like that for quite
12 some time and that the only major shift occurred when the withdrawal
13 occurred, which you marked in that other drawing that you made?
14 A. Yes.
15 Q. Can you give us an idea when this happened exactly and how long it
16 took, some sort of a time-line, please, of this shift between the two
18 A. That was in early September.
19 Q. When you say "early September," what are we talking about? The
20 first line being established or the second line?
21 A. That was after the barracks had been taken and the second line was
22 been established.
23 Q. You say after the barracks had been taken. By whom?
24 A. The line moved from the barracks closer to the town centre once
25 the JNA had entered.
1 Q. Does that mean that before this time there was no communication
2 between the JNA forces inside the barracks and the JNA forces outside the
3 barracks or at the front line?
4 A. Can you ask that question again, please.
5 Q. Does that mean that the JNA barracks was entirely surrounded and
6 besieged by the Croatian forces until the other front line was eventually
8 A. I don't know.
9 Q. You yourself said that the barracks was taken when the second
10 front line was established and that it was at this point in time that the
11 JNA reached the barracks?
12 A. I may have misspoken, but the barracks was never in anybody else's
13 hands but the JNA.
14 Q. I agree with you fully on that one. It definitely wasn't, but
15 there was this one point in time when the barracks found itself behind or
16 within the lines occupied by the Croatian forces.
17 MR. DOMAZET: [Interpretation] Can I have please Exhibit 185,
18 Mr. Usher. I would like to show the witness this exhibit. It was just
19 admitted today.
20 Q. Can you see this, sir?
21 A. Yes.
22 Q. You explained today about the line that you marked with the
23 letter A. That was the front line or the first front line, if I may call
24 it that, up until a certain point in time. You see just behind that line,
25 on the inside of that line, as it were, the mark for the JNA barracks.
1 This seems to imply that the barracks was located in an area controlled by
2 the Croatian forces. I do agree that the JNA never left the barracks, but
3 throughout this period of time the JNA barracks was in an area where it
4 was surrounded by Croat defenders. Would you agree with me, sir?
5 A. Yes, that sounds likely.
6 MR. DOMAZET: [Interpretation] We can take the exhibit off now.
7 But next I would like to show Exhibit 186.
8 Q. You remember this one, sir, don't you? You drew a line today and
9 explained that the second front line, as it were, was near Sajmiste. If
10 we look at this, it's clear that the JNA's outside. What I want to know
11 is about the positions at Mitnica, positions that were still under the
12 control of the forces. You agree with me, right?
13 A. That's at Mitnica between Vucedol and the first houses in Mitnica.
14 Q. Can you mark that for us on this map, please.
15 MR. DOMAZET: [Interpretation] We intend to tender this as a
16 separate exhibit. We don't want to spoil this one.
17 Q. I assume this is the continuation of that line?
18 A. [Marks].
19 Q. Maybe it's easier for us to have a clean map, a new one. Do you
20 want a fresh, unmarked map, or do you want a new one?
21 A. That's all right.
22 Q. Thank you.
23 MR. DOMAZET: [Interpretation] Can we please take this exhibit off
24 then and place -- and place 186 -- 156. I see that the transcript
25 suggests 186. I meant 156.
1 Q. Can you now find your way around, sir? The JNA barracks, you see
2 that, right? The front line at Mitnica, can you mark that for us, please.
3 MR. DOMAZET: [Interpretation] That's fine. Don't zoom in too much
4 because --
5 THE WITNESS: [Interpretation] Between Vucedol and Mitnica.
7 MR. DOMAZET: [Interpretation]
8 Q. Can you draw a line towards Luzac.
9 A. [Marks].
10 MR. DOMAZET: [Interpretation] If we could please zoom out a little
11 so that we can see Luzac to see if the witness can ... Thank you very
13 Q. Could you please put a letter A where Mitnica is.
14 A. [Marks].
15 Q. Can you see Luzac on this map, sir? Mark it with a letter B,
17 A. [Marks].
18 Q. Thank you very much, Witness.
19 MR. DOMAZET: [Interpretation] Your Honours, I would like to tender
20 this map into evidence.
21 JUDGE PARKER: It will be received.
22 THE REGISTRAR: This map will be assigned exhibit number 189, Your
24 MR. DOMAZET: [Interpretation] Thank you.
25 Q. Sir, now I'd like to go back to August 1991. You mentioned that
1 the first shelling of Vukovar occurred in August, and planes flying over.
2 I think you personally saw these planes, if I'm not mistaken. Is that
4 A. Yes, I did.
5 Q. Those two planes that you were talking about, do you know that
6 those were actually shot down while flying over Vukovar?
7 A. No, I don't.
8 Q. Have you ever heard anything about those two planes being shot
10 A. Yes.
11 Q. When you say "no," you mean you didn't hear anything about it at
12 the time, you didn't know about it at the time? Is that what you meant?
13 A. Yes.
14 Q. Can you tell me when you found out and what you found out about
15 these airplanes?
16 A. From stories of some people. I found out that the planes were
17 shot down at the other side of town. I didn't see it. People talked
18 about it.
19 Q. Do you know when in August this happened? When did you see these
20 planes, since you didn't see them being shot down?
21 A. I saw them in early August.
22 Q. Are you sure about that, sir, since many have already said that
23 this happened sometime -- approximately on the 24th of August when the
24 planes appeared?
25 A. Well, perhaps they saw other planes.
1 Q. Thank you. Could you please tell me what your role was in the
2 war. Were you mobilised? In what way?
3 A. I wasn't mobilised. I was a member of the civilian protection of
4 the town of Vukovar. You all know what the tasks of civilian protection
5 are: Taking care of the civilian population, provision of food, water,
6 medicines, and everything else that is implied by the work of members of
7 the civilian protection.
8 Q. When did you start doing this work?
9 A. Sometime after I moved from my own building to the shelter
10 opposite from the hospital at the -- the shelter at the Vupik building.
11 Q. When you spoke before about preparations, you also talked about
12 May and June after the incident in Borovo Selo. You said that
13 preparations started in food, weapons, and so on. You didn't participate
14 in that, did you?
15 A. No, I didn't.
16 Q. If I'm not mistaken, at that time you were 43 years old or
18 A. Yes, that is correct.
19 Q. You said that as you were a reserve officer, a trained reserve
20 officer, and then you also knew a lot from your earlier jobs, how is it
21 possible that you were not mobilised into the Croatian forces which surely
22 didn't have that many people at its disposal, in view of your training in
23 the military skills?
24 A. I was an invalid.
25 Q. So that's why?
1 A. Yes, that's why.
2 Q. So does that mean that even before that you were not obliged to
3 serve in the military. You were excused from serving?
4 A. Yes, that is correct. I was excused and I was no longer summoned
5 to perform any task.
6 Q. If I understand you properly, if you are exempt from military
7 service, then you were not called up. That was your case, was it?
8 A. I don't know.
9 Q. Did you ever officially ask that a medical commission establish
10 the degree of your disability?
11 A. I asked for that before the conflict broke out. I asked to be
12 exempt. I asked the military department to exempt me, but after that I no
13 longer made such a request.
14 Q. When you replied to questions by my learned friend about the
15 public wells in Vukovar, you said that there were many such wells. My
16 question is about the private wells. Am I correct when I say that each
17 private home in Vukovar or practically every private house in Vukovar had
18 its own well that provided water but not drinking water?
19 A. I don't think that that is correct. It wasn't possible to dig so
20 many wells. The ones that did operate were used. It depends on the
21 owner. They were used for whatever their owner saw fit to use them for.
22 Q. Since Vukovar is on the banks of the Danube, that water is not at
23 a large depth, so it is easy to get to that water?
24 A. If I may correct you, the wells in Vukovar drew their water from
25 the Sava River.
1 Q. Very well. I won't insist on that, but ...
2 You mentioned that from the time you left your apartment you --
3 you went to the shelter which was close to the military and police
4 buildings in Vukovar. Is that correct?
5 A. Yes, it is.
6 Q. And you said that you were there until the 15th of November. Is
7 that correct?
8 A. Yes, it is.
9 Q. You also said today that on at least two occasions or on two
10 occasions you saw Dr. Vesna Bosanac and Mr. Marin Bili in the shelter, and
11 their visits related to the negotiations that were being conducted?
12 A. Yes, that is correct. That was on two occasions.
13 Q. So it's logical that this happened before the 15th. Can you
14 determine how much before the 15th you saw them?
15 A. It was probably 10 or 15 days before the 15th.
16 Q. Thank you. Do you know who they had these negotiations with?
17 A. They said that they conducted talks with representatives of the
18 Yugoslav People's Army.
19 Q. And you know that on the basis of what they said?
20 A. Yes, that's correct.
21 Q. Before I continue with my questions I would like to clarify
22 something in the transcript. It states the 15th, but it does not say the
23 15th of November. We're speaking about November. When we talked about
24 the 15th, what we meant was the 15th of November. Thank you.
25 You mentioned two occasions. What was the first time that you saw
1 them and what was the second time, and how much time passed between those
2 two occasions?
3 A. The two occasions were about two or three days apart.
4 Q. So you saw them twice within a period of three days. And on both
5 occasions it was said that they were discussing evacuation with
6 representatives of the JNA, evacuation from Vukovar?
7 A. Yes, that is correct.
8 Q. Before we go on, unfortunately we still have a problem with the
9 transcript. I think that you confirmed something but it wasn't recorded
10 in the transcript, that this is November, that it is the 15th of November,
11 that it's that date, that we are talking about that month.
12 A. Yes.
13 Q. Thank you. I apologise, but I had to say it again because of the
15 After that, during those few days, you said the first meeting was
16 ten days before and then the second one was a couple of days after that.
17 Did you hear from somebody else perhaps, if not from them, what was going
18 on with these talks?
19 A. No, I didn't hear anything.
20 Q. And on the 15th of November did you hear anything? Was that the
21 reason why you moved into the hospital or --
22 A. I mentioned that there was talk about negotiations being conducted
23 between the JNA and Vukovar city representatives. We were not
24 100 per cent informed about the negotiations, so out of caution I decided
25 to go to the hospital with my wife because I thought that if anything were
1 to happen a larger crowd is more powerful, and there are more or better
2 possibilities to stay alive in a bigger crowd. So that was the main
3 reason why I moved to the hospital.
4 Q. Thank you. I think that today you mentioned how you heard that
5 the fall of Vukovar was inevitable, that it was bound to happen, and
6 perhaps that was also one of the reasons why you moved?
7 A. Because I was in the centre of town, in the middle of the events
8 close to the MUP, they were with us, from what they said I heard that
9 there were no longer any resources left for defence, that the hospital was
10 packed with wounded, not only the hospital but other shelters as well, and
11 that was one of the reasons for going to the hospital.
12 Q. Thank you. That day you came to the hospital with your wife.
13 Where did you stay at the hospital? Did anybody approve that you stayed
14 there, if you sought anybody's approval?
15 A. Well, we didn't seek anyone's approval. We settled in a corner
16 somewhere. We thought that was the safest place. It was in the basement
17 of the hospital, which was packed --
18 THE INTERPRETER: Interpreter's correction.
19 THE WITNESS: [Interpretation] It was in the hall on the ground
20 floor of the hospital because the basement was so packed and there was no
21 room for anyone else, and also the atmosphere there was terrible, so
22 that's why we found a place for ourselves in the hall of the hospital,
23 believing that that was the safest place.
24 MR. DOMAZET: [Interpretation]
25 Q. Were you also together with people who were sick or wounded or
1 were they placed somewhere else?
2 A. They were in the basement of the hospital. We were above in the
3 hall of the hospital.
4 Q. At that time there still weren't that many civilians at the
6 A. Right when we came, there weren't too many civilians from other
7 shelters that were near the hospital.
8 Q. And you stayed there. Neither you or your wife left the hospital
9 until the 19th. Is that correct?
10 A. Yes, that is correct.
11 Q. Thank you very much.
12 MR. DOMAZET: [Interpretation] Your Honours, I'm finished with one
13 topic, and I think it's time to complete our work for today. I plan to
14 continue and also finish tomorrow morning.
15 JUDGE PARKER: Mr. Domazet, thank you. Yes, well, there's only a
16 minute to go so there's little point on turning to a new topic.
17 We must adjourn now for the day, as another trial continues
18 shortly. We will resume tomorrow at 9.00 in the morning in this
20 --- Whereupon the hearing adjourned at 1.46 p.m.,
21 to be reconvened on Friday, the 10th day of
22 February, 2006, at 9.00 a.m.