Tribunal Criminal Tribunal for the Former Yugoslavia

Page 2150

 1                           Monday, 1 December 2008

 2                           [Closed session]

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 2151











11 Pages 2151-2225 redacted. Closed session.















Page 2226

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12                           [Open session]

13             THE REGISTRAR:  Your Honours, we are back in open session.

14             JUDGE MOLOTO:  Thank you very much.  If you could get help with

15     the blind.

16             How did you say you pronounce the witness's surname, sir.

17             MR. SAXON:  Your Honour, the correct pronunciation of the

18     witness's surname is "Vole."

19             JUDGE MOLOTO:  Vole.

20             MR. SAXON:  Vole, yes.

21             JUDGE MOLOTO:  Ask him to say it slowly when you introduce him.

22             MR. SAXON:  I'm told it's an old Norse term that means "wall" or

23     "fortification."

24             JUDGE MOLOTO:  Wall not war.

25                           [The witness entered court]

Page 2227

 1             JUDGE MOLOTO:  Good evening, sir.  Just wear your headphones and

 2     then make the declaration, please.

 3             THE WITNESS:  I'm hearing French, Your Honour.

 4             JUDGE MOLOTO:  Do you hear something different?

 5             THE WITNESS:  Now I hear you.

 6             JUDGE MOLOTO:  Thank you.

 7             THE WITNESS:  I solemnly declare that I will speak the truth, the

 8     whole truth, and nothing but the truth.

 9             JUDGE MOLOTO:  Thank you very much.  You may be seated.

10             THE WITNESS:  Thank you.

11                           WITNESS:  MORTEN HVAAL

12             MR. SAXON:  Your Honours, Mr. Hvaal will be testifying here today

13     pursuant to Rule 92 ter.

14                           Examination by Mr. Saxon:

15        Q.   Sir, is your name Morten Hvaal?

16        A.   Yes, it is.

17        Q.   Are you a citizen of Norway?

18        A.   I am.

19        Q.   What is your profession?

20        A.   I'm a photographer.

21        Q.   Do you recall giving a statement to the Office of the Prosecutor

22     of this Tribunal in March 1995?

23        A.   Yes, I do.

24        Q.   And two days ago in my office, did you have an opportunity to

25     review that statement?

Page 2228

 1        A.   Yes, I did.

 2        Q.   And does that statement accurately reflect your declaration and

 3     what you would say if examined orally today?

 4        A.   Yes, it does.

 5             MR. SAXON:  Your Honours, at this time, I would seek to tender

 6     what is 65 ter number 9360, which is the ICTY statement of this witness

 7     from 28 March 1995.

 8             JUDGE MOLOTO:  65 ter 9360 is admitted into evidence.  May it

 9     please be given an exhibit number.

10             THE REGISTRAR:  That will be Exhibit P376, Your Honours.

11             JUDGE MOLOTO:  Thank you.

12             MR. SAXON:

13        Q.   Mr. Hvaal, do you recall giving a statement to the Office of the

14     Prosecutor in February of 2001?

15        A.   Yes, I do.

16        Q.   Again, on Saturday, did you have an opportunity to review that

17     statement in my office?

18        A.   Yes, I did.

19        Q.   And does that statement accurately reflect your declaration and

20     what you would say if examined orally today?

21        A.   Yes, it does.

22             MR. SAXON:  Your Honour, at this time, I would seek to tender

23     what is 65 ter number 9361, which is a redacted version of Mr. Hvaal's

24     statement from February 2001.

25             JUDGE MOLOTO:  Thank you.  It's admitted into evidence.  May it

Page 2229

 1     please be given an exhibit number.

 2             THE REGISTRAR:  That will be Exhibit P377, Your Honours.

 3             MR. SAXON:

 4        Q.   Mr. Hvaal, do you recall giving testimony before this Tribunal in

 5     the trial of Stanislav Galic on the 24th and 25th January 2002?

 6        A.   Yes, I do.

 7        Q.   And two days ago, did you have the opportunity to review the

 8     transcript of your testimony in my office?

 9        A.   Yes, I did.

10        Q.   And does that testimony transcript accurately reflect your

11     declaration and what you would say if examined orally today?

12        A.   Yes, it does.

13             MR. SAXON:  Your Honours, at this time, I would submit 65 ter

14     numbers 9363, which is redacted version of Mr. Hvaal's testimony from

15     24 January 2002; and 65 ter 9364, which is a redacted version of

16     Mr. Hvaal's testimony from 25 January 2002; and associated exhibits

17     65 ter 2998, 3000, and 3007.

18             JUDGE MOLOTO:  65 ter 9363 is admitted into evidence.  May it

19     please be given an exhibit number.

20             THE REGISTRAR:  That will be Exhibit P378 Your Honours.

21             JUDGE MOLOTO:  Thank you very much.

22             Then you have 65 ter 9364, 2998, 3 000, and 3007.  May they be

23     admitted into evidence and given exhibit numbers.

24             THE REGISTRAR:  65 ter 09364 will be Exhibit P379; 65 ter 02998

25     will be Exhibit P380; 65 ter 03000 will be Exhibit P381; and 65 ter 03007

Page 2230

 1     will be Exhibit P382, Your Honour.

 2             JUDGE MOLOTO:  Thank you very much, Madam Registrar.

 3             Yes, Mr. Saxon.

 4             MR. SAXON:  Your Honours, with your permission, I will now give a

 5     summary of the evidence that has just been tendered for admission.

 6             JUDGE MOLOTO:  You may.

 7             MR. SAXON:  Morten Hvaal is a photojournalist who has reported

 8     for many conflict zones around the world.  Between 1992 and 1997,

 9     Mr. Hvaal was based in Sarajevo where he worked for the Associated Press

10     news agency.  Between 1992 and 1995, Mr. Hvaal observed positions

11     controlled by the Bosnian/Serb army, as well as areas controlled by the

12     Army of Bosnia-Herzegovina.  Mr. Hvaal witnessed a number of sniping and

13     shelling incidents in Sarajevo where civilians were killed or wounded.

14     Mr. Hvaal also arrived on the scene of sniping and shelling incidents

15     shortly after they occurred.

16             In addition, Mr. Hvaal and his colleagues were also targets of

17     snipers as they drove through the streets of Sarajevo.  Mr. Hvaal

18     photographed these incidents and other aspects of life in Sarajevo for

19     the Associated Press.

20             Your Honours, may I have your permission to ask several more

21     questions of the witness?

22             JUDGE MOLOTO:  You may.

23             MR. SAXON:

24        Q.   Mr. Hvaal, you and I speak the same language so we need to be

25     careful to pause at the end of questions and answers to let the

Page 2231

 1     interpreters catch up, all right?

 2             From when to when did you work in Sarajevo?

 3        A.   From April of 1992 until 1995 as photographer; and then from

 4     there on, for another two years or slightly less than two years as an

 5     operations manager.

 6        Q.   And who were you working for at that time?

 7        A.   I worked for the Associated Press.

 8        Q.   In 1992, was the Associated Press a small news agency, medium, or

 9     large?

10        A.   The Associated Press is the world's largest and oldest news

11     gathering organisation.

12        Q.   And was that also true in 1992 and the subsequent years?

13        A.   Yes.

14        Q.   What kind of events did you photograph in Sarajevo?

15        A.   I was part of the team that covered as many aspects of the

16     conflict and the situation in the whole of the former Yugoslavia, and I

17     was then the team member that was -- who was in Sarajevo.  We tried to

18     cover anything that we found to be relevant to the situation.

19        Q.   Okay.  And can you give a few examples, please?

20        A.   Obviously, the results of acts of war are and will be the focus

21     of any journalism that takes place in a conflict area.

22        Q.   Okay.  After you took your photographs, how would they be

23     disseminated by the Associated Press?

24        A.   The Associated Press photography and text television and news

25     service functions on a subscription basis; meaning that a large number of

Page 2232

 1     media outlets throughout the world receive a service of photographs,

 2     text, television, and radio news.  The photographs that we would take on

 3     assignment would be transmitted to our headquarters in London, and from

 4     there on distributed to our network or the Associated Press network all

 5     over the world, to clients all over the world.

 6        Q.   And to your knowledge, were your photographs from Sarajevo

 7     published in the news media?

 8        A.   Yes.  We closely monitor to what extent our production is

 9     published.

10        Q.   And to your knowledge, what kind or kinds of news media published

11     your photos from Sarajevo?

12        A.   The Associated Press is one of the leading agencies obviously;

13     and in most cases, if a newspaper or a magazine has one or two --

14     subscribes to one or two news agencies, the Associated Press will be one

15     of them.  So it's fair, I think, to say that on an important story like

16     the situation in Sarajevo during those years, most major international

17     media would at some point have used the production that we transmitted

18     out from there, yes.

19        Q.   What kind or kinds of media are you talking about?

20        A.   I'm talking about major international newspapers, magazines,

21     television channels that sometimes use still photographs, as well as, you

22     know, this -- it's a broad service.  It goes out to anyone basically.

23     There's also the possibility of buying this directly from the files of

24     the AP.

25        Q.   And do you know how many media outlets published your photos from

Page 2233

 1     Sarajevo?  Do you have any idea?

 2        A.   You mean throughout the period?

 3        Q.   Yes?

 4        A.   It would be in the thousands and thousands.  I mean, the

 5     Associated Press photo service reaches several thousands newspapers every

 6     day.  So many of them would have used photographs from Bosnia and from

 7     Sarajevo on a fairly regular basis.

 8             MR. SAXON:  Okay.  Can we please show the witness -- it's

 9     actually now part of Exhibit -- excuse me, it is now Exhibit P380.  Can

10     we please show the witness that, please.

11        Q.   Mr. Hvaal, do you recognize this photograph?

12        A.   Yes, I do.

13        Q.   Did you take it?

14        A.   Yes, I did.

15        Q.   Where and when was this photograph taken?

16        A.   This photograph was taken, I believe, in August of 1993, in what

17     we referred to as the French hospital in Sarajevo.  It is a photograph of

18     a, I believe, five-year-old girl by the name of Irma Hadzimuratovic.

19        Q.   And she appears to have some bandages on her abdominal area.  Do

20     you know what caused her injuries?

21        A.   She was wounded in a mortar attack that also killed her mother,

22     and I believe in the backyard of the building where she lived.

23        Q.   Was this photograph disseminated by the Associated Press to its

24     media subscribers?

25        A.   Yes, it was.

Page 2234

 1        Q.   What, if anything, happened after that?

 2        A.   It was part of the media coverage of this incident that led to

 3     the first proper evacuation of wounded children from Sarajevo since the

 4     beginning of the siege.

 5        Q.   And who carried out that evacuation?

 6        A.   The first evacuation was of Irma herself and her father, as I

 7     recall.  That was carried out by the royal air force, the British royal

 8     air force.  Later on, several or many other children were flown out.  I

 9     believe the first two aeroplanes that came in were Hercules planes from

10     Britain and Sweden.  Those were the first planes that came in to evacuate

11     these children, but this went on over a period of time.

12        Q.   Was the Associated Press the only news agency to cover the story

13     about this girl named Irma?

14        A.   No.  As a result of this initial photograph, the other media

15     obviously caught on to this story, and I think it became the -- for quite

16     sometime, you know, it was the main story out of Sarajevo.

17        Q.   When you say "the other media," are you talking about local media

18     or international media or a mix?

19        A.   In this particular case, everyone, but particularly the

20     international media, television, news agencies, other photography

21     agencies, newspapers.  Basically, all the international media and I

22     suspect most of the national media that were in Sarajevo at the time

23     would have covered this in some way.

24        Q.   Okay.  Thank you.

25             MR. SAXON:  Your Honours, at this time, I have no further

Page 2235

 1     questions.

 2             JUDGE MOLOTO:  Just before I hand you over, Mr. Hvaal, you

 3     mentioned that you started working as a photographer and later as an

 4     operations manager.

 5             THE WITNESS:  Yes.

 6             JUDGE MOLOTO:  What did your work entail as an operations

 7     manager.

 8             THE WITNESS:  I was responsible for the well-being of the

 9     Associated Press staff, both international and local, throughout the

10     former Yugoslavia.

11             JUDGE MOLOTO:  So you were no longer running around and

12     photographing?

13             THE WITNESS:  As of the Dayton agreement when hostilities

14     effectively ceased, it was decided that I would be more useful given my

15     experience in the area trying to assist a large of number of staff that

16     came in following the international troops that moved in to Bosnia

17     shortly after that, yes.

18             JUDGE MOLOTO:  In what way did you assist this large number of

19     staff?

20             THE WITNESS:  By providing -- by making sure that they had the

21     equipment they needed, such as armoured vehicles, personal safety

22     equipment; that everyone had the training they needed; and other

23     equipment that they would need to survive and operate in these fairly

24     hostile conditions.  I also made sure that they had the communications

25     equipment, such as satellite communications equipment and so on, to

Page 2236

 1     function.

 2             JUDGE MOLOTO:  So going back to my question, you at that time

 3     were no longer going about taking photographs of incidents that were

 4     happening.  It was the other people who were doing that.  You were

 5     doing -- you were making sure that you give them logistical support?

 6             THE WITNESS:  After 1995.

 7             JUDGE MOLOTO:  Yes, when you were now a operations manager.

 8             THE WITNESS:  Effectively, when I became operations manager,

 9     obviously, I still have my cameras with me.  If there was an incidents, I

10     would photograph it.  I didn't cease to be a photographer.  But my main

11     responsibility as of sometime 1995, after the siege of Sarajevo began to

12     lift and it was no longer that critically difficult to work there, I --

13     my responsibility was shifted, yes.

14             JUDGE MOLOTO:  Thank you very much.

15             Yes, Mr. Lukic.  Mr. Lukic, I guess you are the one coming out,

16     coming forward.

17             MR. LUKIC: [Interpretation] Let me just prepare after having

18     taken up a reserve position.

19             JUDGE MOLOTO:  By all means.

20                           Cross-examination by Mr. Lukic:

21        Q.   [Interpretation] Mr. Hvaal, good evening.  Did I pronounce your

22     name right?

23        A.   Not bad.

24        Q.   I'm Novak Lukic, and on behalf of the Defence team of

25     Mr. Perisic, I'm going to put a few questions to you now.

Page 2237

 1             In fact, when you were answering Mr. Saxon's questions, you

 2     already covered part of the first topic that I wanted to deal with, and

 3     it has to do with certain specific matters in relation to a news agency

 4     and other media.

 5             As far as I know, as a layperson, the difference between a news

 6     agency and other media television and other media that cover what is

 7     known as reporting, is that an agency carries news in effect, does not

 8     make comments.  It is an agency's job to convey a certain piece of

 9     information, a piece of news, and then hands it over to other media that

10     then further disseminate it; right?

11        A.   Not quite, no.  Larger news organisations also produce journalism

12     back in the shape of commentary and so on, opinion pieces and so on.  So

13     it's a very broad service.  It basically covers pretty much everything

14     you need to run national or international coverage in a newspaper.

15     Certainly, in a combination of agencies, you would be able to do that,

16     yes.

17        Q.   However, what I see is that, in essence, a news agency receives

18     information and then it is supposed to convey this information further to

19     someone who wants to present it through the media to the public.  The

20     essence of an agency's work is that they do not provide comments of their

21     own; for example, like editorials or commentaries in TV studios, things

22     like that.  A news agency only deals with news and tries to sell it

23     further on, so to speak?

24        A.   Again not quite, no.

25             JUDGE MOLOTO:  Yes, Mr. Saxon.

Page 2238

 1             MR. SAXON:  Hasn't Mr. Lukic merely repeated his last question

 2     which was already answered?

 3             JUDGE MOLOTO:  Mr. Lukic.

 4             MR. LUKIC: [Interpretation] I thought I wasn't repeating my

 5     question, but if it seems that I did repeat my question, I was just

 6     trying to be more specific.  It seems that my questions are too extensive

 7     and too confused, as it were.

 8        Q.   A news agency, does it provide information directly to the end

 9     user; that is, to say, the public?

10        A.   Yes.  Today it does in the form of electronic news certainly.  In

11     those days, this was before the internet, it still provided news coverage

12     directly to the public in the form of radio transmissions, for instance.

13     So it is a finished product that leaves the news agency.  These are

14     not -- it's not just a stream of information.  It is a finished product,

15     finished stories, finished photographs, finished television

16     reproductions, and so on.

17             Also, as you asked earlier, this is also something that is sold;

18     people subscribe to this.  So they've already paid; you don't sell

19     individual stories.  People have already paid through a service.

20             JUDGE MOLOTO:  Do they still pay for the service even today when

21     you are accessible through internet?  So the end user can go straight to

22     the internet and get the information from you, instead of getting it via

23     another media who has got it from you?

24             THE WITNESS:  There are a number of different ways of doing this.

25     The large international news agencies, like the Associated Press,

Page 2239

 1     Reuters, AFPDA, and so on, still operate on a subscription basis.  The

 2     smaller agencies do individual sales on behalf of individual

 3     photographers.

 4             JUDGE MOLOTO:  Thank you.

 5             MR. LUKIC: [Interpretation]

 6        Q.   On the basis of what I manage to see from your statements and

 7     from your testimony, generally speaking, you were in the territory the

 8     former Yugoslavia; that's the term that we use here.  Even that -- you

 9     were there even before you came to Sarajevo in 1992.  When was it that

10     you first worked at Associated Press office anywhere in the former

11     Yugoslavia?

12        A.   That would have been in early 1991.

13        Q.   So from early 1991 onwards, before you went to the territory of

14     Sarajevo, for the most part, you were in the territory of the former

15     Yugoslavia, am I right?

16        A.   Well, Sarajevo is also in the former Yugoslavia, so I'm not sure

17     I understand your question.

18        Q.   From the beginning of 1991, up until you went to Sarajevo for a

19     longer stint in April 1992, did you spend the interim period in the

20     territory of the former Yugoslavia?

21        A.   Not all of it, no.  I was there -- I was based in Belgrade for a

22     few months in 1991, and then I left and did several other stories in

23     other parts of the world before coming back in 1992.

24        Q.   However, during 1991, you also covered the territory of Eastern

25     Slavonia and the war in Croatia, if I can put it that way?

Page 2240

 1        A.   Yes, from Belgrade.

 2        Q.   The Associated Press office in Belgrade was actually in Belgrade

 3     during the times of the Socialist Federal Republic of Yugoslavia, pre-war

 4     Yugoslavia; right?

 5        A.   Yes.

 6        Q.   I'm talking about the period while you were in Belgrade.  While

 7     you were still in Belgrade before you went to Sarajevo, did you have

 8     occasion to follow the reporting of the Yugoslav media, the Belgrade

 9     media; or did you hear the comments of those media about reporting from

10     Yugoslavia?

11        A.   To some extent, yes.  But a photographer spends most of his day

12     either in the field or in those days in a dark room, so you try and focus

13     on the information that is necessary in order for you to provide -- or in

14     order for me as a photographer to provide the coverage and the

15     photography that I need to do.  So there isn't a lot of time left for

16     perusing local newspapers and having them translated and so on, no.

17        Q.   However, at the time, were you aware of the opinion that

18     prevailed that the authorities were heavily influencing the media,

19     especially the state-owned media and TV, anywhere in the former

20     Yugoslavia?

21        A.   Like most places in the world, I suspect, with the exception of a

22     very limited number of countries, there is going to be some degree of

23     government interference in media.  To what extent that was taking place

24     in the former Yugoslavia and with the Belgrade based media, would be very

25     difficult for me to give an exact analysis of.

Page 2241

 1        Q.   During your stay in Sarajevo, did you have occasion to follow the

 2     reporting of their media?  Although I assume that you do not understand

 3     the B/C/S language very well, did you have interpreters or translators,

 4     and did you know what their reporting about events was like?

 5        A.   Our field office in Sarajevo had a number of translators and

 6     local journalists working for it whose job it was to follow the news

 7     coverage.  Because of the technical difficulties of producing printed

 8     news coverage in a city under siege with no water, no electricity, and so

 9     on, basically most of this was limited to listening to radio

10     transmissions when there was electricity to power these radio stations.

11             We would listen to, with our translators, the radio transmissions

12     from all sides, any radio station that we could listen to.  That would

13     include all parties to the conflict at that time.  Now, some of these

14     stations were established and operated over a long periods of time,

15     others came and went depending on their access to the technical resources

16     that were necessary.

17        Q.   Do you remember the Oslobodjenje newspaper in Sarajevo, a daily

18     newspaper in Sarajevo during the war?

19        A.   Yes.  It would be very hard not to notice the Oslobodjenje

20     building when you drive past it every day for three years.

21        Q.   Was a TV programme broadcast when there were power cuts?  Was

22     there any television in Sarajevo actually?

23        A.   Watching television was not a priority for us given that we had

24     to run generators to do so.  Most people didn't even have generators.  So

25     I can't say that I watched a lot of television of any sorts, no.

Page 2242

 1        Q.   When you said to me a few moments ago that you tried to listen to

 2     radio broadcasts containing information coming from all sides, would you

 3     agree with me that information, regardless of the media that you followed

 4     them through, that the party that was providing the information never

 5     spoke of the crimes committed by their own people, their own side, if you

 6     will, and that that was a rule in terms of reporting in the former

 7     Yugoslavia?

 8        A.   No, I can't be that categorical.  I haven't listened to enough of

 9     it to say that, so I can't be that categorical, no.  I'm not aware of

10     whether or not there has been reports of incidents that were referred to

11     as crimes.  In fact, there was a period of time in Sarajevo when there

12     were gang wars going on, and I know that that was to some extent

13     reported, and that would involve reporting on criminal acts obviously.

14     So no, I don't think you can, say, give a blanket statement that there

15     was no reporting like that, no.

16        Q.   Do you remember that there were situations in the media when the

17     side on which the victims were would intentionally focus on crimes -- on

18     these crimes, saying that they were committed by the other side actually,

19     even if they weren't?

20        A.   You mean, are you asking about whether or not there are specific

21     incidents of misrepresentation of criminal acts?

22             There's a -- no, I can't give you any specific examples.  I can

23     say that there is obviously, in all conflicts, a great degree of -- or a

24     great lack of accuracy in all reporting.  There's an a element of

25     propaganda in all reporting.  But whether this included direct

Page 2243

 1     misrepresentation of crimes reported by the local media, no, I couldn't

 2     tell you that, no.

 3        Q.   Were you in Sarajevo in February 1994 when the incident at

 4     Markale occurred?

 5        A.   No, I was not there at that time.

 6        Q.   Were you perhaps in Belgrade at the time?

 7        A.   To be honest, I don't remember.

 8        Q.   Now I'm going to move on to another topic, some basic postulates

 9     pertaining to news reporting.

10             Can you give me a brief answer as to whether you agree with me

11     that a journalist that is conveying agency news first and foremost has

12     the task of providing objective information to the public?

13        A.   To the extent that that is possible, yes.  It's a matter of

14     building the largest and most accurate report as possible, and this

15     usually is done by using many sources and many points of reference.  For

16     instance, no story would ever leave Sarajevo without having been seen by

17     the Belgrade bureau.  So it's not a matter of one person writing a story

18     in one place and then presenting that as an objective truth.  It's always

19     a large team involved in reporting for a large news agency on a -- in an

20     important story like that.

21        Q.   Is it the task of every journalist, when he wants to send some

22     information, to check with as many sources as possible the veracity of

23     that information and that he or she believes in the truthfulness of that

24     information?

25        A.   Yes.

Page 2244

 1        Q.   Do you agree with me - and I think that we heard that from your

 2     previous answer when you were giving answers to the Prosecutor in

 3     relation to the photograph that we were looking at - that journalists

 4     have a greet influence over the creation of public opinion?

 5        A.   Sometimes, no, not necessarily always.  The -- leading up to that

 6     particular photograph, I must have photographed dozens of equally

 7     tragically wounded children in Sarajevo hospitals, and this coverage had

 8     resulted in absolutely no response from the other media or the public or

 9     the international community as all.  So it's not always the case.  It

10     depends on many factors and some are still a complete mystery to me as to

11     why one photograph will make a difference and another one will not.

12        Q.   At any rate, I concluded on the basis of your testimony that

13     through the media this photograph caused quite a reaction, or at any

14     rate, yielded the effect of having children treated abroad, so in a way

15     it is that photograph that galvanized the public, as it were?

16        A.   I would say that initially it galvanized the media, and then from

17     there on pressure was brought on in a number of western countries.  And I

18     think the country that responded most quickly to that was Britain.  Now,

19     whether or not the British government reacted as a result of the

20     situation itself or as a result of pressure from the media, that you

21     would have to ask the British government about.

22        Q.   Would you agree with me that images concerning the suffering of

23     children and stories about the suffering of children have the greatest

24     impact in the public -- on the public, and generally speaking anything

25     that has to do with children?

Page 2245

 1        A.   No, not necessarily.  No.  That would be far too simplistic to

 2     put it like that.

 3        Q.   You said to me a few moments ago that you took quite a few

 4     pictures of children in the Sarajevo hospital and that you sent these

 5     photographs through your agency, I assume, to the headquarters of your

 6     agency?

 7        A.   Yes.

 8        Q.   Did you send the pictures of two dead children that you took when

 9     you were viewing the positions of the Serb side in Ilidza?

10        A.   The story of the two children in the morgue there was a bit

11     difficult because we had no way of checking what the background for this

12     story was.  I don't believe that those photographs were transmitted

13     simply because we didn't have what was regarded as accurate information

14     on that.  We had no means of checking with any independent source on

15     that.  We were only given information by either military personnel or the

16     personnel -- people who worked at the hospital or in the morgue as far as

17     I recall.  I can't give you a hundred percent accurate answer on who gave

18     us that information, but we were not -- we didn't have any information

19     from, for instance, the children's parents or relatives or neighbours or

20     anybody who could tell us what had happened.  So it was an indirect

21     source to this, which means that I don't recall whether or not the

22     photographs of those two children were transmitted.  I do recall that the

23     same children were shown to us every time we drove through there, but

24     whether or not they were transmitted, I can't tell you, no.

25        Q.   Do you remember what the persons who showed you the photographs

Page 2246

 1     told you?  How was it that these children had lost their lives?

 2        A.   No, I don't recall the -- the exact cause of death for them, no.

 3     They had -- no, it would be speculation.  I can't tell you exactly, no.

 4        Q.   You said that you had no means of checking the sources, I'll move

 5     on to another subject though.

 6             Do you remember about an incident, was the end of 1991 or the

 7     beginning of 1992 when there was a problem of providing oxygen for

 8     newborn babies in the Banja Luka hospital from Belgrade?  This was

 9     present throughout the media, that was a problem because the oxygen

10     couldn't be taken to Banja Luka?

11        A.   I may have heard of it, but I don't remember any details about

12     that, no.

13        Q.   You don't know whether anyone from your agency went to Banja Luka

14     to verify this information?

15        A.   No, I don't know that.  By the sound of it, I would assume I was

16     not in Belgrade at the time because I'm fairly certain I would have

17     remembered something like that if I had been there.

18             MR. LUKIC: [Interpretation] Your Honours, I would like to move on

19     to another topic now, so then perhaps I could steal three minutes of our

20     time today and finish early.

21             JUDGE MOLOTO:  You may do so if you want to finish early.

22             MR. LUKIC: [Interpretation] Yes, yes.  I don't think it would be

23     a good idea for me to move on to a new topic now, so perhaps I should

24     stop at this point.

25             JUDGE MOLOTO:  Thank you very much, Mr. Lukic.  We will then

Page 2247

 1     stand adjourned to tomorrow.

 2             If you could come back here, sir, at quarter past 2.00 in the

 3     afternoon.  Let me warn you - and I'm sure you know of this, you've

 4     testified here, I'm sure, more than once - that you are not allowed to

 5     discuss the case with anybody now that you've taken the witness stand.

 6             We'll see you tomorrow at quarter past 2.00 in the afternoon.

 7     Court is adjourned to tomorrow, quarter past 2.00, same courtroom.  Court

 8     adjourned.

 9                           --- Whereupon the hearing adjourned at 6.59 p.m. to

10                           be reconvened on Tuesday, the 2nd day of December

11                           2008, at 2.15 p.m.