Tribunal Criminal Tribunal for the Former Yugoslavia

Page 18594

 1                          Monday, 3 December 2007

 2                          [Open session]

 3                          [The accused entered court]

 4                           --- Upon commencing at 9.04 a.m.

 5            JUDGE AGIUS:  Good morning, Madam Registrar.  Would you call the

 6    case, please.

 7            THE REGISTRAR:  Good morning, Your Honours.  This is the case

 8    number IT-05-88-T, the Prosecutor versus Vujadin Popovic et al.

 9            JUDGE AGIUS:  Thank you.  All the accused are present.

10    Prosecution is Mr. McCloskey and Mr. Nicholls.  From the Defence teams I

11    notice the absence of Mr. Meek, Mr. Bourgon and Mr. Josse.

12            All right.  Any preliminaries?  Yes, Mr. Nicholls?

13            MR. NICHOLLS:  Good morning, Your Honours.  Good morning to my

14    friends.

15            I think the only preliminary is that Mr. Blaszczyk we planned to

16    have testify today regarding what we've called the road book, the

17    locations on the Petrovic video.  Two short preliminaries.  One, I think

18    my estimate was off.  I said two hours of direct.  I think it's going to

19    take me quite a bit longer than that probably most of the day and I've

20    told my friends that.  And the second is that I believe we need the

21    response to the 65 ter motion.

22            JUDGE AGIUS:  Yes.  Obviously, I was coming to that actually first

23    and foremost.  What's the position, Mr. Lazarevic?  I see he's interested

24    in intervening.

25            MR. LAZAREVIC:  Yes, Your Honour, I will make a response on behalf

Page 18595

 1    of Mr. Borovcanin Defence.  The Prosecution, in its motion dated 27th

 2    November 2007, requested five exhibits to be added to their 65 ter list.

 3            JUDGE AGIUS:  Yes.

 4            MR. LAZAREVIC:  For three of these, our team or, rather,

 5    Mr. Borovcanin's Defence takes no position.  These are reports pertaining

 6    to the location and procedure for seizure of a video.  I will read the ERN

 7    numbers for the record.  It's 0606-0071 for B/C/S version, and 0606-0073

 8    in English.  The next one is 0606-0070 in B/C/S and 0606-0072.  It's a

 9    receipt for the temporary seizure of a video.  The third one is V000-7149.

10    It's a videotape of the Srebrenica events.  It's more or less the same as

11    the video we already have in the evidence.

12            As for the first two exhibits proposed by the Prosecution, I will

13    refer to the first one as road book.  These are still frames from the

14    Petrovic video and the other one is interactive road book CD, so I'll call

15    it interactive CD.  We oppose to the admission of these two documents or

16    rather these two exhibits to Rule 65 Prosecution list for the following

17    reasons.  First of all, we believe that the probative value of these two

18    evidence is not sufficient to justify the -- their admissibility to Rule

19    65 ter list of the Prosecution.  These two exhibits were made recently by

20    the Office of the Prosecutor so their probative value is a very relative

21    one.  These are not documents generated during the events covered by the

22    indictment.  These are Prosecution-made exhibits which were made very

23    recently and for this reason, their probative value is not that high.

24            On the other hand, we submit that these two exhibits are

25    repetitive to other exhibits in this case.  First, these are still frames

Page 18596

 1    from the Petrovic video.  We have seen Petrovic video many times in this

 2    courtroom and I believe that we will also be able to see it on many other

 3    occasions, so I do believe that it's already contained in the evidence of

 4    this case.

 5            The Trial Chamber at the very beginning of this case was on site

 6    visit and, Your Honours were able to see all these locations, your

 7    attention was directed towards some specific places there, and thus I

 8    believe that Your Honours are very familiar with all these locations, with

 9    all these -- and furthermore, these two -- these two exhibits are

10    repetitive to each other.  They both contain same photographs and same

11    still frames from the very same video, and I believe that the Prosecution

12    has not shown good cause to admit it on to their 65 ter list.

13            JUDGE KWON:  So Mr. Lazarevic, can I take it that you are not

14    challenging those photos are stills from that video?

15            MR. LAZAREVIC:  By all means, Your Honour you are perfectly right.

16    These are all still frames from that video and there is no doubt about it.

17            JUDGE AGIUS:  Thank you.  Do you wish to comment, Mr. Nicholls?

18            MR. NICHOLLS:  Yes, briefly, Your Honour.  I think my friend's

19    really made two objections, one that this evidence would be cumulative and

20    two that the probative value would be low, and Your Honours, I don't think

21    either of those objections are a valid reason to reject this evidence out

22    of hand before you've seen it and heard it.  First of all, this exhibit,

23    this demonstrative exhibit, was -- has been sometime in the making.  It

24    was begun in 2006 and we gave copies as we worked on it to the Defence and

25    to Mr. Lazarevic so he could review it and we talked about it together and

Page 18597

 1    I haven't heard any objection as to the accuracy of the locations marked

 2    in this exhibit.  What it is intended to do is to show Your Honours, when

 3    you see a still or a part of the Petrovic video, where that photo, where

 4    that portion of the film was actually taken and I think that will be very

 5    useful because watching the video, it is sometimes difficult to tell

 6    exactly where one is.

 7            Mr. Blaszczyk is a very experienced investigator on this case.

 8    He's been up and down that road.  I'll proffer he'll testify many, many

 9    times.  And he spent a long time working out on this video where different

10    portions were taken and he used GPS technology to map it precisely and

11    that's what we want to show you is where different portions of these

12    videos were taken.  And it's important because for a lot of this video

13    which we'll learn from the next witness, Mr. Petrovic, Mr. Borovcanin was

14    present in the vehicle while the video was being taken.  I don't think the

15    evidence is cumulative because true these are stills from the video but

16    there were also stills taken of the same locations showing where we are

17    because the video stills are sometimes -- sometimes parts of the video are

18    blurry or it's difficult to tell exactly where one is.

19            The exhibits, the book and the CD are not cumulative to each other

20    because although they contain the same photos, the CD allows the person

21    operating it to see left and right and up and down and move around and

22    gives a much better perspective than just the flat photographic book can.

23    It's true that Your Honours went on a site visit a long time ago at the

24    beginning of this case and I think that's a good reason to admit this

25    evidence, because it will allow Your Honours, I hope, to remember

Page 18598

 1    different places because we have more current photographs in here of the

 2    locations which Your Honours saw as well as the corresponding photos from

 3    the video which was taken in 1995.

 4            The other reason I think it's important to put this in in this

 5    format is Mr. Petrovic, who actually shot the video, based on his

 6    interview is unable to tell where all of these places were that he was

 7    shooting so we can't hear it all just from him.  He said in his interview

 8    that he wasn't sure where some of these places are that he filmed, he

 9    wasn't that familiar with the area and he actually said in part of his

10    interview that he went back recently and tried to figure out where he had

11    been shooting different scenes and he couldn't do it.  So I think this is

12    the only way and the best way to provide you with an overview of that

13    important piece of evidence, the video, and to show you the directions

14    that were taken during the video, the precise places where we stopped, and

15    later where different people are on the video at different times of the

16    day on the 13th and the 14th of July.  So I don't think it's cumulative.

17    Of course, at the end after you've heard the evidence and at the end of

18    the case when you weigh all the evidence you'll be able to assign it

19    whatever probative value you think it deserves, but I don't think now is

20    the time to reject it out of hand.  Thank you.

21            JUDGE AGIUS:  Okay.  I thank you.  Thank you, Mr. Nicholls.

22    Mr. Lazarevic, if you look at the Prosecution motion of the 27th November

23    and precisely the part where the first of these five documents sought to

24    be included in the 65 ter list is described, there is also a comment made

25    there, namely that -- I'm going to read it:  "A substantially similar

Page 18599

 1    rough draft of the road book was disclosed in the late 2006 and the

 2    Defence were told that an improved -- an improved version of the road book

 3    was being produced."

 4            I haven't heard you comment on this because I suppose it does

 5    carry some weight.

 6            MR. LAZAREVIC:  Well, because -- yes, Your Honour, I did not

 7    comment and that is true.  I mean, the Prosecution did provide us with a

 8    copy of this draft material, not just one but on two or three occasions

 9    because this material was changed on quite a number of occasions.  Last

10    one that we received, and this is the one I believe that the Prosecution

11    wishes to admit to their 65 ter list, we received on Friday afternoon if

12    I'm not wrong.  My colleague will tell more.  There are some changes.  I

13    cannot say these are significant changes.  I have to be fair to the

14    Prosecution.  These are not significant changes comparing to the previous

15    draft, but they did provide us with this.  However, what I'm suggesting is

16    that some of these photographs containing this evidence are made last

17    year, I think, and I don't see how can they assist the Trial Chamber.  I

18    mean, these are photographs of some, well, some houses, some meadows and

19    things like that as they look now.  These are not -- part of them are

20    still frames from the video while the other part are photographs taken

21    right now.

22            JUDGE AGIUS:  Okay.  Thank you, Mr. Lazarevic.  Does anyone else

23    wish to comment on the Prosecution motion?  Yes, Mr. Nicholls?

24            MR. NICHOLLS:  Could I just say, Your Honour, and I thank my

25    friend for pointing it out the changes were very minor as we went along

Page 18600

 1    with this.  They weren't new photos, new material; it was mainly

 2    reordering it to try to put it in a more logical manner using the same

 3    photos and changing some of the text underneath the photos, the

 4    explanations but it's the same book.

 5            JUDGE AGIUS:  Thank you.  Any further comments?  None.  I need to

 6    confer with my colleagues.

 7                          [Trial Chamber confers]

 8            JUDGE AGIUS:  We are unanimous here in disagreeing with you,

 9    Mr. Lazarevic and agreeing totally with the submission of the Prosecution,

10    that the inclusion of all these five documents, particularly the first two

11    probably, of these five documents, are important for a better

12    understanding of the video that eventually we will be seeing.

13            So they are -- the Prosecution request is being acceded to, and

14    these will be included in the 65 ter list.  As to probative value, the

15    important sense of the word, as you put it, Mr. Nicholls, this is

16    ultimately a matter that will have to be tended to, addressed, by the

17    Trial Chamber at the appropriate time and not now.  Thank you.

18            All right.  Can we bring in Mr. Blaszczyk?  Or something else?

19    One moment, Madam Usher.

20            MR. NICHOLLS:  Sorry, Your Honour, just the last three exhibits, I

21    don't want to speak for my friend but I believe at this point there is no

22    objection to the documents.

23            JUDGE AGIUS:  No, no.  What we were admitting is the five of them,

24    not just the two.

25            MR. NICHOLLS:  Sorry.

Page 18601

 1            JUDGE AGIUS:  As far as the last three are concerned, we noted

 2    that Mr. Lazarevic took no position.

 3            MR. NICHOLLS:  Thank you.

 4            JUDGE AGIUS:  Judge Kwon anticipated what I was going to come to.

 5    Mr. Ostojic and Mr. Nicholls, Mr. Ostojic hadn't finished his

 6    cross-examination, and I took this motion to mean that this will come up

 7    during re-examination.

 8                          [The witness entered court]

 9            JUDGE AGIUS:  Or is it going to be further testimony?  I don't see

10    it as a further testimony.

11                          [Trial Chamber confers]

12            JUDGE AGIUS:  In other words, do you plan to have Mr. Blaszczyk

13    finish the previous testimony on that chapter and then summon him again on

14    this new chapter or were you going to deal with this matter during

15    re-examination?

16            MR. NICHOLLS:  What -- I spoke to my friend about this yesterday,

17    Your Honour.  What I intended to do, if it pleases the Trial Chamber is

18    now start with the road book and finish the road book hopefully today and

19    then when we have time at the end, Mr. Ostojic would finish his

20    cross-examination on the Drina Corps and any re-examination would take

21    place after we conclude this chapter.

22            JUDGE AGIUS:  All right.

23            Agreed, Mr. Ostojic?  Because this concerns you more than anyone

24    else for the time being.

25            MR. OSTOJIC:  Thank you, Mr. President.  If it's acceptable to you

Page 18602

 1    I could work with that.

 2            JUDGE AGIUS:  For us it's neither fish nor fowl.

 3            MR. OSTOJIC:  Nor for me, Your Honour.

 4            JUDGE AGIUS:  So we are not having breakfast this morning.

 5            Good morning, Mr. Blaszczyk.

 6            THE WITNESS:  Yes, good morning, Mr. President.

 7            JUDGE AGIUS:  Yes.  We are going to open a new chapter today in

 8    your testimony, as you are most probably or definitely aware but then at

 9    some later point in time during the day we'll return to the Drina Corps

10    collection recovery, where Mr. Ostojic has still got to finish his

11    cross-examination.  So I think for this purpose, I need to administer the

12    oath again to you.  Madam Usher.

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

14    whole truth and nothing but the truth.

15                          WITNESS:  TOMASZ BLASZCZYK [Resumed]

16            JUDGE AGIUS:  I thank you, sir.  Please make yourself comfortable.

17            Mr. Nicholls.

18            MR. NICHOLLS:  Thank you, Your Honours.

19                          Examination by Mr. Nicholls: [Continued]

20       Q.   Good morning.

21       A.   Good morning, sir.

22       Q.   Their Honours have been passed out copies of the book you made, 65

23    ter 2986.  Mr. Blaszczyk, could you please briefly, very briefly, describe

24    what this book is and the -- what it shows us?

25       A.   Your Honours, in February 2006, the witness Zoran Petrovic was

Page 18603

 1    interviewed and during this interview he made available this raw material

 2    he had recorded in Srebrenica area in July 1995.  We made a copy of this

 3    raw material for our purpose and then from the copied material, we got the

 4    stills from this copied materials, we collected the stills in this road

 5    book and also we found a location where the stills were -- where the

 6    footage was recorded and we made our own pictures and also we attached to

 7    this book for comparison purposes of course.

 8       Q.   Thank you.  And can you just briefly tell us the different

 9    versions of the Petrovic video that we have that are relevant to this

10    book?

11       A.   We received a few version of the Petrovic video.  We received a

12    Petrovic video, I mean the copy of the Petrovic video from BBC in 2002 and

13    we received in fact we copied raw material, Petrovic video, from him

14    during his interview in 2006, in February 2006, and also we have a copy of

15    Petrovic video which was handed over to us by the Ministry of Defence,

16    Bosnia-Herzegovina, in 2007.

17       Q.   And could you just tell the Trial Chamber about the Studio B

18    footage, what we call the Studio B footage of the Petrovic video?

19       A.   The Studio B footage of the Petrovic video, this is -- it was

20    broadcasted by the Serbian television in 1995, I believe it was July 1995,

21    and consists of the material which had been recorded by Mr. Petrovic

22    during his visit in Srebrenica area in July 1995, and we received a copy

23    of this broadcast from Studio B from Mr. Borovcanin during his interview

24    in 2002.  He handed over this copy to us.  And also, during the interview

25    with Mr. Petrovic, Zoran Petrovic, we received also a copy of the same

Page 18604

 1    broadcast.

 2       Q.   And just to be clear, the Studio B footage is different because it

 3    was edited material for broadcast, it's not exactly the same as the raw

 4    material; is that right?

 5       A.   Yes, you are right.  This is not exactly the same material.  It

 6    was edited material in the studio but consists, of course, the footage

 7    from Petrovic, the raw material from the Petrovic video.

 8       Q.   I'd like to show you quickly a couple of documents, the first one

 9    is 2988.  This is the 26th of June -- 22nd of June, excuse me, 1996,

10    report on television footage from Srebrenica, a Main Staff document.  Can

11    you just tell us what this document is?  I think you'd already referred to

12    it.

13       A.   This is report on television footage from Srebrenica signed by the

14    Colonel Milovan Milutinovic regarding the raw material recorded by

15    Zoran Petrovic, Pirocanac during operation in Srebrenica in July 1995.

16       Q.   Okay.

17       A.   How to [indiscernible] this raw material.

18       Q.   Thank you.  Could you just tell us again when did we receive this

19    document in the OTP?

20       A.   The first time, in fact, OTP team had access to the archive of

21    army to the Ministry of Defence, Ministry of Defence Bosnia and

22    Herzegovina in Banja Luka in October of 2006, and during this -- these

23    meetings, you know, during this access to the archive, they located and

24    they scanned this document and when we received the scanned document here

25    in The Hague we requested the Ministry of Defence to send us the original

Page 18605

 1    copy of this document.

 2       Q.   Okay?

 3       A.   And we received the original, the copy, the original document in,

 4    I believe it was January 2007.

 5       Q.   Okay.  Now, if we could have 2989, please?

 6            JUDGE AGIUS:  Mr. Nicholls, perhaps it's better to clarify this

 7    now rather than later, if the witness can explain it.  The name of

 8    Zoran Petrovic, as we know him here, is Zoran Pirocanac and the witness

 9    also mentioned both surnames, family names, Zoran Petrovic, Pirocanac.  If

10    you could explain what the position is?

11            MR. NICHOLLS:  Yes.

12       Q.   Could you please explain --

13            JUDGE AGIUS:  Whether he's Petrovic, whether he's both, whether

14    he's just Pirocanac.

15            MR. NICHOLLS:

16       Q.   Yes, please explain.

17       A.   Zoran Petrovic also use the nickname of Pirocanac or name of

18    Pirocanac.  And he -- mostly he was both names, Petrovic, Pirocanac.

19            JUDGE AGIUS:  Thank you.

20            MR. NICHOLLS:

21       Q.   Just while we are on this document, who is this who signed it,

22    Colonel Milutinovic?

23       A.   Colonel Milutinovic was the head of information department from

24    the Main Staff of army of Republika Srpska.

25       Q.   Thank you.  Now, if we could go to 2989, please.  This is dated

Page 18606

 1    24th of June 1996 and it's a receipt for a videotape.  Just tell us very

 2    simply what this document is.

 3       A.   This is also receipt for temporarily seized object regarding the

 4    same tape which had mentioned in the previous document and we received

 5    first the copy of this document along with a copy of the previous document

 6    and later on, we received the original of these documents.  The document

 7    has been signed, I believe, by Ljubisa Beara.

 8       Q.   Okay.  Thank you.  I'm through with those two.

 9            Now, I'd like you to explain a little bit more before we start

10    going through the book, how you actually took the photos which were taken,

11    the contemporary photos, up and down the road and matched them to the

12    stills from the Petrovic video.  What did you actually do to make sure you

13    were getting photos of the correct locations?

14       A.   Okay.  Before I went on mission in -- to Bosnia-Herzegovina to

15    locate all these places, Petrovic video, we printed out the stills from

16    the Petrovic video, we took with us also the copy of high quality

17    recordings of Petrovic video, together with portable recorder, player,

18    with us, and we went to the places where the video had been recorded by

19    Petrovic.  And when we were on the places, on this area of Srebrenica,

20    Potocari, Sandici, Lolici, Pervani, we were driving in the same road which

21    was used by Mr. Pirocanac/Petrovic and Mr. Borovcanin and we stopped all

22    these places.  We compared the surrounding topographics with the stills we

23    had printed and with the video we had with us, and also we compare the

24    area which was located by us with the surrounding houses, with the curve,

25    with the made-up of the roads on the spot.

Page 18607

 1       Q.   Thank you.  And besides this mission where were you putting

 2    together photos for the road book, how familiar are you with those roads

 3    in Srebrenica and Potocari, Kravica, Zeleni Jadar?  How many times have

 4    you been in this area yourself?

 5       A.   I can say I'm very familiar with this area.  I've been there many

 6    times, I don't know exactly how many but about 40, 50 probably.

 7       Q.   And if you could just tell us briefly who else was on that mission

 8    with you.

 9       A.   Together with me on mission went also Zoran Lasic, our video

10    assistant and who made the copy of raw material of Petrovic and who was

11    also involved in this project, and in one day I believe Mr. Nicholls also

12    attended this trip.

13       Q.   Okay.  And can you just tell us, and we are nearly done with this

14    part, about how you used a GPS device while you were locating the

15    different places?

16       A.   When we spotted the location which was depicted in Petrovic stills

17    we took the photos of these locations and also we recorded the GPS

18    readings of this particular location and we used, in fact we used two GPS

19    devices because we wanted to be sure that the readings is correct.

20       Q.   I believe Your Honours have a copy of the book now.  Do you have

21    your copy?

22       A.   Yes.

23       Q.   If we could just look at this now.

24            MR. NICHOLLS:  Your Honours, what I plan to do soon is watch the

25    video and stop it at appropriate places and have the witness explain how

Page 18608

 1    the photos and the stills are related to the newer photos.  That will be

 2    done in Sanction and we'll have the transcript of the video as we follow.

 3    So I think it's best to use the hard copies of the book rather than to try

 4    to switch back and forth from e-court because each time we have to get out

 5    of Sanction and then try to find where we were again in the film so if

 6    that's all right.

 7            JUDGE AGIUS:  And I think it will educate us better because later

 8    on that's how we'll have to do it in any case.

 9            MR. NICHOLLS:  Yes, Your Honours, thank you.

10       Q.   Now, briefly, Mr. Blaszczyk, could you just explain, it's pretty

11    self explanatory, we've got maps on the first five pages.  Can you just

12    tell us what those maps show?

13       A.   On the first pages we attached the three maps of

14    Bosnia-Herzegovina and the detailed maps of the area where the Petrovic

15    video had been recorded, the maps were created in BIC [sic] unit here in

16    The Hague by its officer and also we attached satellite image of the same

17    area.

18       Q.   Okay.  Now, it says, in the transcript, BIC unit.  I think it's

19    GIS unit.  Can you tell us very quickly what that is, GIS?

20       A.   Of course, this is GIS unit, this is geographical information

21    system unit.

22       Q.   Okay.  Now, if we can just go to pages 6 and 7, this is chapter 1,

23    Potocari.  And again, quite self explanatory but can you just tell us what

24    these numbered positions refer to on page 7 on the map?

25       A.   This is a map of -- NATO map for Bosnia-Herzegovina, and on the

Page 18609

 1    map also with the help with the assistance of GIS unit, I plotted the

 2    location using the GPS readings we taken in our mission in May in

 3    Bosnia-Herzegovina in these locations.

 4       Q.   Okay.

 5       A.   And I would like to say that this is chapter 1, and for each

 6    chapter --

 7            JUDGE AGIUS:  One moment.

 8                          [Trial Chamber confers]

 9            JUDGE AGIUS:  All right.  Let's proceed.  Sorry for the

10    interruption but we needed to discuss something.

11            MR. NICHOLLS:  Thank you.

12       Q.   If you could continue, Mr. Blaszczyk, you were just saying for

13    each chapter and then you stopped.  You had something to say.

14       A.   I think I should say that I divided this book for five chapters,

15    and each chapter started from the map, detailed map, of the particular

16    area where the footage was recorded by Mr. Petrovic, Pirocanac.

17       Q.   Okay.  And if we could turn to pages 8 and 9, just so that we all

18    understand the way the book is set up, can you -- on the left we've got

19    the Petrovic video still, on the right we've got a photo taken in June by

20    you and the video assistant.  Could you please explain the information on

21    these pages and the way you've set it up?

22       A.   In each chapter, after the map, detailed map of the area, the

23    particular area, the map is followed by the page with the still or stills

24    from the Petrovic video, and these pages with the stills of the Petrovic

25    video is also followed by the recent picture -- recent picture -- the

Page 18610

 1    picture made by us during our mission in Bosnia-Herzegovina, the picture

 2    of the same area which was depicted in the previous page.

 3       Q.   And the counter underneath the photo on the Petrovic video, that

 4    is from the original -- the copy of his original raw footage in the high 8

 5    format, is that right?

 6       A.   Yeah.  You are right.  We used the counter of the digital recorder

 7    device we used to copy the raw material from Petrovic and below also I

 8    attached the information, the location where the stills was taken and the

 9    position on the map, on the previous map of the same location which is

10    depicted on this picture or pictures.

11       Q.   And here we've got 0:00:37:13 and is it right this that this means

12    we are at 37 seconds and actually at frame 13 of that 37th second?  In

13    other words, it's not -- that is the last two digits refer to the actual

14    frame that was used on the videotape?

15       A.   Yes, you are right.  This is the counter from the digital recorder

16    device.

17            MR. NICHOLLS:  Now, Your Honours, I should say that nearly every

18    time this is played on a different player, whether it's in a CD or

19    electronic, the counter may be a little bit different.  When we loaded the

20    entire video, the same video, into Sanction, unfortunately, it's about

21    exactly four seconds ahead when you play it in Sanction.  This is the most

22    precise numbering, which is on the tape which we'll be putting into

23    evidence but the exact still will -- may be about four seconds off if

24    you're playing it in Sanction.  And I think now, Ms. Stewart, if we could

25    start playing the video which is 65 ter 2054, Your Honours.  This is the

Page 18611

 1    copy made during the interview of Mr. Petrovic, the copy of his raw

 2    material which he brought to the video.  And if we could -- stop at 41, 8.

 3                          [Videotape played]

 4            MR. NICHOLLS:  I think we went past it.  If we could stop and just

 5    go back a bit.  That's -- forward a bit.  Okay.  That's close.  We are at

 6    36.9.

 7       Q.   What is the building here?

 8       A.   This is Dutch UNPROFOR base in Potocari, but it's not exactly the

 9    same picture as we had on the page 8 of this road book but it's very

10    similar.  We are coming to this picture.

11       Q.   That's fine.  It's 41.9?

12       A.   Yeah.

13       Q.   And this is heading in the direction now --

14       A.   The car and the cameraman is reading to the direction of

15    Srebrenica.  And on the page 8 we have the same still, we can see almost

16    the same still we can see on the screen.  And on the right side, on the

17    page number 9, we have the picture taken by me and Zoran  Lasic during our

18    mission and depict also the same -- the same building.

19       Q.   And what is the date that this video was taken?

20       A.   The video was taken on the 13 of July, 1995.

21       Q.   Thank you.

22                          [Videotape played]

23            MR. NICHOLLS:  All right.  Your Honours, this will speed up a

24    bit.  There is more detail in the beginning in Potocari and we won't be

25    going through every page at this same pace.

Page 18612

 1       Q.   Okay.  We are at 53.8.  Could you just tell us what we see here on

 2    page 10 of the book and we are at picture A.

 3       A.   We see the group of the people marching towards Bratunac, in

 4    direction of Srebrenica, and this still was also recorded on the 13th of

 5    July 1995 by Zoran Petrovic as another stills from the same location in

 6    Potocari.

 7            MR. NICHOLLS:  If we could continue to about 102?

 8                          [Videotape played]

 9            MR. NICHOLLS:  Stop.

10       Q.   All right.  We went -- we are now at about picture B on page 10.

11    Could you tell us why you selected that one and labelled the Feros

12    building in the picture?

13       A.   I selected this picture because in the background we can see the

14    building who is very recognisable, you know, from the spot, on the spot,

15    when you are in Potocari you can see this building.  It's still in the

16    same shape.  We called it Feros building.  And we can see that people

17    walking also from direction of Srebrenica towards Bratunac.

18            MR. NICHOLLS:  We'll play a little bit more.

19                          [Videotape played]

20            MR. NICHOLLS:  Thank you.

21            JUDGE AGIUS:  I think if you want to refer to what's in page C,

22    you need to go back but I don't know -- I don't know whether you intended

23    to skip it purposely.

24            MR. NICHOLLS:  I was going to skip that one, Your Honour.

25            JUDGE AGIUS:  All right.  Then I misunderstood you before.  Okay.

Page 18613

 1            MR. NICHOLLS:

 2       Q.   Now we've stopped at picture D and we've just gone through picture

 3    C, we can see the sequence on the counters.  Can you just tell us why you

 4    selected this photo we see on page 10, photo D, from the original stills?

 5       A.   Yeah, these two photos are selected from this part of the video we

 6    just played and it showed a group of the people walking from Srebrenica

 7    direction towards Bratunac on the left side of the road looking towards

 8    Srebrenica.  It's also locations Potocari, also Dutch UNPROFOR base.

 9       Q.   And now, just as we are beginning to see how you set up the book,

10    can you show us on page 11 why you selected these photos and labelled them

11    and how you came to the conclusion that where we have A, B, C and D on

12    page 11, the markings in photo 3, that these correspond to the photos A,

13    B, C and D on page 10?

14       A.   On the page 11 I put the picture of -- taken along the road from

15    former Dutch UNPROFOR base and the Feros building.  And on the picture 2

16    and on picture 3 we can see the Feros building which is also depicted on

17    the stills from Petrovic book, on the picture, on the still B, from the

18    page 10.

19       Q.   And so we can see, then, just if I understand you, that where

20    these photos, where this bit of video was taken was really directly in

21    front of and passing by the Feros building towards Bratunac?

22       A.   Yes, you're correct.

23            MR. NICHOLLS:  If we could continue playing now.

24                          [Videotape played]

25            MR. NICHOLLS:

Page 18614

 1       Q.   All right.  Thank you.  We are now at approximately the photo A on

 2    page 12.  Can you just tell us -- and we see there witness van Duijn

 3    speaking.  Can you tell us where we are in these series of photos on page

 4    12 and 13?

 5       A.   In this photo, we are in the Dutch APC check-point.  It was

 6    located -- this check-point was located about 50 metres north of the

 7    express bus compound in Potocari, and almost in the front of the blue

 8    building.

 9            MR. NICHOLLS:  Okay.  If we could continue now.

10                          [Videotape played]

11            MR. NICHOLLS:

12       Q.   Okay.  We are right now at about photo B on page 12 and we can see

13    the hill in the background.  Again, can you tell us how you were able to

14    tell where this spot was?

15       A.   With the same location what was the previous still, this is in

16    Potocari, about 50 metres from the bus compound in Potocari, north from --

17    of the express bus compound and the hills in the background are the same

18    hills which are depicted on the page 13 on my photos from 2006.  And when

19    we played this part of the video, we could also notice the buildings of

20    Zinc Factory in Potocari, and part of the bus compound.

21            MR. NICHOLLS:  Play, please.

22                          [Videotape played]

23            MR. NICHOLLS:  Thank you.

24       Q.   Now, approximately at the last photo on page 12, photo D, we see

25    the woman walking towards Bratunac and the two UN APCs.  Can you just tell

Page 18615

 1    us about this concrete strip which we see on the right side of the photo

 2    coming up to the UPC on the right?

 3       A.   This is a small bridge which is crossing the creek, the creek who

 4    is passing the road from Budak area towards Potocari, to the left side.

 5       Q.   And where is that part of the little bridge over the drainage

 6    creek, where would that be on the photo on page 13?

 7       A.   This is exactly on the right side, actually in the middle of this

 8    photo, in the bottom of the middle of this photo we see the small bridge.

 9       Q.   Finally, that building on the left we see on page 13, can you tell

10    us about that building, the big white and brown brick building behind the

11    fence?

12       A.   This is quite new building.  It was built after the war in

13    Bosnia-Herzegovina, after 1995, I believe after 2000, 2003.  And in the

14    background we can see also on this picture from page 13 the Zinc Factory

15    and Energoinvest factory and part of the bus on the left side behind the

16    new building, the part of the bus compound in Potocari.

17            MR. NICHOLLS:  All right.  If we could now play for a while and go

18    to page 14 and 15.

19                          [Videotape played]

20            MR. NICHOLLS:

21       Q.   Okay.  We stopped at 7.27 on the Sanction, just a little bit past

22    the photo F on page 14, and you've got this location labelled as the blue

23    building and its yard opposite the Feros building.  Can you just tell us

24    about these two pages, pages 14 and 15 of the book, where we are in the

25    video sequence we've just seen?

Page 18616

 1       A.   The stills from the page 14 were taken from the part of the video

 2    we had played just recently, right now.  And it was recorded on -- in the

 3    yard of the blue building which is located in opposite of Feros building

 4    on the road in Potocari and about, from this Feros building, distance to

 5    the white house which is also located across from the DutchBat is about

 6    100 metres towards Bratunac.  And on the page 15, I made -- we made the

 7    recent picture of the same area, I think it's very visible here that it's

 8    the same building, the blue building and its surroundings and on the page,

 9    the page 15, on the picture 4, I made a picture also of remains of the

10    fence which we can see on few stills from the page 14, on still B, still E

11    or still F.  And the white house in relation to this blue building is

12    located about 100 metres towards Bratunac.

13            MR. NICHOLLS:  Okay.  Let's continue, please.

14                          [Videotape played]

15            MR. NICHOLLS:

16       Q.   Okay.  We are on pages 16 and 17, now stopped at approximately

17    picture A on page 16 and we just noticed from the camera scenes that the

18    cameraman, Zoran Petrovic, was walking with his camera and the camera was

19    filming the ground as he walked.  Where are we now?

20       A.   Right now we are in the front of outside of the white house in

21    Potocari.

22       Q.   And again, approximately -- this is -- you said about

23    approximately how long -- how far away is this from the blue building?

24       A.   A very short distance.  We could see how the cameraman left the

25    yard of the blue building and walked towards white house.  He recorded a

Page 18617

 1    group of the people in front of the white house.  It was about 100, 150

 2    metres.

 3            MR. NICHOLLS:  Okay.  If we could just play now some more, please?

 4                          [Videotape played]

 5            MR. NICHOLLS:

 6       Q.   We are now at just about, we've continued and we are now at

 7    picture D on 16 -- excuse me, picture B.  What do we see here?

 8       A.   We see the gate of the white house and the pile of the belongings

 9    in front of the gate.

10            MR. NICHOLLS:  If we could continue playing, please?

11                          [Videotape played]

12            THE WITNESS:  See the same group of the people which had been

13    recorded on the picture A from page 16.

14            MR. NICHOLLS:

15       Q.   And then just as we've seen the camera pan this group of people

16    with Mr. Borovcanin and Mr. Kingori are just in the road near the

17    belongings; is that right?

18       A.   Yes, that's correct.

19       Q.   This is page 16, picture C.   Continue, please.

20                          [Videotape played]

21            MR. NICHOLLS:  Okay.  Stop.  Thanks.  Can we go to that?  Stop

22    here.

23       Q.   We are now at approximately picture 16 D and we will get to it and

24    we saw that the next frame is a picture of a large shell.  Can you just

25    tell us what's happened here?

Page 18618

 1       A.   This is -- we see again the picture of the gate of the white house

 2    located in Potocari, and when we have the frame of the white house gate

 3    and the belongings in front of the white house, we got the picture of the

 4    big shell.  This is not recorded in Potocari, this frame but according to

 5    the witness Petrovic it was recorded over later on probably at his house.

 6       Q.   And have you ever seen that shell yourself?

 7       A.   Yes.  I seen the shell by myself when I went together with witness

 8    Petrovic to his house in Belgrade to collect his raw material from his

 9    house, he showed me the shell on his balcony.  It's the same shell.  Looks

10    the same and probably is the same one.

11       Q.   Did he say it was the same or is that your conclusion from looking

12    at it?

13       A.   He -- he told me that this is the same shell and what he's

14    recorded on his raw material.

15       Q.   All right.  Now, if we could look at -- this is quite self

16    explanatory but page 17 you've got B and D and A and C marked.  This shows

17    the locations of the group of people in A and C as well as the pile of

18    belongings; is that right?

19       A.   Yes.  On the page 17, on the picture number 1, we see I marked

20    with B and D the location of the stills from the page 16 B and D, and A,

21    C, the location of the group of the people which are depicted on the

22    stills A, C, from page 16.  And the second picture, this is a picture

23    taken from the position of A, C.

24       Q.   Okay.  You're talking about picture 2?

25       A.   Yes.

Page 18619

 1       Q.   So if you're at position A, C, where Mr. Borovcanin and

 2    Mr. Kingori are, you can look across the road at the Feros building; is

 3    that right?

 4       A.   It's correct.  When we look across, this is the Feros building and

 5    we see part of the road.

 6       Q.   Okay.  I'd like to now play a different clip.  This is from Studio

 7    B.

 8            MR. NICHOLLS:  Your Honours, this is the Studio B footage.  It's

 9    actually taken from our trial video because there it's got the captioning

10    already.  Thank you.

11                          [Videotape played]

12            MR. NICHOLLS:  And I should say that was 65 ter 2011, the Studio B

13    footage which contains the close-up of the men on the balcony.

14       Q.   Now, can you just tell us about the comparison clip before we

15    watch it that was put together of the raw material, which we received from

16    Mr. Petrovic, which contains the shell, compared to the Studio B material,

17    broadcast in Belgrade on 17 July 1995, which shows zoom up to the men on

18    the balcony.

19       A.   Yes.  We compared the raw material we received, we copied, from

20    Mr. Petrovic, and the Studio B broadcast material we received from

21    Mr. Borovcanin, and we played both of the clips together and we could see

22    that the clips are fit to each other and except the part where we see on

23    the raw material, the copied raw material, the shell from the balcony of

24    Mr. Borovcanin [sic] which was recorded over at later stage.

25       Q.   Before we play that, could we just look at pages 18 and 19 of the

Page 18620

 1    book?

 2       A.   On the --

 3       Q.   And just very simply --

 4            JUDGE AGIUS:  Yes, Mr. Lazarevic?

 5            MR. LAZAREVIC:  I could be wrong but here in the transcript we do

 6    have on page 27, line 5 and 6, the shell from the balcony of

 7    Mr. Borovcanin.  I don't know whether I understood this properly but I

 8    don't remember Mr. Borovcanin having any shells on his balcony.

 9            THE WITNESS:  No, of course this is the shell from the balcony of

10    Mr. Pirocanac, Petrovic.

11            JUDGE AGIUS:  Thank you, Mr. Lazarevic, and Mr. Blaszczyk.

12            MR. NICHOLLS:  Thank you.

13       Q.   Now, I think it's quite obvious but just to be clear, on pages 18

14    and 19, we've got pictures of the men crowded on the balcony.  This is the

15    first time in the book on the left-hand side where we've got images not

16    from the Petrovic video which he gave us but from the Studio B and it's

17    got the logo there; is that right?

18       A.   Yeah, this is correct.  We attached on this page, on page 18, the

19    stills from the Studio B broadcast which are not visible on the raw

20    material handed over to us by Mr. Petrovic.

21       Q.   Thank you.  Now, what I'd like to do, Your Honours, is play 2991,

22    which is a split-screen showing the two segments together.

23                          [Videotape played]

24            MR. NICHOLLS:  And on the right-hand side is the Petrovic video.

25    On the left will be the Studio B.

Page 18621

 1                          [Videotapes played]

 2            THE WITNESS:  On these two clips, on the right side we have the

 3    clip from Petrovic raw material and on the left side we have Studio B

 4    broadcast clip and we can compare how these two clips are fit to each

 5    other.

 6            MR. NICHOLLS:

 7       Q.   And other than about a one or two second gap, they come back to

 8    the same footage at the end after the --

 9       A.   Yes.

10       Q.   Thank you.

11            MR. NICHOLLS:  That ends chapter 1.  Your Honours, what I'd like

12    to do now, if I may, is --

13            JUDGE AGIUS:  I don't know if I'm reading your mind.  Are you

14    thinking of having the break now and continuing immediately after or

15    starting and having the break regularly.

16            MR. NICHOLLS:  No, Your Honours I wanted now Mr. Blaszczyk to show

17    the way the CD part of Potocari works.  The CD only has two sections

18    Potocari and the road, it doesn't have all the parts of the --

19            JUDGE AGIUS:  Okay.

20            MR. NICHOLLS:

21       Q.   So if you can hopefully this will work.  We tried it on Friday.

22    Mr. Blaszczyk should be able to operate it from the laptop.  And can you

23    just talk us through the way this works when you use the controls at

24    first?

25       A.   Okay.  Maybe I will tell that to this road book I attached also

Page 18622

 1    the CD with presentation, with multi-media presentation of two chapters of

 2    this road book, and we are using the computer software to play this CD,

 3    and this is media quick player, QuickTime player, sorry, and we can use

 4    this button, the button on the bottom, to control of this presentation.

 5    The first button to the right, this is information button.  Pressing this

 6    button, we can mark all the area which is link to another picture or

 7    stills.  This is button marked with plus, we can zoom in -- I'm sorry, we

 8    can zoom in -- we can zoom in the present picture, if you want.  This is

 9    zoom out.  And the button on the left, we can go to the previous page.

10       Q.   Okay.

11       A.   And pressing the right button of mouse, we see the map of

12    Bosnia-Herzegovina with the marked area of Bratunac and Srebrenica.  We

13    can also use this information button to see if everything is marked here

14    correctly.  Pressing on this field, the link, we are coming to the map

15    closer to more detailed map of this area, come in again we have again more

16    detailed map of Bratunac area divided with two rectangles of Potocari and

17    also Sandici and Kravica area.  We can go in and we have detailed map of

18    the area of Potocari.  All these circles here with sign, we can see

19    pressing the button on the right and link to another view, another picture

20    or stills.

21       Q.   Okay.  Can you just -- these are the same still photos that we

22    have in the book.  Can you just show us what you've included here?

23       A.   Yeah.  This presentation includes the same stills from Petrovic

24    video we use in the road book and the pictures we made in our mission in

25    this area in 2006.  And we can, with this software, we can easily move

Page 18623

 1    through these pictures and to have better view or better understanding of

 2    the area where the --

 3       Q.   Okay.  If you could go through and just show us what you've

 4    included in here perhaps in the same order that we've just -- that you've

 5    included it in chapter 1?

 6       A.   Okay.  We start with the same order.  Okay.  We are in front of

 7    the white house right -- I'm sorry, in front on the white house, we have

 8    overview of this area.  I'm heading towards direction of Bratunac.  We see

 9    the Dutch base compound in front of us.  We are moving slowly towards

10    direction of Srebrenica.  We are passing the Feros building which is

11    located across the road from white house.  This road heading to

12    Srebrenica.  Here we have link to another picture, extending picture, you

13    know, from the blue -- in the front of the blue building towards

14    Srebrenica.

15            On this -- on this picture, we marked the links to the stills from

16    Petrovic video and we located the place where the stills were taken.

17            This group of people are walking towards Srebrenica, towards,

18    sorry, Bratunac, from Srebrenica direction, and they on the road between

19    blue building and white house.

20            We have the group on the left side of the road, the same road.  We

21    can see the group of the people walking from direction of Srebrenica

22    towards Bratunac.  This is also in the same area.  This is the blue

23    building and white house.

24            In front we see -- in front of us we see the building of Feros

25    company.  We can press the link to the picture from the stills from

Page 18624

 1    Petrovic video.  We can see in the background the same building.

 2            This picture was taken from the front of the white house.  Now,

 3    this link take us to the picture of the white house.

 4       Q.   And if we could go to this link you've got here on the road just

 5    by the white house.

 6       A.   Yeah.  We can press the link here.  We see the picture, we see the

 7    still from the Petrovic video, the group of the people including

 8    Mr. Borovcanin and Major Kingori.

 9            This link take us to the still from Petrovic video as well, in

10    front of the gate.

11            And we are coming to the balcony of the white house.

12            As I said at the beginning, we can use these buttons in the bottom

13    to zoom in and move closer.

14       Q.   Okay.  Thank you.  Are there any other links of Potocari you

15    wanted to show?

16       A.   Yes.  We are in the yard of the blue building.  We see the

17    location of the blue building in relation to the DutchBat, behind the

18    Feros building.

19            And this link can take us to the still from the Petrovic video.

20    We can compare the blue building from this still and the blue building

21    from our recent picture.

22            MR. NICHOLLS:  I think that's a good time, Your Honour.

23            JUDGE AGIUS:  We'll have a 25-minute break.  Thank you.

24                           --- Recess taken at 10.29 a.m.

25                           --- On resuming at 10.59 a.m.

Page 18625

 1            JUDGE AGIUS:  We are at page 20, if we are going back to the road

 2    book.

 3            MR. NICHOLLS:  Yes, Your Honour.  Thank you.

 4       Q.   Mr. Blaszczyk, I think we've pretty much covered maybe not every

 5    single link but pretty much covered the Potocari portion of the CD; is

 6    that right?

 7       A.   Yes.

 8       Q.   Just before we leave Potocari and move on, if I could -- I'd just

 9    like to show one overview to remind us where the area we've been looking

10    at is.  If I could have 65 ter 1517, this was not on my exhibit list for

11    Mr. Blaszczyk.  I e-mailed my friends last night that I might be using

12    this aerial.  While it's loading, Mr. Blaszczyk, this is an aerial image

13    of Potocari dated 13 July.  Thank you.  And without going over it again,

14    can you just show us, we see here we've got marked the Feros building

15    which you pointed out to us and the white house, the Zinc Factory and the

16    UN base and you've explained how the filming began heading towards

17    Srebrenica passing the UN base.  Can you just indicate, it's not marked on

18    here, where the blue building is and the -- just the area where we -- of

19    the video we have been seeing and the pictures we have been seeing.

20            JUDGE AGIUS:  It's already all marked.  I don't know why you are

21    asking to mark it again.

22            MR. NICHOLLS:  No, just if he -- it was only the blue building I

23    didn't see marked, Your Honour.

24            JUDGE AGIUS:  Oh, I see. Okay.

25            THE WITNESS:  This is the blue building.

Page 18626

 1            MR. NICHOLLS:

 2       Q.   Okay.  You've made a red X over the blue building and just if you

 3    can tell us approximately how far Mr. Petrovic, based on the video we saw

 4    and the stills, how far toward Srebrenica we got before the film stopped

 5    at the white house?

 6       A.   Mr. Petrovic, he stopped his car, I mean Mr. Borovcanin together

 7    with Mr. Petrovic, they stopped the car on the way between the white house

 8    and the blue building, a distance of about 100, 150 metres.

 9            JUDGE AGIUS:  All right.  Next to that X that he's marked, could

10    you -- could he write blue building or BB?

11            THE WITNESS:  [Marks]

12            JUDGE AGIUS:  Thank you.

13            MR. NICHOLLS:  Thank you, I think this covers the area.

14       Q.   Could you just please --

15            JUDGE AGIUS:  Yes, Mr. Lazarevic?

16            MR. LAZAREVIC:  Well, I would just like if my colleague could

17    handle this, I believe that Mr. Blaszczyk is now starting giving evidence

18    about where Mr. Petrovic and Mr. Borovcanin were stopping their cars and

19    things like that.  I would like to avoid this kind of evidence with this

20    witness.

21            MR. NICHOLLS:  I think it's pretty clear from the video where the

22    car stops and where we see the camera outside.  We don't know the exact

23    parking spot.  I'm not presenting exactly where it was.  I think it's fine

24    that Mr. Blaszczyk just stated it's in the vicinity between the blue

25    building and the white house based on his viewing of the video and his

Page 18627

 1    knowledge of the area.

 2            JUDGE AGIUS:  It's not precise exactly where the car stopped, just

 3    gave an indication of an area.  And in any case, you can deal with that on

 4    cross-examination, if you wish so, Mr. Lazarevic.  No big deal.

 5            Yes, go ahead.

 6            MR. NICHOLLS:  Thank you, I'm done with that.  We could mark it,

 7    please.

 8       Q.   If could you sign and date it, Mr. Blaszczyk?

 9       A.   [Marks]

10            MR. NICHOLLS:  Thank you.  I've finished with that.

11       Q.   Now, if we could just look at page 21 of the book, quite self

12    explanatory but here we have got marked the locations of the stills in

13    this chapter which you've titled on the road Sandici, Pervani, Kravica; is

14    that right?

15       A.   Yes, this is correct.

16       Q.   Now, if we could go to pages 22 and 23, please, which you've

17    called a panorama of Sandici meadow, it's surroundings and the area.

18    These are clearly not from the Petrovic video.  Could you just explain

19    what you've done here very quickly?

20       A.   I would like to show the Sandici area and its surroundings, it's

21    quite complicated for people who have been there only once or never

22    before.  And I would like to show the location of the particular objects I

23    will refer to in future, like the destroyed house in Sandici meadow, like

24    the destroyed white house opposite Sandici meadow, and Sandici meadow

25    itself.

Page 18628

 1       Q.   Thank you.  Now, if we could turn to pages 24 and 25, and we can

 2    start watching the video which will start shortly.

 3                          [Videotape played]

 4            MR. NICHOLLS:

 5       Q.   Slightly blurry on this frame but we stopped at page 24, the only

 6    picture on that page.  Maybe we can get it slightly sharper.  No.  It's

 7    sharper when it plays.  Can you tell us where we are here on Sandici

 8    meadow, Mr. Blaszczyk?

 9       A.   We are exactly on Sandici meadow, this still was taken at Sandici

10    meadow, in the background we see the house which is located in Sandici

11    meadow.  I made a picture of the same location on the page the picture is

12    marked as the picture 1 on the page 25, we see the same building,

13    destroyed house.  In the picture, from the page 25, and the still from 24,

14    and behind we see the same fields.

15       Q.   Okay.  And was that house -- we can see it's in fairly similar

16    condition still as it was in -- on July 13th, 1995?

17       A.   Yes.

18       Q.   And could we now go to pages 26 and 27?  And just to be clear,

19    Mr. Blaszczyk, could you explain how the picture of the man calling out on

20    page 26, we see him in A, B and C, these are not in exact sequence as

21    we'll see them on the video, but you've grouped them together here; is

22    that right?  Could you explain that?

23       A.   Yes, I did it because in the meantime, the cameraman

24    Zoran Petrovic who recorded this footage, he pointed camera on this man

25    calling other people from the wood and he moved camera to another object

Page 18629

 1    and again he came back to the same object, to the same man.

 2            MR. NICHOLLS:  Okay.  If we could play now?

 3                          [Videotape played]

 4            MR. NICHOLLS:

 5       Q.   Again, we stopped at just about picture C on page 26 and you've

 6    marked on page 27 in picture 1 where these photos are from.  This is just

 7    about in the middle of Sandici meadow; is that right?

 8       A.   Yeah, this is correct and also I made the picture from Sandici

 9    meadow in the direction of the destroyed white house showing the distance

10    between the Sandici meadow, the location I spotted, and destroyed white

11    house across the road from Sandici meadow, and also I marked the direction

12    Kravica and Konjevic Polje.

13       Q.   Okay.  Now, if we could look at pages 28 and pages 29 of the book,

14    we see here pictures of the armoured vehicles on page 28, a truck which we

15    had gone past just a moment ago.  And I notice that on page 29, you have

16    not marked the location of the tank, I'll call it, we see in page 28 D.

17    Why is that not marked on page 29?

18       A.   I didn't mark the location of the tank from the still from the

19    still D, and the truck from still C from the page 28 because I wasn't sure

20    which place these two vehicles were located at that time.  I saw the

21    picture, I know that this is in Sandici meadow, I couldn't locate the

22    place, the exact place.

23       Q.   Okay.  Thank you.  Now, if we could continue playing?

24                          [Videotape played]

25            MR. NICHOLLS:

Page 18630

 1       Q.   Just while it's playing there is a blank spot here and some

 2    voiceover.  Can you tell us what's happening here?

 3       A.   This is recorded over part of the Petrovic raw material.  We can

 4    hear the voice of Mr. Petrovic.

 5                          [Videotape played]

 6            MR. NICHOLLS:  If we could back up a tiny bit, please?  Okay.

 7    Stop.  Thank you.

 8       Q.   We now have gone past photo A and we are at photo B on page 30,

 9    Mr. Borovcanin talking to the two uniformed men and actually we see the

10    date stamp now of 13 July 1995 and the time stamp.  That's on the original

11    raw material from Mr. Petrovic.  If we look on page 31, you've labelled

12    and marked where this scene is taking place.  Can you just explain how you

13    arrived at that conclusion and then we'll watch the next sequence where

14    the camera sweeps.

15       A.   I mark the location of these two men and Mr. Borovcanin, watching

16    the video, Petrovic video, very carefully on the spot in Sandici meadow in

17    this location.  And in this picture, in this particular picture, which is

18    also the still which is also the picture here, the still B on page 13 on

19    the left corner, top of the corner, you see the part -- probably the part

20    of destroyed white house.  And later on, please notice when the cameraman

21    is moving the camera, directing the camera from two men and Mr. Borovcanin

22    to the Sandici meadow you will see that the camera is passing the road and

23    showing us the location of Sandici meadow.  And based on this one I just

24    located this place.

25       Q.   And just so we know, how, in your mind, how precise is this

Page 18631

 1    location on page 31 where you've marked A and B where Mr. Borovcanin is at

 2    this moment of the film?

 3       A.   I believe this is precise.  I can be mistaken by one, two metres,

 4    maybe three metres, but no more.

 5            MR. NICHOLLS:  Okay.  Now if we could play the film and watch the

 6    camera sweep over the road to the meadow.

 7                          [Videotape played]

 8            MR. NICHOLLS:  Back one frame.  Thank you.

 9       Q.   All right.  We saw the camera cross the road now to the meadow and

10    that is we are now looking at page 32 of the book, photos A, B and C shows

11    the camera zooming in at the group of men sitting down in the meadow with

12    some armed men around them.  And I should say, Your Honours, there is a

13    typo in the counter for photo B.  It says 11.54.10 and I believe we

14    noticed yesterday when we were viewing that should be 44.

15            Page 33, you've marked the location of these men sitting on the

16    ground with the armed men around them.  Can you just tell us about how you

17    came to that conclusion?

18       A.   Watching the video, the footage of Petrovic footage I noticed in

19    Sandici, above the Sandici meadow, the small house is also visible, the

20    small house on the still A from the page 32 above the Sandici meadow and I

21    noticed it's the same house when I was over there in Sandici meadow in

22    2006.

23       Q.   Okay.  Now, the photo taken on page 33, I can see that it's a

24    compilation but when those photos were taken, where was the person taking

25    the photograph standing?  What's behind his back?

Page 18632

 1       A.   This is a compilation done by our video assistant Zoran Lasic who

 2    made a lot of photos on this area, compiled the photos in one panorama

 3    view.

 4       Q.   This is taken from across the road, where the white house is

 5    facing towards --

 6       A.   Yeah, the picture is taken from across the road exactly in the

 7    front of the destroyed white house across the road from Sandici meadow.

 8       Q.   Okay.  If we could go now to pages 34 and 35 and play the tape,

 9    please?

10                          [Videotape played]

11            MR. NICHOLLS:

12       Q.   All right.  This is close to approximately 34 C, picture 34 C.

13    We've seen the shooting and the moving of these vehicles as they fire into

14    the hills.  Can you tell us how you just were able to tell which direction

15    the -- these army vehicles were moving and army or MUP vehicles were

16    moving and where they were on the road which you've marked on page 35?

17       A.   As we see on the picture C, from the page -- of the still C from

18    the page 34, the armed vehicles are moving towards Konjevic Polje.  I

19    located this place.  This place is in Pervani, it's approximately about

20    2800 metres from Sandici meadow on the road leading towards Konjevic

21    Polje, and I located, I spotted this place, you know, through the

22    topographic features, like the hills in the background and made up of the

23    roads.

24       Q.   Okay.  And that road between Sandici meadow and Konjevic Polje,

25    it's got various parts which are curved and straight and some banked

Page 18633

 1    walls.  Did you use any of those features?

 2       A.   Yes, yes.  Yes, I did.

 3       Q.   Okay.  So then again, we've now, Mr. Petrovic and Mr. Borovcanin

 4    have left Sandici and are heading towards Konjevic Polje when we get to

 5    this portion of the video.

 6       A.   Watching the video, we see that Mr. Borovcanin together with

 7    Mr. Petrovic left the Sandici and they were heading Konjevic Polje.

 8       Q.   Okay.  If we could continue to play, please?

 9                          [Videotape played]

10            MR. NICHOLLS:  Can I stop for one second?

11       Q.   We could hear some music from the video there playing.  It's not

12    very clear.  It's clearer when you play the video by itself.  Can you tell

13    us where that music was coming from, if you know, if you found that out?

14       A.   This music is coming from -- probably from the car of

15    Mr. Borovcanin.

16       Q.   Okay.  If we can continue, please?

17                          [Videotape played]

18            MR. NICHOLLS:

19       Q.   All right.  The sequence we just saw of several minutes, were on

20    pages 36 and 37 of the book, we saw the houses in A, B and C on page 36,

21    and the firing on -- excuse me, photo D.  And then you've identified

22    several houses on page 37 and marked which ones they are.  And also marked

23    where we are on the road.  Now, 3100 metres from Sandici meadow, still

24    heading towards Konjevic Polje.  Can you just explain how you were able to

25    match up this area?

Page 18634

 1       A.   We moved a little bit further down along the road to Konjevic

 2    Polje and 300 metres, about 300 metres from the previous location, we

 3    spotted the houses which were depicted on Petrovic stills, and we see

 4    these houses on page 36 on the stills A, B and C.  We located these houses

 5    and we came to conclusion that from the video that these two APC, two

 6    armed vehicles were parked next to these houses on the road leading

 7    towards Konjevic Polje.  It's also Pervani area.

 8       Q.   Just very briefly, we can see that the house in photo A on page 36

 9    and the house in photo A on 37, there's been some restoration work going

10    on.  How are you able to tell that these were the same houses?

11       A.   We can compare the pictures, the stills from 1995 and the pictures

12    done in 2006 and we can see the same features like the windows, like the

13    doors of the house.

14       Q.   And did you also --

15       A.   Very similar.  Of course, it was renovated after that but it is

16    visible it is the same house.

17       Q.   Did you also look at the position of these houses relative to each

18    other along the road?

19       A.   Yes, of course, I did.

20       Q.   Now we will be going to the next two pages, 38 and 39 and we'll

21    play the video and catch up to here.  Before we play it, on page 38 we see

22    two houses which you've labelled as damaged -- and which you've labelled

23    as a damaged house, the second one and the location now is 2.000 metres

24    from Sandici meadow on the road leading from Konjevic Polje towards

25    Sandici and Bratunac.  So now, if I'm right, at this point, Mr. Petrovic

Page 18635

 1    is heading back, he's made a U-turn, he's heading back from the direction

 2    of Konjevic Polje towards Sandici meadow; is that right?

 3       A.   Yes, you are correct.  This is the first footage when -- on

 4    Petrovic video when we see that Mr. Petrovic is coming back to Sandici

 5    meadow.

 6       Q.   Okay.

 7            JUDGE AGIUS:  Yes, Mr. Lazarevic?

 8            MR. LAZAREVIC:  I'll have to object.  This is leading question.  I

 9    mean obviously at this point, Mr. Petrovic is heading back, he's made a

10    U-turn, this kind of -- this is basically my colleague giving evidence.  I

11    would like him to avoid this kind of question with the witness.

12            THE WITNESS:  He made that conclusion.  He can ask him.

13            JUDGE AGIUS:  Yes.  Mr. Nicholls.

14            MR. NICHOLLS:  It was leading.  If there is an objection, I'll

15    stop.  I was just trying to move it along.  It's written here and so it's

16    clear.

17            JUDGE AGIUS:  But you've got the message from Mr. Lazarevic.

18            MR. NICHOLLS:  I've got the message, Your Honours.  Thank you.

19       Q.   Okay. Before we play the clip, could you please explain the

20    direction we are going in, we've talked about it but how you concluded

21    that?

22       A.   We see from the later clips that Mr. Borovcanin -- Mr. Petrovic is

23    heading towards Sandici meadow and on this area we spotted the house which

24    is very similar to the house from this clip depicted on the -- on stills A

25    and B from the page 38.  The previous houses was already rebuilt after the

Page 18636

 1    war is -- has totally different shape but this house which we found is

 2    almost the same which we see on the stills on A and B, I mean the match

 3    house from picture 1 and 2 from page 39 and also the curve of the road is

 4    very similar to the curve.  It's the same as on the picture B and A on the

 5    page 38.

 6       Q.   And were you able, from looking at the video, to determine where,

 7    what portion of the road, Mr. Petrovic and Mr. Borovcanin made their

 8    U-turn or were you not able to figure that out exactly?

 9       A.   No, I wasn't able in which point they turn around because as we

10    see it this place is located about 1.000 metres from the previous location

11    and we had the previous clips with armoured vehicles.

12       Q.   Okay.

13       A.   But this is the first footage recorded by Mr. Petrovic on the way

14    back to Sandici meadow after the footage we see in -- with armed vehicles.

15       Q.   Okay.  If we could play the video now, please?

16                          [Videotape played]

17            MR. NICHOLLS:

18       Q.   And then we can move on but this is the same section you've

19    captured on page 38; is that right?

20       A.   Yes.  This is correct, the same two houses.

21       Q.   Okay.  We can continue now in the same direction and look at pages

22    40 and 41, please.

23                          [Videotape played]

24            MR. NICHOLLS:

25       Q.   All right.  It came back quite quickly and we are on page 40 now.

Page 18637

 1    We just passed the man standing against the retaining wall in photo A of

 2    page 40 and we are now seeing the second man in military uniform in photo

 3    B of page 40.  Could you tell us where this location is and how you

 4    determined the location?

 5       A.   This location is located in Lolici area.  This is about 900 metres

 6    from Sandici meadow on the road leading from Konjevic Polje towards

 7    Sandici and Bratunac.  I managed to locate this road by passing this road

 8    several times and also I know that on this road on the left side of the

 9    road we have two retaining walls.  The first one is in the Lolici area and

10    another one is about few hundred metres before we reach Sandici meadow on

11    the left side also and we can see that this is the wall from Lolici area.

12       Q.   Thank you.  Continue, if you have --

13       A.   Yes, and of course, I compare also topography, topographic view of

14    the surrounding hills.

15       Q.   Okay.  All right.  If we could continue playing the video and we

16    would be on pages 42 and 43 now.

17                          [Videotape played]

18            MR. NICHOLLS:

19       Q.   All right.  Now, this sequence still heading towards Sandici, we

20    saw several men without stopping all the way along, we saw the man in

21    photo A, flashing past the camera on page 42.  If we look at photo B, on

22    page 42, we can see there were two men there crouching behind the barrier

23    looking towards the woods.  The fourth man we see in this sequence is in

24    photo C of 42 also crouching by the barrier.  If I'm correct about this,

25    Mr. Blaszczyk.  And then it's difficult to see and it's difficult to see

Page 18638

 1    on the video but right where we stopped on photo D of page 42, how many or

 2    what is that up towards the -- just standing in front of the house we see

 3    ahead on the road?

 4       A.   When you watch very carefully this part of the video you can see

 5    that we can see two men standing behind the barrier in front of the car

 6    heading towards Sandici and Bratunac.

 7       Q.   Now, I won't ask you any leading questions.  Can you explain how

 8    you have marked the locations of photos A, B, C and D as you have on

 9    photos 1 and 2 on page 43?  You've got a straight-on shot and you've got

10    an overview.  If could you explain that to us first.

11       A.   I drove the same road which was used by Mr. Petrovic and

12    Mr. Borovcanin, and I passed the same barriers on the right side of the

13    road leading to Sandici meadow.  It was just before the Sandici meadow,

14    about 400 metres from Sandici meadow, and I compare the video clip and the

15    stills from the video, this video, the Petrovic video, with the features

16    on the road and I marked the location, quite a few locations of these men

17    depicted on the page 42.

18       Q.   Okay.  Now, on page 43, we see on the left side we don't see it on

19    the video but we see a retaining wall.  Is that the second retaining wall

20    were you discussing a moment ago?

21       A.   Yeah.  This is correct.  This is the second retaining wall.  The

22    first one is Lolici and then we are coming to another one, last one before

23    the Sandici meadow.

24       Q.   Okay.  And -- continue.

25       A.   And in the corner of the picture 1 from the page 43, I attach also

Page 18639

 1    the overview of the area and I marked a few locations in this picture,

 2    these overview pictures, Sandici -- like Sandici meadow, destroyed white

 3    house, Kravica warehouse is further down, and to showing how the men were

 4    posted at that time in relation to Sandici meadow and destroyed white

 5    house.  I know that Kravica warehouse is not very well visible here but is

 6    visible from the place where he took the pictures when we zoom in the

 7    picture we can see very easily Kravica warehouse.

 8       Q.   Okay.  And again it's fairly self explanatory but you've marked an

 9    area with a white X.  Can you just tell us what that is, how you came to

10    pick that spot?

11       A.   This spot was pointed to me by the member of the federal

12    commission for the missing person as the place where the exhumation took

13    place, exhumation of the people from Srebrenica, and exhumation was

14    conducted in June 2004 by the federal commission.  And I also saw the

15    pictures and I believe video from this exhumation, and it was conducted

16    exactly in this place behind the barrier down.

17       Q.   If we could continue playing, please, the video?

18                          [Videotape played]

19            MR. NICHOLLS:

20       Q.   All right.  That's good.  If we go to pages 44 and 45 it's very

21    difficult to stop exactly on it, you've got a man who flashes by the

22    camera marked on pages 44 on photo A, and you've marked the location on

23    page 45.  Do you have anything to add to what's clear from your markings

24    here?

25       A.   When Petrovic passed the curve which is visible on the page 43, he

Page 18640

 1    stopped the car over there and from the -- while passing the curve, he

 2    recorded also the man which is depicted on the still from the page 44.

 3       Q.   Okay.

 4       A.   Probably this -- I am pretty sure that the two men depicted on

 5    page 20 -- 42, on still D, they are the men from page 44, still A, and the

 6    man from page 46, still A and B.

 7       Q.   Okay.  I see.  Now, we stopped right at the man in still B on page

 8    46.  I think we can continue playing a little bit now until we get to the

 9    next man.

10                          [Videotape played]

11            MR. NICHOLLS:

12       Q.   All right.  So now we've seen the man who is in 46 A and B, he

13    starts off shouting for people to come out of the hills and then we've

14    seen the armed man on page 46 C.  And on page 47, you've got two overviews

15    where you've marked the locations of these men.  Could you explain that,

16    please, where we are?

17       A.   We are about 200 metres from Sandici meadow along the road

18    Konjevic Polje-Bratunac, direction Konjevic Polje.  We stopped -- actually

19    the stills were taken from Petrovic with video which was recorded in this

20    location, it was before the curve, before they reached the Sandici meadow

21    again.  And watching this video and comparing the features from the video,

22    I mean the features of the terrain over there, from the video, and from

23    life when I was there together with my colleague, I spotted the places

24    where the two men depicted on the stills A, B and C were standing.  And on

25    the right side on the page 47, I just attached the first photo, the photo

Page 18641

 1    1 is the overview of the area with the marks where these two guys were

 2    standing and also I pointed, I marked the location of destroyed white

 3    house and Sandici meadow.  In the second picture, this is panorama

 4    picture, maybe it's not reflect exactly the shape of the road because here

 5    we see that the road is like cycling, and leading towards Konjevic Polje,

 6    but this is straight road with two bends on the left and on the right side

 7    because it was impossible to create a picture which could reflect the real

 8    stage.

 9       Q.   Okay.  So just if I can lead for one point, I'll stop if I get an

10    objection.  It's that the photo on page 47, 2, the curve appears to be

11    more pronounced than it is in reality because you created this panorama

12    shot; is that right?

13       A.   Yes, it's right, it's too bent.

14       Q.   And I think now we can just continue, please.

15                          [Videotape played]

16            MR. NICHOLLS:

17       Q.   Okay.  We are on pages 48 and 49.  We have just seen a sequence

18    where Mr. Petrovic has been outside the car filming men, Mr. Borovcanin

19    and others, on the road.  Can you tell us where we are here and whether we

20    are closer or moving closer or not towards Sandici meadow and what we've

21    called the destroyed white house?

22       A.   In this footage, in these stills from the Petrovic footage, we are

23    getting closer to Sandici meadow.  It's about 100, 150 metres from Sandici

24    meadow.  We see the people walking down from Sandici meadow towards

25    Konjevic Polje.  And also, I just located this place by comparing the

Page 18642

 1    stills we took from Petrovic footage and playing the footage itself on the

 2    spot.  I compare the hills, the road and the features on the road and on

 3    the hills.

 4       Q.   All right.  Thank you.  I think we can keep playing now.

 5                          [Videotape played]

 6            MR. NICHOLLS:

 7       Q.   Sorry, on page 50 now, we've gone slightly past it but the men in

 8    photos A and B on page 50 who we see one crouching under the bush and one

 9    pointing his gun over the barrier, and we see on page 51 a barrier on a

10    curve of the road heading towards the destroyed white house, can you just

11    tell us a little bit how you were able to tell where these two men are?

12       A.   I spotted this location, this location is located about 100 metres

13    from Sandici meadow on the road Konjevic Polje-Bratunac, direction

14    Konjevic Polje.  And the men, the two men, they are standing behind a --

15    the barrier actually that is -- behind the barrier there is creek, also

16    the creek is visible in the Petrovic video.  I made the stills of the

17    creek on the still C and I spotted this location, this is depicted on

18    picture 1, picture 2, on the page 51, and picture 3, I made the picture,

19    we made the picture of the creek below the road.  And also the fourth

20    picture, this is overview of the area with marked location of these men,

21    and relation to this location to the location of Sandici meadow, destroyed

22    white house and Kravica warehouse, and as I said again, before the Kravica

23    warehouse it's not very well visible here on this picture but when you

24    zoom in this picture on the computer, you could see the Kravica warehouse.

25       Q.   If we could continue just a little bit, please?

Page 18643

 1                          [Videotape played]

 2            MR. NICHOLLS:

 3       Q.   Thank you.  Now, at page 52, photo B, on the original footage it's

 4    not particularly clear right on that frame, but it's clear in the photo,

 5    Mr. Borovcanin speaking to a man wearing a blue helmet.  Just again tell

 6    us how you know where we are?  You've marked it on page 53.

 7       A.   As before, I compared the location which I found with two men who

 8    were standing behind the barrier and pointing the guns towards the creek,

 9    and I see that Mr. Borovcanin is standing about 50 metres maybe or 30, 50,

10    30 metres from these men and it's also located on the road leading towards

11    Kravica and Bratunac.  And we can notice on the picture B that the car,

12    from the page 52, that the car used by Mr. Borovcanin - we know that this

13    car was used by Mr. Borovcanin from his statement and also from the

14    statement of his driver - this car is heading towards direction of

15    Bratunac.

16       Q.   All right.  Well, there is -- looks like there is two cars in B

17    which one are you referring to?

18       A.   I'm referring to the grey-silver car.

19       Q.   Okay.  Thank you.  Okay.  We are now going to play some more

20    segment and go, I think, straight through pages 54 and 55 and continue on

21    through 56 and 57.  And then I'll ask you to come back and explain these

22    locations.  Thank you.

23                          [Videotape played]

24            MR. NICHOLLS:

25       Q.   All right.  Now, let's go back to page 54 and 55, please.  We've

Page 18644

 1    seen the men, we can see on page 54 just now on the video walking up, up a

 2    path, past some white pillars around the corner of a white building and we

 3    saw the man with the back-pack head down the -- and in the direction of

 4    the road there.  Can you tell us what we've got depicted here and how you

 5    were able to determine where this sequence of the men walking out of the

 6    woods took place?

 7       A.   From the recordings and from the still that we see that the

 8    recording was done in the destroyed white house located across the road

 9    from Sandici meadow.  We see that the men were walking through the path

10    leading from the north direction -- from the south direction towards the

11    destroyed white house, passing the white house.  And later on we can see

12    that the people are passing the road towards Sandici meadow.  The Sandici

13    meadow is about 100 metres located from this destroyed white house here.

14    We can compare the parts, poles of the house, we see very good the poles

15    are visible on picture 2 on page 55 of the house.  We can see from the

16    recordings that the people are passing these poles.

17       Q.   Now, if we look at page 54, picture C, the man with the back-pack

18    coming around a corner, you've marked his location on page 55 and picture

19    1 as a kind of the front corner of the white house heading down towards

20    the Kravica-Konjevic Polje road.  How did you determine that?  Just that

21    particular man's location?

22       A.   I just followed the recording of Mr. Petrovic and I recognised the

23    wall and the poles of the house depicted on picture 1 from page 55 and

24    this is visible that the man is turning across the corner, behind the

25    corner of this house, from the left -- from the left side of the house.

Page 18645

 1       Q.   Okay.

 2       A.   And on the still C, we can see part of the road and probably bus

 3    parked on the road and behind -- across this road there is Sandici meadow.

 4       Q.   Thank you.  If we could now look at pages 56 and 57, very similar

 5    the way you've marked this on page 57, the location of the men and boys in

 6    photos A through E or A through F, excuse me, on page 56.  I think your

 7    explanation is probably -- well, just, can you please tell me how you came

 8    to this conclusion, this sequence?

 9       A.   This explanation would be the same like the previous one.  It's

10    visible the poles of the house on the destroyed white house located across

11    the road of -- from Sandici meadow and from -- from the recordings we can

12    get more details of this house and also the path.

13       Q.   Okay.  And when were you there, did you walk up and down any of

14    these paths or across the road to the meadow and recreate this path?

15       A.   Yes, I did.  I did it several times.

16       Q.   If we could continue, please, with some video?

17                          [Videotape played]

18            MR. NICHOLLS:  Stop, sorry.

19       Q.   We saw one second of a photo of President Karadzic there.  Do you

20    know how -- do you have any explanation why that's on the tape?

21       A.   It's also recorded over on the original tape, but Mr. Petrovic I

22    think he will explain by himself when he will testify in this Court.

23       Q.   And continue playing.

24                          [Videotape played]

25            MR. NICHOLLS:

Page 18646

 1       Q.   Thank you.  We have just seen, we are at page 58 and photos A and

 2    B we see the man with the leather jacket who asks for water walking down a

 3    path and across the road and then the direction he's going is shown in

 4    photo C on page 58 and we see the back end of a parked bus.  Can you just

 5    tell us where this man was walking in the clip we just saw?

 6       A.   This man used the same path which had been used by the previous

 7    men.  He's walking along the white destroyed house located across the road

 8    from Sandici meadow.  He's -- he's turning in the front of the house we

 9    see he's turning first right and left, crossing the road and going towards

10    Sandici meadow.

11       Q.   Could we continue, please, playing the video for a little while?

12                          [Videotape played]

13            MR. NICHOLLS:  Can we stop?  Sorry.

14       Q.   Now we are at counter 24.10.3, a couple of men in camouflage

15    uniform sitting down by the road and one of them looks quickly away from

16    the camera.  Are these -- is the location of these men put in the book

17    anywhere?

18       A.   No.  I didn't put the location of these men on this road book

19    because I wouldn't able to spot the place where they were sitting.  I

20    believe that this is in Sandici meadow, close to Sandici meadow, but I

21    couldn't locate the place.

22       Q.   Thank you.  Continue.

23                          [Videotape played]

24            THE WITNESS:  I have some assumption but when I wasn't sure I

25    didn't want to attach it to the book.

Page 18647

 1                          [Videotape played]

 2            MR. NICHOLLS:

 3       Q.   Okay.  We can stop there.  That's the next section we see on the

 4    raw footage which we obtained from Mr. Petrovic, and that is the end of

 5    this chapter.  What I'd like to do now, Your Honours, before we leave this

 6    section of the road is play the Studio B footage.  We have a clip from the

 7    Kravica warehouse and we are at pages 60 and 61, excuse me, of the book

 8    now.

 9            JUDGE AGIUS:  One moment, Mr. Nicholls.  You said Studio B but

10    this is what we see is Petrovic footage here as well.  Is --

11            MR. NICHOLLS:  I can explain that, Your Honour.  You're quite

12    correct.  This is the Studio B footage.  It's taken from our trial video

13    compilation.  So that is a bit misleading.  It's the Studio B broadcast

14    segment which will be -- it will have the Studio B logo in the corner of

15    the screen but you're correct it's been labelled this way because he is

16    the one who took the film.

17            JUDGE AGIUS:  Okay.  All right.

18            MR. NICHOLLS:  Thank you.

19                          [Videotape played]

20            MR. NICHOLLS:  And now if we can play the slow motion of the same

21    clip just so that -- to remind us of what the buildings look like.

22                          [Videotape played]

23            MR. NICHOLLS:  Okay.  Thank you.

24       Q.   If we can look now at pages 60 and 61 in your book, Mr. Blaszczyk,

25    you've got the two stills showing two parts of the Kravica warehouse from

Page 18648

 1    the Studio B footage on page 60 and you've made some photos and labels on

 2    page 61 of the Kravica warehouse.  Can you explain to us these locations?

 3       A.   This is Kravica warehouse, the warehouse is located in the village

 4    of Kravica.  And on the page 60 I attached the stills from Studio B

 5    broadcast from edited material of Petrovic footage.  This material, these

 6    stills, this clip, is not visible in the raw material, in the copied raw

 7    material we received from Mr. Petrovic.  It was also recorded over

 8    somehow.  And of course, the place is very known to everybody but I made a

 9    picture of this Kravica warehouse on the right -- on the page 61, I marked

10    the location of the first still which was taken on the west door of

11    Kravica warehouse and as on the page 1 and page -- sorry, on picture 1

12    from the page 61 and on picture 3 on the page 61 as the location A.  And

13    on the page -- on the page 61, on the picture 2 I marked the location

14    where the bus is stopping on the still from Studio B broadcast, on still B

15    from the page 60.

16       Q.   Now -- and then just to give us an idea, how many times have you

17    personally been to the Kravica warehouse location?

18       A.   It's many times.  Difficult to say how many but every time when

19    I'm in this area I'm passing this warehouse.  It could be 50, 60 and more.

20    And this warehouse was described by the witness Jean-Rene Ruez during his

21    testimony in this trial in details.

22       Q.   Okay.  That's the end of chapter 2, Your Honours, that segment of

23    the video we've covered.  Mr. Blaszczyk has created a similar CD

24    presentation for this area of chapter 2 which I'd like him to quickly run

25    us through and show how it works and that's the last part that's on the

Page 18649

 1    CD.  The rest of the book is not contained on the CD.

 2       A.   We are again with presentation --

 3       Q.   Sorry, Mr. Blaszczyk, if you can, try to -- it will come up in a

 4    minute, try to quickly take us through in the same general order that

 5    you've got the -- as the video was taken as and as you've laid out the

 6    pictures in this chapter of the book.

 7       A.   Yes, of course.  We are entering the area --

 8       Q.   Sorry, it's not on our screens, yet.  We'll have to -- okay.  Now

 9    it's -- I think it's working now.  Okay.

10       A.   We see the map of the area of Bratunac, Srebrenica, Kravica and

11    Sandici.  We are coming to the more detailed map of the area of Sandici.

12    On this map, I marked the locations which were depicted on the stills from

13    Petrovic video and located by me during my mission in this area.  We link

14    to the area of Sandici, from the recent picture.

15            This is the link to the still from Petrovic, taken from Petrovic

16    video.  We can compare the house depicted on this still and the house from

17    the recent picture.

18            Also to help ourselves we can use the information button here to

19    mark the link fields.  We have the still from Petrovic video taken in July

20    1995, 13th of July 1995.

21            Also, the still from Petrovic video above the -- on the hill we

22    can see the small house over here.

23       Q.   And, excuse me, just to be clear, that's different from the --

24    that earlier damaged house which you showed us, that small -- you've

25    labeled that one the small house, the earlier one you labelled the

Page 18650

 1    destroyed house which is closer to the meadow, correct?

 2       A.   Yeah, this is correct but this house, this small house, is also

 3    marked in my road book.  We can see the same house on this picture.  We

 4    can compare the area.

 5            We can get another view of the same area from another position.

 6            And the same area from the hill above the road leading towards

 7    Konjevic Polje.

 8            We see the white house across the road, destroyed white house

 9    across the road.

10            On this still from Petrovic video we see part of the car.  I

11    recognised this car as the car used by Mr. Borovcanin and Petrovic.  We

12    see that the car is headed towards Konjevic Polje at this point.  We see

13    the aerial used by the radio from this car.

14            Following the sequence from the Petrovic video, we can see that

15    Mr. Petrovic is following the armed vehicles.  The first footage with

16    armed vehicles we located in -- it was recorded in Pervani area.

17            We can link to the still from 1995.  We can zoom in and we can see

18    the hills in the background and also compare the road.

19            From the recordings we see that armed vehicles moved towards

20    Konjevic Polje, about 300 metres, the place is located by me.  Also here

21    we have the link from the picture to the still from the Petrovic video.

22            And the first footage, on the way back, was recorded in this area.

23            This is the house which is visible also on the still from Petrovic

24    video.

25            And the car in Petrovic is passing the wall in Lolici.

Page 18651

 1            I'm slowly moving this picture towards direction of Sandici and

 2    Bratunac.

 3            Here is the link to the still from Petrovic video.

 4            Here is the link to the second still from Petrovic video of the

 5    man standing and walking towards the wall.

 6            We are coming to the area quite close to the Sandici meadow.

 7            This is the links to the stills from Petrovic video depicted the

 8    men along the road and behind the barrier.  This is the first man before

 9    we reaching the road.  It's very hard to see this man on the recording but

10    he's visible.  We have two men crouching behind the barrier and watching

11    towards south.  The fourth man.

12            And link to the Petrovic still and now I think we can see two men

13    standing on the right side of the road.

14       Q.   Could we go back to that photo -- could we go back to the still

15    that you just showed us the link?  What's that on the dash board of the

16    car, if you can see on the inside on the dash board?

17       A.   Yes, this is a hand set, Motorola hand set.

18       Q.   Okay.  Thank you.

19       A.   We are slowly approaching the area of Sandici.  I took Your

20    Honours to the overview of this area.  Here we have destroyed white house

21    across the Sandici meadow, Sandici meadow itself.

22            The previous picture a still from Petrovic video.

23            And as we see from the recordings, Petrovic recordings, Petrovic

24    got this point before the Sandici meadow, he stopped the car somewhere

25    here and he recorded these two men.

Page 18652

 1            You can compare the curve of the road here, from the recording and

 2    from the still as well.

 3            We see two men also looking towards creek, to the south direction,

 4    and we see the red car and behind this red car we can see also the

 5    silver-grey car used by Mr. Borovcanin and Mr. Petrovic.  The area is

 6    located this about 100 metres, 150 metres, maybe 200 metres from the

 7    Sandici meadow.  The Sandici meadow is on the left side of the road.

 8            We are getting -- we are in front of the destroyed white house

 9    right now and we can see the same area but from different perspective.

10            We have more accurate picture of the car used by Mr. Borovcanin

11    and Mr. Petrovic.

12            We are going to the hill above the Sandici meadow, to see the

13    landscape to see the overview of Sandici meadow, its surroundings.

14            MR. NICHOLLS:  Your Honours, I'm not sure if it's time.  We could

15    try to finish the presentation off quite quickly afterwards.

16            JUDGE AGIUS:  Unless there is a serious objection, we could try to

17    finish this presentation.  No, what I mean to say is this presentation

18    that he is going through now.  I know there are two other parts over there

19    and those are not supported by -- so how long -- how much longer do you

20    think you need to finish this presentation now?

21            MR. NICHOLLS:  Probably I would defer to Mr. Blaszczyk who knows

22    it better than me but I would say 10 to 15 minutes.

23            JUDGE AGIUS:  No, no.  Then we have the break.  Then we have the

24    break.

25            MR. NICHOLLS:  The Kravica section takes a little bit more time

Page 18653

 1    and then it will be finished.

 2            JUDGE AGIUS:  Then we will have the break now.  Agreed?

 3            MR. NICHOLLS:  Thank you.

 4            JUDGE AGIUS:  We'll have a 25-minute break now.  Thank you.

 5                           --- Recess taken at 12.31 p.m.

 6                           --- On resuming at 1.00 p.m.

 7            JUDGE AGIUS:  Go ahead, Mr. Nicholls.

 8            MR. NICHOLLS:  Thank you.

 9       Q.   Now, Mr. Blaszczyk, if you could -- as quickly as you think you

10    can, show us the remaining links for the Sandici meadow area and then we

11    can move to the Kravica portion of your -- of your interactive CD.  Before

12    we do that, can you tell me, if you know which software was used to

13    actually create the CD which we are looking at?  I know we are playing it

14    in QuickTime, but do you know which was used to make it?

15       A.   To be honest, not really because it was created with the help of

16    video assistant, Mr. Zoran Lasic.

17       Q.   All right.  Thank you.  We'll look into that.  If you could just

18    show us whichever remaining links we need to see and then we can move to

19    Kravica.

20       A.   Okay, we are going to the link with the view of the white house,

21    the left side of the destroyed white house across the road from Sandici

22    meadow.  In the previously we seen this house in this location here,

23    marked here.

24            And this is the link to the still from 1995, from Petrovic video.

25            Another link.  Here we see the poles of the white destroyed house.

Page 18654

 1    The same poles right here.

 2            And here we see the corner of this destroyed white house with the

 3    man with the back-pack passing this corner.

 4            I think we -- I think we have seen most of the probably everything

 5    from the Kravica -- from the Sandici meadow.

 6       Q.   That's fine.  Thank you.

 7       A.   And the next stop is Kravica warehouse.  It's not visible on the

 8    copied raw material of Mr. Petrovic but this is brought -- it was

 9    broadcasted by Studio B in 1995, July 1995.

10       Q.   One question before you show us that.  Just when we finished this

11    section of the video, there was a shot of a rations box with a 1997 date

12    on it.  Can you tell us anything about why that is there in the video?

13       A.   Yes.  It was also recorded over by Mr. Petrovic somehow.  I think

14    he will explain the best how it was over-recorded.

15       Q.   Thank you.

16       A.   And we are coming to Kravica.  One in front of the Kravica

17    warehouse.  We see the west door of Kravica warehouse.

18       Q.   Just to be very clear, west door means heading towards -- that's

19    the Sandici end?

20       A.   Yes, the west door is heading towards Sandici, the closest door to

21    Sandici meadow.  This is the road leading to Sandici and Konjevic Polje.

22       Q.   And while we are here, could you just do one spin around so that

23    you could show Their Honours and my friends how we have the entire length

24    of the warehouse and how close it is to the road.

25       A.   Yes, of course.  On the left side of this screen we see the road

Page 18655

 1    now is heading towards Bratunac.  It's visible from this point how close

 2    is the warehouse located in relation to the road.

 3       Q.   Thank you.  And what can you -- please continue.

 4       A.   And we can link to the picture, to the still from Studio B

 5    broadcast.

 6       Q.   Maybe could you show the button which shows us where all the

 7    fields are because that one is not marked well.

 8       A.   Yes, it this one is unfortunately not marked well.  I can press

 9    the information button here.  We see there are additional blue fields

10    here.  This is the links to the pictures, to the stills from Studio B

11    broadcast.

12            We see the west door of the warehouse in Kravica.

13            We see the middle of Kravica warehouse and the bus.  Also this is

14    a still from Studio B broadcast.

15            We can enter through the west door to Kravica warehouse, to the

16    room in Kravica warehouse.

17       Q.   Now, this room, if you'll recall, we had two witnesses, PW-111 and

18    PW-156, you've just entered the west door of the Sandici end.  Was that

19    the one that was identified by survivor 156 or 111, if you recall?

20       A.   This room was identified by the survivor PW-156.

21       Q.   Can you just explain what we have here?

22       A.   Just I went to another corner, to another end of the -- this room.

23    And we are the same room but we look at this room from different

24    perspective.  And as witness, protected witness PW-156 described, he was

25    located somewhere here.

Page 18656

 1       Q.   And you're indicating that rectangular area marked at the end

 2    corner of the building, we can see an outline?

 3       A.   Yes, exactly, according to the witness in July 1995, it was a kind

 4    of booth, this corner.

 5            MR. LAZAREVIC:  I apologise, maybe I should have intervened

 6    earlier but really I don't feel it's appropriate for this witness to

 7    comment on other witness's --

 8            MR. NICHOLLS:  Your Honour, if I may, the only intention is to

 9    provide Your Honours to link it up to the earlier testimony.  It's pretty

10    clear in the transcript just where we are in the house.

11            JUDGE AGIUS:  Then he could have restricted himself that this is

12    relevant for the testimony of PW-whatever he is, and leave it at that.

13            MR. NICHOLLS:  All right.

14            THE WITNESS:  Okay.  We can see this room inside.  We are leaving

15    this room.

16            MR. NICHOLLS:

17       Q.   Before we leave it, if you can, you've been there several times,

18    can you tell us, it's a bit difficult to gain a perspective as you're

19    turning around, what are the approximate -- what are the dimensions,

20    interior dimensions, of this Sandici-end room?

21       A.   It's about 260 square metres, and it had been measured first by

22    the forensic team as far as I remember in September 1996 and also I

23    confirmed by my measurement.

24       Q.   Okay.

25       A.   We are going out from the white house, we are leaving this -- I'm

Page 18657

 1    so sorry, of course, from the warehouse, we are leaving this room.  We

 2    are, again, in front of the west door.  We are coming closer to the east

 3    part of warehouse in Kravica.  We see -- this is east part of the Kravica

 4    warehouse.  It was described by the Witness PW-111.  We can see also the

 5    eastern corner of Kravica warehouse and backyard of the Kravica warehouse.

 6    They are the buildings attached to this complex of Kravica warehouse.

 7       Q.   Thank you.  If you could just finish spinning us around 360 here,

 8    we can get to that wooden -- that funny wooden structure there and the

 9    road again.

10       A.   Behind the trees we have the road, now leading to Konjevic

11    Polje -- Sandici-Konjevic Polje.

12       Q.   Okay.  Thank you very much.  I think you've explained all the

13    features of the CD presentation for that chapter.

14       A.   Yes, I did.  I would like to add that this is representation

15    regarding only the first two chapters of this road book, and relating to

16    13 of July 1995.

17       Q.   Thank you.  If we can continue with the video now where we left

18    off, Your Honours, it will go quicker now because it's less complicated.

19    There aren't men along roads and curves to try to explain.  It will go

20    quite a bit quicker now.

21                          [Videotape played]

22            MR. NICHOLLS:

23       Q.   Okay.  I think we probably recognise that building.  We don't need

24    to go back to it.  Can you just tell us where we are now, which direction

25    are we heading in and where are we?

Page 18658

 1       A.   We are passing the DutchBat compound in Potocari.  The car is

 2    driving towards direction of Srebrenica.  And this is recording from 14 of

 3    July, 1995.

 4       Q.   Thank you.  Please continue.

 5                          [Videotape played]

 6            MR. NICHOLLS:  If we could stop there at 26.11.

 7       Q.   This will continue but on the Studio B edited footage, what do we

 8    see at this point after we hear that music and passing the man leading the

 9    horse or the donkey?

10       A.   After this footage, we see the footage from the clips from Kravica

11    warehouse with dead bodies in front of the Kravica warehouse.  And yeah,

12    this is visible that this footage was recorded on the 14th of July and

13    that Kravica warehouse footage was recorded day before, on the 13th of

14    July.

15       Q.   Okay.

16       A.   It was edited at Studio B.

17       Q.   Okay.  If we can continue, please.

18                          [Videotape played]

19            MR. NICHOLLS:  If we could go back a couple frames?  This is not

20    in the books, Your Honours.

21       Q.   But what's this building that we are passing on the right side at

22    27.16?

23       A.   This is building located in Srebrenica was used by UN, by

24    DutchBat.

25       Q.   Thank you.

Page 18659

 1                          [Videotape played]

 2            MR. NICHOLLS:

 3       Q.   Again, just 27.32.5, what is this -- where are we here with this

 4    handwritten sign?

 5       A.   We are on the street in Srebrenica.  This is the police station in

 6    Srebrenica.

 7       Q.   Okay.

 8       A.   In fact, it was -- this is the police station established by the

 9    Serbs.

10                          [Videotape played]

11            MR. NICHOLLS:

12       Q.   All right.  There aren't so many -- we haven't put so many photos

13    in the still book here but this is on page 64 and 65, the big department

14    store.  Can you just tell us where this is in downtown Srebrenica?

15       A.   This is exactly in the centre of Srebrenica.  I think this is

16    the -- these two pictures are -- these two buildings are the most

17    recognisable buildings in the town.  Is department store Srebrenicanka and

18    municipality building on the right side of this picture.  And recorded --

19    the recording which we have seen right now was done on this street leading

20    to the Srebrenicanka department store from direction of Potocari.

21       Q.   Thank you.

22            We can continue with the video.

23                          [Videotape played]

24            MR. NICHOLLS:  If we can go back to the scene of these men walking

25    up the street from behind?

Page 18660

 1                          [Videotape played]

 2            MR. NICHOLLS:

 3       Q.   It's difficult to see here on this video still playing it in

 4    Sanction, but the patch on the left arm of the man in the middle, have you

 5    been able to tell what patch that is, what that signifies?

 6       A.   Yes, I've seen better quality picture still from this video and

 7    this is the patch of the Drina Wolves unit.

 8            MR. NICHOLLS:  Continue, please.  Sorry, I should have said for

 9    the record we were at approximately 39.41.  Thank you.

10                          [Videotape played]

11            MR. NICHOLLS:  It's playing a little bit choppy at the moment but

12    we can stop here at 41.12.5 just for Your Honours to know, here we are the

13    date and time stamp showing the 14th of July.

14            We can continue.

15                          [Videotape played]

16            MR. NICHOLLS:

17       Q.   All right.  Mr. Blaszczyk we've now -- you could say we have left

18    Srebrenica and come to Zeleni Jadar wood factory, chapter 4 of your book.

19    Could you just -- and this is shown mostly on pages 70 and 71, the photos

20    showing the location and we'll watch this clip in a minute.  I think it's

21    quite clear from your video still you've selected and the current

22    photograph on page 71, looking at photo A on page 70 and photo A on page

23    71.  Can you just tell us where we are and what we see here?

24       A.   Yes, we are in Zeleni Jadar wood factory on the page 70 on the

25    stills A, we see the building, wood factory in Zeleni Jadar.  On the page

Page 18661

 1    71, we see the current picture of the same building.  And on the page B

 2    from the sequences when we play the footage, we see that the people are

 3    working inside the factory.

 4       Q.   Okay.  I think you could say that in 70 B, who are the people in

 5    that photo?

 6       A.   In the first man in front of us, from -- this is Tomo Kovac, the

 7    former Minister of Interior of Republika Srpska.  The second man in the

 8    middle is Dragomir Vasic and the last one is Mr. Borovcanin.

 9            MR. NICHOLLS:  Play the video now, please.

10            JUDGE AGIUS:  Yes, one moment.

11            MR. LAZAREVIC:  I apologise, first I would like to see whether

12    Mr. Nicholls would finish with his testimony today because there is one

13    issue that I would like to raise before the Trial Chamber.  It would take

14    literally two minutes just to make sure that I'm going to have them.

15            JUDGE AGIUS:  We have about five minutes left.

16            MR. NICHOLLS:  Your Honour, there is approximately 20 minutes, a

17    little bit less than 20 minutes of video left which won't require too much

18    intervention by me but I think it's important to see it before Mr.

19    Petrovic comes.  So, no, we won't finish today but we'll finish quite

20    quickly tomorrow afternoon.

21            JUDGE AGIUS:  So why don't we stop here and we'll start the wood

22    factory tomorrow again.

23            MR. NICHOLLS:  That's a good idea.  Thank you.

24            JUDGE AGIUS:  I think so.

25            Okay, Mr. Blaszczyk, we haven't finished yet.  We'll continue

Page 18662

 1    tomorrow in the afternoon at 2.15.  And, hopefully, then we should finish

 2    with you, with cross-examinations too.

 3            THE WITNESS:  Thank you, Your Honour.

 4            JUDGE AGIUS:  Thank you.

 5            JUDGE AGIUS:  Yes, Mr. Lazarevic?

 6            MR. LAZAREVIC:  Yes, Your Honour, I believe I'll have to wait, and

 7    allow Mr. Blaszczyk to leave the courtroom.

 8                          [The witness stands down]

 9            Mr. Blaszczyk was testifying today in the capacity of the witness.

10    He made a solemn declaration.  He didn't finish with his testimony today.

11    We are aware of the situation that Mr. Petrovic is right here in The

12    Hague, and it appears that Mr. Blaszczyk was also present when

13    Mr. Petrovic was giving his interview to the Office of the Prosecution.

14    So, I would just like to raise this issue before the Trial Chamber because

15    we would vigorously oppose to a situation that Mr. Blaszczyk and

16    Mr. Petrovic meet before Mr. Petrovic finishes his testimony.  I'm fully

17    aware that this particular witness is chief investigator in the

18    Prosecution, but right now he's a witness before the Tribunal so he should

19    be prevented of discussing the gist of his testimony with another

20    witness.  Just I would like to raise this for the Trial Chamber.

21            JUDGE AGIUS:  Thank you, Mr. Lazarevic.  Who is going to deal with

22    this?  Yes, go ahead.

23            MR. NICHOLLS:  Could we have one moment, Your Honour?

24            JUDGE AGIUS:  Yes, certainly.

25                          [Prosecution counsel confer]

Page 18663

 1            MR. NICHOLLS:  Thank you, Your Honours, for that moment.

 2            I can understand in principle what my friend is saying.  Our

 3    strong preference, I have not yet met Mr. Petrovic since he's arrived

 4    here, would be to meet with him with Mr. Tomasz Blaszczyk, as the

 5    investigator.  Mr. Blaszczyk was involved in the interview with

 6    Mr. Petrovic and knows him and the Court is aware that we had some

 7    difficulty or was not easy at the beginning getting Mr. Petrovic to agree

 8    to come here and I think it could be helpful.  I don't really see what the

 9    problem is.  Of course, the testimony of both witnesses is related since

10    it covers the same video.  However, Mr. Blaszczyk has testified to is very

11    straightforward.  We would not be discussing his testimony at all between

12    myself and Mr. Blaszczyk or Mr. Petrovic.  He would simply assist me as

13    investigator does in the proofing.  I think especially the nature of this

14    type of testimony, where he is just talking about places he's identified

15    in the video and where he's been is not -- I don't see any risk of

16    corruption of these two meeting, and I would much prefer that

17    Mr. Blaszczyk be available for the proofing this afternoon.  It's not -- I

18    just don't see the problem.

19            JUDGE AGIUS:  And also take an active part?  In other words?

20    Because the proofing will be done by you, presumably --

21            MR. NICHOLLS:  It is by me.  He might ask questions.  He probably

22    doesn't need to, really, but he would --

23            JUDGE AGIUS:  But can he follow the proofing without being present

24    in the same room?

25            MR. NICHOLLS:  Yes, but it's more that I think it will -- it's

Page 18664

 1    more his presence that I want.  I need a -- I always have a witness with

 2    me whenever I talk to anybody, and he knows the witness, Mr. Petrovic, who

 3    is coming and they have -- as I said he's been to his home and all of that

 4    and I think it would be helpful to me, and I just can't imagine where the

 5    problem is going to be.  Any cross-examination is still to come and

 6    anything can be asked about what's talked about but we won't be discussing

 7    Mr. Blaszczyk's testimony at all during that proofing.

 8            JUDGE AGIUS:  Okay.  Mr. Lazarevic, do you wish to comment

 9    further?

10            MR. LAZAREVIC:  Yes, I believe we were all very carefully

11    listening to what Mr. Blaszczyk said.  He made quite a lot of comments,

12    his own comments, about certain parts of this video and, basically, I

13    think that same rule should apply to any witness, whether it's an

14    investigator of the OTP or any other witness.

15            JUDGE AGIUS:  Okay.  Thank you.

16            MR. LAZAREVIC:  Basically they are discussing the same events.

17                          [Trial Chamber confers]

18            JUDGE AGIUS:  Yes.  We are all in agreement here on how it should

19    go.  Judge Prost will be explaining to you exactly how you will be

20    proceeding during the proofing session.

21            JUDGE PROST:  Taking into account the submissions that were made

22    and the Prosecution's point relating to the relationship such as it may be

23    between Mr. Blaszczyk and the -- Mr. Petrovic, we would prefer if

24    Mr. Blaszczyk is present only at the commencement of the interview to

25    greet the witness, to have any preliminary non-substantive discussions and

Page 18665

 1    then he leaves when the actual substantive proofing session takes place

 2    for the remainder of that process.

 3            JUDGE AGIUS:  In addition, I would add that if at any time during

 4    the proofing session you need to consult Mr. Blaszczyk, you can, of

 5    course, interrupt the proofing and go and consult Mr. Blaszczyk.

 6            MR. NICHOLLS:  Thank you.

 7            JUDGE AGIUS:  Okay.  That's the end for today.  Could you convey

 8    our apologies to -- all right.  Okay.  Yes, Mr. Lazarevic?

 9            MR. LAZAREVIC:  Well, Your Honours, I really cannot say anything.

10    We are fine with Your Honour's ruling, just to make sure that it's all

11    done in proper way, I believe it should be maybe recorded.

12            JUDGE AGIUS:  Okay.  Thank you.  We stand adjourned until tomorrow

13    at 2.15.

14                           --- Whereupon the hearing adjourned at 1.50 p.m.,

15                          to be reconvened on Tuesday, the 4th day of

16                          December, 2007, at 2.15 p.m.