Tribunal Criminal Tribunal for the Former Yugoslavia

Page 8944

 1                           Thursday, 3 July 2008

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 8.33 a.m.

 5             JUDGE ANTONETTI: [Interpretation] Madam Registrar, could you

 6     please call the case.

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

 8     number IT-03-67-T, the Prosecutor versus Vojislav Seselj.

 9             JUDGE ANTONETTI: [Interpretation] Thank you, Madam Registrar.

10             Today is Thursday, and I greet everyone here.  I welcome the

11     associates of Mr. Seselj, Mr. Seselj.  I welcome representatives from the

12     OTP, represented by Ms. Dahl and Mr. Dutertre, as well as by other

13     associates, and I also welcome all the others helping us around the

14     courtroom and in the courtroom.

15             Before giving the floor to Mr. Seselj, who has a few topics to

16     address, a few housekeeping matters to address, I would like to say

17     something to Mr. Seselj.

18             For justice to be rendered serenely and effectively, I believe I

19     need to say this.  The Trial Chamber and myself have noted for some weeks

20     now that when witnesses come, a cross-examination is mainly focused on

21     the issue of Seselj's men.  I take the opportunity of having Mr. Seselj's

22     legal advisers in the courtroom to say this.

23             It is true that in the indictment, Seselj's men are mentioned.

24     However, the responsibility of the accused also deals with crimes being

25     perpetrated by others, be it Arkan's men, White Eagles, Red Berets, and

Page 8945

 1     other formations, which means that focusing the cross-examination on one

 2     single issue, the issue of Seselj's men, could be a risk for the Defence.

 3     I wanted to tell this to Mr. Seselj, notably since a few weeks ago I read

 4     the relevant -- I reread the relevant paragraphs in the indictment.

 5     I can also tell you that earlier, the Prosecution, i.e., Mr. Marcussen

 6     himself, gave the Prosecution's case, as far as the entities committed,

 7     the crimes were concerned.

 8             Mr. Marcussen, and I -- you can check the transcript and see that

 9     liability also has to do with the crimes being committed by other

10     elements than the volunteers of the Serbian Radical Party.

11             I wanted to say this in order for the Defence to be fully aware

12     of it.  Of course, it's important to know who did what.  But as the

13     indictment stands, responsibility and liability comes from crimes being

14     perpetrated by a number of perpetrators, whatever their subordination

15     link might be with the accused or with others.

16             I believe I had to say this, Mr. Seselj, in order to make sure

17     that you fully understood what was the indictment.

18             You're representing yourself, you have no counsel, and I believe

19     you absolutely must take this into account.

20             Of course, if you want to focus your Defence and your Defence

21     case on Seselj's men and on Seselj's men only, that's up to you, but I

22     wanted to give you to be fully aware of what is in the indictment

23     opportunity.

24             Mr. Seselj, you wanted to raise some housekeeping matters?

25             THE ACCUSED: [Interpretation] Well, Mr. President, I first have

Page 8946

 1     to say something about this reminder of yours.

 2             It is true that the indictment contains all those elements that

 3     you've just presented, but we've already heard 32 witnesses here and a

 4     number of documents has been tendered, and the Prosecution has failed to

 5     show any connection between me and those other forces and the crimes that

 6     they committed.

 7             The fact that the Prosecution has accused me of all the crimes

 8     that were committed in this war in certain locations, that is -- well,

 9     perhaps they just didn't have enough strength to take into account all

10     the locations.  But I am not here to prove my innocence.  They have to

11     prove my guilt.  And I came here voluntarily to defend the honour, first

12     of all, of the volunteers of the Serbian Radical Party and then of the

13     Serbian people as a whole.

14             As for the repercussions, well, to tell you the truth, this would

15     not be the first trial where the judgement is rendered without any

16     evidence prejudicial to the accused.  That it has happened before at this

17     Tribunal.  Why should I be responsible for Draskovic's Serbian Guard,

18     White Eagles, Arkan's men, Djindjic Panther's, Mauzer's men?  I'm not

19     interested in that.  I don't want to go into all that?  It is my

20     intention to prove that the volunteers of the Serbian Radical Party have

21     been accused with no grounds whatsoever and when we're talking about

22     general allegations to prove that the whole of the Serbian people has

23     been unjustly accused or blamed, and that here before the Tribunal in the

24     The Hague we don't have an impartial Prosecution policy, that the

25     Prosecution policy is tendentious and biased and that crimes committed by

Page 8947

 1     the Serb side are being augmented, and the crimes committed by the

 2     Croats, Muslims and Albanians are being played down.  This has nothing to

 3     do with my case, but I want to say that this is the essence -- this is

 4     the way in which the Tribunal is working.

 5             And you can see that the Prosecution is interrupting me, and

 6     every time I interrupt the Prosecution, you're criticising me.

 7             JUDGE ANTONETTI: [Interpretation] Ms. Doll.

 8             MS. DAHL:  A proper defence obviously includes of course includes

 9     demonstrating bias or motive to fabricate or actual fabrication, but

10     rhetorical insults do not serve as a Defence; and I object and ask the

11     accused to be reminded it is improper to levy insults.  He is to present

12     evidence of his Defence, rather.

13             JUDGE ANTONETTI: [Interpretation] Very well.  Mr. Seselj,

14     proceed.

15             THE ACCUSED: [Interpretation] The statistics of the work of this

16     Tribunal so far shows quite clearly that there is an enormous number of

17     Serbs that charges were brought against and an enormous small number of

18     all the others.  The statistics, when we look at the sentencing, the

19     statistics, when we look at this application of this quasi legal category

20     of joint criminal enterprise, all this speaks in favour of my arguments

21     and not of the Prosecution.

22             And I have two very brief housekeeping matters to deal with.

23     That is why I asked to address you before the witness comes in.

24             JUDGE ANTONETTI: [Interpretation] Go ahead for the other two

25     topics.

Page 8948

 1             THE ACCUSED: [Interpretation] In the course of the

 2     cross-examination of Prosecution witness Redzep Karisik the day before

 3     yesterday, I presented some documents from the Military Court in Mostar,

 4     saying that this was disclosed to me by the Prosecution.  Madam Biersay

 5     for the Prosecution persistently claimed that this was not from the

 6     Prosecution because there is no ERN number there.  And I said that

 7     probably it existed in the English version, but that by mistake it was

 8     not entered into the Serbian version.  And as always, I was right.  This

 9     is evidence.

10             These are the documents that I used, both of them, and you can

11     see the translation into English, and in the English version you can see

12     that there is this N number, and so I would ask the usher to hand these

13     documents to you.

14             MS. DAHL:  Your Honour, if I can briefly reply in order to save

15     time.

16             With the help of the registrar, we were able to identify the

17     source of the document used by Mr. Seselj.  It highlights the problems

18     and waste of time created by untimely disclosure of documents to be used

19     in cross-examination.  It appears that Mr. Seselj used a document

20     translated by CLSS in cross-examination that came from the package

21     submitted with Dr. Osman Kadic.  It doesn't have an ERN number because it

22     hadn't been filed as a translated document by the Prosecution.  So

23     I think that there is no issue here regarding the Prosecution.  To the

24     contrary, it underscores the confusion created by Mr. Seselj bringing in

25     documents that we cannot read.  If he brings them in in advance, in a

Page 8949

 1     working language of the Tribunal, we can avoid these problems entirely.

 2             JUDGE ANTONETTI: [Interpretation] It is true that we had a

 3     problem last time when Mr. Seselj wanted to introduce, during his

 4     cross-examination, the document in B/C/S.  It was a document that he had.

 5     The trial attorney then stood to her feet, and out of memory - I don't

 6     have the transcript here because, so I didn't know we were going to talk

 7     about this - but if I remember right, Ms. Biersay said, "Where does this

 8     document come from," because she had doubts as to the document.  To

 9     answer, Mr. Seselj said that the document had been disclosed by the OTP.

10     Best proof of it was that in the B/C/S version, there were references

11     regarding the Registry.

12             As far as I was concerned, I was fully convinced the document had

13     been disclosed to the accused, since the document came from the Mostar

14     Military District of February 16, 1993.  Of course, such a document had

15     to be in the hands of the OTP, and of course the OTP had to have

16     disclosed this to the accused.  That was it for the moment, and now today

17     Mr. Seselj is showing us the English translation with the ERN number.

18             Well, we'll try to run a better show next time, if the same

19     problem crops up.

20             Second topic, please, Mr. Seselj.

21             THE ACCUSED: [Interpretation] Judges, on the 17th of July, I

22     received the latest work programme from the Prosecution.  The date is the

23     13th of June, and they envisaged Witnesses VS-1022 and Witness 1024.  The

24     they are supposed to testify under 92 ter, and they should be testifying

25     about the crime base in Nevesinje.  That's for the 17th of July.

Page 8950

 1             We have yet to get the first witness to testify viva voce about

 2     those -- about this location, and there will be no such witness, in fact.

 3     And I ask you to review your decision and to decide that at least one of

 4     those witnesses -- I would like to have all of them to testify viva voce,

 5     but in light of the principles that you, yourself, imposed, that at least

 6     one of them be heard in viva voce.

 7             JUDGE ANTONETTI: [Interpretation] Very well, your motion is

 8     noted.  Maybe the Prosecution would like to answer, but the Trial Chamber

 9     will deliberate, and we'll give you our ruling.

10             Ms. Dahl, do you have anything to say on this right now or

11     nothing to add?

12             MS. DAHL:  Your Honour, I think it elevates form over substance

13     to require these witnesses to testify viva voce.  Their material is

14     concise and relates to the crime base, and in this instance we are trying

15     to expeditiously present evidence before we get to the recess, and it

16     made sense to put together a couple of the 92 ter witnesses so that we

17     could move forward in the order of lineup.

18             If you want something from us regarding the type of evidence,

19     then I would ask for a particular date and time to make those submissions

20     so that I can have the trial attorneys who will be leading that evidence

21     address the Chamber.

22             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, just like in the

23     previous cases, we will look at the statements, we'll check the

24     statements.  We'll see whether there's a real need for viva voce

25     testimony or not.  If it's a witness that does not bring in anything

Page 8951

 1     essential and who doesn't really need to be cross-examined, we'll see.

 2             I can't answer you like this, offhand, without having looked at

 3     the two statements.  I can't tell you exactly right now what my position

 4     is.

 5             Ms. Dahl.

 6             MS. DAHL:  I'm sorry, Your Honour, but I want to object to the

 7     motion that the form of testimony should depend on whether or not

 8     Mr. Seselj wants to avail himself of the right that he has under the

 9     Rules.  92 ter allows Mr. Seselj, in every instance, to cross-examine.

10     In an accommodation to him, the Prosecution has not tried to use the

11     92 bis rule, which does tender evidence without any cross-examination,

12     but the Chamber should not accede to his decision to waive

13     cross-examination as a matter of principle.  That is his choice, and it

14     should not be used as a basis on which to make a determination of how to

15     lead the evidence.

16             JUDGE ANTONETTI: [Interpretation] What you just said will be

17     taken into account by the Trial Chamber.  Of course, we know it's not up

18     to the accused to say what he wants, as far as procedure is concerned,

19     because there is a rule that exists, and everybody must abide by the

20     rules.

21             However, the Trial Chamber does have a discretionary power and

22     can decide, in the interests of justice, who should testify in viva voce

23     or under Rule 92 ter, or maybe also Rule 92 bis, which is why when there

24     are 92 bis motions, the Trial Chamber usually turn them down, saying that

25     a cross-examination is absolutely necessary.

Page 8952

 1             There can be motions for viva voce where Trial Chambers say the

 2     evidence would be better led as Rule 92 ter, and the opposite also

 3     applies.

 4             It's up to the Trial Chamber to rule on how witnesses are to be

 5     heard, and the Trial Chamber must take into account different parameters,

 6     the position of the Prosecution, the position of the Defence, as well as

 7     time constraints.

 8             JUDGE LATTANZI: [Interpretation] I apologise, Ms. Dahl.  I don't

 9     want you to think that this Trial Chamber never took into account the

10     fact that the accused said he would waive his right to cross-examination

11     under Rule 92.  Sometimes we ruled otherwise, you know.  The Trial

12     Chamber has its own parameters on which to make decisions.

13             JUDGE ANTONETTI: [Interpretation] Very well.  No more

14     administrative questions.  Let's now bring the witness into the

15     courtroom.

16             Madam Usher, could you please go and get our witness.

17                           [The witness entered court]

18             JUDGE ANTONETTI: [Interpretation] Good morning, sir.

19             THE WITNESS: [Interpretation] Good morning.

20             JUDGE ANTONETTI: [Interpretation] The hearing will resume, and

21     the examination-in-chief will continue.

22             As I told you yesterday, if at any moment you feel ill at ease,

23     just raise your hand and ask for a break.  Otherwise, the break is

24     scheduled for 10.00.

25             Mr. Dutertre, you have the floor.

Page 8953

 1             MR. DUTERTRE:  Thank you, Your Honour.

 2             Welcome to everyone.  I welcome the Defence, and I also welcome

 3     or witness, Mr. Bilic.

 4             THE WITNESS:  Good morning.

 5                           WITNESS:  FAHRUDIN BILIC [Resumed]

 6                           [Witness answered through interpreter]

 7                           Examination by Mr. Dutertre:  [Continued]

 8        Q.   Mr. Bilic, yesterday you told us that the Sjeverni Logor barracks

 9     could be seen from your home and that the JNA were stationed in them.

10     Could you please tell us what happened next to the Sjeverni Logor

11     barracks on April 3rd, 1992?

12        A.   You mean in the shelter, what happened there, the shelter?

13        Q.   Next to these barracks, did anything happen on April 3rd, 1992?

14        A.   Yes, yes.  A tank truck was set there, and it exploded.

15        Q.   When you say "we" or -- you're not giving us -- you're not saying

16     who did this.  Do you know who did it?

17        A.   Well, it was just set -- put there to explode, and then the train

18     of events was put in motion after this tank truck exploded.

19        Q.   So it was deliberate.  Who placed those explosives, if you know

20     that?

21        A.   Well, I don't know.  I can't really answer that, because I didn't

22     see who put it there.  All I saw was it was there.  I could see it from

23     the balcony of my building.

24        Q.   Very well, thank you.  So a tank truck blew up.  It had been

25     placed there.  Did you see the explosion, did you hear it, were you

Page 8954

 1     there?

 2        A.   At that moment, I was passing by the tank truck and came to my

 3     own home.  I got everybody -- well, I drove past it, and I was coming

 4     back from town, going home from town.  And when it exploded -- well, I

 5     was passing by it, and just as I reached my flat, that's when it

 6     happened, it exploded, and then windows were shattered and fell down,

 7     doors, and everything from the explosion.

 8        Q.   Were there any casualties?

 9        A.   Not then, not at that moment, but there was a Skoda car that was

10     buried under the rubble that happened to be going past, so from the

11     explosion.

12        Q.   After this explosion, did you note that more -- a greater number

13     of Serbian soldiers were now in your area?

14        A.   Yes.  Immediately after the tank truck, soldiers began to rally.

15     The Montenegrin soldiers came, and they drank there, ate there, and in

16     the evening attacked civilians.

17        Q.   Would you tell us what units the Serbian soldiers belonged to?

18     Was it the regular army, were they volunteers?

19        A.   Well, they were wearing military uniforms of the olive-green

20     kind, the SMB olive-green kind, but they were from Montenegro, judging by

21     the way they spoke, from Montenegro.

22        Q.   Did they have specific insignias that you might remember?

23        A.   No, no insignia, just denoting that they were soldiers, just

24     having military uniforms.

25        Q.   According to you, did they look like soldiers from the regular

Page 8955

 1     army or did they look like volunteers?

 2        A.   Regular army, like the regular army.

 3        Q.   After this explosion, given the extensive damage and the possible

 4     risk of a new attack, where did you seek refuge?

 5        A.   After the tank truck, we took shelter in the shelter underneath

 6     my house.  There was an atom bomb shelter there, so we went there to be

 7     safe.

 8        Q.   How many people were in the shelter, more or less?

 9        A.   About 300, to begin with.

10        Q.   You remember the ethnical background of the 300 people that were

11     in the shelter with you?

12        A.   Well, they were mixed.  Everybody was there, Serbs, Croats,

13     Muslims.

14        Q.   Could you tell us whether there were women --

15        A.   Women, men, children, elderly people.  Everybody was there.

16        Q.   Very well.  Do you remember the names of some of the people that

17     were with you in the shelter?

18        A.   Well, I knew most of them -- well, my neighbours, but the ones

19     who came from other parts, from Brankovici and further afield, I know --

20     well, I knew them, but didn't know all the names.  The first one was a

21     Serb, Milos.  Then there was a Vojo, who guarded us there in the shelter

22     with an automatic weapon so we didn't have to leave.

23        Q.   I'm not speaking about the people who were standing guard there,

24     but those people that were in the shelter.  Could you give us the names

25     of some of the people who were in the same shelter?

Page 8956

 1        A.   Well, there were quite a lot of families from my building, who

 2     lived in the same building as me, like Omanovic, Milos, Benca.  All those

 3     people were from my building, they all had flats there.

 4        Q.   Any other names that come to mind, people who were living in the

 5     same block of flats as you, for instance?

 6        A.   [No verbal response]

 7        Q.   If it doesn't come to mind, it doesn't matter.  I'll move on to

 8     something else.

 9             You mentioned that someone was guarding the shelter.  Could you

10     tell me -- I don't want you to give me any names, but could you tell us

11     whether there were guards in front of the shelter right from the

12     beginning, as soon as you got there?

13        A.   Straight after the tank truck, the guards turned up, because we

14     happened to be in the shelter.  Shells started falling, and we had to go

15     down to the basement and take refuge.  Thousands of shells fell on the

16     shelter.

17        Q.   To get back to my question, was the shelter guarded by soldiers

18     as soon as you got to the shelter?

19        A.   Straight after the tank truck, that's when they appeared, they

20     came.  They came in a vehicle, and they came there.  Milos, my neighbour,

21     he led them.  No, he kept lists of all of us in the shelter.

22        Q.   I shall -- I would like to move for a brief instant into private

23     session, please, if you will allow me.

24             JUDGE ANTONETTI: [Interpretation] Yes.  Private session, please.

25                           [Private session]

Page 8957











11 Page 8957 redacted. Private session.















Page 8958

 1   (redacted)

 2   (redacted)

 3                           [Open session]

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

 5             JUDGE ANTONETTI: [Interpretation] Witness, the Prosecutor has

 6     been putting questions to you over the last ten minutes about what

 7     happened when this fuel tank exploded, and I'm totally lost, I must

 8     admit.  If you will allow me, I would like to go back a little bit in

 9     time.

10             There is this fuel tank that is placed next to the barracks, so

11     the barracks where there are Serbs; you agree with me on that, do you?

12             THE WITNESS: [Interpretation] Yes.

13             JUDGE ANTONETTI: [Interpretation] The fuel tank explodes.  You

14     don't know who has caused the explosion; you don't know?

15             THE WITNESS: [Interpretation] I don't know, I don't know about

16     that.

17             JUDGE ANTONETTI: [Interpretation] Then for fear of another

18     explosion, the neighbours go and seek refuge, together with you, in this

19     shelter, and you have said that there were 300 of you there, and you

20     provide an important detail, to my mind.  You say that in the shelter,

21     there are Serbs, Croats and Muslims.  Is that right?  That is what you

22     said, isn't it?  And you said that at some point soldiers prevent you

23     from coming out, so one has reason to believe that the soldiers that are

24     there are there to protect you and secure the area, and that you

25     civilians have been asked to stay in the shelter for your own protection.

Page 8959

 1     That I understand.  I understand this so far.

 2             But after that, you say that there were shots fired and shells

 3     that fell in that area; isn't that what you said?

 4             THE WITNESS: [Interpretation] Shells were falling from

 5     Podvelezje, that area up there.

 6             JUDGE ANTONETTI: [Interpretation] Very well.  Shells fell on the

 7     shelter when there were Serbs inside the shelter?

 8             THE WITNESS: [Interpretation] Serbs, just afterwards when they

 9     took us away from the shelter, the ones they had on their list, they

10     separated the Serbs into a bus which they drove towards Zijemlje, up

11     there.  The bus came to fetch them, just them.

12             JUDGE ANTONETTI: [Interpretation] If I understand you correctly,

13     everybody was in the shelter.  Then the Serbs came and asked the Serbs to

14     come out of the shelter; is that right?

15             THE WITNESS: [Interpretation] Yes, they separated the Serbs and

16     took us to north camp, according to a list.  That's how it was.

17             JUDGE ANTONETTI: [Interpretation] Very well.  But what I would

18     like to understand, because this is rather complex:  When the shells fall

19     on the shelter, at that time are there Serbs inside the shelter together

20     with you?

21             THE WITNESS: [Interpretation] Yes, that's right; Serbs, Croats

22     and Muslims, they were all inside.

23             JUDGE ANTONETTI: [Interpretation] You were there.  Can you tell

24     us why the Serbs shot at Serbs and why they shot at the shelter?  Do you

25     have any reason to give us or none?

Page 8960

 1             THE WITNESS: [Interpretation] Everybody fled from their flat

 2     after the explosion.  Shells were falling, but you couldn't stay in your

 3     flat.  You had to go down to the shelter.  We had two shelters in Zalik.

 4     One was underneath my building and the other one was a little further

 5     away, two atomic bomb shelters.

 6             JUDGE ANTONETTI: [Interpretation] Mr. Prosecutor, I'll give you

 7     the floor again.

 8             MR. DUTERTRE: [Interpretation] Yes, Your Honour, thank you for

 9     having clarified all of this.  I was about to address it myself, but now

10     it's done.

11        Q.   Mr. Bilic, were you free to leave the shelter?

12        A.   No, you couldn't go outside -- or, actually, just the women could

13     leave to bring in food and to cook something in the shelter, prepare some

14     food.  Otherwise, well, they wouldn't let us cook in our flats.

15        Q.   If I understand you correctly, you are saying that you were not

16     free to leave the shelter, but women were entitled to go and fetch some

17     food; is that right?

18        A.   Yes, but they had to come back straight away, of course.

19        Q.   What would have happened if they hadn't come back?

20        A.   Well, they'd go and search for that person, so the women had to

21     come back.  It's all there.  You can't escape.  You can see the whole

22     area, so nobody could actually escape.

23        Q.   When you say that you couldn't run away, could you clarify this,

24     please?

25        A.   Well, there were soldiers all over.  You couldn't go from this

Page 8961

 1     side to the other side, cross over to the other side, because --

 2        Q.   When you say "from one side to the other," what do you mean?

 3        A.   I was in the civilian protection.  They made us work.  We were

 4     forced to work, and we had to clean streets from the shells from the

 5     bridge to the tobacco factory.

 6        Q.   I might get back to this later.

 7        A.   They mined all the little streets towards the other side, the

 8     Serbs did.  All the little streets were mined, so you couldn't go to the

 9     Neretva River.  Otherwise, the people of Mostar could have swum across,

10     but you couldn't because of all these little mines that were placed in

11     the side streets.

12        Q.   Very well, you've clarified all this.  Thank you.

13             According to you, what was the purpose of this?  Why did the Serb

14     soldiers guard you without allowing you to move around freely?  Why were

15     you kept in these shelters?

16        A.   Well, they stood guard for as long as the large army came down

17     from the church and surrounded the whole area.  They were the

18     White Eagles, Seseljevci, local Serbs.  All the people we knew from

19     Zalik, actually, these ones.

20        Q.   I'll get back to this later, but to answer the question

21     accurately, what was the purpose of this?  Why did the Serb soldiers

22     stand guard here and prevent you from moving around, since you were only

23     allowed to go and fetch food?

24        A.   Well, they stood guard there and kept saying that nothing would

25     happen to us.  But what happened happened; that is to say that 120 people

Page 8962

 1     were killed.

 2        Q.   You say that White Eagles and Seselj's men and local Serbs came.

 3     When did this happen?  When did you see the White Eagles, Seselj's men

 4     and the local Serbs?

 5        A.   In April 1992, I think.  Yes, 1992.

 6        Q.   Were you in the shelter already or how much time after the

 7     explosion of the fuel tank did this happen?

 8        A.   Everybody saw that, when they came down and came in front of the

 9     shelter and all the rest of it.  I wasn't the only one who saw all that.

10     All the people who were in the shelter saw it.

11        Q.   Very well.  Could you tell us how the White Eagles were dressed?

12        A.   The White Eagles had hats and feathers in their hats.  They had

13     long beards.  Some even had cockades.

14        Q.   Can you describe these cockades to us, please?

15        A.   Round ones with the sign there, the sign of the eagle.

16        Q.   Anything specific which gave you reason to believe that these men

17     were White Eagles?

18        A.   Well, the White Eagles, they weren't as dangerous, didn't look as

19     dangerous.  But the other ones, well, my god, they were more dangerous,

20     the ones with the beards.  They were much more dangerous.

21        Q.   Just to get back to my previous question, were there any other

22     distinctive signs to make you believe that these were White Eagles, or

23     did you hear that these men were White Eagles?

24        A.   Well, I heard that from others, from the Serbs themselves who

25     were in the shelter when these men arrived, and they said who they were,

Page 8963

 1     which soldiers they were.  I didn't invent it, I didn't think it up.

 2        Q.   And when you talk about the Serbs who were there with you, are

 3     you referring to the Serb soldiers or to the Serbs that were in the

 4     shelter together with you?

 5        A.   The ones who were there, the Serbs in the shelter.  They worked

 6     for the Serbs.  They did what they asked them.  This one worked in the

 7     printing works, so that meant for the lists.  And the ones that were on

 8     guard -- the one that was on guard, he didn't let anybody leave, this

 9     man.

10        Q.   You mentioned the White Eagles, and you also mentioned Seselj's

11     men.  Could you tell us how Seselj's men were dressed?

12        A.   They had uniforms and the caps and the cockades.  I don't know

13     what else I can say.  The cockade with the eagle.  And they stood guard

14     in the port.  They were down there when we cleaned the streets.  They

15     whole port, the main street towards the factory.  They stood by the road

16     and brandished their -- and sharpened their knives, because that's where

17     we had to pass -- we had to pass by them.

18        Q.   Can you tell us exactly what kind of uniform they had?

19        A.   There were some in civilian clothes and others in the SMB

20     olive-green uniform, like the military shirts, the army shirts.

21        Q.   Could you describe them to us?  What did they look like,

22     physically, I mean?  Did they look like regular servicemen or could you

23     give us a description, please?

24             JUDGE ANTONETTI: [Interpretation] Mr. Dutertre, your question is

25     somewhat leading.  Just ask him to describe the soldiers.

Page 8964

 1             MR. DUTERTRE: [Interpretation] Yes.  That was the end of my

 2     question, Your Honour.

 3             JUDGE ANTONETTI: [Interpretation] Well, Mr. Dutertre, well,

 4     rephrase your question.

 5             MR. DUTERTRE: [Interpretation] I was just wanting to move on.

 6        Q.   Could you tell us what Seselj's men looked like?

 7        A.   How can I describe them?  They were dressed in both ways, mixed;

 8     civilian trousers and other types of shirts.  Well, they didn't look like

 9     regular soldiers.  They had long beards.

10        Q.   I wasn't interested in the clothing, per se.  I was interested in

11     physical characteristics, the hair and so on and so forth.  So what did

12     they look like, physically, I mean?  You mentioned the long beards.

13     Could you give us any more details?

14        A.   As far as beards go, well, he had -- they had caps on their head,

15     so I couldn't really see their hair.

16        Q.   When a little earlier you mentioned that those that had beards

17     were dangerous, these were Seselj's men that were bearded?  These were

18     the ones you wanted to refer to or not?

19        A.   Yes, that was them.  I saw them at the institute where I did some

20     painting, a paint job.  I was there painting their kitchen, and I stood

21     beside them, in Bijelo Polje.

22        Q.   We'll proceed in chronological order, if you don't mind.

23     Otherwise, everything will get all mixed up.

24             So in the shelter, among those soldiers that were standing guard,

25     were there any of Seselj's men?

Page 8965

 1        A.   No -- yes, one from Novi Sad.  He was with us in the shelter.  He

 2     wasn't standing at the door.  He was with us.  They had the automatic

 3     doors, and he was inside, right inside by the office, and everybody,

 4     well -- well, he'd just sit there sharpening his knife.  And he kept

 5     silent.  He didn't like talking much.  Well, they didn't let us go up to

 6     him.

 7        Q.   Could you tell us whether he was from the beginning -- what I

 8     mean, from the moment you got there, was he there?

 9        A.   He came at a time when all those soldiers came down from the Serb

10     church.  They surrounded the whole of Zalik, and that's when he came,

11     too, when these others came down from the Serbian church, when all these

12     other soldiers came.

13        Q.   What time period are we talking about?  How many days after the

14     explosion of the fuel tank are we talking about; five days, ten days?

15     How many days?

16        A.   Four days later or five days later, at the most.  They appeared

17     straight away.  It didn't last long; for three or four -- we were in the

18     shelter for three or four months, all of us civilians, but you had -- it

19     wasn't a long time, but you had to survive living in that shelter, let me

20     tell you.

21        Q.   Was this person there permanently or was he just there from time

22     to time, this man whom you call Seselj's man?

23        A.   In the shelter until they took us away, those of us who could

24     move, to north camp, according to the lists they had.

25        Q.   Did he have an accent when he spoke?

Page 8966

 1        A.   Well, Serbian.  We asked him where he was from, and he said he

 2     was from Novi Sad.  We asked him.

 3        Q.   How do you know that this man was one of Seselj's men?

 4        A.   Well, we didn't determine that he was a Seselj man straight away.

 5     He didn't have a beard.

 6             THE INTERPRETER:  Could the witness repeat whether he had a beard

 7     or not?

 8             MR. DUTERTRE: [Interpretation]

 9        Q.   How did you get to learn that, because you said you didn't know

10     it right away?

11        A.   We asked him, and what he told us then is what I'm telling you

12     now.

13        Q.   If I understand you correctly, it is he who told you that he was

14     one of Seselj's men?

15        A.   He told me personally.  I was in the group when they asked him.

16        Q.   Could you tell us how he behaved with the people who were

17     detained there?

18        A.   [Previous translation continues] ... there and followed the

19     situation in the shelter.

20             MR. DUTERTRE: [Interpretation] Your Honour, I think the court

21     reporter needs to have a short break.

22             JUDGE ANTONETTI: [Interpretation] Let's have a break.  We shall

23     have a break and have a 20-minute break now.

24                           --- Recess taken at 9.30 a.m.

25                           --- On resuming at 9.55 a.m.

Page 8967

 1             JUDGE ANTONETTI: [Interpretation] The hearing's resumed.  Good

 2     morning, Madam Court Reporter.

 3             You may proceed.

 4             MR. DUTERTRE:  [Interpretation] Thank you.  May we move into

 5     closed session?

 6             JUDGE ANTONETTI: [Interpretation] Yes, Madam Registrar, please

 7     do.

 8                           [Private session]

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

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Page 8968











11 Page 8968 redacted. Private session.















Page 8969

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13   (redacted)

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15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19                           [Open session]

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

21             MR. DUTERTRE: [Interpretation]

22        Q.   Mr. Bilic, am I to understand that the person you have just

23     mentioned - no need to say his name because now we're in open

24     session - that this person would go to the shelter where you were kept?

25   (redacted)

Page 8970

 1             JUDGE ANTONETTI: [Interpretation] I was sure this was bound to

 2     happen.  I was sure he was going to say the name.

 3             Madam Registrar, can you please redact.

 4             Please proceed.

 5             MR. DUTERTRE: [Interpretation]

 6        Q.   This person, whose name you've just given, would he come to the

 7     shelter?  Don't say his name again.

 8   (redacted)

 9             MR. DUTERTRE: [Interpretation] I'm so sorry, Mr. President, I

10     wanted to remain in open session but --

11             JUDGE ANTONETTI: [Interpretation] Yes, we'll start again.  Let's

12     go back into private session.

13                           [Private session]

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

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Page 8971











11 Pages 8971-8972 redacted. Private session.















Page 8973

 1   (redacted)

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18   (redacted)

19   (redacted)

20   (redacted)

21                           [Open session]

22             THE REGISTRAR:  Your Honours, we're back in open session.

23             MR. DUTERTRE: [Interpretation].

24        Q.   Could you tell me where the military institute of Bijelo Polje

25     is?

Page 8974

 1        A.   It's right next to Bijelo Polje.

 2        Q.   As part of the work that you were forced to do whilst the Serbian

 3     forces were still in Zalik, did you have to go and work at the Bijelo

 4     Polje military institute?

 5        A.   Yes. (redacted), my neighbour, and I - my neighbour who worked in the

 6     same company as me and he died after the war - we went.

 7             JUDGE ANTONETTI: [Interpretation] Madam Registrar, we'll have to

 8     redact line 22, the neighbour's name.

 9             MR. DUTERTRE: [Interpretation] Yes.  I guess that this man was

10     rather a victim.

11        Q.   And what kind of work did you do at the military institute?

12        A.   Painting work, painting, wall painting.

13        Q.   Where exactly?

14        A.   The kitchens, the kitchen and the reception area and the lobby.

15        Q.   How long did it take, that work at the military institute?

16        A.   Not long, two or three days, until the chief officer arrived and

17     said something was going to happen and we could leave, and then we went

18     back to the shelter in Zalik.

19        Q.   Did you see soldiers during the two or three days you spent at

20     the military institute?

21        A.   We saw them on every step in the institute.

22        Q.   Could you tell us which units they were member of?

23        A.   There were all sorts, not just the regular JNA, there were other

24     soldiers as well, paramilitaries and others.

25        Q.   You mentioned paramilitaries, all sorts of soldiers.  Which group

Page 8975

 1     did these soldiers belong to?

 2        A.   There were also soldiers wearing civilian clothes, soldiers

 3     wearing JNA uniforms, soldiers wearing mixed clothing, civilian trousers

 4     with a military jacket.  It was all mixed up.

 5        Q.   Were you able to hear or see whether these individuals who were

 6     not regular soldiers, as you said, were members of specific groups or

 7     units?

 8        A.   Well, I don't understand these things very well --

 9             THE INTERPRETER:  The interpreter did not understand the last

10     sentence.

11             MR. DUTERTRE: [Interpretation]

12        Q.   Did you see some of Seselj's men in the military institute?

13        A.   There were those with beards who sharpened knives, and I would

14     pass by them in the compound itself, they stood next to the hospital in

15     the institute, that's where they were standing in front of the door to

16     the hospital because there used to be a military hospital there.

17        Q.   Did you see whether the soldiers whom you describe as Seselj's

18     men wore any insignias?

19        A.   The ones in the institute only had big beards, they didn't have

20     any insignia; the ones I saw in town at Luka and in Zalik, they did have

21     insignia, the ones guarding the harbour, the Luka next to the tobacco

22     factory down the road.

23        Q.   I suppose that's -- you saw them during your work obligation.

24     You're mentioning an insignia, could you describe it, those people who

25     were at the bridge?

Page 8976

 1        A.   For the most part they walked around in military uniforms and

 2     then the officers with their ranks, they had epaulettes, I saw quite a

 3     few of those, because their military hospital was there.  And once I took

 4     some medicine back to the shelter because the children had upset stomachs

 5     because the water was bad in the shelter, and there were officers there

 6     and they gave me medicines to take back.

 7        Q.   Very well.

 8             MR. DUTERTRE: [Interpretation] Can we move quickly for a brief

 9     moment to private session.

10                           [Private session]

11   (redacted)

12   (redacted)

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14   (redacted)

15   (redacted)

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Page 8977

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17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21                           [Open session]

22             THE REGISTRAR:  Your Honours, we're in open session.

23             JUDGE ANTONETTI: [Interpretation] Let's move back to private

24     session because Mr. Seselj wants to say something.

25                           [Private session]

Page 8978











11 Pages 8978-8981 redacted. Private session.















Page 8982

 1   (redacted)

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 8   (redacted)

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15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19                           [Open session]

20             THE REGISTRAR:  Your Honours, we're in open session.

21             MR. DUTERTRE: [Interpretation]

22        Q.   Mr. Bilic, who came to the Zalik shelter on June 13th, 1992?

23     Maybe I can reformulate my question.  What happened on June 13th, 1992,

24     in the Zalik shelter?

25        A.   You mean the speech in Zalik that went on -- the talking that

Page 8983

 1     went on all night?

 2        Q.   You told us that a certain day you were taken to the north camp

 3     and then to Sutina.  What date did that happen?  When was that?

 4        A.   The 4th, April 1992, or the 4th, thereabouts.

 5        Q.   We know that you entered the Zalik shelter in April 1992, but you

 6     also told us that you were taken to the north camp and then to Sutina at

 7     a point in time.  Could you tell us when that was?

 8        A.   I can't remember now.  I can't remember the exact date.

 9        Q.   Was it in May?  In June?

10        A.   I think it was in May.

11             MR. DUTERTRE: [Interpretation] Mr. President, may I jog the

12     witness's memory?

13             JUDGE ANTONETTI: [Interpretation] It seems that he does not

14     remember things, and of course the Appeals Chamber allowed memories to be

15     jogged.

16             MR. DUTERTRE: [Interpretation] This is the hearing of -- page 5,

17     paragraph 2, this is the hearing of January 25th, 2001, and it starts

18     with -- I won't continue what I was reading because it's not the point.

19        Q.   Mr. Bilic, do you remember whether you were taken to north camp

20     and Sutina on June 13th, 1992?

21        A.   It could be that day.

22        Q.   Very well.  What happened that day?  Could you tell us who

23     arrived into the shelter?

24        A.   I came to the shelter -- well, the JNA soldiers came and the

25     officer with them.  General Perisic was with them, he was the commander

Page 8984

 1     at north camp at the time.

 2        Q.   What time was it?

 3        A.   At about 10.00 in the morning, they took us to north camp, we

 4     went there on foot to the premises there and the corridor, and we were

 5     surrounded with automatic rifles --

 6        Q.   We'll do this step by step.  Among the soldiers who came, were

 7     there locals, were there also soldiers coming from the outside?

 8        A.   There were locals too, this man Boro, there were people from

 9     Rastani and Bijelo Polje, locals, they escorted us too.

10             JUDGE ANTONETTI: [Interpretation] Witness, marginal question.

11     You're saying that General Perisic who was commanding the north barrack

12     came also?

13             THE WITNESS: [Interpretation] In the corridor too when they took

14     our ID cards from us.

15             JUDGE ANTONETTI: [Interpretation] Very well.  When you were

16     interviewed in 2001, we have your statement, you do not mention

17     General Perisic.  Why is that?

18             THE WITNESS: [Interpretation] He was the general there.  Now, the

19     other men -- well, there were lots of officers.  He wasn't alone, there

20     wasn't just one, there were lots of officers all in military uniforms.

21             JUDGE ANTONETTI: [Interpretation] Yes, but in your statement you

22     say that there's a group of about 15 soldiers who came, you're talking

23     about soldiers only, you're not mentioning any officers and certainly no

24     general; and suddenly you're talking about a general.  And I wonder why

25     it is that in 2001 when you were interviewed you never mentioned this

Page 8985

 1     general, but now you're mentioning him.

 2             THE WITNESS: [Interpretation] As far as the general is concerned,

 3     he could -- well, I could state on other occasions when his daughter was

 4     captured, for example, when she was on Radio Mostar, then he gave our

 5     prisoners in exchange for his daughter, the ones he had captured at

 6     Podvelezje, that area.  He was the general all the time and issued orders

 7     in north camp while others did too.

 8             JUDGE ANTONETTI: [Interpretation] Very well.

 9             Mr. Dutertre.

10             MR. DUTERTRE: [Interpretation]

11        Q.   You said there were also locals, but -- you said there were

12     locals, but I guess that there were also soldiers who were not locals,

13     who were from another area?

14        A.   Mostly it was the locals that escorted us, those from Rastani,

15     Bijelo Polje, Vrapcici, those Serbs, mostly them; and they were in the

16     trucks, they loaded us up when they drove us to Sutina.  One was in that

17     small van.

18        Q.   Let's not move ahead.  We are going to go on a step-by-step

19     basis.  So you're telling us that most of them were locals, but some of

20     them were not locals; is that right?

21        A.   They were the ones that went in front.  These others escorted us

22     on the sides.  The normal soldiers went in front, the others guarded us

23     from round about, from the sides, because it was a big column.

24        Q.   When these men came into the shelter, what did they order you to

25     do and what did they do?  We are still in the Zalik shelter and they just

Page 8986

 1     entered.  What did they ask you to do?

 2        A.   Nothing.  They just rushed around and said any -- all of you who

 3     can move should start -- get going and the others, the elderly people who

 4     weren't able to walk properly, they stayed on in the shelter, all the

 5     others went outside.

 6        Q.   Once you were out, what happened?

 7        A.   They put us in a line and we set off in a column towards north

 8     camp.

 9        Q.   Did the women stay with the men and children, where were they

10     separated?

11        A.   The women, elderly, and children stayed behind of course in the

12     shelter.

13        Q.   So the men were separated and left?

14        A.   [Previous translation continues] ...

15        Q.   Can you tell us what ethnicity were these men?  What was the

16     ethnicity of these men who were separated from the women and children?

17        A.   Muslims, just Muslims.

18        Q.   How did you reach the north camp?

19        A.   We went on foot, out of the main gate, or rather, into the main

20     gate and into north camp, on foot to north camp, the building, which was

21     near the gate.

22        Q.   How many Muslim men left the Zalik shelter to go to the north

23     camp?

24        A.   Quite a few of us, about 80, thereabouts.

25        Q.   How long did this walk take?

Page 8987

 1        A.   Well, five or six minutes, it's quite near, towards town.

 2        Q.   During that trip who was escorting you, who was guarding you?

 3        A.   Those soldiers with the weapons they had in their hands.  They

 4     escorted us.

 5        Q.   Once in the north camp, i.e., Sjeverni Logor barracks, you said

 6     that you went into a building.  What happened in that building?  What did

 7     you have to do?

 8        A.   They took us into a large hall, a long corridor actually, some 40

 9     or 30 metres long, it's a big building, you know, and there's a faculty

10     there now in that building.  In front at the door there was some soldiers

11     with officers, I saw some officers there.  Well, it was the main office

12     and they took our ID cards and drew up a list one by one, and I gave a

13     Serb who was there the keys to my house because I had the feeling that

14     they would take us away somewhere else and I gave this man the keys to my

15     home to take back to my wife, and he did that.

16             MR. DUTERTRE: [Interpretation] Can we now please move to private

17     session.

18             JUDGE ANTONETTI: [Interpretation] Madam Registrar.

19           [Private session] [Confidentiality partially lifted by order of Chamber]

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

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Page 8988











11 Page 8988 redacted.  Private session.















Page 8989

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17   (redacted)

18     happened because you told us you gave your IDs and what happened after

19     that?

20        A.   After that they put us into vans and there were benches there and

21     there was six or seven of us in this small van or jeep and they drove us

22     away and there was a soldier with a gun sitting there in between, between

23     us, guarding us in the van.

24        Q.   Where did they take you?

25        A.   To Sutina, to the cemetery, Gradsko.

Page 8990

 1        Q.   What time did you arrive in Sutina more or less?

 2        A.   Well, we arrived at around 10.00 or 11.00 -- 10.00.  We spent the

 3     whole day and the whole night there in Sutina.

 4        Q.   Did all the men who had arrived with you in the north camp

 5     eventually ended up in Sutina or did only part of them arrive in Sutina?

 6        A.   They loaded us all up and took us to Sutina but as they arrived

 7     they disappeared.

 8        Q.   I'll come back to this.  In Sutina where were you placed, you

 9     personally?

10        A.   There were three rooms and they put us in -- all into a smaller

11     room but there were three rooms actually in that corridor.  It's just at

12     the entrance where their sort of refrigerator area was in Sutina, and

13     there was one man wearing a white coat.  He was an officer too and he had

14     a list and read out names from the list who would be killed and who

15     wouldn't.

16        Q.   Well, take us in chronological order.  There are three rooms, you

17     were all placed in the same room.  Could you tell us exactly what this

18     room looked like, was it small?  Was it big?  Was it dark?  Was there a

19     lot of light?  Tell us, please.

20        A.   It was large [as interpreted].  You could get 20 people in there

21     like sardines, about 20 people, you could cram them all into that room.

22     There was no WC, there was no light, nothing, it was dark, total dark, we

23     were all in total darkness.

24        Q.   Do you know the name of some of the people who were locked up in

25     this room with you?

Page 8991

 1   (redacted)

 2     wherever, he was with us there.  There were Muslims there, quite a lot of

 3     them, a lot of Muslims, two or three Croats.  There wasn't a single Serb

 4     there with us, and that was normal.  There wouldn't have been, would

 5     there?

 6        Q.   Were there only men or were there also women and children?

 7        A.   Just men.  The women stayed behind in the shelter like the

 8     children and the elderly people.

 9        Q.   Do you know whether among the people detained in this room some

10     had uniforms or were they all dressed in civilian clothes?

11        A.   All civilians, all the ones they brought in were civilians.  None

12     of them were soldiers.

13        Q.   Have you heard, seen, or heard whether other people were locked

14     up in the two other rooms that you mentioned?

15   (redacted)

16     there, the one who did the driving.  I was transferred later on.  When

17     these people were transferred to the small room, they transferred me to

18     this other room.  When it seemed that the killing started sooner, so it

19     went on the whole night, the whole day and the whole night.

20        Q.   When you were in that room with some other 20 people, could you

21     hear what was going on in the other rooms?

22        A.   No, but we did hear the ones coming in and reading out the names

23     from the list, the man in the white overcoat, they read out the names,

24     opened the door, and then said, You go out, you outside, and they

25     separated them and as they left, they left never to return.


Page 8992

1        Q.   Did you hear what was happening to them, when these people were

 2     told to leave the other room?

 3        A.   All you could hear was a burst of gun-fire from a machine-gun

 4     from behind the building, two machine-gunners, and they would shoot from

 5     time to time.  They would let them sort of go and then they would mow

 6     them down with the machine-gun fire.  There were two machine-guns that I

 7     personally saw, but I can't describe them.

 8             THE ACCUSED: [Interpretation] Judges, does all this need to be in

 9     private session?  I think we should have moved into open session ages

10     ago.

11             MR. DUTERTRE: [Interpretation] -- it's justified we could have

12     moved, we were a bit negligent.  Please ask the question again.

13             JUDGE ANTONETTI: [Interpretation] Could we please move into open

14     session?

15             MR. DUTERTRE: [Interpretation] Yes, after the series of names,

16     you know, we can move back into open session, maybe if we could do this.

17     This part of the transcript can become public after the series of names.

18   (redacted)

19   (redacted)

20                           [Open session]

21             THE REGISTRAR:  Your Honours, we're in open session.

22             MR. DUTERTRE: [Interpretation]

23        Q.   Sir, have you heard anyone putting up resistance or maybe

24     rebelling, any of the other people who were in the other rooms?

25        A.   You could hear screaming, blows on the concrete, and then the

Page 8993

 1     shooting and then nothing after that.  They kept coming and going -- oh,

 2     the small vans, the jeeps, kept coming and going.

 3        Q.   At that point in time you were also locked up, you were hearing

 4     everything.  What did you think was happening?  What did you infer from

 5     all this?

 6        A.   [Previous translation continues] ...  like all the rest, what was

 7     going to happen would happen until Boro came by --

 8             THE INTERPRETER:  The interpreter didn't hear what --

 9             MR. DUTERTRE: [Interpretation]

10        Q.   Let me reformulate.  What did you think was happening to these

11     other people who were taken out of the other rooms?

12        A.   They killed them, what else?  That's what happened and that's

13     what I'm telling you -- and that's what I was waiting for, the same fate

14     just like all the rest, but he came and saved me, got me out of there.

15        Q.   At what time did the shooting start?

16        A.   Well, the whole day when we were shut up there we were in total

17     darkness and you could just hear people being taken away, comings and

18     goings, jeeps coming by, taking people away.

19        Q.   We've talked about the other rooms.  Did some men -- were some

20     men taken out of the room in which you were?

21        A.   Not from the other rooms, just from our room while this was going

22     on, but I couldn't see what was happening in the other rooms.

23        Q.   You said some men were taken out of the room in which you were.

24     Who took them out?  We understood that there was a man or person dressed

25     in white.  Who was the person who took them out of the room?

Page 8994

 1        A.   Well, we were taken out by those people in uniform.

 2        Q.   Were these local soldiers or non-local soldiers?

 3        A.   There were two wearing olive-drab military uniforms.

 4        Q.   Did they have an accent?

 5        A.   Well, I can't tell you specifically yes or no because they were

 6     all mixed up.

 7        Q.   What do you mean by mixed?  In other words, some had an accent

 8     and some didn't?  Could you specify, please.

 9             Did some of the soldiers have an accent and some others did not

10     have an accent?  If you remember of course could you tell us.

11        A.   Well, I remember that they were shouting, making a lot of noise,

12     but I was not in a situation where I could actually determine their

13     accents.  I know that they were shouting and screaming and pushing people

14     out with their rifle-butts as they were taking them out.

15        Q.   How long did you stay in this room where you had been put

16     together with another 20 people?

17        A.   I remained in that room until 2.00 or 3.00 a.m. in the night,

18     that's when I was saved and I went back to the shelter in Zalik, or

19     rather, to my apartment above the shelter, and I hid there so that they

20     couldn't find me anymore.

21        Q.   You said that you left the room.  When you left the room where

22     were you put then?

23        A.   To a large room where Hamdija and another man --

24             THE INTERPRETER:  The interpreter didn't get the name.

25             THE WITNESS: [Interpretation] -- from the small room into the big

Page 8995

 1     room, where Hamdija was.

 2             MR. DUTERTRE: [Interpretation] Could we briefly move into closed

 3     session to address the names, please.

 4             JUDGE ANTONETTI: [Interpretation] Could we move into private

 5     session, please, Madam Registrar.

 6                           [Private session]

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 8996











11 Pages 8996-8998 redacted. Private session.















Page 8999

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6                           [Open session]

 7             THE REGISTRAR:  Your Honours, we're in open session.

 8             MR. DUTERTRE: [Interpretation]

 9        Q.   What makes you say, Mr. Bilic, that this man who was threatening

10     you with a knife in the second room was one of Seselj's men?

11        A.   Well, it needn't necessarily be so, but he was from Serbia.  His

12     accent was different from the accent of the local Serbs that I was

13     familiar with.

14             MR. DUTERTRE: [Interpretation] Could we move for a few moments

15     into closed session, please.

16             JUDGE ANTONETTI: [Interpretation] Madam Registrar, please.

17                           [Private session]

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 9000

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12                           [Open session]

13             THE REGISTRAR:  Your Honours, we're in open session.

14             MR. DUTERTRE: [Interpretation]

15        Q.   Mr. Bilic, I shall just say the person who saved you.  I won't

16     mention his name and I don't wish you to mention his name in open session

17     either.  So this person who saved you, where did this person take you to?

18        A.   He took me from Sutina, and then I was able to walk over the hill

19     to my home and his home was just behind this block of flats.  So I just

20     went to Zalik, and I shut myself in my apartment and I found shelter

21     there.

22        Q.   What time was it approximately when this person saved you and

23     enabled you to leave Sutina?

24        A.   Just before dawn, so the dawn after that night when all those

25     people went missing.  It was not dawn yet.  When I get to Zalik, it

Page 9001

 1     became light.

 2        Q.   That is a useful clarification.  On leaving Sutina, were you able

 3     to see whether -- what did you see when you left Sutina?  Did you see

 4     armed men?  What did you see?

 5        A.   Well, I saw machine-gun and two people who were dug-in just

 6     behind the building, behind where our rooms there, so there was a

 7     machine-gun nest there and the whole night they fired this machine-gun --

 8     well, there was some lulls in the shooting, but for most of the time

 9     there was fire.

10        Q.   Did you ask the person who had saved you what was happening?

11        A.   Yes, I asked him what was going on.

12        Q.   And what did he say?

13        A.   He didn't let me talk a lot, but he did say that he was this

14     close to being promoted to the rank of major.

15        Q.   Did he say anything about what was happening in Sutina?  Did you

16     question him on that account?

17        A.   He didn't want to talk about that at all because nobody would

18     give you any answers anyway.

19        Q.   Did he go straight to your flat or did you go via the shelter?

20        A.   [Previous translation continues] ...  I took the keys from my

21     wife in the shelter and I went up, I just fled.

22             MR. DUTERTRE: [Interpretation] Could I move into private session

23     for a few moments, please.

24             JUDGE ANTONETTI: [Interpretation] Registrar, please.

25             Just a moment.

Page 9002

 1                           [Private session]

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 9003

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4                           [Open session]

 5             THE REGISTRAR:  Your Honours, we're back in open session.

 6             MR. DUTERTRE: [Interpretation]

 7        Q.   Mr. Bilic, the people who were in the shelter, did they question

 8     you about what had happened to your companions?

 9        A.   Yes, they did ask me about that.  I didn't know what to tell

10     them.  Well, they saw me alive and the others were gone, and then they

11     started threatening me, that I would not live and things like that and

12     yet here I am, still alive after the war.

13        Q.   What is your feeling about the degree of organization and

14     preparation relating to what happened in Sutina?

15        A.   Well, I don't know what to think.  I can't speak on other

16     people's behalf.  Those people who set that up should tell you that; it's

17     not my place to do that.

18        Q.   Did you think that all of this had been organized, had not been

19     organized?

20        A.   It was war, there's nothing more to say; and in this war

21     everybody's true nature came out.

22        Q.   In light of the speeches or in light of what you'd heard --

23             THE INTERPRETER:  Interpreter's correction.

24             MR. DUTERTRE: [Interpretation]

25        Q.   -- in the shelter, somebody came to talk to you for a whole

Page 9004

 1     night.  Did you think that what was happening in Sutina was a direct

 2     consequence of that?  What were your feelings about this?

 3        A.   Well, it was genocide to destroy us Muslims, nothing else, just

 4     as they had agreed with the Croats, that Croats should do it on one side

 5     and they on the other and that they should throw all of us Muslims into

 6     the Neretva River -- well, it was made public in speeches, it was said on

 7     TV.  So that was what they wanted to do, but they failed to create

 8     Greater Serbia.

 9             MR. DUTERTRE: [Interpretation] Thank you, Your Honour.  I have no

10     further questions.

11             JUDGE ANTONETTI: [Interpretation] I just have a short follow-up

12     question to put to you.  When you were released by the person whose name

13     I'm not going to mention, you came back to your flat.  And then after

14     that, sir, did you stay there or did you change your place of residence?

15             THE WITNESS: [Interpretation] I remained in the same apartment,

16     that's where I live now.

17             JUDGE ANTONETTI: [Interpretation] How long did you stay there

18     for?

19             THE WITNESS: [Interpretation] I stayed there four or five days,

20     that's when the troops barged in, that's when the Croats crossed the

21     Neretva.  They first went to Sutina and then they went to Zalik because

22     the troops were all mixed up.  There were us, our guys, with the lilies

23     and the Croats, and they found me there around the corner.

24             JUDGE ANTONETTI: [Interpretation] In other words, the mixed

25     troops, i.e., Croat and Muslims who accounted for the fact that you were

Page 9005

 1     totally free?

 2             THE WITNESS:  [No interpretation]

 3             JUDGE ANTONETTI: [Interpretation] This is a clarification after.

 4     It is now 11.30.  We shall have a 20-minute break, this will be our last

 5     break.  We shall resume after that and as you know, we will finish at a

 6     quarter after 1.00 and the cross-examination is likely to be continued

 7     next week.

 8                           --- Recess taken at 11.26 a.m.

 9                           --- On resuming at 11.48 a.m.

10             JUDGE ANTONETTI: [Interpretation] The hearing's resumed.

11             Mr. Seselj, you may proceed for your cross-examination.

12             MR. DUTERTRE: [Interpretation] Mr. President, allow me one

13     observation.  We have just received a document disclosed in B/C/S.

14     Mr. Seselj plans to use it.  I do not know when he wants to use it, but

15     obviously if we are to continue next Tuesday with the cross-examination

16     maybe he should use it then so that we have time to read it and have it

17     translated.

18             JUDGE ANTONETTI: [Interpretation] Yes, Mr. Seselj, there is a

19     document that has not been translated.  If you plan to use it, it might

20     be better to use it next week so as to give time to the Prosecution for

21     the document to be translated.  This being said, I do not have the

22     document.  I see Madam Registrar has a copy.

23             Yes we have it now.  Thank you.  You may proceed.

24                           Cross-examination by Mr. Seselj:

25        Q.   [Interpretation] Mr. Bilic, yesterday during the

Page 9006

 1     examination-in-chief you marked the locations of the places mentioned,

 2     and I intervened because I thought it was an accidental mistake when you

 3     said it all took place on the right bank of the river Neretva.  You know

 4     that the Neretva has its source underneath Mount Bjelasnica and flows

 5     into the Adriatic Sea, do you not?

 6        A.   It has its source in Hodzici under a mountain called Jabukova

 7     that's where the spring is, it's not in Mount Bjelasnica.

 8        Q.   Below?

 9        A.   Below in Konjic.

10        Q.   Does it flow into the Adriatic Sea?

11        A.   Yes, in Ploca.

12        Q.   And when you look from the source towards the mouth, all these

13     things, Zalik, Sutina, Obarak, they're all on the left bank; is that

14     right?

15        A.   Well, after the war it's been referred to as the left bank;

16     before the war we never referred to the left bank or the right bank, it

17     was all the same.

18             JUDGE ANTONETTI: [Interpretation] Yes, Madam Dahl.

19             MS. DAHL:  I note the pace, between the speaker question and

20     answer was quite quick.  And if you would remind both the accused and

21     witness to please pause.

22             JUDGE ANTONETTI: [Interpretation] Yes, I forgot to remind

23     Mr. Seselj and the witness they both speak the same language and

24     therefore they should wait until the question to be interpreted before

25     they answer.  This goes for you, Mr. Witness, so the interpreters can

Page 9007

 1     interpret because the problem is when you speak at a very swift pace the

 2     interpreter has not finished translating and Mr. Seselj already puts a

 3     new question so it's hard to follow.  There is one solution.  When

 4     Mr. Seselj has put a question to you, you count until five in your head

 5     and then you can answer.

 6             Mr. Seselj, go ahead.

 7             MR. SESELJ:  [Interpretation].

 8        Q.   Well, Mr. Bilic waited so long that I was afraid he wouldn't

 9     answer my question at all, so I think this intervention was quite

10     inappropriate.  Mr. Bilic waited three times longer than was necessary.

11     But all right, Madam Dahl likes to intervene although she's unable to

12     find real reasons for doing so?

13             Mr. Bilic, before the war --

14             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, this is out of

15     place.  Ms. Dahl made an observation.  Let us endeavour to work serenely.

16     It may be that at times the witness waited, but it could happen also that

17     he wouldn't wait and would answer straight away.  So I just want to

18     pre-empt that.  I think it's better.

19             Please continue, Mr. Seselj.

20             MR. SESELJ: [Interpretation]

21        Q.   Mr. Bilic, before the war everybody knew where the left and right

22     banks were, right?  Zalik, Sutina, and Duborak [phoen] are all on the

23     left bank, as is the north camp barracks and the military institute; is

24     that right?

25        A.   Yeah.

Page 9008

 1        Q.   And the JNA was there from the beginning, right?

 2        A.   Yes.

 3        Q.   Is it correct that as early as September 1991 there was a

 4     Croatian armed rebellion in Mostar and in western Herzegovina?

 5        A.   I've heard about that.

 6        Q.   Did you see it?  Were there certain divisions in the Mostar area

 7     as early as September?

 8        A.   At that time there were no changes in Mostar yet.

 9        Q.   Were there conflicts between the JNA and the Croatian

10     paramilitary forces?

11        A.   Yes, and also the territorials, the territorials defending Mostar

12     began to gather there.

13        Q.   Who were they defending Mostar from?

14        A.   Well, you were stirring things up.

15        Q.   Who was?

16        A.   You, the Serbs.

17        Q.   Well, how come you say the Serbs did that when it was the Croats

18     who rebelled?

19        A.   Well, you stirred things up, first in Croatia --

20             THE INTERPRETER:  Could witness and the accused please slow down.

21             MR. SESELJ: [Interpretation]

22        Q.   In Sarajevo you killed the father of the groom --

23             JUDGE ANTONETTI: [Interpretation] Look at line 5, page 65, the

24     interpreters are asking you to speak more slowly because you've started

25     again, you know, question and answer, no stop and the interpreters need

Page 9009

 1     to breathe.

 2             Witness, you answered a question by Mr. Seselj.  Even if you

 3     don't like the question, you have to answer it.  It is important for the

 4     Judges to know what happened, and since also as to events prior to the

 5     tank truck explosion which may have caused several events to take place,

 6     but there may be other causes.  And through the questions we discovered

 7     that before that there had been a conflict for some time in Mostar, a

 8     conflict between the Croats and the Serbs, Croats, Muslims, and Serbs.

 9             So we may as well try to unravel all this.  If you don't like the

10     question, that's not the issue, you have to answer it, you have to answer

11     questions and answer that question alone.  It is your obligation to

12     answer questions because the proceedings in this Tribunal are such that

13     it's driven by parties.  The parties put questions.  The Judges do have a

14     part to play, but not the main part as is the case in your country.  So

15     Mr. Seselj is entitled to ask any questions he wants to, provided he

16     doesn't insult you, of course, or provided he doesn't broach topics that

17     may lead to discussions.  But that put aside, he can ask any questions,

18     you have to answer them.

19             This being said, and of course this is not going to be taken out

20     of the time given to Mr. Seselj, he may now proceed.

21             MR. SESELJ: [Interpretation]

22        Q.   Mr. Bilic, is it correct that at the beginning of that conflict

23     in Mostar in September 1991 the JNA held the two predominant features,

24     Velez and Hum, Velez is on the left bank of the Neretva and Hum on the

25     right bank; is that correct?

Page 9010

 1        A.   Yes.

 2        Q.   Is it correct that the Croatian paramilitary forces took most of

 3     Mostar?

 4        A.   Yes.

 5             MR. DUTERTRE: [Interpretation] It's such a general question, I

 6     mean Mostar when?  It is absolutely vague.

 7             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, could you ask the

 8     witness when the Croatian paramilitary forces took over Mostar.  You say

 9     September 1991 and then we don't know, but it may be that the witness is

10     not in a position to answer.  I don't know.

11             MR. SESELJ: [Interpretation]

12        Q.   In September 1991 there was a conflict between the Croatian

13     rebels and the JNA.  Bosnia and Herzegovina was not at war yet at that

14     time.  The government of three national parties in coalition was

15     functioning, the SDA, the Muslim party; the SDS, the Serbian; and the

16     HDZ, the Croatian party.

17             MR. DUTERTRE: [Interpretation] My objection is not that now

18     Mr. Seselj would testify himself as to the events that took place.  He

19     needs to seek information from the witness as to the date when the

20     events.  It was inadmissible because it was too vague.

21             JUDGE ANTONETTI: [Interpretation] Yes, the Trial Chamber is

22     already aware of what you say.  You have to ask a question of the

23     witness.  Tell him:  Witness, do you know that in September 1991 there

24     was a conflict between the Croatian rebels and the JNA?  And he anyway

25     say yes, no, or I don't know, otherwise the Prosecutor will be on his

Page 9011

 1     feet saying you are testifying.

 2             THE ACCUSED: [Interpretation] Well, it would be best for the

 3     Prosecutor to cross-examine instead of me.  This is really pointless.

 4             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, I am not willing to

 5     let you manipulate the proceedings.  There are rules.  You are to conduct

 6     the cross-examination, and in this Tribunal cross-examination is governed

 7     by certain rules arising from Anglo-Saxon law.  You are entitled to ask

 8     questions, but you're not allowed to testify through the questions you

 9     put.  That is the difference, and if you are to testify systematically

10     you're going to have objections from the Prosecutor and that will be a

11     waste of time; you know that as well as I do.  When the Prosecutor does

12     not comply with Anglo-Saxon rules, you are the first one to object.

13             Let us avoid this.  Therefore, put your question in such a manner

14     that even if you want to highlight an event you have to seek confirmation

15     by the witness of the events through leading questions; that is

16     authorised.  That's it.  Please continue.

17             THE ACCUSED: [Interpretation] Well, now you've made me so

18     frustrated with this initial noise that I don't even feel like putting

19     questions, but I'll do my best.  I didn't observe you yelling like that

20     at representatives of the OTP, but that's up to you and your --

21             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, you are impolite,

22     you are impolite, discourteous.  You spent your time criticising

23     everybody, including Judges; this is inadmissible.  I reminded you what

24     the rules were that prevail in this Tribunal.  You may comply with them

25     or turn them down.  Everybody's got their own opinion, but that's the

Page 9012

 1     rules.  Questions are put by the Prosecutor as part of the

 2     examination-in-chief and the Prosecutor is not entitled to testify, he is

 3     allowed to ask questions which he does in a non-leading way; and if he

 4     ever does, as you could see this morning, he is out of order by the

 5     Trial Chamber and you at times do the same.  You criticise the Prosecutor

 6     for doing that.  That's the Prosecution part of the examination.  When

 7     cross-examination comes, you can ask any questions, but you're not

 8     entitled to testify.  If you testify, the Prosecutor will be on his feet

 9     and will object.  This is what I'm telling you now, and you do not want

10     to admit it, but these are the rules.

11             THE ACCUSED: [Interpretation] Before I continue my

12     cross-examination, I must first thank you for telling me that I'm

13     impolite.  I'm very grateful to you for that.

14             MR. SESELJ: [Interpretation]

15        Q.   Mr. Bilic, do you know what the JNA controlled on the west bank

16     of the river Neretva apart from the hill of Hum before this conflict

17     broke out?

18        A.   Podvelezje.

19        Q.   Well, we said that Podvelezje is on the west or east bank.  The

20     river Neretva divides Herzegovina into east and west Herzegovina and it's

21     been like that for 500 years; isn't that right?

22        A.   You controlled Siroki Brijeg up there, there were a lot of tanks

23     up there.

24        Q.   Well, look, the army pulled out of that area.  Siroki Brijeg is

25     almost 100 per cent inhabited by Croats?

Page 9013

 1        A.   Yes.

 2        Q.   And the army found it intolerable there because of the Croatian

 3     rebellion and the army pulled out of there?

 4        A.   Well, they were forced to leave.

 5        Q.   Well, they may have been forced to leave because it was a

 6     large-scale uprising by Croats.  So you are unable to say what else the

 7     JNA held on the west bank apart from the hill of Hum?

 8        A.   I don't know.

 9        Q.   Is it correct that throughout September, October, November,

10     December 1991 there was an exchange of fire between the JNA and Croatian

11     paramilitary units across the river Neretva?  The JNA was firing on one

12     side and the Croatian paramilitary forces on the other.  Is that correct?

13        A.   Yes, it is.  There were tanks underneath Podvelezje, yes.

14        Q.   Well, not just from Podvelezje.  There was artillery firing from

15     the west bank also.  There was also sniper fire on both sides.  Is that

16     correct?

17        A.   Yes.

18        Q.   There was artillery fire.  Very well.  And now, when Vance's plan

19     was adopted it was towards the end of December 1991 there was a

20     cease-fire; is that right?

21        A.   I'm not a politician.  I didn't concern myself with that truce.

22        Q.   But for a while there was no shooting, there was a status quo,

23     whoever was in control of certain area remained there.

24             In 1992 was there fire in Mostar in January, February, March in

25     1992?  Was there military activity?

Page 9014

 1        A.   You mean our side?

 2        Q.   Was there any shooting at all?

 3        A.   All I know is that the army and the JNA collected the weapons

 4     from the civilian protection so that when they burst in no one had any

 5     weapons.  The JNA collected all the weapons to prevent people from

 6     shooting.

 7        Q.   Well, first of all, the civilian defence didn't have any weapons,

 8     it was the Territorial Defence that had weapons?

 9        A.   They had rifles.

10        Q.   In early 1991 the army took the weapons from the Territorial

11     Defence?

12        A.   Yes, right away.

13        Q.   Before the war in Croatia broke out --

14             JUDGE HARHOFF:  Slow down, both of you.

15             MR. SESELJ: [Interpretation]

16        Q.   Can you confirm that in January, February, and March 1992 in

17     Mostar there was no fire on either side?

18        A.   There was no fire until the tank truck exploded.

19        Q.   That's what I wanted to hear.  Thank you very much.  So it was

20     the explosion of the tank truck in front of the wall of the JNA Barracks

21     that was the signal for new armed hostilities?

22        A.   That's correct.

23        Q.   When the tank truck exploded --

24        A.   That's when it started.

25        Q.   -- that's when the real war broke out?

Page 9015

 1        A.   -- that's when I got back from the Gacko, from the field, it

 2     started from up there, from Gacko.

 3        Q.   The explosion was so strong that it almost destroyed one of the

 4     barracks buildings and many surrounding civilian buildings; is that

 5     correct?

 6        A.   Yes.

 7        Q.   Many flats were damaged by the detonation and were unfit to live

 8     in; is that right?

 9        A.   Yes.

10        Q.   When that happened you went to the atom bomb shelter; is that

11     right?

12        A.   Yes.

13        Q.   That atomic shelter was built for a real nuclear war?

14        A.   Yes.

15        Q.   So it has an automatic door that would seal itself, it was a vast

16     area where hundreds of people could take shelter and food could be kept

17     there?

18        A.   Yes, yes, yes.

19        Q.   And there were also devices to cleanse the air.  So you were

20     quite clear from nuclear, biological, or chemical weapons, even had they

21     been used?

22        A.   Well, as for nuclear and biological weapons and so on, not all

23     the work had been finished, but there was enough air.

24        Q.   But the artillery certainly couldn't harm you in that shelter?

25        A.   Hundreds of shells and tank shells and everything and mortar

Page 9016

 1     shells fell on the shelter, but they couldn't harm us.

 2        Q.   You said thousands of shells fell?

 3        A.   Yes, because there were two wars, one on each side.

 4        Q.   Very well.  I just said that those shells that fell on the

 5     shelter were fired from Podvelezje; is that right?

 6        A.   Mostly, yes, mostly from up there.

 7        Q.   Well, did somebody target the shelter intentionally with

 8     artillery from Podvelezje?

 9        A.   The Serbs from up above, I don't know whether they saw what they

10     were shooting at, but there were shells falling around about the shelter.

11        Q.   Well, I assume the JNA from Podvelezje targeted Croatian

12     positions and not their own forces and their own civilians?

13        A.   Well, both sides targeted this, in the Serb war and the Croatian

14     war, they targeted the shelter.

15        Q.   I just want to put right what you said in the

16     examination-in-chief when you said that the shells were coming from

17     Podvelezje and targeting your shelter, that's impossible, because the

18     shells falling on your shelter were fired by the Croatian forces; isn't

19     that right?

20        A.   Well, when they began their war.

21        Q.   But we said that the war began after the 3rd of April, the real

22     war?

23        A.   Well, the Serb army hadn't withdrawn yet when the shells were

24     still falling.

25        Q.   It was still the JNA until the 19th of May, wasn't it, right?

Page 9017

 1        A.   Yes.

 2        Q.   The JNA targeted Croatian positions from the left bank and the

 3     Croatians from the right bank targeted the positions of the JNA and the

 4     inhabited settlements of civilians as well; isn't that right?

 5        A.   I know when you from Podvelezje targeted the Croatian side and

 6     some of our main buildings too were destroyed in town, Tito's Street,

 7     Razvitak and companies like that.

 8        Q.   Is Tito's Street on the west bank, the right bank?

 9        A.   On our side under Podvelezje.

10        Q.   Under Podvelezje, I see.  Well then that was targeted by the

11     Croats too, not the JNA.  Why would the JNA target territory under its

12     own control, there's no logic there, is there?

13        A.   Well, it was Croats and Serbs targeting, they both targeted.

14        Q.   Well, yes, both sides targeted but not themselves, they targeted

15     the other side, the opposite side.  Am I right?  Why would you target

16     yourself if you can target the enemy, right?

17        A.   Well, I don't really know.

18        Q.   All right, fine.

19             JUDGE ANTONETTI: [Interpretation] One moment, Witness.  I felt

20     like asking the question Mr. Seselj just put whilst the Prosecution was

21     questioning you, but I had some doubt as to who targeted the shelter.  I

22     even asked you this.  I said were there Serbs in the shelter with you,

23     and you said yes there was Serbs and Croats.  So I wondered why Serbs

24     would target their own Serbs.  Now in his questions Seselj highlights the

25     fact that it was the Croatian artillery that targeted the shelter.  Do

Page 9018

 1     you agree with him on this point, on his idea, on his suggested

 2     explanation, namely, that when you were in the shelter the shells falling

 3     were fired by the Croats not by the Serbs?

 4             THE WITNESS: [Interpretation] All I know is that the main road is

 5     above the shelter which leads to the sea, and on in fly-over on the main

 6     road there was a tank there all the time, the latest type of tank, the

 7     big type of tank, it was stationed there and didn't move until the Serbs

 8     withdrew.  It was there all the time and did the shooting.  Yes, it shot

 9     at the Croatian side and they had already united the Muslims and Croats

10     to fight together; that's how it was.  And then afterwards when they

11     started shooting from up there, Podvelezje, that's when shells fell on

12     the shelter, around the shelter.  They would hit somebody's flat, kill a

13     whole family, things like that, just any old which way.

14             JUDGE ANTONETTI: [Interpretation] Please proceed, Mr. Seselj.

15             MR. SESELJ: [Interpretation]

16        Q.   That shelter protected all of you, the Serbs, the Croats, the

17     Muslims, civilians from artillery and sniper fire, right?

18        A.   Yes.

19        Q.   And the civilians were forbidden to move around except for the

20     bare necessities, to go and fetch food or clothing or something like

21     that, right?

22        A.   Yes.

23        Q.   And you weren't allowed to move around because it was dangerous,

24     a threat to your lives, right?

25        A.   Yes, from the shells.

Page 9019

 1        Q.   All right.  Now we're progressing a little, we're making headway.

 2     Mr. Bilic, you were in that shelter from the 4th of April, which is the

 3     day after the explosion in front of the barracks, up until the 13th of

 4     June, right?

 5        A.   Yes.

 6        Q.   April, May, June, that's almost two and a half months, right?

 7        A.   Yes.

 8        Q.   And your neighbours, the Serbs, how long were they in the shelter

 9     with you, the civilians?

10        A.   They were there right up until we were taken away, until the bus

11     came and took the Serbs away from the shelter.

12        Q.   That was a little earlier, was it?

13        A.   In the bus.

14        Q.   The bus arrived much earlier than you were taken away to Sutina?

15        A.   They were separated and sent to the bus and -- when I came back

16     from Sutina to my flat, when I came back from Sutina.

17        Q.   Mr. Bilic, it wasn't quite like that you said something different

18     a moment ago.  You said that the buses had arrived to take the Serbs away

19     from the shelter and that they took the Serbs to Zijemlje which is an

20     outskirt of Mostar?

21        A.   Yes, yes, when I was saved, that day, that's when they were

22     getting ready and preparing everybody --

23        Q.   Just a moment, Mr. Bilic, just a moment, let's take this step by

24     step.  This happened more than a month before the 13th of June, it

25     happened sometime at the beginning of May, that's when that took place.

Page 9020

 1     And when the Serbs were taken away from the shelter the artillery fire

 2     stopped pounding the shelter.  You told us that during the

 3     examination-in-chief, right?

 4        A.   Yes, of course.

 5        Q.   So as soon as the Croats heard that the Serb civilians had left

 6     the shelter and that that remained were the Muslim and Croatian

 7     civilians, they stopped their artillery and sniper fire targeting

 8     civilian features, right?

 9        A.   Yes.

10        Q.   And then you were able to leave the shelter and go about your

11     work obligations, right?

12        A.   Yes, well we worked, but there was still shooting.

13        Q.   All right, you went to work where the sniper fire couldn't reach

14     you?

15        A.   Between the buildings.

16        Q.   Yes, that's right.  So your job was to clear up the rubble from

17     the destroyed buildings, to deal with the rubble, the bricks and

18     everything else --

19             MR. DUTERTRE: [Interpretation] Please slow down.

20             JUDGE ANTONETTI: [Interpretation] Witness, I asked you to wait

21     before you answer, and you're not doing so.  Mr. Seselj is also firing

22     questions at you even when you aren't finished answering, so because of

23     this we have overlapping and we have a big problem with interpretation.

24     So with this please try and wait before you answer, otherwise there's so

25     much overlapping we cannot follow.

Page 9021

 1             MR. SESELJ: [Interpretation]

 2        Q.   I just resolved the problem, Mr. President, that cropped up

 3     during the examination-in-chief, and you and the Prosecutor were unable

 4     to deal with it.  When the Serbs left the shelter, the shelling stopped,

 5     and then it was possible for the work obligations to go ahead and for the

 6     people who were in the shelter and able-bodied men could be sent to do

 7     certain work and certain jobs, and that's the problem solved.  That's

 8     that cleared up --

 9             MR. DUTERTRE: [Interpretation] Your Honour, I think the witness

10     said the opposite.  He said that he started working when shelling was

11     still going on, so Mr. Seselj is not using the witness's words.

12             JUDGE ANTONETTI: [Interpretation] Witness, you heard Mr. Seselj

13     say that according to him when the shelling stopped you were able to go

14     to work and people started to be able to move again.  This is what

15     Mr. Seselj is saying.  The Prosecutor is saying that that is not the

16     case.  You're the only one to tell us what happened.  Is Mr. Seselj

17     right?  Is he right?  Is he wrong?  If he's wrong, why is he wrong?

18             THE WITNESS: [Interpretation] No, he wasn't right.  That's not

19     when there was -- well, when the Serbs left.  There was no work

20     obligation then, after that.  These were taken -- these people were taken

21     to Sutina and that's when we worked, before we were taken to Sutina.  And

22     once they took us to Sutina there was nobody left to work, to do the

23     work.  All the people who could do some work had been killed.  Only women

24     and children and two or three elderly persons remained in the shelter.

25             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, given what the

Page 9022

 1     witness said, you may proceed.

 2             MR. SESELJ: [Interpretation]

 3        Q.   In two places in Mostar you saw groups which you identified as

 4     being Seselj's men, Seseljevci, right?  And that was in Luka or the port

 5     and the military institute, right?

 6        A.   Yes.

 7        Q.   You described them?

 8        A.   Yes.

 9        Q.   How did you know that they were Seselj's men?

10        A.   The person who led us, Savo, he said himself, These men are not

11     from here, they're not ours, they're not our local people, they're people

12     from up there, from Novi Sad, or rather, Serbia -- from far away.

13        Q.   The fact that they were from Serbia was sufficient for you to

14     conclude that they were Seselj's men, right?

15        A.   Well, you can tell by looking at them and, yes, they had big

16     beards, they had insignia, markings, what else can I say?

17        Q.   Did they have a beard like me?  What did you say, a beard like

18     me?

19        A.   You haven't got a beard, just like me, I haven't got one either.

20        Q.   Well, how would they be Seselj's men by the fact that they wore a

21     beard when I never wore a beard.  Perhaps there was another way to

22     identify them as being Seselj's men, not everybody wearing a beard can be

23     identified as Seselj's men?

24        A.   Well, the others weren't capable or weren't responsible for what

25     the others did.

Page 9023

 1        Q.   So they were most capable for doing their job and that's why you

 2     thought they were Seselj's men, right --

 3             JUDGE ANTONETTI: [Interpretation] This answer is not

 4     satisfactory.  Mr. Seselj is asking you whether just wearing a beard is

 5     sufficient to make you a Seselj's man.  You're not answering that.

 6     Mr. Seselj adds that he himself is beardless, is clean-shaven.  So

 7     through his question he's trying to highlight the fact that -- the

 8     connection, the possible connection between being -- having a beard and

 9     being a Seselj's man.  You're not clear in your answer.  When you say

10     they were Seselj's men because those men had beards, does that mean that

11     for you having a beard is sufficient to make anyone Seselj's man, but

12     Mr. Seselj wears no beard?  Do you understand my question or do you want

13     me to reformulate it?

14             THE WITNESS: [Interpretation] I understand it.  Well, it -- they

15     need -- it wasn't obligatory that they would have been Seselj's men, but

16     I saw Seselj's men on television so that's why I thought it -- there were

17     ten of them.

18             MR. SESELJ: [Interpretation]

19        Q.   All right.  So we agree that you concluded that they were

20     Seselj's men.  Let's leave it at that, because they're similar to some

21     people you saw on television.  I'm satisfied with that answer.  We don't

22     have to dwell on that.

23             But anyway, you had direct experience yourself with two men whom

24     you also identified as being Seselj's men, right?  And one of them was

25     from Novi Sad together with you in the shelter, right?

Page 9024

 1        A.   Yes.

 2        Q.   Was he from the 4th of April right up to the 13th of June in the

 3     shelter with you, all that time?

 4        A.   When they came down from the Serbian church, when the soldiers

 5     surrounded us and he came and he was there from then on.

 6        Q.   So from the 4th of April to the 13th of June he was there all the

 7     time?

 8        A.   He disappeared from Zalik, my wife told me, she was there, she

 9     was in the shelter.  He left, they took him away.

10        Q.   And you knew that he was Seselj's man although he didn't have a

11     beard?

12        A.   Well, he talked to us and he said he was from Novi Sad and was a

13     Seselj's man.

14        Q.   Yes, I heard that; but he didn't have a beard, did he?

15        A.   No.

16        Q.   He was in the shelter with you because he had a girlfriend,

17     Vojo Pejanovic's daughter, and was she in the shelter with you too?

18        A.   Yes, she was but she was mostly in her flat.

19        Q.   But she was with him all the time?

20        A.   Yes, they were going out together.

21        Q.   So this allegedly Seseljevci was in love and was with his

22     girlfriend straight away and it didn't enter his head to go into battle?

23        A.   Well, he was at the airport, he took her in an aeroplane or to

24     aeroplanes.

25        Q.   So that was his participation in the war, was it, going around

Page 9025

 1     with his girlfriend, right?

 2        A.   Yes.

 3        Q.   Now you said that when this man Seseljevci was in the shelter

 4     with you, that he sharpened his knife.  Did he sharpen his knife every

 5     day?

 6        A.   He did nothing else but just kept quiet, was silent and sharpened

 7     his knife.

 8        Q.   So for two and a half months he was sitting there sharpening his

 9     knife --

10             THE INTERPRETER:  This is impossible to translate at this speed.

11     Thank you.  Could the speakers please slow down.

12             JUDGE ANTONETTI: [Interpretation] Mr. Seselj at line 18 the

13     interpreters lost track of what you were saying so please slow down.

14             MR. SESELJ: [Interpretation]

15        Q.   Was it a knife sharpener that you used or was it with -- was it

16     an electrical appliance or what?

17        A.   Well, no, it was a grindstone, a wet stone, you did it by hand.

18        Q.   He was there sharpening his knife.  All right.

19             Now, if he sharpened his knife for two and a half months, that

20     knife must have been as sharp as a needle, as thin as a needle?

21        A.   Well, I didn't look at it, I don't know.

22        Q.   All right.  But you said these other Seselj men too whenever you

23     would see them were sharpening their knives, the Seseljevci in the

24     institute and in Luka?

25        A.   Well, whenever we passed by them, they would be sharpening their

Page 9026

 1     knives.

 2        Q.   So whenever you came by they would take out their knives and

 3     start sharpening them --

 4             THE INTERPRETER:  The interpreters cannot hear the answers of the

 5     witness because it's just too fast and overlapping.

 6             MR. SESELJ: [Interpretation]

 7        Q.   You did your military service for a time, right?

 8        A.   For a short time.

 9        Q.   But you were issued a weapon, weren't you?

10        A.   No, I didn't have one then and I underwent training.

11        Q.   Well, you couldn't have undergone training without a rifle?

12        A.   Well, yes, I did it for the air force --

13        Q.   You had to do infantry training, Mr. Bilic?

14        A.   I was in the aviation and technical service, so we didn't need a

15     weapon.

16        Q.   All right.  But it was the M-48 rifles that were in use, the

17     carbines, at that time, dating back to the 1950s and the 1960s that the

18     army had?

19        A.   I know they had rifles, but I really don't know what they had.

20     I'm not well up on rifles, on weapons.

21        Q.   All right.  Now, the people that you saw, what weapons did they

22     have in their hands, the men you referred to as Seselj's men?

23        A.   Well, mostly those short automatics.

24        Q.   You mean Kalashnikovs?

25        A.   Something like that.

Page 9027

 1        Q.   Or the AK-47, which was the JNA type of weapon?

 2        A.   The old type, you know, you would put the charge inside.

 3        Q.   Do you know the kind of bayonet that goes with a Kalashnikov?

 4        A.   I don't know anything about bayonets.

 5        Q.   Well, you have a knife which is shorter than the classical type

 6     of bayonet but it's wider, precisely the type that you describe, the

 7     semicircle shaped knives that you mentioned, the Kama?

 8        A.   Well, yes.

 9        Q.   And that's placed on a Kalashnikov for close-up fighting?

10        A.   Well, you have a long one on a rifle --

11        Q.   Those are the old rifles with these long straight knives --

12             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, wait for the

13     answer, please, and you're going much too fast and the interpreters are

14     losing track.

15             THE ACCUSED: [Interpretation] Very well.  We've cleared that up

16     as well now.

17             MR. SESELJ: [Interpretation]

18        Q.   You mentioned another Seselj man who put a knife to your neck,

19     right?

20        A.   Yeah, that was a dangerous one.

21        Q.   Right, dangerous.  And you said that you concluded that he was a

22     Seseljevci because he was dangerous?

23        A.   Judging by his accent, he didn't speak like the locals.

24        Q.   Did he speak like Serbs in Montenegro or like Serbs in Serbia,

25     people in Serbia?

Page 9028

 1        A.   Well, I really can't answer that, I don't know -- how should I

 2     know what part of Serbia he came from?

 3        Q.   All right.  I can understand that you're afraid and couldn't

 4     concentrate on that, but you should be aware that in Herzegovina itself

 5     people in certain areas speak with different accents; is that right?

 6        A.   Yes.

 7        Q.   Well, for example, my mother and my father come from Trebinje

 8     municipality and they speak differently than people in Mostar do.  People

 9     from Trebinje and people from Mostar don't speak the same way.

10        A.   Well, the differences aren't very great.

11        Q.   No, but you can still tell where someone comes from by those

12     differences?

13        A.   Well, I worked in Gacko I've worked in Trebinje.

14        Q.   So only by the fact that his accent was different did you

15     conclude that this man who put a knife to your throat was a Seseljevci,

16     you have no other reason for saying so?

17        A.   No, I don't.

18        Q.   All right.  Can we have on the ELMO the decision of the military

19     court in Mostar --

20             JUDGE ANTONETTI: [Interpretation] Hold on, I interrupted because

21     the answer was not on the transcript, but now it is.

22             MR. SESELJ: [Interpretation]

23        Q.   Mr. Bilic, I'll try to be finished with my cross-examination very

24     quickly so that you are free to leave today.  I see that you don't have a

25     lot of patience for my questions and you don't really like answering them

Page 9029

 1     and I'll respect that --

 2             MR. DUTERTRE: [Interpretation] These comments are totally

 3     inappropriate.

 4             JUDGE ANTONETTI: [Interpretation] Proceed, Mr. Seselj.

 5             MR. SESELJ: [Interpretation]

 6        Q.   I assume, Mr. Bilic, that you are aware that the military

 7     prosecutor's office in Mostar in early 1993 submitted a criminal report

 8     against people who perpetrated the crime at Sutina; is that right, have

 9     you heard about that?

10        A.   No, I haven't.

11        Q.   Did you hear that there was an investigation into that crime?

12        A.   They said there was going to be an investigation.

13        Q.   Bodies were exhumed; is that correct?

14        A.   Yes, yes, that was done.

15        Q.   And exhumation of bodies is always an investigative activity,

16     right, so there was an investigation going on and in the course of the

17     investigation the bodies were exhumed.  At the motion of the district

18     military prosecutor's office, the military district court in Mostar on

19     the 2nd of March, 1993, issued an order on conducting an investigative

20     procedure against 30 men.  Is that on the screen?  Yes.

21             Now, please look at this list.  You don't have to say any of the

22     names out loud, just look through them and tell me whether there is a

23     single man here who is not a local man from Mostar or the surrounding

24     area.  The first one is from Mostar, right?

25        A.   (redacted), yes.

Page 9030

 1        Q.   Don't say names because when you start mentioning names we'll

 2     have to move into closed session.  So this second one is from Vrapcici,

 3     right, from Mostar, and the third one is from Mostar too.  Please don't

 4     read the names out loud.

 5        A.   Yes, yes, from Zalik.

 6        Q.   Well, you can see the fourth one is from Mostar and so is the

 7     fifth one, the sixth one.  Are you following?

 8        A.   Yes.

 9        Q.   The seventh one is from Mostar, right?  What about the eighth

10     one, is he from Mostar?  It says Mostar --

11        A.   Well, they all lived in Mostar for the most part.

12        Q.   Well, let's look at the next page, there are 30 in total.  And

13     they are suspected of having committed the crime in Sutina on the 13th of

14     June, 1992.  You see number 9, he's from Mostar as well, right, and then

15     number 10, he's from Mostar, the 11th person is from Mostar, are you

16     following me?  Number 12 from Mostar.  13 is from Nevesinje.  Have you

17     come to number 13 yet?

18        A.   Yes, I can see it.

19        Q.   Nevesinje, very well.  And then the 14th is from Mostar again,

20     Vrapcici is in Mostar.  The 15th also from Mostar, from Vrapcici, don't

21     mention his name; you know him, but don't mention his name.  The 16th is

22     also from Mostar, is that right?  And the 17th is from Mostar, you know

23     him too don't mention his name.

24        A.   Well, I know almost all of them.

25        Q.   Very well.  Just don't mention their names.

Page 9031

 1        A.   I know them from before the war.

 2        Q.   Well, until there is a trial and until their innocence or guilt

 3     is proved, we won't mention their names.  18 and 19 are also from Mostar,

 4     number 20 is from Vrapcici, that's Mostar again, right.  The 21st is from

 5     Mostar, the 22nd is from Mostar.  Let's look at page 3 now.

 6             THE ACCUSED: [Interpretation] Can we move to page 3, please,

 7     Madam.

 8             MR. SESELJ: [Interpretation]

 9        Q.   23 is also from Mostar, right?  24 is from Mostar, 25 is from

10     Mostar, 26 is from Mostar, 27 is from Mostar, Vrapcici; 28 is from

11     Mostar, 29 is from Mostar, and 30 is from Mostar.  They're all from

12     Mostar except for one who comes from Nevesinje.  Is that right?  Can you

13     see that, Mr. Bilic?  Are you convinced?

14        A.   Well, I don't know about all of them, they're not all from

15     Mostar.

16        Q.   Well, all right, not all of them because one is from Nevesinje.

17     Let me ask you this:  The district military court in Mostar heard many

18     people in connection with this crime.  All the survivors and people who

19     were able to know certain details in other ways, they also interviewed

20     certain Serbs who lived in Mostar.  They didn't call you, they didn't

21     summon you, did they?

22        A.   No one ever summoned me.

23        Q.   All right.  They didn't summon you, but I will show you two

24     statements by people who were interviewed in that investigation.  One man

25     is called Dervo Topalovic, do you know him?

Page 9032

 1        A.   Bero, he was locked up in north camp.

 2        Q.   Well, he managed to survive by some miracle, so let's see his

 3     statement before the military court in Mostar, we're now dealing with the

 4     cantonal court in Mostar which took the proceedings over --

 5             MR. DUTERTRE: [Interpretation] Your Honour, I was trying to

 6     check, but I don't know whether these exhibits have been disclosed to the

 7     OTP.  They might not have ever been disclosed to the OTP.  I would like

 8     Mr. Seselj to let us know where these statements come from and whether

 9     these have been disclosed to the OTP, and if they have not been disclosed

10     before the beginning of the hearing I object to these.

11             JUDGE ANTONETTI: [Interpretation] These statements I assume,

12     Mr. Seselj, are statements given by people who are on the list that you

13     must have had them because the Prosecutor disclosed these to you or the

14     OTP did not disclose these to you and then you have got hold of them

15     yourself.  If you -- this did happen, did you disclose these to the

16     Prosecutor?

17             THE ACCUSED: [Interpretation] Mr. President, the Prosecutor

18     provided me with all of this but the problem is the OTP doesn't know what

19     they gave me this is under Rule 65 ter 2569, page 4, it's the lady who

20     acts in the registry has it.  I think she can put it on the screen in

21     English.  The number is 2569.

22             JUDGE ANTONETTI: [Interpretation] Thank you for that information.

23             Mr. Dutertre, Mr. Seselj has just told us that these documents

24     come from the OTP.  I had a question also on the topic.  The Prosecutor

25     from Mostar conducted an investigation and drew up an indictment which we

Page 9033

 1     have before us.  What I would like to say is this:  What happened to this

 2     case?  Did the OTP look into the matter and see what has happened?  When

 3     you look at the indictment like I do you can see that at the moment I

 4     wanted to read it out the indictment disappears from the screen.  In this

 5     document it is mentioned that since April 1992 there are local Chetniks

 6     and there are members of the JNA who have committed whole series of

 7     offences which are listed here.  Has the Prosecutor been made aware of

 8     this?  Has he used this document?  Has he checked what has happened to

 9     this or was there no follow-up to this case?

10             MR. DUTERTRE: [Interpretation] Your Honour, as far as the

11     document that Mr. Seselj would like to use, there are a great number of

12     documents on its 65 ter list.  We can't remember every single document

13     that is in there.  As far as the investigation conducted in Mostar is

14     concerned, I will get back to you with accurate information as soon as I

15     can because off the top of my head I would probably be wrong, and I had

16     rather get back to you with the right information.

17             JUDGE ANTONETTI: [Interpretation] Please proceed, Mr. Seselj.

18             MR. SESELJ: [Interpretation]

19        Q.   Mr. Bilic, do you see that?  Here at the top you see it's a

20     statement made on the 29th of December, 2000, to the investigating judge

21     of the cantonal court in Mostar, which means that the cantonal court took

22     over this case from the military court; is that right?

23        A.   Yes.

24        Q.   Well, now we have this statement before us.  On the first page we

25     have the basic data and then on page 2, Mr. Topalovic, turn to page 2,

Page 9034

 1     please, describes these events in similar way to the way you described

 2     them, of course two people can't describe an event in exactly the same

 3     way; but he gives his perception of this event and now on page 2 we can

 4     see that nowhere does he mention any Seselj's men.  Dervo Topalovic whom

 5     I trust and whom I respect never mentions a single Seselj man.  Can you

 6     see that not a single Seselj man is mentioned here?  That's the only

 7     reason I'm showing this document, there's no other reason.

 8             MR. DUTERTRE: [Interpretation] What is the exact question, Your

 9     Honour?  I would like to know what the question is actually.

10             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, on the basis of

11     this document what is the question you are putting to the witness?

12             THE ACCUSED: [Interpretation] The question was very clear and

13     concise.

14             MR. SESELJ: [Interpretation]

15        Q.   Can you, Mr. Bilic, see anywhere in this statement made by

16     Dervo Topalovic any mention of Seselj's men?  Please go through the whole

17     statement, it's a page and a half long, and confirm that nowhere does he

18     mention Seselj's men.

19        A.   Well, his situation is one thing and mine is another.  He didn't

20     walk around, he didn't see things, he was constantly locked up in north

21     camp until the Croats and Muslims came in and he was liberated.

22        Q.   Very well.  I have another statement here, it's a statement, it's

23     page 6 of this same document; it's a statement by Admir Boloban also made

24     on the 29th of December, 2000, to the investigating judge of the cantonal

25     court in Mostar.  Can we have that statement.

Page 9035

 1             Do you know Admir Boloban?

 2        A.   Yes, I do.

 3        Q.   Well, let's go through his statement now.  Please turn to the

 4     next page.  His statement is somewhat longer, but on the next two pages,

 5     on the following two pages, we can see that he doesn't mention Seselj's

 6     men anywhere either.  Can you see here that there's no mention of

 7     Seselj's men?  Are you convinced?

 8             MR. DUTERTRE: [Interpretation] If the witness is asked to confirm

 9     something, please allow for enough time so that he can read it.

10             JUDGE ANTONETTI: [Interpretation] Well, this document is rather

11     long.  I have the English version and the B/C/S version.  In a split

12     second if Seselj's men are mentioned in the document this is something

13     which you should be able to see, and seemingly this is not mentioned in

14     the B/C/S text.  Can you confirm this, please.

15             THE WITNESS: [Interpretation] I can confirm, but what I saw in

16     Zalik and elsewhere, those insignia and all that, I can't say anything

17     different from what I've already said.

18             JUDGE ANTONETTI: [Interpretation] Sir, the difference between

19     statements which are given to the investigators of this Tribunal or to

20     any other entity for that matter, in this case there's an investigating

21     judge -- in the year 2000, this statement was given in the year 2000,

22     this was no war at that time and the investigating judge hears the

23     witnesses.  Any average investigating judge will try to find out who the

24     perpetrators were, and the judge in question asks questions.  And as

25     you -- what you have before you is that the summary of the interview

Page 9036

 1     between you and your neighbour - and I'm sure that this judge who was a

 2     professional judge tried to understand what did what.  Strangely enough

 3     in the document we have before us, Seselj's men aren't mentioned.

 4             Can you give us an explanation for this or not?

 5             Well, the witness answers those questions that have been put to

 6     him by an independent professional judge who wishes to get to the truth.

 7     So when this neighbour of yours sits in front of the judge, the judge

 8     wanted to find out who was there at the time.  And the neighbour, your

 9     neighbour, doesn't mention anything about this.  You were not confronted

10     with this judge, but maybe you can provide an answer.

11             Yes, Mr. Dutertre.

12             MR. DUTERTRE: [Interpretation] Admittedly, the indictment

13     mentions the Croats solely.  It was difficult perhaps to extradite

14     people, but I wonder to what extent the witness can answer questions on

15     statements which were made when he wasn't there and a situation with a

16     judge which he knows nothing about, but I understand the purpose of your

17     question.

18             JUDGE ANTONETTI: [Interpretation] Can you answer this question,

19     Witness?  Why did your neighbour not mention Seselj's men when it could

20     be very obvious?  That could be the first thing he said to the

21     investigating judge:  Yes, these were Seselj's men, we were captured by

22     Seselj's men.  And this is not mentioned in the document, right?  At the

23     end I see that a soldier of the JNA in uniform, so he did give a number

24     of details.  Why doesn't he mention this?  Perhaps you could say that you

25     don't know if you don't know or maybe you have your reasons.

Page 9037

 1             THE WITNESS: [Interpretation] I don't know how to answer this.

 2             MR. SESELJ: [Interpretation]

 3        Q.   Very well.  We won't dwell on this any longer, as we don't have a

 4     lot of time.

 5             THE ACCUSED: [Interpretation] Madam, this statement that I

 6     received today from Belgrade, could you please put it on the ELMO.

 7             MR. DUTERTRE: [Interpretation] This is precisely the statement

 8     which I suggest should be shown at a later stage.

 9             JUDGE ANTONETTI: [Interpretation] Well, Mr. Seselj is trying to

10     move on quickly so that the witness can go back home as quickly as

11     possible.  We shall do as best we can with the resources we have.

12             Your associate speaks B/C/S; unfortunately, we have no such

13     person.

14             THE ACCUSED: [Interpretation] And this will be interpreted by the

15     interpreter, Mr. President, I hope that you too have concluded just as I

16     have that this witness cannot hide his animosity towards me and that is

17     why I want to cut short the cross-examination --

18             MR. DUTERTRE: [Interpretation] This is totally inappropriate.  I

19     would like these comments to be put an end to.

20             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, you are not to make

21     any conclusions.  The Trial Chamber will draw its own conclusions when it

22     has enough evidence before it.  You have a Bench with professional Judges

23     before you, so please trust them.

24             So this is the text you would like to show.  Please proceed.

25             MR. SESELJ: [Interpretation]

Page 9038

 1        Q.   Mr. Bilic, did you know Nedjeljko Bojanic?

 2        A.   No.

 3        Q.   He was born in Bogodol in the Mostar municipality, in 1956, and

 4     he lived in Zalik in the high-rise building from the beginning of 1991 up

 5     until June 1992 -- well, it's not really very clear here, you can't

 6     really read it.  And he says, having provided some general information

 7     about Zalik, neighbourhood to the north of Mostar, along the -- between

 8     the main Sarajevo-Mostar road and the north camp barracks.  He says that

 9     the population was mixed, just as you have told us, Serbs, Croats,

10     Muslims, and he says that the three peoples were there in about equal

11     proportion.  Do you agree with that?

12             MR. DUTERTRE: [Interpretation] A procedural issue.  I have a

13     four-page document, Your Honour.  The fourth page which is a certified

14     copy is illegible as it stands, so we cannot see and read whether there's

15     a connection.

16             JUDGE ANTONETTI: [Interpretation] Well, we're not going to waste

17     any time over this.  You never can tell.  It might prove useful.  All we

18     know is that in the local proceeding a statement is given and the

19     statement is given by each individual.  This is then certified.  The

20     Trial Chamber or the local court then certified it and it's signed and

21     stamped.  As my colleague as reminded us on several occasions, what is

22     certified is only the signature.  The stamp does not certify the content

23     of the document in question.  Everybody knows that.

24             Please proceed, Mr. Seselj.

25             MR. SESELJ: [Interpretation]

Page 9039

 1        Q.   Mr. Bilic, this gentleman here says that the north camp was

 2     publicly criticised by Muslims and Croats as a large stronghold of the

 3     JNA which advocated the survival of Yugoslavia and that's why protest

 4     marches were organized in front of the barracks with demands being made

 5     that the army move out.  Do you remember those protest marches before the

 6     explosion took place?

 7        A.   Well, it was a long time ago, I really don't remember that.

 8        Q.   Very well.  He says that there were regular soldiers and some

 9     reserves in the barracks, mostly Serbs and Herzegovina, which were in

10     favour of keeping Yugoslavia together.  And then he goes on to say about

11     the tensions between the two polarised parties, Serbs were in the JNA and

12     the Territorial Defence and Croats and Muslims were in their own

13     Territorial Defence, the HOS, the Croatian armed forces, is that not

14     right, and in their police; is that correct?

15        A.   Well, I don't know how to really answer this question.  It is a

16     little bit complicated for me.

17        Q.   Well, if it's complicated, then let us move on.  He says that the

18     armed conflict between the polarised parties occurred when the extremist

19     from the Muslim-Croatian coalition attacked the barracks on the 4th of

20     March, there may be a mistake made by either him or you, he says the 4th

21     of March, you say the 3rd of March, but that happened around about that

22     time?

23        A.   Yes.

24        Q.   And then he says the attack was carried out at 1700 hours in such

25     a way that a tank truck was brought in from Bijelo Polje, it was full of

Page 9040

 1     explosives and various pieces of iron, it was parked next to the largest

 2     building in the north camp barracks where the soldiers' quarters were

 3     located.  Since at that time the troops were resting in the dormitory, it

 4     was obvious what the objective was.  The explosion was so destructive

 5     that it fully destroyed the military dormitory and caused substantial

 6     damage to the other buildings close by in the barracks, and civilian

 7     facilities that were across the road from the barracks.  At the time of

 8     the explosion I was outside of my building and my sister was in the

 9     apartment with small children.  They survived by mere miracle.  My

10     building, 12 storeys, 64 apartments, was fully demolished and most of the

11     surrounding buildings were damaged.  When this explosion took place over

12     70 civilians were wounded and two Croats who were passing by in a vehicle

13     were blown to pieces.  Fortunately only one soldier was severely injured

14     in the dormitory, but he soon died.  Is this an accurate description,

15     Mr. Bilic?  You don't want to say anything?

16        A.   Yes, yes, that's how it was.

17        Q.   Okay.  So that's how it was.  And then he goes on to say --

18             THE INTERPRETER:  The accused is kindly asked to read more

19     slowly.

20             MR. DUTERTRE: [Interpretation] I can understand that he wants to

21     go fast and release the witness, but he reads a long bit and then he

22     makes 10 or 15 proposals and asks the witness whether that's right.  So

23     when the witness says yes we don't know what he says yes to.  It might be

24     better to break it down.  I know we are under time constraints.  We also

25     need to have re-direct.  So let's have some sense in this.  Because the

Page 9041

 1     answer yes, we don't know what it is yes to.

 2             JUDGE ANTONETTI: [Interpretation] Yes, Mr. Seselj, please could

 3     you ask for some explanation.  What does he say yes to.

 4             THE ACCUSED: [Interpretation] The description of the situation,

 5     the consequences of the explosion.  One building was fully demolished and

 6     the others were damaged, the barracks building almost completely

 7     destroyed.  That's what the witness provided his answer to, and he says

 8     well more or less that was it.  He didn't give us a very decisive answer,

 9     as far as I can remember.

10             MR. SESELJ: [Interpretation]

11        Q.   Okay.  So when the troops started clearing up the rubble looking

12     for the victims, not knowing who was in the dorm at the time, gun-fire

13     was opened on them, first from the Orlac neighbourhood across the Neretva

14     river and then from the residential buildings in Zalik.  It was quite

15     clear to us that this was a coordinated attack carried out in order to

16     destroy the army.  After this day mortar and artillery attacks from the

17     other bank of the Neretva River controlled by armed Croatian Muslim units

18     owned the troops in the barracks were a daily occurrence so that several

19     soldiers were injured and there were even people who were killed

20     including a neighbour of mine Milenko Ivanisevic.  Do you know about this

21     fire being opened from the Croatian Muslim side and the killing of

22     Ivanisevic, this soldier by the name of Ivanisevic?

23        A.   Well, I don't know anything about that.

24        Q.   Fair enough.  He goes on to say:

25             "In the evening fire was opened from rifles in the residential

Page 9042

 1     buildings in Zalik, that was a JNA-controlled area, on the soldiers on

 2     the barracks resulting in injuries to three soldiers.  For this reason

 3     we, the loyal civilians, were asked by the army command in the barracks

 4     to assist them to identify the assailants, but this did not help.  I know

 5     that after two soldiers were injured or wounded the reservist soldiers

 6     from the barracks organized a search of the houses and apartments and

 7     there was a pair of brothers, I think their last name was Kuko, who had a

 8     house above the main road.  They found some rifles and the barrels were

 9     still hot.  They were as far as I could hear from the others arrested and

10     taken away to the military prison in Bileca.  Is that so?

11        A.   Yes, that's so.

12        Q.   On the suspicion that they attacked the army with snipers?

13        A.   Yes we, that's quite true.

14        Q.   After this comprehensive search of the apartments in Zalik that

15     was -- that were close to the barracks, the shooting incidents involving

16     the army became less frequent but there were such instances.  Soon after

17     that, there was a complete blockage of the bridges on the Neretva River,

18     the Muslim and Croatian population in the part of Mostar south of the

19     railway station mostly crossed to the right bank of the Neretva which was

20     controlled by the Muslim-Croatian units, and -- but in Zalik most of the

21     population remained on the right bank.  Since there were daily -- there

22     was daily shelling on the barracks and the Zalik neighbourhood which was

23     close to the barracks, the population for the most part moved to two

24     atomic shelters.  They were together there, Serbs and the others.  As for

25     the food supplies it was difficult and there was only one shop that was

Page 9043

 1     next to the Matkovici -- or rather, it was owned by Matkovici, but at any

 2     rate they were selling food to most people.

 3        A.   I don't know about that.

 4        Q.   Did you buy stuff from them?

 5        A.   I didn't.

 6             And then he goes on to say:  "For those reasons the barracks

 7     command ordered that everybody should be in the barracks and that a list

 8     of all people in Zalik should be made and to control whether they were

 9     present in the shelters in the evenings.  Some civilians were in charge

10     of making those checks.  I personally did not know them because I had

11     spent a short time in Zalik.  I know that everybody moved around freely

12     during the day, went to their apartments, and in the evening there was a

13     curfew in place.  And movement through the neighbourhood was prohibited

14     for all those who were not members of the military or the TO.  At the

15     Matkovic place there was a group of people, mostly his neighbours, from

16     the village and from Zalik who in collaboration with the military

17     maintained law and order in this neighbourhood.  This situation lasted

18     until the JNA withdrew from Bosnia and Herzegovina.  Since Croats and

19     Muslims who were in Zalik were not in the army, a request was made to put

20     them in work units, to clear up the main road Marsala Tita's Street which

21     was impassable because of the rubble caused by the fighting."

22             And he goes on to say that:  "The local police was also

23     involved," to cut a long story short and he doesn't know if there were

24     any other jobs to be done apart from this one.  And that this street was

25     deep behind the confrontation lines and that people working there were

Page 9044

 1     not exposed to direct sniper fire from the other side.

 2             And then this is important:  "In the Zalik area there were no

 3     volunteer units from outside, not even Seselj's men.  The only armed

 4     units were those that belonged to the JNA, to the TO, and several police

 5     officers" --

 6             MR. DUTERTRE: [Interpretation] Can we know what the question is?

 7             THE ACCUSED: [Interpretation] You will learn that in good time.

 8             JUDGE ANTONETTI: [Interpretation] Yes, but upon reading all this

 9     the witness is bound to get confused and so are the Judges.  I mean,

10     they've lost it already some of them.  So please break it down in various

11     questions, otherwise we get lost, because now you're moving on to another

12     topic which is the issue of Seselj's men, whilst before we had a

13     description.  You should have finished by saying:  So this is the

14     description given by that man, do you agree or not, and he would have

15     given you an answer, yes, no, I don't know.

16             THE ACCUSED: [Interpretation] Mr. President, I simply skimmed

17     this over, rephrasing it, to come here to the point where this

18     eye-witness says there were no volunteer units from the outside and there

19     were no Seselj's men in Zalik.

20             MR. SESELJ: [Interpretation]

21        Q.   Is this true, Mr. Bilic?

22        A.   Well, the only thing I can tell you is that there in the Matkovic

23     shop there was the staff and there was a machine-gun on the top of that

24     house.  That's all I know, all I can tell you.

25        Q.   Well, thank you for that.  He says the only armed units were

Page 9045

 1     those belonging to the JNA, TO, and several police officers.  It was hard

 2     to get to Zalik from the south zone where the Mostar Municipal Assembly

 3     was because a part of the road from the Orthodox church by the Sarica

 4     cemetery and the mosque was daily -- was almost impassable during the day

 5     because it was exposed to the sniper fire from the other bank of the

 6     Neretva river, is that correct, that it was impossible to get to the

 7     municipality by the day because of the sniper fire from the other bank of

 8     the Neretva river.  You don't know?

 9        A.   I don't know, well there was fire coming from all directions.

10        Q.   Fair enough.  As far as I know four civilians were killed by this

11     fire who moved to the southern part on their own risk and -- well, this

12     might be of importance to you.  The Serbian Territorial Defence for all

13     intents and purposes did not have any military uniforms.  They often wore

14     combined civilian and military clothes, there were no -- there was no

15     strict command or any orders to cut their hair or beards so that there

16     were people with long beards and long hair.  Everybody did whatever they

17     pleased.  Some of them obtained military uniforms through different

18     channels, some wore American boiler suits, camouflage, or single-colour,

19     it was complete -- a complete mess in this respect.

20             Is this correct?

21        A.   Well, there were many people fleeing from the army ranks and

22     throwing down -- throwing away their uniforms.  So you could find those

23     parts of uniforms.

24        Q.   Okay.  So now he talks about the withdrawal of the JNA --

25        A.   As soon as this began people started deserting, some of them,

Page 9046

 1     they went home.

 2        Q.   So he says after the JNA withdrew, the all-out attack from the

 3     Croatian-Muslim side started on the 13th and the 14th of June.  Do you

 4     know about this attack and the breakthrough from Capljina to Stolac and

 5     Mostar from the south?

 6        A.   Yes, I heard about that there were people talking about that.

 7        Q.   He says that the left bank of Mostar was defended by Serbs,

 8     territorials, who were not used to fighting and there was -- there were a

 9     lot of casualties, some people were wounded, some were killed, and there

10     was chaos?

11        A.   Yes, well the fighting started.

12        Q.   So he's talking about the withdrawal towards Vrapcici and Bijelo

13     Polje and he says at that time the Muslims attacked the command of the

14     Serbian army in --

15             THE INTERPRETER:  Could the accused please read slowly.  It is

16     impossible to interpret at this rate of speed.

17             JUDGE ANTONETTI: [Interpretation] I stopped you because the

18     interpreter was lagging behind.  Please continue.

19             MR. DUTERTRE: [Interpretation] Yes, it's hard to follow.  I will

20     have some very few brief questions in re-direct, so if we want to release

21     the witness, we should --

22             JUDGE ANTONETTI: [Interpretation] Well, Mr. Seselj keeps that in

23     mind.

24             THE ACCUSED: [Interpretation] Well, I will complete my

25     examination right now so that the Prosecution will have a chance to do

Page 9047

 1     the redirect.

 2             MR. SESELJ: [Interpretation]

 3        Q.   Could you please turn the next page and here Mr. Nedjeljko

 4     describes the chaotic situation.  Could you please move it a little bit.

 5             And then he says about the mass withdrawal from the whole Neretva

 6     valley, he says that for the most part all the houses in the Neretva

 7     valley were burned, that Serbs there were killed.  Have you heard about

 8     that, that all Serbs in the Neretva valley, all the Serbs that were found

 9     by the Croatian-Muslim forces?

10        A.   No, no, I haven't heard about that.  I didn't go there, I

11     couldn't go there.

12        Q.   And he says:  "Later on I learned that Muslims were killed in

13     this withdrawal, those who found themselves in the shelter in Zalik, and

14     for me and my colleagues this -- we took it as a great shame for us

15     because this had not been the practice of the Serb army that far.  He

16     says he doesn't know how many people were killed and we know why, but he

17     says that as far as he knew this was a reprisal for those who were killed

18     in Vrapcici by their fellow fighters and this was the consequence of the

19     chaotic situation and the absence of chain of command and the resignation

20     after the loss of positions."

21             So this is his explanation why this crime against Muslim

22     civilians occurred.  Do you think this lie as a basis, a motive, I'm not

23     trying to a justify a crime, a crime is a crime; but were those the

24     motives of the people who perpetrated the crimes?  What do you think?

25        A.   Well, I wouldn't say that.  I would be more in favour of saying

Page 9048

 1     it was genocide.

 2        Q.   Well, Mr. Bilic, if you say genocide, you have to know what this

 3     implies.

 4             MR. DUTERTRE: [Interpretation] The witness has answered.

 5             THE WITNESS: [Interpretation] That you would observe all over

 6     Bosnia.

 7             MR. SESELJ: [Interpretation]

 8        Q.   Well, this completes my examination.  I wanted to go into some

 9     other things, but in order to give some time to the Prosecution for the

10     re-direct, I will complete my examination now.

11             JUDGE ANTONETTI: [Interpretation] Thank you, Mr. Seselj.

12             Your re-direct, Mr. Prosecutor.

13             MR. DUTERTRE: [Interpretation] I shall be very brief.

14             JUDGE ANTONETTI: [Interpretation] Thank you in advance.

15                           Re-examination by Mr. Dutertre:

16        Q.   [Interpretation] I'm not going to refer to transcript pages.  You

17     heard the cross-examination.  You said that Serbs, Mr. Bilic, were

18     evacuated from the basement prior to the 13th of June, that's what was

19     said in cross-examination.  Could you tell us why -- why the Serbs did

20     not evacuate you as well, you and the Croats who were in the basements,

21     was it out of humanity?  Did --

22        A.   I didn't understand the question.

23        Q.   Why the Serbs did not evacuate you, as they did evacuate their

24     Serb fellow citizens?

25        A.   Well, we had already been taken to Sutina and there were just the

Page 9049

 1     women and children who remained there.  When I got back from Sutina I saw

 2     buses picking up Serbs and only women and children remained.  I saw the

 3     bus in front of the shelter, it was white, a large white bus and they

 4     headed up there towards Zijemlje.

 5        Q.   I understand.  So the Serbs being evacuated from the basement

 6     where you were, that happened on the day when you went to Sutina, is that

 7     how I should understand?

 8        A.   But when I got back from Sutina, that was one day and one night.

 9     Just before dawn I saw the bus taking away the Serbs, I saw them board

10     the bus to be taken away, and I saw them from my apartment because I had

11     already taken shelter in my apartment just around the corner.  That's

12     where I spent four days and four nights without anything to drink or

13     anything to eat.

14        Q.   And up until that day, had the shelter been shelled, had there

15     been artillery fire up until that day?

16        A.   No, after I got there, there was no shelling.

17        Q.   Okay, but had there been shelling until the day when you were

18     taken out of the basement to be taken to Sutina?

19        A.   Well, shells were falling up until that time.  We couldn't go

20     out.

21        Q.   Regarding this person who is -- who says he's a Seselj's man in

22     the basement.  When he said so, that he was a Seselj's man, how far were

23     you from him?

24        A.   Well, we sat right next to it.  There was a group of us.  We were

25     sitting next to him.  There were about ten of us there.  I wasn't alone.

Page 9050

 1        Q.   When you returned around the 14th, returned to your apartment --

 2             THE ACCUSED: [Interpretation] The previous question was

 3     tendentious.  Perhaps this soldier was Seselj's man in order to have

 4     success with women, not to fight a war.

 5             THE WITNESS: [Interpretation] Well, I don't know that.  You

 6     should ask him, not me.

 7             MR. DUTERTRE: [Interpretation]

 8        Q.   When you returned to your home after having spent the night of

 9     the 13th to the 14th in Sutina, you stayed there some time.  But tell us,

10     were the Serbs still there in Zalik, at around Zalik, or was the attack

11     of the Croatians already started?

12        A.   I was in a flat around the corner and they were still guarding

13     the north camp, and four or five days later, after they took away the

14     Serbs, after some four or five days, they came -- our people came from

15     the other side and came to the north camp and then the Serbs withdrew

16     with their vehicles and everything in the direction of Zijemlje and they

17     all withdrew, the civilians, the Serb civilians, and the soldiers as

18     well.

19        Q.   My last question.  When you were forced to do labour outside, was

20     there artillery shooting, was there shooting from the artillery or

21     shooting from snipers, yes or no?

22        A.   A shell would fall close to us, but nobody was actually targeting

23     us.  We were doing our job cleaning up, loading up on to a truck.

24     Sometimes our men would climb up on to the truck to make the garbage more

25     compact and they would fall from it and break their arm.  Things like

Page 9051

 1     that happened.  These were Vranica trucks belonging to the Vranica

 2     Construction Company from Sarajevo.

 3             MR. DUTERTRE: [Interpretation] I have no other questions.

 4             JUDGE ANTONETTI: [Interpretation] Witness, thanks to the

 5     Prosecution and to the Defence's help, we were able to finish today, you

 6     don't have to stay over the weekend.  I would like to thank you for

 7     coming to The Hague to testify, and I wish you a safe return home.

 8             And now talking to Mr. Seselj and to the Prosecution we have the

 9     witness scheduled for three days, and we will be sitting in the

10     afternoon.  Therefore, we meet again on Tuesday at 2.15 p.m.  I wish

11     Mr. Seselj's associates a safe return home also.  They came here to

12     attend this hearing today.  Thank you all, and we'll meet again on

13     Tuesday.

14                           --- Whereupon the hearing adjourned at 1.19 p.m.,

15                           to be reconvened on Tuesday, the 8th day of

16                           July, 2008, at 2.15 p.m.