Page 1202
1 Wednesday, 28
2 [Open session]
3 [The witness entered court]
4 [The accused entered court]
5 --- Upon commencing at 9.33 a.m.
6 JUDGE ROBINSON: We continue with the cross-examination by
7 Mr. Vucicevic.
8 MR. VUCICEVIC: Good morning, Your Honours.
9 WITNESS: WITNESS D [Resumed]
10 [Witness answered through interpreter]
11 Cross-examined by Mr. Vucicevic: [Continued]
12 Q. Witness D, we have stopped yesterday the -- when you took the
13 uniform and you were sent to the -- your first assignment. Could you tell
14 us where was that assignment?
15 A. My first assignment was at the checkpoint at the railway station.
16 Q. [Previous translation continues]... that checkpoint?
17 A. My shift lasted eight hours.
18 Q. How long did you stay as reserve policeman in Ljubija? From 29th
19 when did your duties cease to exist?
20 A. About one month, I don't know. I don't recall exactly.
21 Q. How many checkpoints were on the jurisdiction of Ljubija police
22 station?
23 A. I don't know.
24 Q. How many checkpoints did you serve on?
25 A. Always one and the same.
Page 1203
1 Q. So on April 30th you were on that one? On May 1st you were on
2 that one, weren't you?
3 A. Not on the 30th of April. Yes on May 1.
4 Q. [Previous translation continues]... on that checkpoint on May
5 1st?
6 A. The second shift.
7 JUDGE ROBINSON: Mr. Vucicevic, already I am seeing now for the
8 second time on the transcript "previous translation continues", which
9 means that you have asked a question before the translation of the answer
10 from the witness has been completed. So please, again, I ask that you
11 observe the pause.
12 MR. VUCICEVIC: Yes, Your Honour.
13 Q. [redacted]
14 [redacted]
15 A. In the evening -- that is, in the morning.
16 Q. Was that on the -- was that on the evening on May 1st or the
17 morning of May 2nd?
18 A. Morning of the 1st of May.
19 Q. What did he tell you during that meeting and what did you tell
20 him?
21 A. He told me that I should not leave the house until he gets there.
22 Q. You have testified already that he had arrived shortly thereafter;
23 isn't that correct?
24 A. Yes.
25 Q. I will ask you the question again: Once you met him, what did he
Page 1204
1 tell you and what did you tell him?
2 A. He told me that the Serbs had taken over the power, that the
3 Muslim and Croat policemen were sent home, that they were relieved of
4 duty. And I don't recall telling him anything, but we went together to
5 the Ljubija police station.
6 Q. [redacted]
7 [redacted]
8 A. No. At Ljubija.
9 Q. When did he sign that loyalty in Ljubija?
10 A. The last days of May or the first few days of June.
11 Q. What did he do from May 1st until the end of May, beginning of
12 June?
13 A. He regularly discharged his duties like other police officers.
14 Q. [Previous translation continues]... Ljubija?
15 A. Yes.
16 Q. So at that time, on May 1st, through the end of May or beginning
17 of June, it is fair to state that Serbs, Serb authorities, have not taken
18 control of police station in Ljubija?
19 A. Correct.
20 Q. Have you gone -- from April 29th to 22nd of May, have you gone at
21 all from Ljubija to Prijedor?
22 A. I don't recall exactly. As a civilian, yes. As a policeman, no.
23 Q. Did you drive your own car or you rode with somebody else?
24 A. On one occasion in someone else's car.
25 Q. And getting into the Prijedor, you had to pass through Tukovi?
Page 1205
1 A. Right.
2 Q. Notice any checkpoints in Tukovi?
3 A. Yes.
4 Q. Were you stopped at that checkpoint in Tukovi?
5 A. Yes.
6 Q. And what was the procedure at that checkpoint once you were
7 stopped?
8 A. They checked our documents and searched the car to -- for
9 weapons.
10 Q. Did you recognise any of the men manning that checkpoint?
11 A. Yes, Aziz Aliskovic.
12 Q. So that was a checkpoint that was on the jurisdiction of Ljubija
13 police station, wasn't it?
14 A. Yes.
15 Q. But before you came to Tukovi, you had to pass through Hambarine;
16 isn't that correct?
17 A. Yes.
18 Q. And there was also a checkpoint in Hambarine, wasn't there?
19 A. Below Hambarine, closer to Ljubija.
20 Q. What was the distance between checkpoints in Hambarine and
21 Tukovi?
22 A. Two kilometres.
23 Q. You testified yesterday that Mr. Aliskovic was in charge of that
24 checkpoint too. You testified that, didn't you?
25 A. Yes.
Page 1206
1 Q. Have you seen when you were stopped in Hambarine on any occasion
2 that Mr. Aliskovic was there?
3 A. Yes.
4 Q. Have you recognised any other men at checkpoint in Hambarine?
5 A. Yes. I knew them, but I don't recall their names.
6 Q. [Previous translation continues]... I'm going to ask you the
7 question, the question about their names. Have you noticed if there were
8 any Serbs among men on checkpoint in Hambarine?
9 A. No.
10 Q. So there were no Serbs?
11 A. No.
12 Q. And there were no Serbs on checkpoint in Tukovi?
13 A. Yes. Let's distinguish. The checkpoint at Tukovi and the
14 checkpoint below Hambarine were two separate check points.
15 Q. [Previous translation continues]...
16 A. And there was a checkpoint before Hambarine.
17 Q. And just to --
18 THE INTERPRETER: Microphone to the counsel, please.
19 JUDGE ROBINSON: Microphone, Mr. Vucicevic.
20 MR. VUCICEVIC:
21 Q. Just to make sure, you have also said a couple of minutes ago,
22 that there was about one kilometre distance between those two
23 checkpoints?
24 A. The checkpoint below Hambarine and the checkpoint before
25 Hambarine, on the other side, was one to two kilometres. The checkpoint
Page 1207
1 below Hambarine on the other side, between Tukovi, was also about two
2 kilometres.
3 Q. Were those men on all of these three checkpoints that you had to
4 pass through uniformed, or how were they dressed?
5 A. At that time there were a number of people wearing different
6 uniforms.
7 Q. What kind of uniforms did they have, if you could enlighten the
8 court?
9 A. Military, police, and civilian.
10 Q. When you said "military," what -- which military did they belong
11 to? Which military did this men belong to?
12 A. At that time, it was already the Serb military, and I concluded
13 that by the insignia on the uniforms.
14 Q. Let me just make sure that we are -- I want to assist you here.
15 You said earlier there were no men of Serb ethnicity to those -- at those
16 checkpoints. And now you're saying there were men in various uniforms and
17 those ones in military uniforms belonged to the Serbian army. That's a
18 little bit of a contradiction there. Would you clarify that?
19 A. Yes. The checkpoint below Hambarine, that means in the direction
20 Ljubija-Prijedor which was manned by the Serb police and the Serb
21 military. From that checkpoint, 1 to 2 kilometres across the Hambarine in
22 the direction of Prijedor was a checkpoint manned by the police. From
23 that checkpoint in the direction of Prijedor, there was a checkpoint at
24 Tukovi that was manned by the Serb police and the Serb military. And what
25 I forgot to say that between the two checkpoints, that is the checkpoint
Page 1208
1 below Hambarine, there was police and military that belonged to the TO.
2 MR. VUCICEVIC: Your Honour, with your permission, I think there
3 was so many checkpoints here and I have been there so many times, and I'm
4 just losing witness, you know, where those checkpoints are. But this is
5 very important. And with your permission, I would like to give him a map
6 so he can just indicate on the map where those checkpoints were and who
7 was where.
8 JUDGE ROBINSON: Yes.
9 MR. VUCICEVIC: If I may approach the ELMO so that I can indicate
10 the road that he is talking to so that he easily could point them out.
11 JUDGE ROBINSON: Yes, Mr. Vucicevic.
12 MR. VUCICEVIC:
13 Q. [Interpretation] This is a much larger scale than the rest;
14 Ljubija, Donja Ljubija. No this is Donja, and this is Gornja, upper and
15 lower Ljubija.
16 A. In this map I really cannot see anything.
17 Q. [Previous translation continues] [In English]... everything here,
18 maybe I am just showing to you to --
19 JUDGE ROBINSON: Yes, Mr. Mundis.
20 Hold on a minute, Mr. Vucicevic. There is an objection.
21 MR. MUNDIS: Yes, Your Honour, we object. It appears as though
22 counsel for Mr. Kolundzija may have crossed the line into testifying
23 himself at this point.
24 JUDGE ROBINSON: You are very close to that, Mr. Vucicevic.
25 MR. VUCICEVIC: Your Honour, I will show you, this is a map and
Page 1209
1 map is, on its face, neutral. Map does indicate it's bigger man than the
2 learned counsel has presented. There is all these geographic entities on
3 this map. I was barely showing the witness the road on that map so he can
4 point to assist the Court. You know, but witness was looking here and he
5 was looking on the ELMO and I said it's not on this map. Now it's on the
6 map.
7 JUDGE ROBINSON: Yes, but you cannot give the evidence. The
8 evidence must come from the witness.
9 MR. VUCICEVIC: Well, if the witness, you know --
10 JUDGE ROBINSON: Ask the witness the questions.
11 MR. VUCICEVIC:
12 Q. Sir, could you see on this map now --
13 THE INTERPRETER: Will the counsel please use the microphone?
14 MR. VUCICEVIC:
15 Q. -- Donja Ljubija, Gornja Ljubija --
16 JUDGE ROBINSON: Mr. Vucicevic, you have to go back because the
17 interpreters are not getting your questions, and bear in mind that we are
18 not trained in cartography.
19 MR. VUCICEVIC: Your Honour, neither am I.
20 JUDGE ROBINSON: Yes.
21 A. Your Honours, I can barely see this map, and the lighting is a
22 problem. But since I know the road quite well, that is, the one between
23 Donja Ljubija and Prijedor, I will repeat what I have stated.
24 My checkpoint was at the railroad station of Donja Ljubija, at the
25 bus station, that is. The next checkpoint was below Hambarine about 4 or
Page 1210
1 5 kilometres from the point where I was on duty. The next checkpoint on
2 the far side of Hambarine was about 1 to 2 kilometres farther away, and
3 one after that was in the direction of Prijedor at Tukovi, 3 to 4
4 kilometres away from the one below Hambarine, or about 7 to 8 kilometres
5 from the checkpoint where I was.
6 MR. VUCICEVIC:
7 Q. [Previous translation continues]... into the reserve police,
8 weren't you?
9 A. Yes.
10 Q. As a reserve policeman, you had to respond to emergencies; wasn't
11 that part of your duties?
12 A. Probably yes, but we didn't have that.
13 Q. [Previous translation continues]... without being able to respond,
14 you had to at least have minimal ability to read the maps of your own
15 town, weren't you?
16 JUDGE ROBINSON: Mr. Vucicevic, again, we are having on the
17 transcript "previous translation continues" in respect of the last two
18 questions, which means that you are asking your question before the
19 translation of the witness' answer has been completed. There will come a
20 time when the Court's patience will be worn, and you must try to cooperate
21 because we are not getting the translation of your questions. So we are
22 not getting the evidence. That's what it really means.
23 Are you now wearing the earphones?
24 MR. VUCICEVIC: Yes, I am.
25 JUDGE ROBINSON: Well, please wait for the translation of the
Page 1211
1 answers. Yes, continue.
2 MR. VUCICEVIC: Would, please, Court direct the witness to answer
3 the question.
4 JUDGE ROBINSON: What was the question, because the question was
5 not complete. Just rephrase it.
6 MR. VUCICEVIC:
7 Q. Sir, you were admitted into the reserve police and you had to
8 respond to the emergencies, and the part of those minimum abilities you
9 had at least to be in a position to read the map of your community,
10 weren't you?
11 A. Sir, I know the map very well. I did not say that I was unable to
12 read it, I just said that I could not see it.
13 JUDGE ROBINSON: Yes, let's move on.
14 MR. VUCICEVIC:
15 Q. You said that there were -- at some checkpoints, there were
16 military men who were Serbs, and at other checkpoints, there were military
17 men who were non-Serbs. Were those men, Serbs and non-Serbs, mixed on any
18 of those checkpoints?
19 A. Yes, at my checkpoint.
20 Q. But that was not -- your checkpoint was not the one on the road
21 from Hambarine to Tukovi that I was addressing, wasn't it?
22 A. No, but we also had mentioned my checkpoint.
23 Q. [Previous translation continues]... brings me to another point.
24 Do you know of any Serbs who have responded to mobilisation to JNA --
25 strike it. Do you know any Muslims who responded to mobilisation in
Page 1212
1
2
3
4
5
6
7
8
9
10
11
12 Blank page inserted to ensure pagination corresponds between the French and
13 English transcripts.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1213
1 September of 1991?
2 A. Yes.
3 Q. A lot of them responded, wasn't it true?
4 A. Not that many. There were some.
5 Q. And some of them went to serve in Croatia, wasn't that correct?
6 A. How do you mean to serve in Croatia?
7 Q. Serve their assignment in Croatia, if you know.
8 A. At that time one could not go to Croatia.
9 Q. I'm referring to September of 1991.
10 A. Correct.
11 Q. What is true -- just to correct the record, is it true that some
12 Muslims who put on the JNA uniforms went to serve in Croatia? Is that
13 answer -- what is your answer to that question?
14 A. You mean as military personnel, as soldiers to go to Croatia, to
15 the front line?
16 Q. Yes.
17 A. Yes.
18 Q. And some of them had military ranks, lieutenants, captains?
19 A. Correct.
20 Q. And some of them stayed throughout the years of warfare in Bosnia,
21 later in army of Republika Srpska, didn't they?
22 A. To my knowledge, all those who responded, the majority that is,
23 who at that time went to the front, after the return, did not go there any
24 more. I know officers, captains, reserve -- from the reserve force who,
25 after their return, took off their uniform and returned it -- that is, who
Page 1214
1 no longer went to the front.
2 Q. [Previous translation continues]... one or two or three that
3 didn't do it but stayed all the way until Dayton agreement?
4 A. No.
5 Q. So isn't it fair to say that on April 30th, that Serb authorities
6 took over the power in town of Prijedor only, while in town of Ljubija,
7 they didn't take over the power?
8 A. Yes.
9 Q. Isn't it fair to say that throughout month of May, there was a
10 demarcation line or, you know, territory -- was known who controls which
11 territory, which was marked by different checkpoints?
12 A. Approximately except for Ljubija, that is the settlement of
13 Ljubija itself, not counting the surrounding settlements.
14 Q. [Previous translation continues]... a few Serbian villages which
15 are located southwest or west from Ljubija?
16 A. Whether they were to the south or the southwest, I wouldn't know
17 but I can give you some villages such as Lyeskari, Miska Glava, those two
18 localities.
19 Q. You testified yesterday, you said that late Drago Tokmadzic was
20 from Lyeskari, wasn't he?
21 A. Correct.
22 Q. And that was a Serbian village?
23 A. Kalajevo is right next to Lyeskari, or rather it is 100 metres
24 distance, yes, that's quite right.
25 Q. And before the war everybody knew that, including yourself, that
Page 1215
1 Mr. Tokmadzic was a man from the mixed marriage? His mother was Serbian
2 and his father was Croat; wasn't that true?
3 A. Yes.
4 Q. But between Ljubija and Prijedor, there is village of Hambarine?
5 A. Yes.
6 Q. And you already testified that those checkpoints that were on the
7 line which was abutting the Serb-controlled territory were the checkpoints
8 manned only by non-Serbs, that's correct? You already said it.
9 A. It is below Hambarine.
10 Q. You have also testified yesterday there was no incidents, no
11 shooting, from either side, from April 30th through May 22nd; is that
12 correct?
13 A. Until the shelling of Hambarine, that's right, but the date, I
14 don't remember.
15 Q. You are a citizen of Bosnia and Herzegovina, and being a citizen,
16 you have heard that Bosnia and Herzegovina were recognised by certain
17 countries in the -- in April of 1992. Do you remember the date?
18 A. No.
19 Q. Jog your memory if I suggest it was on April 6, 1992?
20 A. Possibly. I don't know.
21 Q. Were they any military activities and casualties between the
22 various ethnic groups in Bosnia from April 6th through April 30th? And
23 I'm referring to any other municipality in Bosnia-Herzegovina.
24 A. I don't know.
25 Q. Those days, have you read newspapers?
Page 1216
1 A. Yes.
2 Q. Which newspapers have you read?
3 A. Don't remember.
4 Q. [Previous translation continues]...
5 A. May have.
6 Q. But you don't recall whether you ever, from April 6th through
7 April 30th, whether you ever in those days took the Kozarski Vyesnik in
8 your hands?
9 A. No, I do not remember.
10 Q. [Previous translation continues]... from Sarajevo? It was the
11 major daily paper from the whole state.
12 JUDGE ROBINSON: Yes, Mr. Mundis?
13 MR. MUNDIS: Yes, Your Honour, the Prosecution will object on
14 relevance grounds. We are prepared to give the Defence counsel some
15 leeway on cross-examination, but we fail to see how this has any relevance
16 with respect to the specific charges for which Mr. Kolundzija is charged
17 with respect to the Keraterm camp.
18 JUDGE ROBINSON: Yes. What's the relevance?
19 MR. VUCICEVIC: I can't help, Your Honour, when the shoe is on the
20 other foot, everything seems so different. The Prosecutor has alleged
21 there was a state of peacefulness in Bosnia and Herzegovina before the
22 aggression of the Serbs -- of Serb authorities happened in the
23 municipality of Prijedor on April 30th. I'm just testing that. That is
24 in the indictment and that is in their Pre-Trial brief, and I'm just
25 testing that premise. It's background, Your Honours. I would be happy
Page 1217
1 if --
2 JUDGE ROBINSON: We are consulting. The Chamber is consulting.
3 [Trial Chamber confers]
4 JUDGE ROBINSON: Yes, Mr. Vucicevic, the Chamber agrees it is of
5 some relevance to the case, but you are not to belabour the point. I mean
6 you have been cross-examining now for over an hour. So will you please
7 proceed and deal with this point fairly quickly.
8 MR. VUCICEVIC: Your Honour, I can lead on these because this is a
9 cross, after all.
10 Q. Witness, have you heard about the clashes, military clashes at
11 Ravno?
12 A. No. Not at that time. Now I know.
13 Q. In April of 1992 you never heard of them?
14 A. I did not.
15 Q. [Previous translation continues]... at Bosanski Brod?
16 A. No.
17 Q. Military clashes in Bijeljina?
18 A. Yes.
19 Q. And I'm directing your attention now to the time while you were a
20 policeman, and that's May. You heard about military clashes in Sarajevo
21 on 3rd of May?
22 A. Yes.
23 Q. You heard of military clashes in Tuzla on 13th or --
24 A. No.
25 Q. -- 14th of May?
Page 1218
1 A. No.
2 Q. So it is fair to say there were military activities in all other
3 areas of Bosnia by that time?
4 A. Possibly.
5 Q. And isn't it fair to say that Prijedor was the centre of
6 Yugoslavianism which was depicted by the famous slogan "Brotherhood and
7 Unity" in the communist times?
8 A. Yes, you could say so.
9 Q. And perhaps that is the reason why you were not interested what
10 was going on in the other areas in Bosnia and Herzegovina, because you
11 couldn't believe that ever the shooting is going to take place in
12 Prijedor?
13 A. It is true that I could not believe it.
14 Q. [Previous translation continues]...
15 A. Yes.
16 [redacted]
17 [redacted]
18 [redacted]
19 [redacted]
20 A. Yes.
21 Q. So the idea of brotherhood and unity did not break up completely,
22 but that part of unity broke up, but brotherhood, perhaps some people in
23 your community thought that Serbs and Muslims could still continue to be
24 brethren.
25 JUDGE ROBINSON: Mr. Vucicevic, that's -- it seems more a matter
Page 1219
1 of comment.
2 MR. VUCICEVIC: Your Honour, he has testified yesterday that there
3 was a gentleman who was a military officer, police officer, that brought
4 him food to Keraterm. And how am I going to, you know, going to get some
5 leeway please to relate it, to put it in right perspective. Because it
6 is -- witness here who can put it in right perspective. He lived there.
7 JUDGE ROBINSON: Proceed, but the question is so long that I
8 believe the witness will have difficulty understanding it.
9 A. I understood the question, and I can answer it. At that time it
10 required considerable courage to refuse to sign that loyalty. Had I had
11 the choice, I would have signed it too, but I never had that choice, which
12 does not mean that all those who signed it were not, afterwards, thrown
13 out and removed and dismissed from that same Serb police in Ljubija.
14 Q. [Previous translation continues]... that were in the military did
15 not have that fate. That didn't happen to them. They stayed in the
16 military throughout; isn't that correct?
17 A. You will have to ask Mehmed Captain First Class from Donja Ljubija
18 about that.
19 Q. Just with due respect, the Defence will bring the captain to
20 testify about this.
21 MR. VUCICEVIC: Let me just look at my notes, Your Honour.
22 Q. Did you have any desires to become a policeman while you -- when
23 you were a young man?
24 A. Perhaps I did.
25 Q. Did you ever made ahead -- went ahead and made application to the
Page 1220
1 police station to accept you as a policeman prior to this what had
2 happened prior to the outbreak of war?
3 A. Yes, when I finished doing my army service.
4 Q. [Previous translation continues]... what had happened with your
5 application?
6 A. I don't know. I simply handed it over. That was it.
7 Q. Was that before or after you went to vocational school to become
8 electrician?
9 A. When I finished my army service in 1984, maybe 1985.
10 Q. Witness, I would like to direct you to the question: When did you
11 finish your vocational school to become an electrician?
12 A. In 1982, 1983 is when I completed the training. I know what you
13 want to ask me. You can go to do your military service until the age of
14 27, and you could go to a six-month course and then become a regular
15 policeman.
16 Q. This is a third time I'm coming to this question: When did you
17 become an electrician?
18 A. In 1982-1983.
19 Q. When you applied to be a policeman, was that your first choice?
20 A. I mentioned 1984 to 1985.
21 MR. VUCICEVIC: I would kindly ask the Trial Chamber to direct the
22 witness to answer the question. The question was rather simple.
23 JUDGE ROBINSON: The question was: "When you applied to be a
24 policeman, was that your first choice?" What's your answer to that?
25 A. No, Your Honours. My first choice was the business, the art of
Page 1221
1 electrician. I said that in 1982-1983 --
2 MR. VUCICEVIC: Your Honour -- it's in the record. We have to
3 move on.
4 Q. When -- while being interested to become a policeman, have you
5 heard that police in those days were beating people while in their
6 custody?
7 A. No.
8 Q. So when did you hear the phrase that in order to be admitted for
9 the medical treatment that you have to say instead, "Police had beaten me
10 up," instead, "I fell off the truck," or "... fell from the car." When
11 did you hear that phrase?
12 A. I concluded when in the camp itself that it was better to say that
13 you'd fallen off a vehicle rather than you had been beaten. And I also
14 heard from other inmates that that was better than -- a better answer than
15 the other one.
16 Q. When you were in the camp, there were no trucks, there were no
17 cars there, were they?
18 A. But it wasn't only when you had to go to the hospital, it was for
19 all occasions. If a guard asked what was the matter with you, it was much
20 better to say that you'd fallen than that you'd been beaten.
21 Q. You used the word "fallen." When you testified yesterday you said
22 when you were taken out, first you said you were hit and you fell, and in
23 cross-examination, you said that you lay down, that you didn't fall. So
24 which is true? Or explain what's the difference between laying down and
25 falling?
Page 1222
1 A. Well, to lie down, you have to fall down first. Depends on the
2 situation. If one goes to bed, then one lies down of his own will, but if
3 on such an occasion, one lies down to the ground, then it must mean that
4 he fell down. One can also fall down of his own will, that is lie down of
5 his own will, but if one is first hit, then he will fall and then he will
6 lie down. But I didn't lie down in the sense that you mean. I crouched.
7 Rather, I lent -- I leaned against a wall to protect at least one side of
8 my body.
9 JUDGE ROBINSON: Mr. Vucicevic, please move on.
10 MR. VUCICEVIC: Your Honour, I think this is a very important
11 point because the witness is using inconsistencies in his testimony which
12 do not have any explanation so far. I think you know that it's him to
13 explaining how did it all happen. It's very important because it bears on
14 credibility of entire testimony.
15 JUDGE ROBINSON: Yes. We will assess the credibility.
16 MR. VUCICEVIC:
17 Q. You were hit by Dusan Knezevic, Duca. How tall was he when he was
18 standing in front of you?
19 A. He stood underneath. That is, I was on the threshold of the door
20 at the time when he hit me. He could be, I should say, one metre 80, one
21 metre 90, give or take a few.
22 Q. He is up at one metre 90? Knezevic is one metre 90?
23 A. No, not that tall.
24 Q. Could it be that he is 175?
25 A. Perhaps. I didn't measure him.
Page 1223
1
2
3
4
5
6
7
8
9
10
11
12 Blank page inserted to ensure pagination corresponds between the French and
13 English transcripts.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1224
1 Q. [Previous translation continues]... numbers are not important.
2 The important is when he stood below --
3 A. Why do you ask me?
4 Q. When he stood below you, how far up to you did he come here? You
5 can just show. Was he up to your chin, up to your chest here? How high
6 was he up to you?
7 A. Up to my chest.
8 Q. Okay. So when he took the baton to hit you, which hand did he
9 hold that baton in?
10 A. Right.
11 Q. And could you just point exactly what part of the head did he hit
12 with -- did he hit you on, with one finger, please?
13 A. [Indicates].
14 Q. So the baton went, as you showed, horizontally, didn't it?
15 A. I don't know.
16 Q. So that means the hit was hard indeed, wasn't it?
17 A. What that means, sir, is that he beat me good, that I was all
18 battered up. And I am not the only one who speaks about that. Quite a
19 number of people who were in the same room with me know about that. And I
20 cannot tell you exactly, but I can describe it, if the Honourable Court
21 permits me to do so.
22 Q. [Previous translation continues]... standing here and in deep
23 sympathy what had happened to you. I think any --
24 A. No. If you sympathise with me, you would have spared me such
25 questions.
Page 1225
1 Q. I'm merely trying to establish what had happened, because at the
2 time, sir, even being a witness or perhaps being innocently accused, it is
3 a function of this court to examine the facts, and facts are words which
4 are logically connected, and when you testify, with all sympathy to all
5 what you went through, it is still important to remember --
6 JUDGE ROBINSON: Mr. Vucicevic, will you please spare us the
7 speech and continue with your cross-examination? And try to bring it to a
8 close as quickly as possible.
9 MR. VUCICEVIC:
10 Q. So you -- if you don't remember how he hit you, you don't remember
11 how you fell down, do you?
12 A. I do remember it well, how he hit me and how I fell.
13 Q. Were you standing up when he hit you? Or you were beginning to
14 already lay down? You were in the process of kind of lowering yourself
15 down? In which position, standing up or you are slowly going down as he
16 was taking a swing at you?
17 A. Your Honours, may I show it?
18 JUDGE ROBINSON: Yes, yes.
19 A. [Witness stands up] When we were called out, or rather when we
20 were told that four men should come out --
21 MR. VUCICEVIC: Your Honours, the witness should show, not just
22 give a speech.
23 JUDGE ROBINSON: Yes, but he has to be able to explain what he's
24 showing.
25 MR. VUCICEVIC: Yes, Your Honour.
Page 1226
1 JUDGE ROBINSON: For it to be intelligible.
2 A. I was standing in the doorway. Duca was in front of me. He hit
3 me with his baton here. I turned and fell down next to the open door and
4 I leaned against a wall and I was in this position, and he then continued
5 to hit me on the head. From time to time I would manage to shield my head
6 with my hands but then he would beat me here. And from different sides,
7 others approached and kicked me in the head, around my kidneys, in the
8 stomach, on the chest. And I had a feeling that Duca was talking to
9 someone and beating me with his baton on the head as I was -- as I went
10 into the crouching position and then, as I -- and then as I lay down on
11 the ground.
12 JUDGE ROBINSON: That's a visual and dramatic explanation. Let us
13 see whether we can conclude this part of the evidence now.
14 MR. VUCICEVIC:
15 Q. How big was -- you're a big man.
16 MR. VUCICEVIC: Could we just have a closed session?
17 A. Correct.
18 MR. VUCICEVIC: Or a private session?
19 JUDGE ROBINSON: Yes.
20 MR. VUCICEVIC: Only for one minute, quickly.
21 [Private session]
22 [redacted]
23 [redacted]
24 [redacted]
25 [redacted]
Page 1227
1 [redacted]
2 [redacted]
3 [redacted]
4 [redacted]
5 [redacted]
6 [redacted]
7 [redacted]
8 [redacted]
9 [redacted]
10 [redacted]
11 [redacted]
12 [redacted]
13 [Open session]
14 JUDGE ROBINSON: Thank you, Mr. Vucicevic.
15 Re-examination, Mr. Mundis?
16 MR. MUNDIS: Just a few questions, Your Honour.
17 Re-examined by Mr. Mundis:
18 Q. Witness D, in response to questions from Mr. Rodic, the Defence
19 counsel for Dosen, you indicated that both Damir Dosen and his brother
20 were known by the nickname of Kajin. Do you recall testifying that?
21 A. Yes.
22 Q. Now, just to clarify, when you were at Keraterm, you testified
23 that Kajin was a shift commander; is that correct?
24 A. Correct.
25 Q. Which one of the Dosen brothers were you referring to as the shift
Page 1228
1 commander?
2 A. Damir.
3 Q. And is that the person that you saw in the courtroom and
4 identified yesterday?
5 A. Yes.
6 Q. Now, the time when you were being beaten and you called out for
7 assistance, your testimony was that you called to Pilip and Kajin to come
8 to your assistance. Do you remember testifying about that?
9 A. Correct.
10 Q. And the person that you testified came to your assistance was, in
11 fact, Kajin; is that correct?
12 A. Correct.
13 Q. Which Kajin were you referring to who came to your assistance at
14 that time?
15 A. I was referring to Damir.
16 Q. And that's also the person that you identified and recognised in
17 the courtroom?
18 A. Correct.
19 MR. MUNDIS: Thank you, Witness D. The Prosecution has no further
20 questions.
21 JUDGE ROBINSON: Witness D, that concludes your testimony. You
22 are released.
23 THE WITNESS: [Interpretation] Thank you, Your Honours.
24 [The witness withdrew]
25 JUDGE ROBINSON: Yes Mr. Ryneveld?
Page 1229
1 MR. RYNEVELD: Thank you, Your Honour. Before calling the next
2 witness, could we go into private session very briefly? Because I'm going
3 to be making an application for this witness to be given protective
4 measures even though he has not been part of the application for
5 protective measures earlier. The reasons therefore unfortunately will
6 have to be in private session, if we may.
7 JUDGE ROBINSON: Yes, yes.
8 [Private session]
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 1230
1
2
3
4
5
6
7
8
9
10
11
12
13 Page 1230 redacted private session.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1231
1 [redacted]
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 [Open session]
Page 1232
1 MR. RYNEVELD: Just one other comment, if I may, and that is that
2 it may be that counsel may want to refer to other witnesses on the list by
3 name. It's the familial relationship that causes the damage. In other
4 words, we haven't edited out the names of people, because the names of
5 people mean nothing unless people know that certain of those names people
6 are, in fact, witnesses here. So if reference to their familial status
7 could be avoided in the course of reference to them, I believe that many
8 of the redactions wouldn't be necessary and we may also be able to conduct
9 more of these in open session.
10 JUDGE ROBINSON: Yes.
11 MR. RYNEVELD: Is Witness E being brought in? Thank you.
12 [The witness entered court]
13 JUDGE ROBINSON: Yes, let the witness take the declaration.
14 THE WITNESS: I solemnly declare that I will speak the truth, the
15 whole truth, and nothing but the truth.
16 WITNESS: WITNESS E
17 [Witness answered through interpreter]
18 MR. RYNEVELD: Mr. Usher, could you please show the witness a
19 document that is now being handed to you.
20 Examined by Mr. Ryneveld:
21 Q. First of all, Witness, I'd like you to look at that piece of
22 paper. Do you see your name -- don't tell us what it is -- but do you see
23 your name on that piece of paper and your birth date?
24 A. Yes.
25 Q. Yes. And you see that behind your name and birth date that you
Page 1233
1 will be referred to as Witness E; is that correct?
2 A. Yes.
3 MR. RYNEVELD: Might this be marked as the next exhibit, please,
4 Your Honours.
5 THE REGISTRAR: Prosecution Exhibit number 15.
6 MR. RYNEVELD:
7 Q. Now, Witness E, I understand, sir, that you are of Muslim
8 ethnicity, and you were born at a small village near Sarajevo; is that
9 correct?
10 A. Yes.
11 Q. While you were still very young, I understand you and your parents
12 moved to Prijedor; is that also correct?
13 A. Yes.
14 Q. You completed your schooling, and after your schooling you worked
15 for about four years in a furniture shop in Prijedor; is that correct?
16 A. Yes.
17 Q. And you did your compulsory military service with the JNA, and you
18 were discharged from that on the 5th of September when you became a member
19 of the reserve until 1983; is that correct?
20 A. Just a small correction regarding the date. It's 5th September.
21 The rest is correct.
22 Q. Thank you. I thought I had said that. But until the 5th of
23 September 1979. And then in 1983, because of an injury to your arm, you
24 were declared incapable of further military service and you were no longer
25 in the reserve as well; is that correct?
Page 1234
1
2
3
4
5
6
7
8
9
10
11
12 Blank page inserted to ensure pagination corresponds between the French and
13 English transcripts.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1235
1 A. Yes, that is correct.
2 Q. I understand, sir, you went to work as a welder in Croatia for a
3 number of years until 1991 and then you returned to Prijedor where you
4 were on the 1st of May when something happened in 1992?
5 A. Yes.
6 Q. On the 1st of May 1992, sir, I understand that you were in
7 Prijedor when the Serb forces took over control of that town; is that
8 right?
9 A. Yes.
10 Q. And you knew that the police station and all the important
11 buildings, including the railway station and government buildings had been
12 taken over by the Serbs?
13 A. Yes, that was announced on the radio.
14 Q. And do I understand, sir, that when that was completed, there
15 would be a Serbian flag flying over the building as well?
16 A. Yes.
17 Q. And you say you heard it on the radio. Was it also on
18 television?
19 A. We could rarely watch television. There was -- there were power
20 outages, but we could transistor radios when we had batteries.
21 Q. Now, prior to the takeover, sir, is it fair to say that the
22 ethnically mixed community would live peaceably side by side?
23 A. Yes, at first.
24 Q. And there were many mixed marriages?
25 A. Yes.
Page 1236
1 Q. I understand that changed after the takeover; is that correct?
2 A. Yes.
3 Q. Now, sir, about a month later, towards the end of May 1992, I
4 understand that you and your brother were taken into custody; is that
5 correct?
6 A. Yes.
7 Q. And the people that took you into custody were dressed in uniform?
8 A. Yes.
9 Q. What kind of -- did you recognise any of the people that took you
10 into custody?
11 A. I did not know them.
12 Q. Did you know what ethnicity they were?
13 MR. VUCICEVIC: Objection to the question. It calls for
14 speculation. If he didn't know them, he wouldn't know their ethnicity.
15 MR. RYNEVELD: I'll move on.
16 JUDGE ROBINSON: Yes.
17 MR. RYNEVELD:
18 Q. Sir, you've told us about listening to the radio. Did you receive
19 any instructions via the radio announcement as to a manner in which one
20 could show loyalty to the Serbs?
21 A. Yes.
22 Q. What was that?
23 A. They told us on the radio that we should wear a white armband
24 around our left arm and that would show the loyalty to the Serbs.
25 Q. When you were being arrested, sir, could you tell whether you and
Page 1237
1 your brother were the only people being arrested or was it happening to
2 neighbours as well?
3 A. They gathered us all, all of us who were there. They said that we
4 should take our jackets with us, that we would be there for questioning
5 for two or three days and then we would come back.
6 Q. And could you see what was happening to some of your neighbours as
7 they were being arrested?
8 A. I don't understand the question. I don't know exactly.
9 Q. All right. After you were arrested, were you transported
10 somewhere, and if so, on what?
11 A. They gathered us from your homes and made us run down, followed by
12 these transporters, to the buses. When we came to Osmana Dzafica,
13 soldiers said, "Pull out everything you have in your pockets, as well as
14 watches and jewellery and money," and some of them were hit there. And we
15 were transported -- they put us in buses, and that is how they transported
16 us to the barracks.
17 Q. Did anything happen to you personally as you were being placed on
18 the bus?
19 A. Yes.
20 Q. What was that?
21 A. One of them, a soldier, had a hunting rifle. He said, "Open your
22 mouth." I did. And he put the barrel in my mouth and he pulled the
23 trigger, but the -- it was empty, and he said, "Don't be afraid, don't be
24 afraid. It's empty."
25 Q. How did you react to that incident at the time?
Page 1238
1 A. Well, nothing -- I was scared but I was calm. Had I made any
2 move, who knows what would have happened.
3 Q. Now, how many people were being gathered and placed on these
4 buses?
5 A. About 150 to 200 people. We did not count, so I don't know
6 exactly.
7 Q. Did you recognise -- did you know the people that were being
8 gathered along with you and your brother?
9 A. Yes. These were my neighbours. We knew each other in this local
10 commune. Almost all of us knew each other.
11 Q. This local commune where you lived in, I take it that's sort of a
12 neighbourhood or a suburb of Prijedor, is it?
13 A. Yes.
14 Q. And was it mixed ethnicity in that commune or neighbourhood, or
15 was it largely dominated by one particular ethnicity?
16 A. The majority of the population was Muslim.
17 Q. And these people that were being herded on to the buses, do you
18 know what ethnicity they were?
19 A. They were all Muslims.
20 Q. You said you went to the military barracks; where are those?
21 A. It was at Urije, on the road to Bosanska Dubica, on the left-hand
22 side.
23 Q. Now, this location that you named, is that also still in the area
24 of Prijedor or is it outside of Prijedor?
25 A. It is all the territory of Prijedor, as Donja Purharska, the local
Page 1239
1 commune is, the Urije. This area was called Urije from as long as I can
2 remember.
3 Q. I appreciate that and it's my question that's at fault. I
4 understand that there is an opstina Prijedor which takes in a whole large
5 territory with lots of villages, and then there is the town of Prijedor.
6 Was it within the town of Prijedor, this location that you mentioned, the
7 military barracks?
8 A. The centre of town is what we are referring to as town, and the
9 edge of town was the settlements that were about two and a half to three
10 kilometres away from the barracks. Later they renamed it Prijedor 1, 2, 3
11 and 4. Donja Purharska was Prijedor 2, and I don't know exactly where
12 Urije was.
13 Q. All right. When you went to the military barracks, did you get
14 off the buses or did anything happen there?
15 A. We -- at that time, we did not get off the buses. They were
16 waiting for us and then they took us to Omarska.
17 Q. On the same buses?
18 A. Yes.
19 Q. And how long did it take to get to Omarska?
20 A. To be honest, I don't know exactly. I cannot say because in that
21 fear, we did not know where we were and what was going on.
22 Q. Was Omarska far away?
23 A. It is about 18 kilometres away from Prijedor.
24 Q. And the buses drove straight to Omarska, did they? And by that I
25 mean they didn't stop along the way?
Page 1240
1 A. Yes, they did not stop.
2 Q. When you got to Omarska, were you let off the buses, or what
3 happened there?
4 A. They told us to wait and then some people came and said that we
5 couldn't go there because Omarska was full and they had to take us back,
6 so then they took us back. They took us back to Keraterm.
7 Q. And when you say "back to Keraterm," do you say that because
8 Keraterm is on the outskirts of Prijedor?
9 A. Yes. That is near the sign which marks the city limits.
10 Q. So Prijedor is on the inside of the city limits of Prijedor on the
11 way to Banja Luka; is that fair to say? I'm sorry, I meant to say
12 "Keraterm."
13 A. Yes.
14 Q. All right. Sir, I understand that you arrived at Keraterm still
15 the same day that you were arrested?
16 A. Yes.
17 Q. And just so we are clear, we are talking about the 31st day of
18 May, 1992?
19 A. Yes.
20 Q. What happened when you got there?
21 A. When we arrived they told us to get off the buses and then they
22 lined us up against a wall, made us lean against a wall, then they
23 searched us. There were a number of men, I don't know how many -- I don't
24 know how many men were searched at the time and when one group was done,
25 then they would call another and so on.
Page 1241
1 Q. And at the time you were searched, did anything happen to you or
2 the people who were with you being searched?
3 A. They searched everyone. I had nothing on me. A fireman had a
4 small knife so they started beat him. "Is this what you're going to use
5 to beat Serbs?" I don't know what else they were saying to him. But
6 later on, they gave him what they were calling a special treatment. I
7 think is what they were saying.
8 JUDGE ROBINSON: Mr. Ryneveld, we come to the break now.
9 MR. RYNEVELD: Thank you.
10 JUDGE ROBINSON: We will take the break and resume at 11.30.
11 Witness E, you are not to discuss your evidence with anybody,
12 including members of the Prosecution team.
13 We are adjourned.
14 --- Recess taken at 11.02 a.m.
15 --- On resuming at 11.30 a.m.
16 JUDGE ROBINSON: Yes, Mr. Ryneveld.
17 MR. RYNEVELD: Thank you, Your Honour.
18 Q. Now, Witness E, we -- just before we broke, you were telling us
19 that you had arrived at Keraterm. Do I understand correctly, sir, that
20 after you were searched, you were placed in one of the rooms at Keraterm?
21 Do you remember which room you went to first?
22 A. It was the largest room there, straight ahead. A large room that
23 you walk in, walk into directly with a big door, and to the left there was
24 another one.
25 Q. All right. And how long did you stay in that room?
Page 1242
1 A. We stayed there for about 15 or maybe 20 days, I'm not sure, until
2 they interrogated us. And after we would be interrogated, then they would
3 move to us a different room.
4 MR. RYNEVELD: All right. Might the witness be shown a
5 photograph, Exhibit 2, please.
6 Q. Perhaps, Witness, if I could have your attention directed to
7 photograph 2B. First of all -- I'm waiting for the image to come to the
8 ELMO. All right.
9 First of all, do you recognise the scene in that photograph, sir,
10 as something that you're familiar with?
11 A. Indeed, that is Keraterm.
12 Q. And this first room that you were placed in, you say the one that
13 was the largest room, do you see that in this photograph that you
14 identified as being of Keraterm?
15 A. Yes.
16 Q. Would you take the pointer, please, and show Their Honours,
17 please, which of the -- or where the room is that you were first placed
18 in?
19 A. [Indicates].
20 Q. All right. And then you were -- you say you were interrogated.
21 And after you were interrogated, you were placed in yet another room;
22 which room is that? Would you point that out for us.
23 A. Right, it's this one here.
24 Q. You are pointing to the room that has the large doors immediately
25 to the left side of the building; is that correct?
Page 1243
1 A. That's right, yes.
2 Q. And the first room you were placed in was to the right of that
3 room?
4 A. Right, yes. Except that this is a different door. It didn't look
5 like this then.
6 Q. All right. By the photograph now, the doors look different now
7 than they did in 1992; is that what you're telling us, sir?
8 A. Yes. Yes.
9 Q. The location of the rooms are the same?
10 A. Yes, that is all the same.
11 Q. Did you know when you were there, did you know these rooms by any
12 particular designation such as a number, for example? Did you refer to
13 them by any number?
14 A. Later on when four rooms were set up, then they became Rooms 1, 2,
15 3, and 4. At first only this larger room existed, but later on all these
16 others were set up and those who were interrogated were taken to Room 1,
17 and after a certain period of time to Room 3 too.
18 Q. Okay. So this first room that existed, the larger room, what did
19 that eventually become known as?
20 A. One.
21 Q. Just so that I'm clear, the very first room that you went to, the
22 larger room, the one that you say was to the right of the first room, what
23 did that become known as?
24 A. Number 2.
25 Q. All right.
Page 1244
1 A. That was later on.
2 Q. All right. So a room that was later on referred to as Room 2,
3 that's where you went first, then were you interrogated, then you went to
4 Room 1; is that correct? Do I understand you?
5 A. That's right.
6 Q. Did you stay in Room 1 for the balance of your detention at
7 Keraterm or did you go to another room later?
8 A. Later, no, I didn't spend most of my time there. I -- the longest
9 period of time I spent in number 4. That was a room that was turned into
10 a military prison, mostly for Serb soldiers, that is, who had got drunk or
11 done something, and that is where they were kept. But then later on,
12 because we were too many, because the first two and the third room were
13 overcrowded, then they put us in Room 4, and the military prison was
14 transferred behind the building.
15 Q. All right. Now, you went to Room 4. You were there with a number
16 of other prisoners; is that correct?
17 A. Yes.
18 Q. You talked about the rooms being overcrowded. How many prisoners
19 were in the room that you determined to be overcrowded?
20 A. Well, this large one that we referred to as number 2, it had some
21 500 or -- men in it. I mean, one couldn't really breathe properly because
22 people were sweating, perspiring, there was no ventilation, there was
23 nothing. And as they were bringing in other people, it was getting more
24 and more crowded. They had to open another room then.
25 Q. How about the conditions in Room 1, in terms of being crowded?
Page 1245
1
2
3
4
5
6
7
8
9
10
11
12 Blank page inserted to ensure pagination corresponds between the French and
13 English transcripts.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1246
1 A. Much better. The conditions were much better because one could
2 open the door, so that we did not have any problems of that kind there.
3 One could breathe easier. It was much better when compared to the other
4 one.
5 Q. Were there any particular kinds of prisoners housed in these
6 different rooms? In other words, were the prisoners in Room 1 different
7 from the prisoners in Room 2 or 3 or 4?
8 A. Yes. It was -- they were, the first two rooms, number 1 and
9 number 2, that is first number 2 and after interrogation, people will be
10 put in number 1, and as they were bringing in new people, they began to
11 transfer them. And then suddenly they began to bring in people from
12 Kozarac, and so they opened number 3, and that was overcrowded and they
13 were transferring to Room 1, to Room 2, to 3, and then they had to empty
14 that depot, and then they transferred the prison behind and they again
15 sent us there. That is, they asked us who wants to go there. And then we
16 did apply to go to that room, my brother and I, and some others. We said
17 we would go there. I mean, to Room 4. And that is where we went.
18 Q. All right. Let's move on, sir. While you were at the camp, can
19 you tell us whether anything happened at the camp to the prisoners, that
20 you could see or hear?
21 A. Yes.
22 Q. What kinds of things did you see or hear happening to prisoners
23 while at the camp?
24 A. They had made a penal group. There were some pallets as you
25 entered Room 2; three, four, five pallets. And when I came, yes, they
Page 1247
1 would take it out on various prisoners, doing to them all sorts of
2 things. That is how -- what it was like in the beginning.
3 Q. I'm sorry to ask you to be specific about doing all sorts of
4 things. What do you mean when you say they were doing all sorts of things
5 to prisoners? What did they do to them?
6 A. Beat them, and what do I know. That little Car was killed. It
7 was Duca and Ziga. They beat him with a rifle and the machine-gun
8 somewhere on the road to Bosanski Novi, and he was caught there and they
9 wanted him to show them how he had carried this machine-gun. They forced
10 him to run with it and then to crawl with it. And then they were beating
11 him. And at some point he simply fell down on the ground, and then Duca
12 and Ziga hit him with their feet all over the body. And then he was lying
13 on the ground, and then they took him -- he was carried into one of the
14 rooms, and the next day he died.
15 Q. Did you see this incident yourself, sir?
16 A. I did, yes, because it was right opposite the door and the door
17 was open.
18 Q. Was this in the daytime or at night?
19 A. Daytime.
20 Q. Who did you see beating him?
21 A. I saw Zigic and Duca.
22 Q. Did you know Zigic from before your internment at Keraterm?
23 A. Yes.
24 Q. How did you know him?
25 A. For a while we were together involved in youth brigades and then
Page 1248
1 he became a taxi driver and I worked in the field. And at times when I
2 would see him there, when I came into that town, then I would ask him to
3 take me to a hotel. If I went to the hotel, of course, I would pay the
4 fare to him always. He lived in Cirkin Polje.
5 Q. How about this man that you referred to as Knezevic? Do you
6 remember his full name?
7 A. I don't. I don't even know him. I mean, I did not know him
8 before. I only could hear them say or shout out, "Duca is on his way."
9 Q. And did you see Duca participate in this matter as well, in the
10 beating?
11 A. The two of them did it together, he and Zigic.
12 Q. Was it only Zigic and Duca or were there other people involved?
13 A. I cannot remember exactly because nine years is not a short period
14 of time. The two of them simply stuck in my memory because I saw them
15 personally.
16 Q. Now, I heard you make reference to a machine-gun and crawling.
17 I'm not quite sure exactly what you said about that. Perhaps you could
18 indicate to us what you saw in relation to what Car was doing while Duca
19 and Zigic were beating him?
20 A. They gave him a machine-gun to carry and run in a circle carrying
21 it. And after that, they told him to go down on his fours and to crawl
22 with it around, with that machine-gun. And as he did that, they beat him
23 and kicked him and yelled at him, "How you've come here to kill Serbs," I
24 can't really remember their words they used.
25 Q. All right, sir. I'm going to turn to another incident. In your
Page 1249
1 stay at Keraterm, did you become familiar with the names or did you know
2 any individuals by the name of Banovic?
3 A. I did not know them personally before. I only heard that they
4 were called Banovics in the camp and that they were twin brothers, but
5 they were different.
6 Q. How -- were you able to tell them apart?
7 A. Yes.
8 Q. Were there some unique features about any one of them that allowed
9 you to tell them apart?
10 A. Yes. One of them had long hair and was nicknamed Cupo, and the
11 other one had short hair and had an earring. They were not all that
12 alike.
13 Q. So from that statement, do I assume that they were not identical
14 twins but fraternal twins, if you know?
15 A. Yes. They were fraternal twins, that is what I heard. I do not
16 have any knowledge of that, but their likeness was not all that big. I
17 mean one couldn't really say immediately that they were twins.
18 Q. Sir, you referred to an individual by Cupo that you referred to.
19 Did you see him do anything to anyone while you were at Keraterm?
20 A. Yes.
21 Q. What?
22 A. He was the one who beat. He had a baseball bat, and he beat some
23 prisoners from Kozarac. And then once as we went for lunch, he took out a
24 knife and pricked him in his left leg, in his left thigh.
25 Q. Maybe I don't understand your answer, but you said he took out his
Page 1250
1 knife and pricked him. To whom are you referring when -- who did he prick
2 with the knife, if anyone?
3 A. Yes. An inmate. I don't really know who that was, because there
4 were people whom I did not know, whom I'd never seen before.
5 Q. Did I understand you correctly that that knife incident happened
6 while people were on their way to lunch, or did I misunderstand you?
7 A. Yes. Yes. Right. That is, if one can call it lunch, because we
8 would get something to eat only once a day around 7.00 in the evening and
9 we called that lunch. So it was on our way to lunch when that happened.
10 Q. Thank you, sir. Sir, while we're still talking about Cupo, did
11 you know someone by the name of Jovo who was also with you in Room 4?
12 A. I did not know him before, because he lived somewhere up in
13 Ljubija so that I did not know the man. But he was brought to the camp,
14 and they put him in Room 4.
15 Q. Do you recall what happened to Jovo, if anything, while you were
16 in Room 4 with him?
17 A. I don't understand.
18 Q. Let me rephrase the question. Did something happen to Jovo that
19 you can tell us about today, sir?
20 A. Yes. I don't know when it was when they called him out, but I
21 think he was a very short time there, and the same day he was brought in
22 there they called him out. He went out and they beat him, and beat him,
23 and beat him. And after that, they put him back inside, and I think it
24 was the same Cupo Banovic who had called him out. And then they shouted,
25 "That is how we punish Serb traitors."
Page 1251
1 Q. Where was Jovo beaten, in terms of location?
2 A. I couldn't see it all, but they were beating him from between
3 number 1, that is where they had taken him and then all the way down to
4 number 4.
5 Q. Did you personally see this beating, sir?
6 A. I saw Banovic hit him with that baseball bat.
7 Q. As a result of that beating, do you know what happened to Jovo?
8 A. I think that he died shortly afterwards.
9 Q. Did you know someone with a nickname of Faca?
10 A. Yeah. That is, I didn't know him. I never met him so I don't --
11 I don't know him. I don't even know what his real name is. But since he
12 came to the camp at Keraterm, as he would come, somebody would point a
13 finger at him and say, "What's up Faca?" "Faca come over here," and then
14 he would slap somebody in the face.
15 Q. Was Faca an inmate of the camp or was he a visitor or a guard, or
16 do you know?
17 A. He came to the camp from time to time, and at times he also came
18 with his dog there.
19 Q. And when he came to the camp, apart from slapping people in the
20 face, did you see him do anything else?
21 A. I did not see him do anything else. But I heard from a friend who
22 lived in Brezicani that he had killed his relative, that is, this friend
23 of mine told me that he had seen him kill him in the -- in a lavatory, but
24 I did not see that. I don't know.
25 Q. When this Faca came to the camp, you told us that he would
Page 1252
1 sometimes slap people in the face; is that correct?
2 A. Yes.
3 Q. How often did he come to the camp?
4 A. I couldn't really say. He did not come all that often, perhaps a
5 few times. Well, not a few, several times.
6 Q. I'm not trying to press you on the matter, sir, but sometimes we
7 don't know what "few" or "several" means. Are you able to attach a
8 approximate number to "few" or "several", or if not, I'm not asking you to
9 speculate?
10 A. Well, several times is when I -- I mean, four, five, six times.
11 Q. All right. And apart from slapping people in the face, did you
12 see him do anything else in relation to prisoners?
13 MR. GREAVES: Your Honour, he's been asked that question and he's
14 already answered it in the negative. He did not see him do anything else,
15 which is at line 11:53:06.
16 MR. RYNEVELD: It matters not. I'll move on.
17 JUDGE ROBINSON: Please move on.
18 MR. RYNEVELD: Certainly.
19 Q. Just returning, if I may, to one thing that I forgot to ask you
20 when we were talking about Jovo. You gave the opinion that you think he
21 died. What drew you to that conclusion, sir? What did you see or hear
22 that led you to the conclusion that Jovo died from that beating?
23 A. We saw that he was not breathing any more and took him out to the
24 left from our door to a pallet.
25 Q. All right. Did you know a police officer from Ljubija in the camp
Page 1253
1 by the name of Drago?
2 A. Yes, I knew him.
3 Q. Do you know if anything happened to him while he was detained in
4 the camp?
5 A. He was detained for a while and then one night they called him
6 out, or rather evening. At night-fall he was called out. I don't know
7 who exactly called him out. It could be Banovic, but I can't really say.
8 Banovic was one of them. And they took him out and beat him. We barely
9 heard him. All we heard were blows. And something clinking, like a rifle
10 or something. And one could hear that baseball bat hitting something.
11 Q. You referred to the name Banovic. You don't know if Banovic did
12 the beating. Do you know whether Banovic was there or do you know whose
13 shift it was on?
14 A. No, not really. Banovic was there. But now I just cannot recall
15 -- I can't remember which shift it was. I think it was the shift that
16 Crni was in, but I don't know his name.
17 Q. All right. When you referred to Banovic and the baseball-bat
18 sound, which Banovic are you referring to?
19 A. Cupo, Cupo. Yes. His brother did nothing. He just sat up there
20 and did nothing. He did it all.
21 Q. All right. Do you know what happened to --
22 JUDGE ROBINSON: Mr. Ryneveld, the witness earlier said, I think
23 it was the shift that, is it, Crni was in?
24 MR. RYNEVELD: I believe he used the word "Crni." I'm going to
25 get to Crni in a couple of paragraphs.
Page 1254
1 JUDGE ROBINSON: Okay.
2 MR. RYNEVELD: I'm still on 10, about to move to 11, and Crni is
3 referred to in 12.
4 JUDGE ROBINSON: Yes.
5 MR. RYNEVELD: Thank you.
6 Q. Just a couple more questions, sir, about Drago. Do you know what
7 happened to him after this beating? Do you have any personal knowledge
8 of --
9 A. Yes. He died after he was beaten.
10 Q. How do you know that?
11 A. Well, you could see the man was turned all black and blue.
12 Q. Did he come back into your room after the beating but before he
13 died?
14 A. He didn't come back. He was carried in, back in.
15 Q. Who carried him in?
16 A. I think that they called out some four inmates to carry him
17 through the door into the room.
18 Q. And you saw he was dead, did you?
19 A. After, after -- well, it all looked to us like a minute or two but
20 it could have been half an hour, 20 minutes. But at any rate, he died
21 shortly.
22 Q. And do I assume that his body was taken out of the room and taken
23 away after that?
24 A. That's right. All of those who died were taken out to the left of
25 this room and put on a pallet. There was one next to a door, and that is
Page 1255
1 where they were put, and then a small truck would come from the public
2 utilities company, and took them away. Where, I do not know.
3 Q. That's fine, thank you. Sir, are you also aware of a person who
4 was ethnically Albanian who ran a cake shop in Prijedor?
5 A. I had heard that he was of Albanian ethnic background. I could
6 hear his accent when he was speaking, and I knew that he had a pastry
7 shop, and he was there with me in the camp.
8 Q. Did something happen to him, to your knowledge?
9 A. He was also taken out, beaten. They used all kinds of objects on
10 him. He had scars on his head. There was blood. But -- and then shortly
11 thereafter, he died, so there was no more blood after that.
12 Q. Do you know who beat him or who was present or what shift was on
13 during that beating?
14 A. The shift where the most beatings took place was the one where the
15 Banovic was, and this Keli and Crni. It was mostly during their shift
16 that the most beatings took place, and we were most afraid of that shift.
17 Q. And you've just told us that's when it usually happened. What
18 happened -- are you able to tell us whether or not -- which shift was on
19 when the Albanian gentleman was beaten to death?
20 A. I think -- I didn't know this name, but I knew him by the nickname
21 of Crni. "Crni" means dark. He was not very tall. He may have been
22 about 170 centimetres tall, well-built, short hair. He was always wearing
23 a short, black T-shirt, and he had a nickel-plated pistol with
24 nickel-coated bullets.
25 MR. RYNEVELD: All right, sir. Your Honours, I anticipate that
Page 1256
1
2
3
4
5
6
7
8
9
10
11
12 Blank page inserted to ensure pagination corresponds between the French and
13 English transcripts.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1257
1 during the course of the next discussion there may be a quote which will
2 -- might identify someone. I'd like to move into private session very
3 briefly.
4 JUDGE ROBINSON: Yes.
5 MR. RYNEVELD: Thank you.
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 1258
1
2
3
4
5
6
7
8
9
10
11
12
13 Page 1258 redacted private session.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1259
1
2
3
4
5
6
7
8
9
10
11
12
13 Page 1259 redacted private session.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1260
1
2
3
4
5
6
7
8
9
10
11
12
13 Page 1260 redacted private session.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1261
1 [redacted]
2 [redacted]
3 [redacted]
4 [redacted]
5 [redacted]
6 [redacted]
7 [redacted]
8 [redacted]
9 [Open session]
10 JUDGE ROBINSON: Yes.
11 MR. RYNEVELD: Thank you, Your Honour, for that. I would have
12 carried on.
13 Q. Sir, perhaps allow me to rephrase my question earlier about Duca.
14 You told us that he came to the camp from time to time, and I asked you
15 when he did -- on those occasions when he did come to the camp, what would
16 he do? I think you told us that he came with somebody, or did I get that
17 wrong?
18 A. They were coming, and Zigic would come with him and some others.
19 There was one with a red beret, I don't know who he was, and several
20 others. They would come in a jeep or some other vehicle. They would
21 always come at dusk.
22 Q. And without getting into specifics in answer to this question,
23 when they came, what would happen, in general?
24 A. He took Fajzo and he said, "Who killed my brother?" He asked
25 Fajzo. And he told him, he said, "You put my brother's head in a vise and
Page 1262
1 kept tightening it until he died." And then they brought Fajzo's wife and
2 child and told him, "We'll kill them both if you don't tell us." And then
3 he cried and he said that he didn't do it, and so on.
4 Q. All right. Maybe I can get a couple of details. Do I understand
5 correctly that on one of these occasions when Duca came to the camp, he
6 had dealings with a man that you refer to as Fajzo; is that correct?
7 A. I'm sorry, I did not understand.
8 JUDGE MAY: We have done this.
9 MR. RYNEVELD: Thank you.
10 Q. Did you see Fajzo's wife and child at the camp?
11 A. Yes. She was holding it in her arms.
12 Q. Did anything happen to Fajzo?
13 A. Yes. Duca came, took a knife, and he sort of cut him across the
14 knife [as interpreted]. Then we bandaged him. I don't know how much he
15 cut him.
16 Q. You referred to, I believe you said, a punishment group. How many
17 people were in that group?
18 A. That group kept changing. There weren't always the same people in
19 it.
20 Q. And this group you're referring to, were those inmates in the
21 group or are you talking about perpetrators, people who did things in the
22 group?
23 A. That was a group of inmates.
24 Q. All right, sir. And I think I'm going to move on. Do you know
25 what happened to Fajzo? Did he stay at the camp?
Page 1263
1 A. He did not stay at Keraterm. He was called out. I don't know
2 whether he was sent to Omarska or somewhere else. I don't know exactly.
3 Sometime they would call out people and say that they were going to
4 Omarska, but we did not know where they would end up.
5 Q. So you know he was called out, but you don't know what happened to
6 him; is that correct?
7 A. Yes.
8 Q. Sir, I'm going to turn now to an incident. Do you remember
9 something that happened to the inmates of Room 3, latter part of July,
10 1992?
11 A. Yes. We were sleeping. It may have been 3.00 or 4.00 in the
12 morning. I don't know exactly. We could not orient ourselves. We did
13 not have watches so we did not know what time it was, but -- we could not
14 know the precise time. But we could hear a song, a Serbian national song,
15 and suddenly we could hear shattering of glass and something, words to the
16 effect, "Don't run." I don't know who said that. And then it started,
17 the shooting, first several shots, and then bursts of fire. I don't know
18 what weapons were fired. That I don't know exactly.
19 Q. You were in Room 4 at the time?
20 A. Yes.
21 Q. That's right next door to Room 3?
22 A. Yes. There is only a wall separates them.
23 Q. Did anything happen, during the course of this gunfire you heard,
24 to anyone in your room, Room 4?
25 A. Yes. One young man was hit in the arm by a ricochet.
Page 1264
1 Q. Do you know what type of prisoners were being housed in Room 3
2 just before this shooting incident you've referred to? Do you know where
3 these people were from?
4 A. Yes. They were from the area of Hambarine, Carakovo, Biscani, the
5 area up there. This is an area called Brdo.
6 Q. And do you know how long those people had been at Keraterm before
7 this shooting incident?
8 A. I think six to seven days, perhaps. I don't know exactly.
9 Q. Did you know someone at Keraterm by the name of Kole, the nickname
10 of Kole?
11 A. Yes.
12 Q. And what was his position at the camp?
13 A. He was a shift commander.
14 Q. Referring to the night of the shooting incident, do you recall
15 anything that would lead you to believe whether or not Kole was there or
16 not there?
17 A. I do not recall exactly whether he was present there during the
18 shooting, but when the shooting was going on, he said, "Stop shooting.
19 Fuck your mothers." Something like that.
20 Q. Did you know this Kole before the armed conflict?
21 A. I used to know him. Not that I was very close to him, but I did
22 know him.
23 Q. How long had you known Kole?
24 A. That I wouldn't be able to tell you.
25 Q. In what sort of circumstances did you know Kole? Like were you at
Page 1265
1 particular locations when you saw him?
2 A. I think that he played soccer for Cirkin Polje, but we also had a
3 club ourselves so we played them, and so I knew him through these soccer
4 teams.
5 Q. Do you know whose shift was on, and if so, how do you know about
6 that shift being on?
7 A. That was Kole's shift, because he would come at 10.00 p.m. and
8 lock the door, and this is how I know that it was him.
9 Q. Did you see Kole at Keraterm that evening before the shooting
10 incident?
11 A. Yes, he came to take over the shift. The shifts were taken over
12 at 6.00, 6.00 a.m. or 6.00 p.m., so one shift was from 6.00 to 1800 hours
13 and the other one 1800 to 6.00.
14 Q. One other question about that, sir, and that is you think that you
15 heard Kole's voice. Is there something about his voice that would allow
16 you to recognise it if and when you heard it?
17 A. He has a somewhat, I don't know, rough voice if I can -- actually,
18 it's a bit rough and a bit high-pitched.
19 Q. Sir, after the shooting incident, did something happen the -- in
20 the morning hours of the day following the incident?
21 A. Yes.
22 Q. Can you tell us?
23 A. In the morning they collected the dead bodies and they placed them
24 to the left, which is the place they would always put dead bodies before
25 taking them away. I think this was done during the Banovic and Crni's
Page 1266
1 shift. Later on in the evening, I don't know what time it was exactly,
2 they took out a group of people. They beat them there, and they killed
3 them.
4 Q. How do you know that?
5 A. Well, they took them out of Room 3. This is what we were told
6 later. We knew that it was not from Room 4, Room 2 or Room 1, so it must
7 have been from Room 3. They brought them out they were crying. They
8 said, "Don't. Don't." And suddenly shooting started, and later somebody
9 started shouting, "My leg. My leg." And then you could hear shots.
10 Q. Now, were there some people in your room, sir, who were involved
11 in the aftermath of the shooting incident on the first incident? Let me
12 be more specific. Do you know an Aco and Sekerin?
13 A. Aco and Sekerin, yes.
14 Q. Yes. Go ahead. What did they do, if anything?
15 A. They were carrying the dead over there. This is what we learned
16 three days later.
17 Q. Did they tell you about how many bodies there were after that
18 first shooting incident?
19 A. I heard, according to their accounts, that there were 127 killed.
20 Q. Did they also tell you how many were wounded?
21 A. I don't know exactly. They told us but I cannot recall the exact
22 number. I think that there was about 57, something like that. I don't
23 know exactly.
24 Q. That's fine, sir.
25 A. Or 47.
Page 1267
1
2
3
4
5
6
7
8
9
10
11
12 Blank page inserted to ensure pagination corresponds between the French and
13 English transcripts.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1268
1 Q. All right. Now, sir, you've told us that the following day, if we
2 want to call it that, in other words, there is a morning shift and you
3 said that people were being taken out, and then later on you told us that
4 there was an additional number of people who were being beaten; is that
5 correct? Do I understand you correctly that later the following evening
6 something happened further to Room 3 prisoners?
7 A. The first shooting was during Kole's shift. The second shooting
8 was the very next night, the night after. When the night came, they
9 brought them out. Later on I learned that it was 22 men dead, that they
10 brought out, beat them, and then killed them all.
11 Q. Did you hear that information from Aco and Sekerin as well or from
12 someone else?
13 A. These were the men who had stayed in Room 3 who said this.
14 Q. Thank you. Sir, you've told us that you knew Kole before the
15 conflict and did you talk to Kole a few days after the shooting incidents?
16 A. Yes.
17 Q. Do you remember what Kole told you?
18 A. He said to me, "I think -- had I been there, nothing would have
19 happened."
20 Q. Now, you say you knew Kole before the war. And do you think that
21 you would be able to recognise this individual if you were to see him
22 again?
23 A. Yes.
24 Q. Would you look around the courtroom now, sir, and if the person
25 that you've referred to in your evidence as Kole, if he's in the
Page 1269
1 courtroom, could you point him out, please, and tell us where he's
2 sitting?
3 A. To my right at the end.
4 Q. All right. You are pointing in the direction of -- to your right,
5 did you say? Could you hold up your right hand.
6 A. To the right from me.
7 Q. I see.
8 A. He is at the very end.
9 Q. You are looking to your left and holding up your right hand, which
10 is the opposite hand. Perhaps you could point at the individual so that
11 Their Honours can see where you are pointing.
12 A. It's the one at the very end by the corner over there.
13 Q. You are pointing to the back wall of this courtroom or to the
14 wall. There are six seats, for the record, in that back wall. There are
15 three policemen and three people in civilians. Can you tell us which
16 chair, counting from left to right, the person that you refer to as Kole
17 is sitting in? Counting from left to right including the police
18 officers.
19 A. The fifth chair.
20 MR. RYNEVELD: Thank you. For the record, identifying Kole.
21 JUDGE ROBINSON: Yes.
22 MR. RYNEVELD: Thank you.
23 Q. Sir, did -- were you ever allowed to use the telephone?
24 A. I asked Kole if we could call home after that to just let them
25 know that we were all right, and he let us do that. So we went to make
Page 1270
1 our calls and we called our homes.
2 Q. And when you were making these calls, where was the telephone
3 located?
4 A. It was in that room next to the weigh bridge.
5 MR. RYNEVELD: Might the witness be shown Exhibit 2 again,
6 please.
7 JUDGE ROBINSON: Yes.
8 MR. RYNEVELD: And I'm going to ask that the usher show the
9 witness Exhibit 2C.
10 Q. First of all, sir, do you recognise the photograph now shown to
11 you marked Exhibit 2C in these proceedings?
12 A. Yes.
13 Q. Is that the room or weigh -- by the weigh bridge to which you have
14 referred to in the foreground?
15 A. Yes.
16 Q. You earlier told us that, I believe, that when you were taken to
17 be beaten, you were -- this is the place where the commanders were; is
18 that correct?
19 A. That's right.
20 Q. Did you go to this particular hut, that is the one with the flat
21 roof and the white -- in the foreground of the photograph 2? Is that
22 where you were taken to use the phone?
23 A. That's right.
24 Q. Would you take your pointer, if you would, please, and tell us
25 where the phone was located and what did you see near the phone?
Page 1271
1 A. Here, inside, next to this glass where it opens, that is where the
2 telephone was, and next to the telephone were the lists.
3 Q. Did you see any lists?
4 A. I did. There were all the lists, the lists for all the four --
5 for all four bedrooms, dormitories.
6 Q. All right. Now, sir, were all the prisoners given the right to
7 use this telephone?
8 A. No.
9 Q. Who do you know -- are you able to tell us how many prisoners were
10 allowed to phone home?
11 A. I know that my brother and I used it. I don't know how many
12 others.
13 Q. Thank you. And you and your brother knew Kole before the war?
14 A. I don't know about my brother. I know that I knew him.
15 Q. Thank you. Do you know someone by the name of Kajin or someone
16 referred to by the name of Kajin while you were at Keraterm?
17 A. Yes.
18 Q. And how did you know him?
19 A. I knew him for quite sometime before the war.
20 Q. Had you had any dealings with an individual by the name of Kajin
21 before the war?
22 A. Yes. Once we got into a fight at the railway station. He and his
23 colleague were involved. I don't know who that was.
24 Q. Do you remember what the fight was about?
25 A. Yes. He was refusing to pay for the use of the lavatory to a
Page 1272
1 woman who was there, and we started an argument. And we had all had a
2 drink or two, so we got involved in a fight.
3 Q. And did you see this person with whom you had been in a fight at
4 Keraterm?
5 A. Yes.
6 Q. Sometime during your dealings with this individual at Keraterm,
7 did he make reference in any way to your previous encounter?
8 A. When I saw him there, I hid inside for the first two or three
9 days. I was afraid. I dare not come out. But then he called me out and
10 said, "Listen, I'm not one of those who will go for tit-for-tat. Nobody
11 will touch you. But I do know that you carried a rifle in the SDA call it
12 attack on Prijedor."
13 Q. Did he indicate anything to you about what would happen to you if
14 you had belonged to a particular group?
15 A. I don't remember.
16 Q. Could you describe Kajin for me?
17 A. Yes. At that time he was younger than he is today. And he was
18 rather thin, tall, blond, dark-blond or something.
19 Q. Now, you say you knew this man before the war. How well did you
20 know him before the war, apart from this fight you had with him?
21 A. Well, it's difficult to say how long, because he's younger, and we
22 were not often in the same company, but when we went swimming, we'd go
23 together or would be in the same place, I mean hotels. I came across him
24 at various places.
25 Q. How often did you have dealings with him at Keraterm? How often
Page 1273
1 did you see him, apart from this conversation with him that you've just
2 related to us?
3 A. What do you mean, "often"?
4 Q. That's something I'm going to have to ask you to describe for us.
5 On how many occasions would you say you saw this person you refer to as
6 Kajin?
7 A. He was the camp commander in the early days, in the beginning, so
8 that we would see him every day.
9 Q. Do you think that you would recognise this individual today if you
10 were to see him again?
11 A. Yes.
12 Q. Would you please, then, look around the courtroom, and if the
13 person you've referred to as Kajin is in the courtroom, could you point
14 him out, please, and tell us where he is sitting?
15 A. He is in the middle, next to -- one, two, three, the third seat
16 from left to right.
17 Q. Third seat left to right. Thank you.
18 MR. RYNEVELD: For the record, again, identifies Damir Dosen.
19 JUDGE ROBINSON: Yes.
20 MR. RYNEVELD:
21 Q. Sir, you've made reference to people that you say were in a
22 special punishment group and referred to Duca. Do you recall any
23 incidents involving those inmates where Kajin was present?
24 A. I think he was there when Car was killed. I believe he was there
25 at the time.
Page 1274
1 Q. Did Duca or Zigic ever appear while he was on shift, to your
2 knowledge?
3 A. Well, they did, but I just don't know how many times.
4 Q. Do you remember any one incident that you know Kajin was present
5 and, if so, how you know he was present?
6 A. Well, once they took out the man who is called Kocijas, who was
7 nicknamed Kocijas, and another guy. It was sometime in the evening. I
8 wouldn't know the exact hour. And forced the two of them to fight between
9 themselves, that is to deal blows to each other. And as they were doing
10 this, a soldier or somebody came up and said, "Stronger, stronger," and
11 then hit one of those and said, "This is how you deal a blow." And that
12 was it, and then he laughed and that was it.
13 Q. Who laughed?
14 A. I didn't hear the interpretation.
15 Q. My question is: Who laughed when the prisoners were forced to
16 beat each other?
17 A. Kajin was laughing. Kajin was laughing.
18 Q. Did you know an individual by the name of Sikirica while you were
19 at Keraterm?
20 A. I never knew him before.
21 Q. Did you know someone by that name while you were an inmate at
22 Keraterm?
23 A. I only knew him by nickname, that is what I had heard, that his
24 name was -- that he was called Sikirica, that he worked at Celpak, and
25 that he was a shift foreman. That is what I heard.
Page 1275
1 Q. Did this individual that you later heard to be referred to as
2 Sikirica ever tell you what his function was at the camp? Did he
3 personally tell the inmates that?
4 A. Yes. When he came he said, "I'm the new camp commander." That
5 was it.
6 Q. Did you ever see the individual that you refer to as Sikirica
7 involved in beating of any of the prisoners while in your presence?
8 A. I don't remember seeing him.
9 Q. Do you remember whether people were beaten while he was on duty?
10 A. Yes.
11 Q. How frequently?
12 A. Usually when the Banovic group was there, that is Banovics and
13 that Keli and Crni. They were usually the ones who beat.
14 Q. Could you describe this gentleman that you knew as Sikirica for
15 us, very briefly?
16 A. Well, he wore a military uniform, very smart, well-ironed,
17 military boots, and at that time, he had a mustache, thin mustache, and
18 short hair.
19 Q. And how often would you say you saw Sikirica in the camp during
20 the period of your detention, sir?
21 A. From the beginning every day.
22 Q. Do you feel that from your seeing this man at the camp, having him
23 tell you he was camp commander, and seeing him nearly on a daily basis,
24 you would be able to recognise him if you were to see him again?
25 A. Yes.
Page 1276
1 Q. Would you look around the courtroom and go through the same
2 procedures as you did for the other individuals, please.
3 A. It's the second one from the left to right. The second seat with
4 the beard. Now he has a beard. He didn't have it before.
5 Q. And again, that's in the back row as I'm looking at the courtroom
6 to your left?
7 A. Yes. I can see him directly from here, but there is also a guard
8 before him.
9 MR. RYNEVELD: Might the record show that he's identified the
10 accused Sikirica.
11 JUDGE ROBINSON: Yes.
12 MR. RYNEVELD:
13 Q. Sir, what can you tell us about conditions at the camp after
14 Sikirica told you that he was the new camp commander?
15 A. Nothing. It could only get worse. It couldn't get better.
16 Because we could not have from the beginning, we could not have any
17 protection afterwards. We had no protection.
18 Q. Very briefly, sir, I'm going to ask you a couple of questions
19 about camp conditions. You've already told us about food. Very briefly,
20 what kind of food and how often would you be fed, and how were the
21 conditions about getting to and from the food?
22 A. Well, the food wasn't anything to write home about. We had one
23 meal a day. In the beginning it was a little earlier. Later on they
24 moved it on to 7.00 in the evening, and there wasn't enough food for
25 everybody. There wasn't food for everybody all the time.
Page 1277
1 At times when Banovics, and Keli, and those others, when they were
2 there, then we would be given 30 seconds to have a meal, and I don't think
3 you can take a single bite in 30 seconds.
4 Q. What would happen to you if you exceeded the time limit they said?
5 A. Well, beaten, and they'd hit whoever they could lay their hands
6 on.
7 Q. How about the toilets, sir, were there sufficient toilets?
8 A. No. And they were all blocked at times. We tried to clean them.
9 I mean one simply couldn't go in because of -- what do you call it that
10 smell, that stench, what to call it. They were all flooded. At times
11 when there was water, we washed them.
12 Q. Were there facilities for washing yourselves or your clothes?
13 A. No, we did not. No, we did not have that. At times during Kole's
14 shift, we'd ask Kole, "Can we go? Is there water?" And then at times he
15 would allow us and say yes. So on one occasion we all had a bath during
16 Kole's shift.
17 Q. The water that was supplied or available, was that drinking water
18 or was it -- well, was it drinking water or was it a different kind of
19 water?
20 A. At times drinking water was brought in, cisterns, from the water
21 supply company and the fire brigade. And at times we also used the water
22 from the hydrant when there was no other water, when there was no other
23 water.
24 Q. Did the prisoners develop any diseases to your knowledge or any
25 gastro symptoms to your knowledge while you were an inmate? And by
Page 1278
1
2
3
4
5
6
7
8
9
10
11
12 Blank page inserted to ensure pagination corresponds between the French and
13 English transcripts.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1279
1 "gastro" I mean stomach ailments.
2 A. Yes. Some contracted dysentery, that is, vomiting and diarrhea.
3 Q. What was the effect on your body weight while you were at
4 Keraterm?
5 A. I lost 14 and a half kilograms during that time from the beginning
6 to the end.
7 Q. You arrived in Keraterm on the 31st of May 1992, and you left
8 when?
9 A. On the 5th of August 1992.
10 Q. I understand you were taken to Trnopolje where you were eventually
11 released on the 12th of August; is that correct?
12 A. I was released -- well, I'm not quite sure. Was it the 8th of
13 August?
14 Q. Were you at -- let me ask this in two questions. Were you taken
15 to Trnopolje?
16 A. Yes.
17 Q. Did you stay long?
18 A. Three or four days. Three, I think.
19 Q. Did you have to sign any documents in order to be released?
20 A. Yes. In order to be released, I had to sign over everything and
21 to leave the town.
22 MR. RYNEVELD: I just want to consult with my colleague and I
23 believe those are my questions. I just want to make sure.
24 [Prosecution counsel confer]
25 MR. RYNEVELD:
Page 1280
1 Q. So how long approximately would you say you stayed at Keraterm?
2 Are you able to tell us that or we can do our own math?
3 A. Altogether, 68 days. I mean Keraterm and Trnopolje.
4 MR. RYNEVELD: Thank you, Witness. Those are my questions. Would
5 you answer my learned friends, please.
6 JUDGE ROBINSON: Mr. Greaves, I think we'll take the break now.
7 MR. GREAVES: Thank you very much. I was going to ask you to do
8 that.
9 JUDGE ROBINSON: Witness E, we are going to adjourn until 2.30.
10 During the break you are not to discuss your evidence with anybody and
11 that includes members of the Prosecution team. We stand adjourned.
12 --- Luncheon recess taken at 12.59 p.m.
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 1281
1 --- On resuming at 2.33 p.m.
2 JUDGE ROBINSON: Yes, Mr. Greaves?
3 MR. GREAVES: Thank you very much, Your Honour.
4 Cross-examined by Mr. Greaves:
5 Q. Witness E, I'd just like to ask you quickly please about this: Is
6 it correct that in relation to these matters, you have made two statements
7 to the Office of the Prosecutor, one in February, 1995 and a second in
8 August of last year, 2000?
9 A. Yes.
10 Q. And is this also right, that when you made your second statement,
11 you were able to go through the details of your first statement and to
12 confirm that what you'd put in your first statement was accurate, with the
13 exception I think of one minor detail concerning a member of your family;
14 is that correct?
15 A. Yes.
16 MR. GREAVES: Thank you. Your Honour, may we go into private
17 session, please?
18 JUDGE ROBINSON: Yes
19 [Private session]
20 [redacted]
21 [redacted]
22 [redacted]
23 [redacted]
24 [redacted]
25 [redacted]
Page 1282
1
2
3
4
5
6
7
8
9
10
11
12
13 Page 1282 redacted private session.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1283
1 [redacted]
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 [Open session]
22 MR. GREAVES:
23 Q. I'd like to ask you this, please, Witness E, you were in Prijedor
24 at the end of April 1992. Is it correct that you, yourself, were not in
25 employment at that time?
Page 1284
1 A. At that point, I did not work.
2 Q. Between the takeover of Prijedor by Serb-dominated entities and
3 your arrest, were you able to move around the municipality in the ordinary
4 way that you had previously been able to do?
5 A. No.
6 Q. Was that because there were now some checkpoints manned by the
7 military or the police which were checking identities?
8 A. I don't even know that they were checkpoints. I just didn't feel
9 like going down there.
10 Q. So because of the change in political situation, you decided in
11 large to remain at home; is that right?
12 A. Yes.
13 Q. Did you hear of or witness any military activity or fighting in
14 the Prijedor area at the end of May 1992?
15 A. I heard -- I had heard some shooting, but I did not know what was
16 going on.
17 Q. When you were arrested on the 31st of May 1992 with, I think,
18 about 150 others, would this be correct that the make-up of that group
19 was, in essence, men of military age? Would you accept that?
20 A. No, I do not agree. I was not able-bodied.
21 Q. The phrase I used was "men of military age" not military
22 capability, Witness E, military age. Would you accept that? In other
23 words, 16 to 60.
24 A. I don't know what is the military age. There were men who were
25 over 60, over 70. They could not have been of military age.
Page 1285
1 Q. Don't mention any names, Witness E, but is it right that you were
2 questioned about the age of your father at the time of your arrest?
3 A. Yes.
4 Q. And you told the people who had come to arrest you that he was 60,
5 and having told them that he was that age, they allowed him to stay,
6 didn't they?
7 A. Yes.
8 Q. And also left behind were your mother and sister. Again, don't
9 tell us any names. That's correct, isn't it?
10 A. Yes.
11 Q. The -- some of the people who came to arrest you, you considered
12 to be Chetniks, don't you?
13 A. I don't understand. What do you mean when you say "Chetniks"?
14 Q. Well, what you told the Office of the Prosecutor in both of your
15 statements is that you considered some of them from their accents, at
16 least, to be Chetniks either from Lika or Licani?
17 A. I called them men from Lika. They had those accents and they had
18 cockades on their hands.
19 Q. But the phrase you used to describe them, do you accept, was
20 "Chetnik"?
21 A. Yes.
22 Q. Having been arrested, you've told us of your various travels to
23 various places, Witness E. Is this correct that it became evident when
24 you were turned away from Omarska because there was insufficient room, it
25 was evident, was it not, that no organisation had taken place concerning
Page 1286
1 your group as to where you were going to go?
2 A. I don't know whether there were any preparations for that. I
3 cannot conclude anything about that. They just gathered us up. I don't
4 know if they knew how many people they were going to get.
5 Q. Were the people who were driving the buses to Omarska, were they
6 surprised to be turned away? Could you see that?
7 A. No.
8 Q. You couldn't see it or they weren't surprised?
9 A. They just told them, "Go back," and then they just turned around
10 and they went back.
11 Q. Upon your arrival at Keraterm, is it right that you were searched,
12 and one of the items which was taken from you was your identity card?
13 A. Yes, and cigarettes and a lighter.
14 Q. And were identity cards taken from all the other people who
15 arrived at the same time as you?
16 A. Yes.
17 Q. It's right also that that identity card was returned to you whilst
18 you were in detention at Keraterm; is that not so?
19 A. Yes.
20 Q. And is that true of the other detainees, they also had their
21 identity cards returned?
22 A. Not all identity cards were returned to everyone. Some remained
23 there.
24 Q. Without asking you to put a definitive, accurate figure on it,
25 what sort of proportion of the people in the camp had their identity cards
Page 1287
1 returned to them, Witness E?
2 A. I wouldn't be able to say.
3 Q. Would you say it was the majority of people had their cards
4 returned or a minority?
5 A. I do not know that. I know that my brother and myself had our
6 identity cards returned to us. I don't know about the others. I really
7 cannot say.
8 Q. During the process of you all arriving and being searched, one
9 individual was mistreated. That was because he was found in possession of
10 a knife; is that correct?
11 A. In fact, we have to make a distinction. There is a difference
12 between a knife and a cakija.
13 Q. Perhaps you could tell us what the difference is, Witness E, so we
14 can understand your answer, please?
15 A. Knife is bigger, you know what a knife -- and cakija is smaller
16 and it falls, so it's something that you bring along in your pocket so
17 that you can maybe slice an apple or cut some bacon or something like
18 that.
19 Q. In English I think we would use the word "penknife" to describe
20 such an implement. Is that something that you would understand?
21 A. Yes, yes, that's it.
22 Q. I thought that's what you meant. Is this correct also, Witness E,
23 that initially, upon your arrival at the camp, there was no mistreatment
24 for at least two or three days?
25 A. I cannot recall exactly those two or three days.
Page 1288
1 Q. If I was to refresh your memory from the second statement which
2 you made to the Office of the Prosecutor, you told them on that occasion,
3 "For the first two or three days, nothing happened to us." Does that
4 refresh your memory, Witness E?
5 A. Something like that. That's how it was approximately, even though
6 we had been -- we were locked up so we were not in position to know what
7 was going on.
8 Q. I'd like now to turn to some specific incidents involving
9 individuals you've talked about. The Serb whose name was Jovo, you've
10 told us what -- something of what was said at the time, but is this
11 correct, that the motive for ill-treating that person was because he had
12 either voted for the SDA or had displayed posters of the SDA or Alija
13 Izetbegovic at his home?
14 A. The people who knew him, who used to know him, and he was from
15 Ljubija, they said that his -- there were SDA posters on his house, but I
16 don't know whether this was true, but this is what I heard.
17 Q. And the Banovic brother who assaulted him did so out of -- because
18 he was wanting to take out his revenge and aggression upon Jovo; is that
19 correct?
20 A. I don't know whether Banovic said that, but I heard that someone
21 said later something like it. "This is how we punish the traitors."
22 Q. The reason I ask you - and may I refresh your memory from your
23 statement made in 1995 - is that you said to the Office of the Prosecutor,
24 "Banovic who carried the baseball bat took out his revenge and aggression
25 on him." Is that something that you were able to observe and conclude?
Page 1289
1
2
3
4
5
6
7
8
9
10
11
12 Blank page inserted to ensure pagination corresponds between the French and
13 English transcripts.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1290
1 A. He beat him. And why he beat him, that I don't know.
2 Q. Turning now, Witness E, please, to the man Drago Tokmadzic. Is it
3 right that in relation to him, the motive for attacking him was because he
4 was both Croat and an active police officer?
5 A. Probably. I don't know exactly.
6 Q. You are not able to say who it was precisely who beat Drago
7 Tokmadzic?
8 A. I heard -- what's his name? This Banovic, whose nickname was
9 Cupo, I heard him, his voice, and his baseball bat, which had that hollow
10 sound when it delivered blows.
11 Q. Would this be correct, that the body of Drago Tokmadzic was taken
12 away in a hearse?
13 A. I think that they were all taken away in a hearse except those --
14 but we will come to that. Those who died individually were taken away in
15 a hearse.
16 Q. Can I turn, now, please, to the Albanian, the man who owned the
17 cake or ice-cream shop at the Prijedor station. Is this correct: That
18 the motive for assaulting him was because he was believed to be wealthy,
19 and there was an interest in extorting money from him?
20 A. There is a great possibility that that was so.
21 Q. The man, Car, who was alleged to have a machine-gun when he was
22 arrested, was that the focus of the ill-treatment of that man?
23 A. Yes.
24 Q. And is it right that that was an incident which took place at
25 night?
Page 1291
1 A. They dealt with him during the day.
2 Q. Apart from Jovo, you were aware of other Serb detainees, I think,
3 in Room 4. How many were there who were detained in Room 4, Serb
4 detainees?
5 A. With us?
6 Q. Either with you or later separately.
7 A. They were not with us. They were -- they were there when there
8 were only Rooms 1 and 2 as military detention. They brought them there,
9 men who either got drunk or did I don't know, and this is where they kept
10 them. One of those who had beaten us when we were being placed on buses
11 also ended up there.
12 Q. Can you say, please, if you know, how many people were being --
13 how many Serbs were being detained at any one time?
14 A. That I don't know.
15 Q. I'd like to turn now to the issue of camp commanders, please,
16 Witness E. During your stay, it's right, isn't it, that three separate
17 people were commanders of the Keraterm facility?
18 A. Yes.
19 Q. The person who was commander of the Keraterm facility when you
20 arrived remained in that position for some 25 days after your arrival; is
21 that correct?
22 A. Approximately that.
23 Q. So that person was replaced on or about the 25th of June 1992.
24 A. Yes, something like that.
25 Q. The second person who was commander of the camp, was that person,
Page 1292
1 in turn, replaced sometime around the 27th of July 1992?
2 A. I don't know exactly. We could not keep track of the -- of dates,
3 and we could not orient ourselves in that respect. So I wouldn't be able
4 to say exactly what date it was. We did not have a calendar. And we did
5 not have watches in order to be able to see what date it was.
6 Q. Just so that we can try and fix it, if you will assist me, please,
7 Witness E, you told the Office of the Prosecutor in your statement in 1995
8 that you had remained at Keraterm from 31st of May until the 8th of
9 August.
10 A. On the 5th of May. On the 8th of May [sic], I left the camp.
11 Q. The 8th of May or the 8th of August?
12 A. Of August.
13 Q. And just help me about this: Is this correct that the change from
14 the second commander to the third commander took place shortly after the
15 incident in Room 3 and about a week before you were transferred to
16 Trnopolje?
17 A. I did not understand the question. My apology.
18 Q. That's all right. I'll do it again. Can I just refresh your
19 memory from the two statements which you've made to the Office of the
20 Prosecutor. What you've told them was that in relation to the change-over
21 from the second to the third commander, that that event took place shortly
22 after the incident in Room 3 when people were killed, and about seven days
23 or thereabouts before your transfer to Trnopolje.
24 Does that refresh your memory as to when the change-over took
25 place, Witness E?
Page 1293
1 A. The first commander was there for about 20, 25 days. The second
2 commander came after him, and the last 7 days, 7, 8 days something like
3 that, that is when the third commander came.
4 Q. Thank you very much.
5 Did you learn the name of the third commander either at the time
6 or subsequently?
7 A. I only knew that he worked -- that he had worked in a shop. I
8 don't know what his name was. Actually, a lumber yard. I know that that
9 company was from Banja Luka, but I cannot recall it now.
10 Q. If I suggested the name Marinko Sandzak to you, would that ring a
11 bell?
12 A. I don't know his name because I had not known him before. He did
13 state his name and he told us that nobody would touch us while we were
14 there.
15 Q. And so that third person was in command when you left for
16 Trnopolje and supervised the closure of Keraterm and the transfer of
17 prisoners; is that correct?
18 A. Sikirica was also there with him.
19 Q. But by that time, the man you had been told was Sikirica was no
20 longer the commander, was he?
21 A. He was no longer the commander, no longer. He had taken over that
22 post.
23 Q. Indeed, I suggest, and you must deal with it, Witness E, that at
24 no time did he personally tell you or anyone else that he was commander of
25 the camp. The only thing he may have said was that he was commander of
Page 1294
1 security at Keraterm. That's correct, isn't it?
2 A. That is not true. When he came he said, "I'm the commander
3 here."
4 Q. Those were his words, "I'm the commander here." I'd like to move
5 on, please, Witness E, to the punishment group or the special treatment
6 group. Would this be correct that that was established by Zigic and Duca
7 around the 20th of June 1992?
8 A. I'll tell you one thing, I do not remember the dates and I
9 couldn't know the dates, but this group was set up after three or four
10 days, not after two or three.
11 Q. What you told the Office of the Prosecutor in August of last year,
12 Witness E, was this: "Around 20 days after my arrival in Keraterm, the
13 guards established what they called the punishment group." Does that
14 refresh your memory as to what you've said in the past?
15 A. No. The punishment group was not set up then. It was set up
16 before, right after the arrival in the camp, three or four days later,
17 that's it.
18 Q. All right.
19 A. And this group came into being right then.
20 Q. Is this correct, Witness E, that the focus of the perpetrators who
21 were involved in that was against those firstly who were considered
22 extremists?
23 A. No. They were not Muslim extremists.
24 Q. You see, again what you told the Office of the Prosecutor was that
25 the basis for selection was those prisoners who were selected as
Page 1295
1 extremists on their arrival in Keraterm.
2 A. Yes.
3 Q. And did you understand by the phrase "extremist" or the concept of
4 "extremist," these categories of people: Those who were known to be
5 members of the SDA or activists in the SDA, people who they believed were
6 involved in military activity, and in particular people from Kozarac who
7 may have taken part in resistance at Kozarac?
8 A. I wouldn't know that is what they called them. I do not know how
9 they identified them. That young boy, that Kocijas, he did not belong to
10 any resistance or any party, but allegedly he had killed a guy who was a
11 Serb and that was why he was to be in that group.
12 Q. But the other type, the other categories of people, can you say
13 anything to confirm that that was how they focused their attention? In
14 particular, but not exclusively, on those kind of people?
15 A. I don't understand the question.
16 Q. I will put it to you again. Forget for a moment about the young
17 man you've spoken about just now. Is this correct, that by "extremists"
18 were meant, for example, people who were members of the SDA or were
19 activists in the SDA, people who had taken part in resistance fighting or
20 military activity, in particular people from Kozarac?
21 A. I don't know what they thought. I don't really know who was a
22 member of SDA or who wasn't, so I cannot say yes or no or why.
23 Q. Is it right that many of the group who were part of the special
24 treatment group were, in fact, from Kozarac?
25 A. Not all of them.
Page 1296
1 Q. But many of them were, weren't they, Witness E?
2 A. Yes, majority, I'd say.
3 Q. And is it within your knowledge that Duca Knezevic also came from
4 Kozarac?
5 A. I don't know. I don't really know where he comes from.
6 Q. When you were interrogated, Witness E, can you help us about
7 this: Was the nature of those questions about you personally?
8 A. Well, they asked me who I am, what I am, where I was born, where I
9 came from, where I'd served the army, if I had any weapons, if I carried
10 any weapons, if I knew who carried the weapons, who sold the weapons, if I
11 knew that there were weapons for sale, and things like that.
12 Q. Is this correct, that the people who were conducting your
13 interrogation were what were known as inspectors who had come from outside
14 the camp?
15 A. I don't really know where the people -- where these people came
16 from. I did know one of them, but I cannot place him really.
17 Q. Did they appear to be, as it were, professional policemen, used to
18 asking questions in this way? Would that be right?
19 A. Excuse me?
20 Q. Did the people who were interrogating you appear to you to be
21 professional policemen, for example, used to interrogating people?
22 A. I don't know. They wore uniforms, but I just don't know what they
23 were, policemen or military. I just don't know. But they wore military
24 uniforms.
25 Q. After people had been interrogated, Witness E, did that lead to
Page 1297
1 those who had completed the process of interrogation being moved from one
2 room to another?
3 A. Yes.
4 Q. And is this correct - and if you don't know the answer, please
5 tell us - that the people who took the decision as to where people would
6 be moved, those were the people who had conducted the interrogations?
7 A. I didn't really understand that question, sorry.
8 Q. Yes. The people who took the decisions as to whether you should
9 be moved from one room to another, or indeed from one camp to another, did
10 you understand that that was -- those were decisions taken by the people
11 who had conducted the interrogations?
12 A. After the interrogation, they would move us from one room to
13 another. Two or three days later, or perhaps even the next day, depends,
14 some were called out to be sent to Omarska, to collect all their
15 belongings and go to Omarska.
16 Q. I'd like to turn now to the matter concerning Room 3, Witness E,
17 please. You saw none of the preparations for that incident; is that
18 correct?
19 A. No. I was asleep at the time. I'd just fallen asleep.
20 Q. Did you subsequently, or indeed at the time, learn that the
21 incident had been perpetrated by soldiers who had come from outside?
22 A. I do not really know who did that. I did not learn that. I do
23 not know who fired the shots or what.
24 Q. Did you learn anything of how many people had been involved in
25 perpetrating that incident?
Page 1298
1 A. No. I don't know. I don't know.
2 Q. From what you were able to hear, Witness E, would you accept that
3 it was at least one member of the Keraterm personnel who did what he could
4 to prevent and stop what was taking place?
5 A. I heard Kole shouting, "Stop, don't fight, fuck you, don't fire."
6 Q. And is this also right, Witness E, that you understood from what
7 you heard that, in part, he had tried to prevent and stop what was going
8 on by discharging a submachine-gun in the vicinity of the perpetrators?
9 A. Well, I don't know whether he fired or somebody else because I
10 could not see that. But I could identify the automatic rifle because
11 there is a difference between it and machine-guns or other rifles and then
12 I thought that it could be him.
13 Q. And it's right, isn't it, that the shooting stopped after the
14 intervention of Kole?
15 A. More or less.
16 Q. And would it be right to conclude from that fact that the
17 intervention that you had heard was therefore effective?
18 JUDGE ROBINSON: Yes, Mr. Ryneveld.
19 MR. RYNEVELD: I understand what my friend is trying to do, but
20 there is a point at which the speculation that's being called from the
21 witness goes beyond his realm of knowledge. He's told us what he knows.
22 What my friend is trying to do is get something that's for argument as
23 opposed to witness' argument.
24 JUDGE ROBINSON: Yes, we agree.
25 Please move on, Mr. Greaves.
Page 1299
1 MR. GREAVES:
2 Q. It's right, isn't it, Witness E, that Kole, on other occasions,
3 was responsible for preventing people who were not supposed to be at
4 Keraterm from coming into the premises?
5 A. I don't understand the question, I'm sorry. Could you rephrase
6 it, please?
7 Q. Yes. You were aware that Kole had, on occasions, prevented people
8 from coming into the Keraterm facility from outside?
9 A. I must say I don't remember that, but I do -- I must say that
10 during Kole's shifts there were no problems. We could sleep quietly and
11 everything when Kole was on duty. And if somebody came and hit an inmate,
12 then he would hit him and tell him to leave us alone.
13 Q. Is this right, that you told the Office of the Prosecutor in
14 August of last year that you remembered seeing soldiers coming to the gate
15 of Keraterm seeking to come in, wanting to come in, and Kole turning them
16 away and that he would swear at them and say that they would not come in
17 whilst he was on duty; do you recall that?
18 A. Yes, yes, yes, that's right. Yes, quite.
19 Q. And that on occasions, Zoran Zigic would be in the camp during
20 Kole's shift, but he would not mistreat people during that period.
21 A. He came as a visitor.
22 Q. Yes. And when he came during Kole's shift, Zigic did not
23 perpetrate any mistreatment; is that correct?
24 A. Kole did not allow any mistreatment.
25 Q. And during Kole's shift, the man Duca Knezevic would not come in
Page 1300
1
2
3
4
5
6
7
8
9
10
11
12 Blank page inserted to ensure pagination corresponds between the French and
13 English transcripts.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1301
1 at all.
2 A. I did not see him then. I don't remember.
3 Q. Help us about this, please, Witness E: Do you know or did you
4 know at the time in 1992 of somebody called Zivko Knezevic? Does that
5 name mean anything to you?
6 A. No.
7 Q. Just two bits of detail, please. The man you have identified as
8 Dusko Sikirica, you didn't see that person ever carrying weapons whilst he
9 was in the Keraterm facility; is that correct?
10 A. I did not.
11 Q. Can you help us about this: As far as inmates who were sick or
12 unwell, was there anybody who you believed to be suffering from epilepsy,
13 which you understood to be suffering from epilepsy?
14 A. Yes.
15 Q. Was it one person or more than one person?
16 A. More than one.
17 Q. Was one of those somebody called Nehru Garibovic?
18 A. That's right.
19 Q. Finally, these matters, Witness E, if you can help us, please.
20 During the time when you were detained at Keraterm, how many people do you
21 say were detained along with you?
22 A. I could not say, not the exact number. There were quite a
23 number. Many people passed through that camp. I should say about 1.200,
24 1.300 maybe. I wouldn't really know.
25 Q. Would this also be correct, Witness E, that of those who passed
Page 1302
1 through the camp, some were released completely to return to their homes.
2 A. During the first fortnight, yes. After interrogations, some were
3 released. After that, nobody was released.
4 Q. Can you say how many people were released in that way during the
5 first fortnight?
6 A. I wouldn't really know.
7 Q. During the time when you were in Keraterm, Witness E, would you
8 accept this: That all of the detainees were in the complete power of the
9 Serb authorities throughout the period?
10 A. Excuse me, did all?
11 Q. Yes. Throughout the period that you were detained at Keraterm,
12 would you accept that you and your fellow detainees were in the complete
13 power of the Serb authorities who had detained you?
14 A. Well, yes.
15 Q. And would you also accept that throughout that period, there was
16 nothing that would have prevented those same Serb authorities from killing
17 all of you en masse?
18 A. I simply fail to understand the question. I am at a loss.
19 Q. It's right, isn't it, that those, the Serb authorities could, if
20 they had wished, have killed all of you at any time?
21 A. Yes, that's true.
22 MR. GREAVES: If Your Honours will just give me a moment, please.
23 I have no further questions. Thank you very much, Your Honour.
24 JUDGE ROBINSON: Yes, thank you. Mr. Petrovic.
25 MR. PETROVIC: [Interpretation] Thank you, Your Honour. May I
Page 1303
1 begin?
2 JUDGE ROBINSON: Yes.
3 Cross-examined by Mr. Petrovic:
4 Q. Witness E, I should first like to ask you to tell us briefly --
5 I'm sorry, I have some problems with my headset -- to tell us briefly what
6 was life like in Bosnia in the 1980s?
7 A. It was perfect.
8 Q. You mean everybody lived peacefully, quietly, in harmony,
9 regardless of the ethnic origin?
10 A. Yes.
11 Q. We can therefore conclude that that was the best time ever, at
12 least in our memory, isn't it so?
13 A. Yes, the 80s.
14 Q. At that time you were convicted for slandering, for offending the
15 former president Tito, isn't it?
16 A. Yes. Tito was involved, but no, I did not insult his memory.
17 Q. But what happened?
18 A. Well, I was in railway station, in a pub, and we were sitting and
19 drinking and there was a policeman with us. And they were singing some
20 song, and I said, "Well, that's not really how it is, you -- it's like
21 that." And he said, "What do you know about this song? What do you
22 want?" Right. And he tells me, "Well, if you know the lyrics of that
23 song, you sing it." And when he said that, I said, "Oh, fuck it. I've
24 just forgotten it." And then he said, "Oh, so you are using foul language
25 to speak about Tito and you this, you that." But I've never done that in
Page 1304
1 my life.
2 Q. A moment ago you told us that you were a member of the Liberal
3 Party. I do apologise. You told us a while ago that you were a member of
4 the Liberal Party, and just in a sentence will you tell us which were the
5 -- what was the basic political doctrine of that party?
6 A. You mean --
7 Q. Very briefly.
8 A. You mean -- well, I was just an ordinary member. I wasn't a
9 politician.
10 Q. Yes. I understand that you were a member, but you must have had a
11 reason to join that party?
12 A. Because everybody was in that, Croats and Serbs and Muslims and
13 all the others, and that's why I was there too.
14 Q. It is true that the Serbs took over the town of Prijedor without
15 firing a single bullet?
16 A. Yes.
17 Q. And it is also true that you heard about that, as far as I
18 understood you, from the radio because the power had been cut off?
19 A. I was with a friend who used to work for a bakery up there, and
20 his name is Mladen Rabac, and he worked in a bakery, and I was with him,
21 that is I visited him from time to time. He would just say, "Why don't
22 you come over? Why don't you drop by?" And I did drop there and I was
23 there until 4.00 or 5.00 in the morning because the bakery was open --
24 open only at night, and I was carrying some -- carrying rolls or something
25 with me. And I saw some vehicles full of troops, but no plates, nothing,
Page 1305
1 just passing by. What they were doing, I really don't know. But when I
2 arrived home in the morning, then I learned that the SDS had taken over
3 power in Prijedor.
4 Q. So at that time, in Prijedor, the power had already been cut off,
5 is it, was cut off or you began to run into trouble with power supply
6 because you said that you had to use your radios because television was
7 not working?
8 A. Yes, that's quite true. There was no electricity.
9 Q. And in the months that followed, while you were detained in that
10 Keraterm, there was no electricity?
11 A. Well, at times there was; at times there wasn't.
12 Q. Could you tell us the frequency of power outings and the other,
13 and when you had the power?
14 A. I can't really tell you.
15 Q. You mentioned in your statement that in pre-war Bosnia there were
16 very many mixed marriages; is that correct?
17 A. Yes, it is.
18 Q. And I should say around 70 per cent, isn't it; wouldn't you say?
19 What do you think? How many?
20 A. Well, had I ever got married, perhaps I would have known that.
21 Q. And it is quite true that in Prijedor people gave their children
22 names regardless of whether their children were Serb? They were often
23 given Croat names or the other way around? There were many such cases?
24 A. I don't know.
25 Q. And do you know what kind of a name is Damir, whose name is it?
Page 1306
1 A. No.
2 Q. It doesn't sound like a Croat name to you, does it?
3 A. I have a friend whose name is Jasmin and yet he's a Serb.
4 Q. If I understood you well, before the war, you all frequented the
5 same places, you all socialised and were -- and kept company to each
6 other, with some more, with some less, isn't it?
7 A. Yes, you could say that.
8 Q. And you used to see Kajin at all those places where you went?
9 A. Well, not at all the places where I went to, yes.
10 Q. But at some places you frequented you also saw him?
11 A. Yes.
12 Q. And at that time none of you rank and file people even dreamed of
13 something might happen as what did happen a couple of weeks or couple of
14 months later?
15 A. Never. I didn't even know what was going on.
16 MR. PETROVIC: [Interpretation] Could we just go into private
17 session, please, for a moment?
18 JUDGE ROBINSON: Yes.
19 [Private session]
20 [redacted]
21 [redacted]
22 [redacted]
23 [redacted]
24 [redacted]
25 [redacted]
Page 1307
1 [redacted]
2 [redacted]
3 [redacted]
4 [redacted]
5 [redacted]
6 [redacted]
7 [Open session]
8 MR. PETROVIC: [Interpretation]
9 Q. The barracks where you were taken was at that time controlled by
10 the Yugoslav People's Army or some Serb military forces, is that how would
11 you say?
12 A. That's what I already stated.
13 Q. When did you learn that Keraterm was used as a prison for Muslims
14 and people of other faiths and ethnic groups?
15 A. When I got there.
16 Q. And you had never heard -- you had not heard about that
17 previously. After you arrived at Keraterm, you were searched, right?
18 A. Yes.
19 Q. And you did not know any one of those who searched you? Will you
20 please -- you nodded but we need a verbal answer for the record.
21 A. No.
22 Q. People who searched you were not Keraterm guards, the ones that
23 you would see later?
24 A. I don't know exactly. I did not know them. That was it.
25 Q. And later on you never met them, correct, if I understand you
Page 1308
1 correctly? That is, in the subsequent two months, you did not see them
2 there?
3 A. Let me tell you something. We had our backs turned to them. This
4 is what we had to do.
5 Q. At that time did you observe that some other military police or
6 paramilitary unit was part of the security at Keraterm?
7 A. At first some came to provide assistance at night.
8 Q. Were these members of the military police or members of the
9 Territorial Defence?
10 A. I think that it was the Territorial Defence.
11 Q. Did you know any one among these people?
12 A. Yes, I knew one, Savo. He unfortunately died.
13 Q. Do you know who was their commander, who was their leader?
14 A. I wouldn't be able to tell you.
15 Q. But I wouldn't be wrong if I said that they had their own
16 commander or superior person?
17 A. It is possible, but we were not in a position to know who was
18 doing what and --
19 Q. Today also, when asked by Mr. Greaves, you said - and you
20 previously stated that too - that in the first days not much was going on
21 in the camp?
22 A. To some people nothing particular happened, but to those who were
23 member of the punishment group, they did have something happen to them.
24 Q. When you say the first days, how many days do you have in mind, a
25 couple of days, five, six days?
Page 1309
1 A. I know that it is different -- interpreted differently. A couple
2 of days sometimes means two days, sometimes a full week, sometimes even
3 ten days, sometimes -- so it refers to different time frames.
4 Q. Very well. So people interpret differently what a couple of days
5 means. To you what did a couple of days mean? Let's say in the situation
6 when -- as when you mention it in your statement, what did you mean by a
7 couple of days?
8 A. Between two and five days.
9 Q. Thank you. I presume that upon your arrival at Keraterm, you very
10 quickly learned that there were guards there, that they were organising
11 some kinds of shifts; is that correct? Did you notice that in the -- that
12 at first there were two shifts?
13 A. Yes.
14 Q. Would I be wrong if I said that -- that a person whom you called
15 Crni was in one of these shifts, in fact one of the shift's leaders?
16 A. Yes, but I don't know who he was and what he was. I didn't know
17 whether he -- who was the shift leader there, and I didn't know what he
18 was doing, but I knew that he was doing almost everything.
19 Q. And along with Crni, you also saw Zigic?
20 A. He and Zigic were there in the same shift most frequently.
21 Q. And did Zigic work as a guard at first, or you don't know that?
22 A. I don't know exactly whether he worked as a guard but he did -- he
23 was coming there, but I don't think that he worked there as a guard.
24 Q. And these shifts at first were 24-hour shifts, a full day, these
25 guards, one group, let's say Crni's group, and then another group would
Page 1310
1 come and stay for 24 hours? Was that so in these first days, as you
2 said?
3 A. I don't understand that question.
4 Q. Let me put it this way: At first when you said that there were
5 only two groups of guards, these guards worked in 24-hour intervals?
6 A. No.
7 Q. No? How long did they work?
8 A. Approximately 20 -- no, 12. Then some -- then they would go home
9 to get some rest, and the other group would come. The group that gave --
10 that provided assistance.
11 Q. A group for providing assistance?
12 A. Yes. Remember we talked about it.
13 Q. Oh, I remember. So they were not regular guards?
14 A. That is correct. They came at night.
15 Q. So in those first days, they provided security?
16 A. They provided assistance. For instance, like that friend of mine
17 Sava, and when he saw us there in the camp he started crying, threw away
18 the weapon, and went home.
19 Q. You said that later on, there were three shifts?
20 A. Yes.
21 Q. When, approximately, these three shifts became established?
22 A. They were also going 12 hours apiece, and then they would go home,
23 rest, and the next day they were the first shift, and then the second
24 shift, and those who had -- who were on the night shift would go and have
25 24 hours off to rest off.
Page 1311
1
2
3
4
5
6
7
8
9
10
11
12 Blank page inserted to ensure pagination corresponds between the French and
13 English transcripts.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1312
1 Q. When were these three shifts established, approximately, in
2 relation to your date of arrival at Keraterm?
3 A. That's an awkward question, and a lot of questions have been asked
4 of me and I don't know if I can say 100 per cent.
5 Q. Of course I'm not asking you about the exact date, especially in
6 the light of what you have gone through there, and following nine years, I
7 understand fully that you cannot remember everything. I'm asking you for
8 an approximation. We know that everything you are saying is an
9 approximation given the amount of time that has passed.
10 A. Yes. Nine years have passed by, it's a lot.
11 Q. Of course. So please, if you can do your best to put it in time
12 for me.
13 A. Well, let me tell you.
14 Q. Can we say two -- after about two weeks?
15 A. Yes. Two, three weeks.
16 Q. Let's go back to another issue. When you arrived, you were in
17 Room 2?
18 A. Yes. This is what we started calling it later. It wasn't called
19 that at that time.
20 Q. So it was an internal designation that you introduced?
21 A. No, it wasn't really us. It was them. They designated it as 1,
22 2, 3, 4. As more and more prisoners, inmates arrived, they expanded. For
23 instance, when they were gathering people from Kozarac, then a large group
24 came and --
25 Q. Very well, we'll come to that later.
Page 1313
1 A. But for two days we were in Room 2 --
2 Q. And then you were moved to Room 1?
3 A. After interrogation.
4 Q. And after having stayed in Room 1 for a few days, you moved to
5 Room 4 and this is where you stayed until the end?
6 A. Yes.
7 [redacted]
8 [redacted]
9 [redacted]
10 JUDGE ROBINSON: Mr. Petrovic, with the cooperation of the
11 interpreters, we are going to be working until 5.00, so we are going to
12 take a break until -- a break at a quarter to 4.00 for 15 minutes.
13 MR. PETROVIC: [Interpretation] Thank you, Your Honour.
14 Q. So along with -- you spent all that time with Witness B there, in
15 other words, you together came to Room 2, then to Room 1, and then
16 transferred to Room 4?
17 A. Yes.
18 Q. I assume that you were with Witness B throughout the day every
19 day? It would make sense.
20 A. Well, we did not hold hands.
21 Q. Of course. But you were there. Nobody was going there, he wasn't
22 going anywhere, you weren't going there, excluding interrogation of
23 course?
24 A. Occasionally one could go from one room to another room.
25 Q. How did you two move to Room 4?
Page 1314
1 A. I think he came to me and he said: "Do you want to come to Room
2 4?" I said "Why?" He said, "We're all going so why don't you come along
3 too."
4 Q. Do you know whether somebody had told him to go there, suggested
5 to go, or what?
6 A. They probably did, but I don't know. I didn't even know about it
7 until he mentioned it to me.
8 Q. Did three shifts start operating at the time when you moved to
9 Room 4 or perhaps a little bit before that time or a little bit after that
10 time? And as we are not saying things in -- putting things in an accurate
11 way --
12 A. You are saying that it's inaccurate. I cannot say that it's
13 inaccurate. I cannot know the exact time, the exact hour. We didn't have
14 a calendar or a watch.
15 Q. Well, this is why I'm trying to relate it to a certain event like
16 your move to Room 4. So was it around that time?
17 A. What event now?
18 Q. I'm sorry, I think that we had a misunderstanding. I'm going to
19 try to explain it to you again. My question to you is: Because you
20 cannot recall a date, which I understand and fully respect given the
21 amount of time that has passed, can we say that you moved to Room 4
22 approximately a day plus/minus, but around the time when three shifts
23 started operating?
24 A. When the people from Kozarac were gathered, this is when the third
25 room was established. There were too many of us in the first and second.
Page 1315
1 We couldn't breathe anymore. The air was too stuffy.
2 Q. Let's try it this way. Kozarac took -- happened in late May; is
3 that correct? They gathered these people around in late May, and in the
4 very first days of June, they were already there. They were already
5 detained.
6 A. I could not tell you exactly. These -- at that time, we were
7 in -- also in fear. We were a bit lost. Too lost to be able to say
8 that.
9 MR. PETROVIC: [Interpretation] Your Honours, this might be the
10 right moment for a break.
11 JUDGE ROBINSON: Yes, it is. We'll take a break until 4.00.
12 Witness E, you are reminded not to discuss your evidence with anybody
13 during the break including members of the Prosecution team.
14 --- Recess taken at 3.45 p.m.
15 --- On resuming at 4.00 p.m.
16 JUDGE ROBINSON: Yes, Mr. Petrovic?
17 MR. PETROVIC: [Interpretation] Thank you, Your Honour.
18 Q. Witness E, you repeatedly said today that brothers Banovic were on
19 Crni's shift, isn't it?
20 A. Yes.
21 Q. Will you tell me, please, will you please try to describe Crni
22 once again? What did he look like, how did he dress?
23 A. I think he was about 170 tall. I never measured him, so I can't
24 really know. And he was always in a black T-shirt, short sleeves, short
25 hair, dark, well-built.
Page 1316
1 Q. Did you used to see that man around the town before the war?
2 A. Once or twice perhaps, on a motorbike or something.
3 Q. What kind of a motorbike?
4 A. He rode a Kawasaki.
5 Q. Did you frequent Zvejzdas?
6 A. I wouldn't know.
7 Q. And where did you see him around the town, if you remember?
8 A. Somewhere near the fly-over.
9 Q. Tomo Prodan, does that ring a bell?
10 A. Yes.
11 Q. You don't know a man called Tomo Prodan?
12 A. I didn't really know people's names.
13 Q. Did you ever discuss a person called Tomo Prodan with your
14 brother? Perhaps he knew him.
15 THE INTERPRETER: The interpreters did not hear the answer.
16 MR. PETROVIC: [Interpretation]
17 Q. And what does this Banovic who used this baseball bat look like?
18 A. Well, he was on the short side with long hair.
19 Q. Was there anything characteristic about him, something else?
20 A. I couldn't really say now.
21 Q. You mentioned today you -- on several occasions you mentioned an
22 event or rather the incident with Jovo Radocaj, didn't you?
23 A. I know that his first name was Jovo. What was his last name, I
24 don't know.
25 Q. At the time when he was beaten, you stood in the doorway of your
Page 1317
1 dormitory and watched it, didn't you?
2 A. What do you mean? What does "doorway" mean?
3 Q. You were in the door, I mean the door frame?
4 A. Well, I was slightly over there.
5 Q. Where?
6 A. On the inside.
7 Q. So you -- as you testified today, you saw that Banovic hit --
8 Banovic hit Jovo with his bat 10 or perhaps 12 times?
9 A. Well, I didn't stand there all the time.
10 Q. But you saw him beat him, didn't you?
11 A. Yes.
12 Q. And before that, if I remember well, you said today how he called
13 him out?
14 THE INTERPRETER: We could not hear the witness's answer.
15 JUDGE ROBINSON: Witness E, your answers are not being picked up
16 by the interpreter. Would you please move forward closer to the
17 microphone?
18 A. Will that be all right?
19 JUDGE ROBINSON: Please continue.
20 MR. PETROVIC: [Interpretation] Thank you, Your Honour.
21 Q. A while ago you described how he was taken from Room 1 towards
22 your room, isn't it?
23 A. Yes.
24 Q. There in front of your room is where the incident that we are
25 talking about happened. Will you please give us an answer? Will you
Page 1318
1 please say yes or no? Don't just nod your head because the interpreters
2 cannot interpret that.
3 A. I saw Banovic beat him when he brought him into that passage or
4 whatever.
5 Q. What passage?
6 A. Well, that passage of Room 4.
7 Q. He brought him from some other place?
8 A. Yes. He brought him there. He took him over to the weigh bridge.
9 Q. So they took him towards the weigh bridge from the direction of
10 Room 1?
11 A. From number 1 or from 2. No, from number 4 towards the weigh
12 bridge.
13 Q. Now, let us try to figure this out. This morning you said they
14 took him from the direction of Rooms 1 and 2 towards Room 4.
15 A. This morning I said they called him out from Room 4. He wasn't in
16 Room 1. He was in Room 4. And they took him up there, and then they beat
17 him on the way from there to here, from 1 to 4. I think that is what I
18 said.
19 Q. Right. And you said it was during Crni's shift?
20 A. Yes.
21 Q. And who carried Jovo into that room where you were?
22 A. They brought him into that passage there, and then they told three
23 or four of our inmates to carry him away.
24 Q. Do you remember one of those detainees who carried him in?
25 A. No.
Page 1319
1 Q. Then when you testified about Drago Tokmadzic's death, you said
2 how you saw a hearse take him away in the morning?
3 A. Well, not really in the morning. He first lay there for sometime
4 until they arrived.
5 Q. Did you see, perhaps, a woman, a physician come in the morning to
6 establish his death? Did you see any of the policemen who were not any of
7 the regular guards in the Keraterm there that morning? Will you please
8 say yes or no.
9 A. No, I did not see that.
10 Q. This morning you spoke about the incident involving Car. In the
11 beginning of your examination, you described in detail who beat him and
12 you said it was Ziga and Duca. Was Crni there?
13 A. Yes, Crni was there and Keli too.
14 Q. Today you told us about this event in detail, but later on, when
15 my learned friend from the Prosecution asked you about Kajin, you then
16 said, "Maybe," "Perhaps," "I think so," something to that effect, that you
17 also saw Kajin there.
18 You made several statements as it has already been established
19 about that, and today during your direct examination, until the Prosecutor
20 asked you about Kajin, you also told us about that without ever mentioning
21 this detail, and I'll read you some of that. This is a statement of the
22 20th -- no, let's start from the statement that you made in February 1995
23 which is three years after you left Keraterm.
24 You said as follows: "I saw Zigic and Duca beat Car. There were
25 present other guards, but I cannot remember the names and I cannot
Page 1320
1 describe others who were there. I was in Room 2. The beating took place
2 and I watched it with others from a distance of 16 metres."
3 That is what you said in February 1995. Then in August this year,
4 and at this interview the -- my learned friend from the Prosecution who
5 examined you today was present also, and you describe in detail the
6 beating of Car. "Crni, Zigic, Duca also took part in this." That is
7 identical as you told us today. You said, "There were also others who
8 beat Car, but I cannot remember who they were."
9 So in none of your statements, three years after that or the
10 statement that you made a few months ago, August last year, you never
11 mentioned Kajin.
12 A. No, I don't, because he was the commander there.
13 Q. So you -- the first time you mentioned that Kajin was present was
14 in the conversation with the Prosecutor a few days ago. How is it that
15 you suddenly remembered it?
16 A. Well, one can always remember something.
17 Q. But how did you remember?
18 A. I don't know, but I did.
19 Q. Wouldn't it be true that you are not sure whether he was there or
20 wasn't; would you allow such a possibility?
21 A. Kajin was there at the time.
22 Q. Tell me then where did Kajin stand?
23 A. I think as there was a bunker -- there was a bunker there and they
24 were beating him there, and he was behind them. From my angle I think he
25 was behind them.
Page 1321
1 Q. Will you take it slowly and tell us where did you stand? Where
2 was Car beaten? Where did you stand?
3 A. I was in dormitory 2.
4 Q. And who was there with you?
5 A. All the detainees.
6 Q. Was your brother there?
7 A. He was there too, but he wasn't with me.
8 Q. Was there somebody else?
9 A. Well, I'm telling you all the detainees were there, all of them.
10 Q. Right. Do you want me to give you names?
11 Q. No, there is no need to. So everybody watched it?
12 A. Yes.
13 Q. And they all saw what you saw?
14 A. Well, they should have, unless they had their heads down or
15 something.
16 Q. So where did this thing happen?
17 A. Right next to the bunker, next to the weigh bridge, the weigh
18 bridge is slightly in front of it. I'm talking about Keraterm. The weigh
19 bridge is in front of -- they were next to the bunker, whether they called
20 it the bunker or something, but it is -- that is where it happened.
21 MR. PETROVIC: [Interpretation] Could the witness be shown
22 Prosecutor's Exhibit 2B, please?
23 Q. Will you please -- will you show us on this photograph where did
24 you stand?
25 A. This is dormitory 2, and I was inside, perhaps two or three metres
Page 1322
1
2
3
4
5
6
7
8
9
10
11
12 Blank page inserted to ensure pagination corresponds between the French and
13 English transcripts.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1323
1 away, to the right if you now face the building, right here where I'm
2 pointing.
3 Q. So two or three metres behind the door?
4 A. No, not behind the door because the door was open.
5 Q. But inside?
6 A. Yes, inside.
7 Q. And where were others? Behind you, next to you, in front of you?
8 A. Well, they were all there next to me, behind me. There was
9 perhaps one in front of me, only one, maybe one, perhaps just one. I
10 can't remember exactly.
11 Q. And where were Ziga, Duca, and Crni? Where were they?
12 A. You can't see it on this photograph.
13 Q. Let us then try with Exhibit 2G. Would that be more or less the
14 view from dormitory 2?
15 A. No.
16 Q. Will you have 2B again, please?
17 MR. PETROVIC: [Interpretation] With your leave may we just look
18 for the right photograph? Could you please put this photograph -- show
19 this photograph to the witness?
20 Q. This is a photograph of a model. Can you recognise it?
21 A. Yes.
22 Q. Right. Now, will you show on this photograph where was Ziga,
23 Crni?
24 A. Here, at this corner here. Can you see it, this door here? That
25 is Room 2. This is number 2, the door right next to this larger room, and
Page 1324
1 they were here, directly at the bunker, and as you look from the
2 dormitory, the bunker is to the left, and they were to the left of the
3 bunker. And that is in front of the bunker that he ran in circles and
4 carried this machine-gun.
5 Q. And now just tell me when is it that you saw Kajin?
6 A. Well, Kajin was there all the time. He was there all day.
7 Q. But you just -- you say all day?
8 A. Yes.
9 Q. So perhaps you saw him before that and perhaps you saw him after
10 that?
11 A. He was there all the time, next to that bunker. They were all
12 there by the bunker watching Car circling.
13 Q. I'm not asking you about all of them. I'm asking about Kajin.
14 A. And I'm telling you that Kajin was there.
15 Q. Will you please show us exactly where is it that he stood when you
16 saw him?
17 A. Well, I do not know the time.
18 Q. I'm not saying the time. I'm asking about the place. That is
19 where he was all the time?
20 A. Yes, all the time.
21 Q. And how long did it all take?
22 A. I couldn't tell you that.
23 Q. Well, did it take a couple of minutes or --
24 A. Can't say. It could be couple of minutes and it could have been a
25 couple of hours. I really don't know.
Page 1325
1 Q. Very well. Thank you. In August were you interviewed in detail
2 about Kajin's role in that -- in Keraterm by the investigators, that is my
3 learned friend from the Prosecution? Did he ask you in detail about this?
4 A. Well, he was the shift commander at the time.
5 Q. That is not what I'm asking you. I'm asking you whether you spoke
6 in detail about Kajin's role in Keraterm in August when the investigators
7 interviewed you, visited you, headed by my learned friend?
8 A. Well, we discussed it. Whether it was in great detail or not, I
9 really don't know.
10 Q. But you answered all the questions about Kajin that the Prosecutor
11 asked you?
12 THE INTERPRETER: The witness says yes, the interpreters believe,
13 because he's away from the microphone.
14 Q. But you answered to the best of your recollection at that point in
15 time?
16 THE INTERPRETER: The interpreters believe the witness said yes
17 because he is away from the microphone.
18 Q. And on that occasion, you were also asked details about Car?
19 JUDGE ROBINSON: Again, I ask -- the interpreters are having
20 difficulty hearing your answers, so please stay closer to the microphone.
21 A. My apologies.
22 JUDGE ROBINSON: Go ahead.
23 MR. PETROVIC: [Interpretation] Thank you, Your Honour.
24 Q. On that occasion you were asked in detail also about the incident
25 concerning Car?
Page 1326
1 A. Yes.
2 Q. And on that occasion you said who took part in that and who was
3 present?
4 A. Well, yes, but I couldn't remember all of them.
5 Q. For the last time, I'm asking you to explain it to us. How is it
6 that you remembered it on the 23rd of March, 2001, nine years later, and
7 after so many previous questions about Car and Kajin?
8 A. How? Well, I wouldn't know myself, but whatever, I just
9 remembered.
10 Q. Well, I put it to you that you are not sure that you saw Kajin
11 there and that you are now affirming something that you did not see or, at
12 best, what you are not sure about?
13 A. I do affirm that Kajin was there.
14 Q. Right. Let us move on to some other topics. You mentioned that
15 in Keraterm, Faca killed a man. What was that man's name?
16 A. I didn't mention that he killed a man. A man, relative of the
17 killed person came to me. He lived in Brezicani, and he said that Faca
18 had killed his relative in the WC.
19 Q. When I say "mentioned," I mean you mentioned it today during the
20 examination. I don't mean anything else. What was that man's name?
21 A. I don't know.
22 Q. Perhaps I will refresh your memory if I tell you that his name is
23 Muharem Nadarevic?
24 A. Oh, perhaps I didn't understand what you said who it was who told
25 me that. Did you ask me who was killed or who told me that?
Page 1327
1 Q. Who was killed.
2 A. But Muharem Nadarevic wasn't killed.
3 Q. What was the name of the man who was killed?
4 A. I don't know.
5 Q. Tell us, after the incident that you described, that is, after the
6 murder or the massacre, whatever you care to call it in Room 3, in the
7 morning Cupo came to your room and asked, "Are there any wounded?"
8 A. He did not enter the room. He was next to the edge of the
9 building, and he said then, "Are there any wounded?" And one guy who was
10 wounded by the ricocheted bullet casing said that he'd been wounded and so
11 he said that he was wounded.
12 Q. And at that point, Cupo's shift wasn't on duty, isn't it?
13 A. I remembered it later. I remember it later that they had taken
14 over the duty. I did not remember it at that time.
15 Q. But in your statement of 15th August, you said the following, "I
16 remember that in the morning after the massacre, Cupo Banovic turned up at
17 the doorway to my room and asked if there were any wounded."
18 A. Right.
19 Q. Next sentence, "I don't know why he was in the camp because his
20 shift was not on duty that morning." So when is it that you remembered?
21 Is it that you again remembered it a few days ago?
22 A. Not a few days ago, today.
23 Q. But this is the statement that you made in August last year?
24 A. That's right.
25 JUDGE ROBINSON: There appears to be no French interpretation.
Page 1328
1 Do we have French interpretation? Yes. Yes, we now have French
2 interpretation. Please proceed.
3 MR. PETROVIC: [Interpretation] Thank you, Your Honour.
4 Q. You and your brother told that man not to come out, but he wanted
5 to come out, I mean the wounded man.
6 A. Right.
7 Q. And that same evening, a new massacre took place, didn't it?
8 A. Yes.
9 Q. And that night, Crni was on duty?
10 A. Well, that was the shift. That's the shift, the one that stayed
11 on.
12 Q. So now let's try it this way. The second massacre took place the
13 next night; am I right?
14 A. Yes.
15 Q. At what time of the night approximately?
16 A. Around 3.00 or thereabouts. That was it. I don't know exactly,
17 because I had no way of determining that.
18 Q. But -- and Crni's shift was on at that time. That is what you
19 said.
20 A. Well, I don't know exactly what shift. Perhaps it was another
21 shift that day and they came back nevertheless.
22 Q. You mentioned this incident that happened, and I am going back to
23 the pre-war situation. The incident that you had with Kajin in a
24 restaurant at the railway station, or what is it, a coffee shop or
25 something. There was a clash between the two of you, wasn't there?
Page 1329
1 A. Yes.
2 Q. And there was another guy with him. And who paid the piper to put
3 it that way?
4 A. They won.
5 Q. Did you exchange some blows, were there any fisticuffs or
6 something?
7 A. Yes.
8 Q. I read you two statements, and I conclude from them that Kajin was
9 the ones who fared worse.
10 A. Well, if you say so.
11 Q. In your first statement you said that you had an argument with
12 him. In the second one you said you had a fight, which one is right?
13 A. The second, we got into a fight.
14 Q. Your statement -- your August statement says, "Before the war I
15 knew him superficially, but once I gave him a beating. Once I beat him."
16 Is that correct?
17 A. Well, we got into a fight. Now who got the beating, really I
18 cannot say. But be that as it may, the two of them fled.
19 Q. Do you remember if you hit him once, more?
20 A. Well, I guess so. I can't really remember because it could have
21 been, I don't know, 12, 13 years ago.
22 Q. Could you remember where did you hit him? Do you -- can you
23 remember?
24 A. No, I can't.
25 Q. Well, can I then conclude that you held a grudge against one
Page 1330
1 another?
2 A. No, never. Nothing, nothing before that or after that. Except
3 that he refused to pay that woman for the use of lavatory. I told him,
4 "Why don't you pay that?" And then they jumped, "Why are you meddling?
5 Stop it." And that is how we came to fists.
6 Q. But on the first -- initially when you arrived at Keraterm, you
7 were afraid to meet face to face with Kajin?
8 A. Yes.
9 Q. Why?
10 A. Because earlier some men had come and, for instance, he slapped
11 him and others brought him out and beat him.
12 Q. So they were taking out revenge on people for what he had done?
13 A. Yes, I said for a slap.
14 Q. Is it true that Kajin did nothing to avenge himself on you?
15 A. That is correct.
16 Q. Did he say that no one was to touch you?
17 A. He said as follows: "I am not one of those who will bear a
18 grudge." I don't know how to explain it. "So I'm not one of those who
19 will seek revenge."
20 Q. Yes.
21 A. So this happened between men. And he said, "Had you had weapons
22 on, I would have killed you, but while I was -- while I'm here, nobody can
23 touch you."
24 Q. Are you referring to the weapons used during the attack on
25 Prijedor?
Page 1331
1 A. Carrying our arms in general. I didn't even know about the attack
2 on Prijedor.
3 Q. After that, did you have some courage to get out after you talked
4 to him?
5 A. Yes. After that I had no problem.
6 Q. Until then you did not come out at all?
7 A. That was at the very beginning for the first two or three days.
8 Q. Did Kajin treat anyone else in this way, this fair and protective
9 way, if I can put it that way?
10 A. Well, he did not allow just anyone to be bothered.
11 Q. You mean was it only the people whom he knew, or he did not pay
12 attention, he did not discriminate?
13 A. He said those who were innocent, he said that those who were
14 innocent would not be bothered.
15 Q. In one of your statements of 1995, you said that Kajin was too
16 soft with the prisoners. What did you mean by that?
17 A. I don't understand the question.
18 Q. Let me read it to you. The statement is from 1995, that is the
19 one from February. "I think that they believed that Kajin was too soft on
20 detainees, and he was relieved after I don't know how many days."
21 A. Most probably he was on the side of the people who had not done
22 anything. He was protecting them. He probably knew that some of these
23 people did not do anything or had nothing to do with some things. For
24 instance, that attack on Prijedor, on whatever these people called it, I
25 don't know what people did and who was involved in what. First of all, we
Page 1332
1
2
3
4
5
6
7
8
9
10
11
12 Blank page inserted to ensure pagination corresponds between the French and
13 English transcripts.
14
15
16
17
18
19
20
21
22
23
24
25
Page 1333
1 didn't even know why we were being taken to the camp.
2 Q. At that time you said Kajin allowed doctors to treat you?
3 A. Yes, that is correct. And we asked for pills, and in fact a man
4 who was missing an arm would come with medicines and other things.
5 Q. Did Kajin call him to come?
6 A. Yes. We told Kajin what we needed and then he did it.
7 Q. When Kajin was on duty, were there any problems -- and when he was
8 present, were there any problems about going to the toilet? Did you have
9 any problems in that regard? If you don't know, I'll just withdraw the
10 question.
11 You mentioned a moment ago that Kajin was present during another
12 incident when someone called Sistek -- was that Samir Sistek?
13 A. Yes. He was from Foca.
14 Q. When he was taken out. And Kajin was not present when he was
15 taken out?
16 A. He was there, to the side.
17 Q. No, no, no. I'm referring to the moment when he was called out
18 from the room, when he was taken out of the room, when Sistek and another
19 man were taken out, Kajin was not present?
20 A. He was present, off to the side.
21 Q. What do you mean to the side?
22 A. He was to the left.
23 Q. Can you please describe this to the left? To the left of what?
24 A. When I looked out the room, Room number 2, straight to the right
25 were Duca and Zigic, and I don't know how many were there. There was one
Page 1334
1 with a red beret, I didn't know how many men were there. We couldn't even
2 see all of them. And I saw first they made this Kocijas to sing some
3 songs and he did. And then it was, "Let's see, guys, how brave you are,
4 how you can fight." So they asked they fight each other.
5 Q. But who was it who was calling them out?
6 A. It was Zigic.
7 Q. And who was telling them, "Come on guys, let's see"? Who was
8 that?
9 A. Zigic.
10 Q. And who demanded that they fight each other?
11 A. Zigic.
12 Q. And what time of the day was that?
13 A. It was around the nightfall. I cannot say exactly whether it was
14 8.00, 9.00 or 10.00.
15 Q. Was that the time around the point when the shifts were changing?
16 A. I wouldn't be able to tell you.
17 Q. How long did this last?
18 A. I don't know.
19 Q. Approximately?
20 A. Approximately half an hour.
21 Q. Can you just tell me when did you recall that incident?
22 A. It sort of came to me, I don't know exactly, but I remembered it.
23 Q. When did it happen, on the 23rd of May? What incident -- I
24 apologise. Now, the incident I'm referring to now --
25 A. Oh, I've known that from the beginning when I first arrived, since
Page 1335
1 I was there.
2 Q. My question to you is --
3 A. Oh, you mean when I remembered?
4 Q. Yes.
5 A. Perhaps last year.
6 Q. Did you know about that incident in August last year?
7 A. Yes.
8 Q. When the Prosecutor asked you about Kajin in great detail and
9 comprehensively, why didn't you tell him that?
10 A. I didn't think of it. There are many things that I still haven't
11 said.
12 Q. Did he ask you in detail about Kajin?
13 A. He asked me approximately what shifts there were, who was shift
14 commander, whether Kajin was shift commander, whether he was shift
15 commander, camp commander, things like that.
16 Q. Did he ask you whether Kajin took part in any of the incidents?
17 A. Yes, he did.
18 Q. Why didn't you say it then, that -- what you said now?
19 A. Well, he didn't take part. He just observed it.
20 Q. But did he, my friend, ask you whether he was present? And
21 knowing that he is professional, I'm sure that he would have asked you
22 whether he was present at the incident.
23 A. I don't know. Maybe I made some kind of mistake, perhaps. I
24 don't know.
25 Q. You said a mistake. What does it mean? You did not remember?
Page 1336
1 A. I guess I did not remember at the moment.
2 Q. How long did this interview last?
3 A. I don't know. I don't know exactly.
4 Q. Did this interview last half an hour, 15 minutes? Your interview
5 with the -- my learned colleague who examined you today?
6 A. You mean --
7 Q. No, no. I'm not referring to the examination today. The
8 interview with the Prosecutor in August last year.
9 A. I don't know, five or six hours.
10 Q. And in these five or six hours of conversation and recollection,
11 you could not remember what you just told us today?
12 A. Questions are one thing and answers are another thing. A person
13 forgets things.
14 Q. Let me sum up. The same person asked you the same question and
15 you gave different answers?
16 A. I recalled what I had seen. I did not lie about anything. And I
17 did not say anything that was untrue but only things that I remembered and
18 that I saw.
19 Q. Today you said this: During the first days, at first, Kajin was
20 the camp commander?
21 A. Yes.
22 Q. Then when I asked you, when I asked you to explain to me what the
23 first days or the beginning meant to you, you said that it could have been
24 a couple of days or five or six days, correct?
25 A. Yes. It was couple of days or approximately five to six days.
Page 1337
1 Q. When you said the first days you meant?
2 A. When we first came to the camp.
3 Q. So the first couple of days are the first five or six days?
4 A. Yes.
5 Q. To my learned friend, Mr. Greaves, you said that this was 25 days?
6 A. From where?
7 Q. That Kajin was the camp commander for 25 days?
8 A. I said that in the first days there were no problems, that we
9 were --
10 Q. I'm sorry, I wasn't asking you about problems. I was asking you
11 about who the camp commander was. You said five or six days, then about
12 an hour ago you said 25 days?
13 A. I said that he was relieved of duty 20 -- I'm saying 25 days
14 before he was relieved of duty.
15 Q. Let me try -- perhaps we don't understand each other.
16 MR. PETROVIC: [Interpretation] With the indulgence of the Trial
17 Chamber, I think this is an important point. I would like to take it from
18 the top.
19 JUDGE ROBINSON: Continue, if you can do it quickly, yes.
20 MR. PETROVIC: [Interpretation] Yes, thank you.
21 Q. This morning you said that Kajin was the commander at Keraterm in
22 the first days, in the beginning. Then when I asked you -- when I asked
23 you to explain what the first days -- what the beginning was, you said
24 five to six days; is that correct?
25 A. You asked me what it means a couple of days. That's all you asked
Page 1338
1 me.
2 Q. I had asked you and we discussed it at some length, what it meant
3 to you the couple of days and the first days?
4 A. Yes, and I explained it to you.
5 Q. When we bring these two together, the first days, and what it
6 means to you, the first days or the first couple of days, we come to Kajin
7 being the commander for five or six days or I don't understand you at
8 all.
9 A. Kajin was the commander until Sikirica arrived.
10 Q. That is not in dispute, we agree on that.
11 A. I think it went on longer.
12 Q. What I'm interested in knowing is exactly how much time?
13 A. We did not have the calendar or a watch. I can say one, two,
14 five, 15, 50 days. To me it was all the same.
15 Q. You said in the beginning in the first days --
16 JUDGE ROBINSON: Mr. Petrovic, I think we -- I think you've
17 covered that sufficiently. You have been on this point for quite some
18 time.
19 MR. PETROVIC: [Interpretation] With your indulgence and with my
20 utmost respect, if you can indulge me for a couple more questions only.
21 Just to try to clarify it.
22 JUDGE ROBINSON: Yes.
23 MR. PETROVIC: [Interpretation]
24 Q. You said that in the first days at the beginning, the command --
25 he was the commander, and then you said that it was 25 days. You spent a
Page 1339
1 total of two months in Keraterm. For you, the beginning is the first half
2 of your stay in Keraterm?
3 A. He was there from the first day when we entered and the next day
4 until the evening, and then in the evening he was relieved by Sikirica. I
5 don't know how many days it was. I don't know. We can say -- it's very
6 thought-involving this whole thing.
7 Q. Very well. Let's move on. At first who were the shift
8 commanders?
9 A. Kajin was, in this one shift, and I don't know about the others.
10 I don't know about the other two shifts.
11 Q. At first were you locked up by Kajin and then the next night by
12 Crni?
13 A. I cannot recall now, but the door was closed. I don't know
14 whether the door was locked.
15 Q. In these first days, did you see Kajin at night?
16 A. Perhaps at first until they got organised. I don't know exactly.
17 MR. PETROVIC: [Interpretation] Just one moment, Your Honours.
18 [Defence counsel confer]
19 MR. PETROVIC: [Interpretation]
20 Q. When Sikirica arrived, how many times did you see Kajin after
21 that?
22 A. I don't know exactly, once, twice.
23 MR. PETROVIC: [Interpretation] Just one moment, please.
24 [Defence counsel confer]
25 MR. PETROVIC: [Interpretation]
Page 1340
1 Q. In your statement from August last year, you said this: "After
2 that, I saw Kajin in the camp on only one more occasion. Perhaps he came
3 more often."
4 A. After?
5 Q. I'm asking after Sikirica.
6 A. Perhaps once. He may have come more often.
7 Q. Just three quick questions. In the beginning, if you can tell me,
8 you who were detained there, did you receive food from your homes? Did
9 somebody come to the gate to deliver something?
10 A. Yes.
11 Q. Do you perhaps remember one occasion when a soldier drove up to
12 the camp and pulled out a zolja and tried to fire it at you inside?
13 A. I don't recall.
14 Q. And can you tell me one more thing: Do you remember whether there
15 was some special lighting in Keraterm? Were there any floodlights?
16 A. After that massacre, yes, there were some floodlights.
17 Q. Do you recall whether Zigic was also detained, locked up in one of
18 these rooms at Keraterm?
19 A. I don't recall that.
20 Q. Do you remember a person named Maroslic whom Zigic released from
21 prison in exchange for money?
22 A. I don't know who that person is.
23 MR. PETROVIC: [Interpretation] I have no further questions, thank
24 you.
25 JUDGE ROBINSON: Yes, Mr. Ryneveld.
Page 1341
1 MR. RYNEVELD: Your Honours, before Mr. Vucicevic starts, I just
2 wondered, in light of the extensive cross-examination on statements which
3 the witness didn't have an opportunity to see, and because there may be
4 some issues of credibility that the Court may want to take into account as
5 a result of cross-examination, whether the statements to which the witness
6 was cross-examined on ought not now be marked as exhibits in these
7 proceedings, especially in relation to allegations of recent recollection
8 of events and as you know from the proofing the document that we have
9 provided, the sources have been provided in terms of where that was
10 provided.
11 I think it's important for the Court that these statements to
12 which reference has been made ought be marked as exhibits.
13 [Trial Chamber confers]
14 JUDGE ROBINSON: Yes. Yes. We agree. Certainly. I'd like to
15 see them.
16 MR. RYNEVELD: Thank you, Your Honour. I don't know -- I think we
17 have copies now, but otherwise we can certainly provide them by tomorrow
18 morning, but we may have enough copies now to have them marked.
19 JUDGE ROBINSON: You can do that later.
20 Mr. Vucicevic --
21 MR. VUCICEVIC: I will try to finish in five minutes.
22 JUDGE ROBINSON: I think tomorrow morning. Have the night to
23 reflect and come back refreshed.
24 MR. VUCICEVIC: Thank you, Your Honour. It will be good for both
25 the witness and myself.
Page 1342
1 JUDGE ROBINSON: Yes, certain.
2 We are going to take the adjournment now.
3 Witness E, you are reminded not to discuss your evidence with
4 anybody including the members of the Prosecution team. We adjourn until
5 9.30 tomorrow.
6 --- Whereupon the hearing adjourned
7 at 4.57 p.m., to be reconvened on Thursday
8 the 29th day of March, 2001, at
9 9.30 a.m.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25