Tribunal Criminal Tribunal for the Former Yugoslavia

Page 1343

1 Thursday, 29 March 2001

2 [Open session]

3 [The witness entered court]

4 [The accused entered court]

5 --- Upon commencing at 9.32 a.m.

6 JUDGE ROBINSON: Mr. Vucicevic, you are to commence your

7 cross-examination.

8 MR. VUCICEVIC: Thank you, Your Honour.


10 [Witness answered through interpreter]

11 Cross-examined by Mr. Vucicevic:

12 Q. Good morning, Witness E.

13 THE INTERPRETER: Mr. Vucicevic, your microphone.


15 Q. Good morning. My name is Dusan Vucicevic. I'm an attorney from

16 Chicago, and I represent Dragan Kolundzija in this matter.

17 MR. RYNEVELD: Excuse me for interrupting.


19 MR. RYNEVELD: Our headsets don't appear to be working and

20 although I can hear Mr. Vucicevic, I don't anticipate I will be able to

21 hear the witness' answer. Nothing is working on our control panel.

22 JUDGE ROBINSON: Let us have that matter checked. Is it working

23 now?

24 MR. RYNEVELD: This panel still doesn't, but I have an alternate

25 one that will work. The usher has solved our problem.

Page 1344

1 THE INTERPRETER: Microphone for Mr. Ryneveld.

2 MR. RYNEVELD: I'm just going to say that the panel still doesn't

3 work but the usher has fixed our problem. We have an alternate source of

4 input, that's fine.

5 JUDGE ROBINSON: Thank you. You may continue.


7 Q. Witness E, you testified yesterday that you were arrested by

8 soldiers and also after some detour, you were taken to Keraterm where you

9 noticed the soldiers who have checked you out, frisked you?

10 A. The soldiers, the guards, those who were with us who escorted the

11 bus.

12 Q. You also testified when you came to the Keraterm, you did not know

13 anybody who was there. Were those men who were there soldiers, but not

14 the guards that came a few days later; is that correct?

15 A. It is, yes.

16 Q. So you did not notice -- you didn't see Kole there when you came.

17 So you saw Kole a few days later. If you could approximately say how many

18 days later?

19 A. I wouldn't know.

20 Q. Okay. Now, I'm going to ask you just quickly a few questions that

21 you have testified about yesterday, and to amplify them some. You said

22 that you never saw any beatings, torture, killings, or any mistreatment of

23 prisoners on Kole's shift; isn't that true?

24 A. It is.

25 Q. As a matter of fact, on Kole's shift there was several things that

Page 1345

1 were done throughout which made your stay there somewhat easier; isn't

2 that correct?

3 A. Yes.

4 Q. You testified about your brother and you using the phone, but

5 somehow the transcript showed that it was only you and your brother that

6 used the phone. You meant the other people used the phone also.

7 A. Perhaps. I did not see that.

8 Q. On how many occasions have you used the phone on Kole's shift?

9 A. Once or maybe twice, twice, I think.

10 Q. And if you -- if we take as a reference point, the beating that

11 you suffered by Crni on his shift, was the first time that you used the

12 phone before you were beaten up?

13 A. I couldn't say. I'm not sure. I don't know exactly. No, I did

14 not use the telephone after I was beaten.

15 Q. Do you know whether your brother had used the phone to inform your

16 family that you are doing well, whatever it means under the circumstances

17 of your confinement, but that you are still alive after the shooting on

18 Room 3?

19 A. Yes.

20 Q. Let me move to food and water supplies. Are you aware that Kole

21 took several prisoners on many occasions to the water well in the

22 neighbourhood to fetch some cold, clean water for drinking?

23 A. I know nothing about it, believe me.

24 Q. Do you know that Kole took a few inmates home to change, to see

25 their families and they brought them back home?

Page 1346

1 A. Yes. There were several of them.

2 Q. If you know, who were those inmates? Would you please state their

3 names.

4 A. I don't know their names. I just know them very superficially.

5 Q. It was very unusual and nobody has ever expected that something

6 like that could happen in Keraterm; isn't that true?

7 A. Yes, it is.

8 Q. You remember that Kole had given food which was delivered to the

9 guards but that was not consumed by the guards, that he had given to the

10 prisoners?

11 A. Yes.

12 Q. Would you please describe where was the food, that food for the

13 guards, delivered? Where was it taken, and how were the prisoners

14 selected who were -- who were fed with that additional food?

15 A. I don't remember how they were getting their food. I really

16 couldn't remember that. But he would give the food and then tell those

17 young lads and said, "Give it to those young lads." You know, there were

18 some young lads, 14, 15 years old.

19 Q. Exactly. Your recollection on that point is just enlightening the

20 court and all of us, but another point, if you could remember, was he,

21 Kole, selecting those men or he had allowed the inmates to select them?

22 A. I do not know.

23 Q. Thank you. You said that you saw Zigic came once or so on Kole's

24 shift but he didn't beat anybody at that time, didn't abuse anybody at

25 all; that's correct?

Page 1347

1 A. I cannot remember all of that now because it was a long time ago,

2 and one simply forgets things after all that time. Maybe he did come.

3 I'm not sure.

4 Q. Thank you. That was indeed a long time ago, and I appreciate your

5 answer. You said that -- when you testified on direct, and that was

6 yesterday, in the transcript that is page 59, line 4, you said that you

7 saw Kole on the night, on 24th of July, when he took over the shift;

8 that's correct?

9 A. I don't know which date it was. I'm not sure about the date

10 because we did not know the dates. I only know that Kole once took over

11 the shift and locked the dormitories around 10.00.

12 Q. So when you saw Kole that night, where was he standing when you

13 saw him for the first time?

14 A. At the door. He locked the door, he left, and then we couldn't

15 see him.

16 Q. So that -- isn't it true that that evening, and that afternoon,

17 the door of your room was open?

18 A. At night? You mean at night?

19 Q. No, what I --

20 A. After 10.00 the door was always locked. Commanders locked the

21 door to avoid then something happening or prevent somebody coming out.

22 Q. Exactly. My question then just logically follows. If that was

23 locked at 10.00, it was open prior to that and it was open throughout the

24 early evening and throughout the day; that's true?

25 A. Yes.

Page 1348

1 Q. And in your statement that you have given to the Office of the

2 Prosecutor dated August 15, 2000, which you have read -- strike it --

3 which was read to you in Bosnian, and it was true, which you had signed,

4 and I'm going to read it to you in Bosnian because I have a Bosnian

5 version here. You said: [Interpretation] "I did not see before the

6 massacre of people in Room 3 any -- I did not see any preparations before

7 the massacre of people in Room 3." [In English] You said that in -- on

8 August 15, didn't you?

9 A. Well, I suppose I did, if it says so.

10 Q. Okay. Since that was just an ordinary day, on that day, you went

11 out to drink water, didn't you?

12 A. I don't understand the question, I'm sorry.

13 Q. On that day, prior to the incident in Room 3, the shooting at Room

14 3, since that was an ordinary day, you went out to drink some water

15 throughout that day, any time from early in the morning until the time

16 that the doors were locked?

17 A. I cannot say, really, because I just don't know exactly. I don't

18 remember. I'm not sure.

19 Q. And on that day, being that it was an ordinary day, you went out

20 to have the meal, that one meal that was delivered to you once a day,

21 didn't you?

22 A. Yes, at 7.00 in the evening.

23 Q. And that meal was just delivered as on any other day, wasn't it?

24 A. No. I don't remember that it was every day because at times there

25 was no electricity, so sometimes it was delayed, but it was usually around

Page 1349

1 7.00.

2 Q. So do you remember whether there was any electricity in Keraterm

3 compound on that day?

4 A. I don't remember -- no, no, there was not.

5 Q. And the only way that you could know whether there was electricity

6 or not, it was according to the water that was pumped out of the hydrants;

7 correct?

8 A. Well, not necessarily. I do not know how they pumped the water or

9 where they did it from. At times the hydrant would drip without

10 electricity of anything. But more or less, yes, at that time when there

11 was electricity, there was water too usually.

12 Q. So Witness E, I'm just trying to kind of, you know, put some

13 landmarks here for Court to, you know, understand what was happening

14 there. And if there was anything else that -- throughout daytime, any

15 other indicators throughout the daytime that could tell you whether there

16 was electricity, please help us.

17 A. I don't remember. I don't think that there was electricity then

18 because we had electricity very seldom.

19 Q. So do you remember then whether you received water on that day by

20 means of water tank, tanker truck, that was delivering that water very

21 frequently?

22 A. No. It was the tanker from the public utilities company 4th of

23 July, and at times it would come from the fire brigade.

24 Q. So in order to know there were no water -- there was no water on

25 that day, and to have received the food, you had to go out of the room on

Page 1350

1 that day, didn't you?

2 A. Excuse me, I don't understand. Could you please reword it?

3 Q. You have already testified that you had taken some food on that

4 day that, you know, that there was no electricity on that day because

5 there was no water there. So in order to have seen all of this, you had

6 to come out and walk in front of Room 4.

7 A. Yes.

8 Q. Did you see, when you went out, any prisoners being beaten in

9 front of -- on the grass in front of the Rooms 3 and 4?

10 A. At what time?

11 Q. Any time throughout that day.

12 A. Can't remember that. I don't think so. I don't know.

13 Q. So that's why you said it was just one of those ordinary days?

14 A. I don't know what an ordinary day is to you.

15 Q. You also testified that after the door was locked, you fell

16 asleep; is that correct?

17 A. Yes. Yes.

18 Q. So --

19 MR. VUCICEVIC: Your Honours, I don't know whether the voice is

20 cutting here but my microphone is coming -- not microphone, but earphones

21 are coming on and off. It might be a lose contact. If everything is

22 okay, I will proceed.

23 JUDGE ROBINSON: Is the registrar aware of a problem, a technical

24 problem? No, we are not aware of any problems. I think you should

25 proceed.

Page 1351

1 MR. VUCICEVIC: Okay. Thank you, Your Honour.

2 Q. And you felt so secure that you could go to sleep on that

3 evening. Kole's shift was on. There was nothing to worry. As usual, you

4 could go to sleep?

5 A. When he was there, we could have some rest and get some sleep.

6 Q. Could you try to remember what exactly woke you up and at what

7 time?

8 A. I don't think I'm able to fix the time, but I think it must have

9 been after midnight, but was it 1.00 or 2.00 or 3.00 in the morning, I

10 couldn't say. We were woken up by a song from dormitory 3, and they were

11 singing, "Who is saying? Who is lying? Serbia is small." That is what

12 we heard, and that is what woke us up, because they were singing loudly.

13 Q. And there was a -- also a rancor or a quarrel and a fight among

14 the men in Room 3 because that was a really thin wall between those two

15 rooms? You could hear it, couldn't you?

16 A. I don't know what went on there, be they have a fight or what. I

17 couldn't -- you can hear some things. You can hear people talking at the

18 top of their voices or yelling. But why they were doing that, I have no

19 idea.

20 Q. While they were yelling, could you hear, "We want to break out, we

21 don't have air"?

22 A. I do not remember.

23 Q. In your statement, you indicated -- that you have given in 1995,

24 you indicated that you were beaten up 42 days after your confinement in

25 Keraterm. How did you -- this is not -- nothing to trick you, just to

Page 1352












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Page 1353

1 inform us all. How did you ascertain that number, 42? You must have been

2 counting the dates, marking them somehow.

3 A. I think we all counted days as of our arrival in the camp. That

4 was the only thing. Otherwise, there was no way of knowing.

5 Q. Okay. And you are certain that Crni was still a shift commander

6 at that time? You testified so, didn't you?

7 A. I don't understand the question. What do you mean?

8 Q. You have testified already that Crni, the shift commander who

9 called you out of the room and then who was present while you were beaten,

10 that he was indeed a shift commander on that night.

11 A. It was he who -- no, believe me, I really don't know whether he

12 was the true shift commander. It was from what I saw, how he behaved, and

13 what he did that I perceived him as such, but he was the one who took me

14 away, and he beat me, he, Keli, and that pilot whom I know. That is, I

15 only know that he was called a pilot. And the remaining three that were

16 there, I did not know them at all.

17 Q. Yesterday when you were cross-examined by Mr. Petrovic, you said

18 that at the beginning there were two shifts and commander of one shift was

19 Crni. So do you change your mind from yesterday to today?

20 A. I do not remember.

21 Q. It is in the transcript. You, in your -- in your statement that

22 you've given to the OTP on August 15, 2000, you have testified that you

23 had had conversation with Kole after the shooting on Room 3. How many

24 days after; do you remember?

25 A. Three days later.

Page 1354

1 Q. Where did it take place, on what location in camp?

2 A. Well, somewhere in front of the dormitories, between the third and

3 the fourth dormitory. We sat on the curb next to the asphalt path.

4 Q. And it wasn't only you and Kole sitting, but there were other men

5 sitting there around Kole? That was the first time when Kole came back;

6 isn't that correct?

7 A. I don't remember whether there was anybody else there. I know I

8 talked with him, and I asked him for cigarettes.

9 Q. So doesn't that indicate that Kole is very good friend of yours

10 when, after such a terrible occurrence, that you and him would sit alone

11 to have a chat about it? Or perhaps there were the other people who knew

12 him so well and they were around, but you perhaps don't remember?

13 A. I'm not sure I understood the question.

14 MR. VUCICEVIC: Could we have a closed session, please -- private

15 session for a second?


17 [Private session]

18 [redacted]

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Page 1355

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22 [redacted]

23 [Open session]

24 JUDGE ROBINSON: Yes, we are back in open session.


Page 1356

1 Q. [Interpretation] You sat on the grass in front of Room 3, and this

2 is how you stated that it is happened when Kole told you this. "I don't

3 know what happened, but had I been there, it would not have happened."

4 A. Correct.

5 Q. [In English] Objection in the translation. Not"there", here.

6 I'll read it again. [Interpretation] "I don't know what happened, but had

7 I been here, it would not have happened."

8 A. Yes, that is correct. Had I been here, it would not have

9 happened.

10 Q. [In English] [Previous translation continues]... that's what you

11 just heard, because if you heard anything else, you would have testified

12 about it.

13 MR. VUCICEVIC: There is no answer on the transcript, Your Honour,

14 that's why I am pausing.

15 JUDGE ROBINSON: Witness E, what is the answer to the question?

16 Did you hear the question?

17 MR. VUCICEVIC: I believe the witness answered "Yes, absolutely,"

18 but somehow it didn't get on the transcript.

19 Q. Is that what you said, Witness E?

20 A. You asked me whether it was true that this was the only thing he

21 said.

22 Q. Yes.

23 A. I said, "Absolutely."

24 Q. Thank you, Witness E. So since Kole was sitting on the place

25 where the shooting -- where the shooting took place from or close

Page 1357

1 thereabouts, he might have referred, if he was there, right on that spot

2 where you were. He didn't say, "If I was in town," or, "If I was in

3 camp." He just said, "If I was here." So that could have meant that one

4 and you didn't inquire about anything else; is that correct? A

5 possibility?

6 MR. RYNEVELD: Your Honour.


8 MR. RYNEVELD: That, again, is for argument, not for speculation

9 by the witness. All the witness can testify to is to what he heard said.

10 He shouldn't be asked to speculate about what was going on in Kole's mind

11 at the time. That's for argument by counsel, in our respectful

12 submission.

13 MR. VUCICEVIC: Your Honour, if I may respond to this objection.


15 MR. VUCICEVIC: I think there was only one word here that has to

16 be explained, and that one word was -- it's a general word, and I'm asking

17 the witness to explain how he understood it, and what that word could have

18 meant at that time. That's all what I'm asking. I'm not suggesting. I'm

19 not testifying. I'm not putting any words in his mouth.

20 [Trial Chamber confers]

21 JUDGE ROBINSON: Mr. Vucicevic, you may ask the witness what he,

22 the witness, understood it to mean, not what he understood Kole to mean --


24 JUDGE ROBINSON: -- by the statement. Let's try to move along.

25 MR. VUCICEVIC: Yes. This is going to be my last question. I

Page 1358

1 just have another cite here so that the witness is going to be in a better

2 position to answer it.

3 Q. Witness E, you have testified yesterday, and you have precisely

4 used these words, [Interpretation] "Kole told me had I been here, nothing

5 would have happened." [In English] But in your statement of August, you

6 said something different, something similar. Not exactly the same words,

7 different words. You said -- and I'm citing in Bosnian: [Interpretation]

8 "I don't know what happened, but had I been here, it would not have

9 happened." [In English] So you did not repeat word to word what Kole

10 said. That was your general recollection for what he said; isn't that

11 correct?

12 A. To me it all -- it is all the same, the way I see it. "Had I not

13 been here," or "if I were here," or the third one, I don't know. It's all

14 more or less the same. It depends on how people express themselves, but

15 grammatically speaking, it's correct.

16 Q. And after he said this to you, you didn't ask him one single

17 question, what did he mean by this statement?

18 A. I cannot recall now, but this was a long time ago, 1992, nine

19 years ago, almost nine years ago. We can say it's nearly nine years. I

20 cannot recall every word I exchanged with him, how long I spoke. I

21 remember that I asked him for cigarette and I remember that we talked

22 about this, what these words reflect. If I remembered anything more, I

23 would have said.

24 Q. I'll ask you something else. You were testifying yesterday that

25 various people, a lot of people, maybe six, seven, were tortured and

Page 1359

1 killed in Keraterm. Isn't it true that none of these people were killed

2 on Kole's shift?

3 A. Except for the massacre which took place, I am unaware of anybody

4 being touched or beaten. I don't know. I cannot guarantee about the

5 others.

6 Q. You also testified that the people that were selected as the

7 punishment group, they were deemed to be extremists; isn't that true?

8 These are all the things that you said now, because, you know, we can go

9 quickly.

10 A. The people -- you asking about the people who were called

11 extremists?

12 Q. Yeah.

13 A. They called them extremists. I don't know who it was who named

14 them extremists, but in reality, they called them people for special

15 treatment.

16 Q. Those are all the things that you testified yesterday, and I don't

17 have any dispute with them. I'm just asking you to affirm that Serb

18 authorities at that time called extremists those ones that took arms to

19 fight them actually in attack on Prijedor or liberation of Prijedor. It

20 all depends which side we are on.

21 A. They considered all people who were in the SDA extremists. Those

22 who were not with the SDS, to them they were all extremists, some to a

23 lesser, some to a greater degree.

24 Q. But those ones that had arms or that were caught with arms right

25 after attack on Prijedor, they were certainly considered extremists, so we

Page 1360

1 can let those ones, just regular members of SDA, aside from the time

2 being. Those ones that had arms in their hands were considered

3 extremists, that's for sure?

4 A. I don't know who had weapons, nor whom they considered to have had

5 weapons or to have been extremists. There were a lot of hunters in our

6 midst. They had weapons.

7 Q. I was not about ever to ask you that question because you were --

8 never testified or said that you were involved yourself in looking who had

9 weapons, so we will not go there, Mr. Witness E. Could I have -- I have

10 an exhibit, please. Mr. Witness E, I would like you to look at this

11 document, to read these names, and to tell me, do you know whether any of

12 these people are well and living today?

13 A. I only know about the first -- top two, that they are alive. I

14 don't know about the rest. Bakir Hrncic, who left with me in Travnik, and

15 Malik Hrncic, whom I found in Travnik when I crossed Mount Vlasic.

16 Q. Let me just follow this up. Has any of these men spent time in

17 Keraterm that you know of?

18 A. Edin Tepic.

19 Q. And is he alive?

20 A. I don't know exactly, but he was a fireman.

21 Q. Okay. The one that was arrested with you that had the cakija in

22 his pocket?

23 A. No, it was not him.

24 Q. Okay. As long as we are at that term, I think you ought to

25 explain to the court what cakija really means, because it was talked about

Page 1361

1 that yesterday and that is a pocket knife typical for Bosnia; isn't that

2 correct? But pocket knife, this is about ten centimetres long, isn't that

3 correct?

4 A. About this, there was some that are smaller.

5 Q. Usually -- and usually does have a blade which is just that long

6 too, just as the handle is on one side and the blade forward. And the

7 blade is about one and a half to two centimetres wide.

8 MR. VUCICEVIC: Your Honours, it's important.

9 JUDGE MAY: It's a folding knife, I think you might call it, in

10 English.

11 MR. VUCICEVIC: It's a folding knife, but I haven't seen it any

12 place in the west, and it's kind of typical. Because what I am going to

13 ask him now you will see the difference.

14 Q. Because this is a knife which is sometimes used to slaughter a pig

15 or slaughter a lamb?

16 A. It is impossible.

17 Q. Okay. Let's go back to these names. If -- could you read, there

18 is handwriting on the B/C/S and it reads, "The group which participated in

19 the attack against Prijedor on May 30th, 1992." So if there is a name or

20 two here that I know of, and that the Prosecutor knows of that survived,

21 perhaps there are some other ones that survived also; isn't that true?

22 MR. RYNEVELD: Excuse me, what kind of --

23 MR. VUCICEVIC: I'm not going to mention any names.

24 JUDGE ROBINSON: Mr. Ryneveld.

25 MR. RYNEVELD: I just don't understand the relevance of that

Page 1362












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Page 1363

1 question to this witness. If my friend, again, wants to make this as an

2 argument, I just don't know how this witness can be of assistance to that

3 question.

4 JUDGE ROBINSON: What's the relevance of this question of

5 survivors?

6 MR. VUCICEVIC: Because if the man who has survived has been

7 caught with a weapon in his hands and he has survived, then perhaps he

8 might revise his statement what extremists are.

9 JUDGE ROBINSON: We'll allow it. Proceed quickly.

10 MR. VUCICEVIC: Thank you.

11 Q. If a man who is on this list has been caught with a weapon in his

12 hands and he had survived, perhaps your view of what extremists are or

13 your view of what Serbs considered extremists should be somewhat narrower,

14 shouldn't be?

15 A. I would like to say something if I can.

16 Q. [Previous translation continues]... we have to finish this.

17 Because you only know one man here, and I'm saying if that man had some

18 arms and survived, then your -- what you said before what Serbs considered

19 extremist should be modified, shouldn't it?

20 JUDGE ROBINSON: Are you in a position to answer that question,

21 Witness E?

22 A. This Tepic, he didn't have any weapons and there are other Tepics

23 and the father's name is different. So I cannot even say who this one

24 is. I know that the name is familiar. I did not say that I knew the

25 man.

Page 1364

1 JUDGE ROBINSON: You have explored this point sufficiently. Yes,

2 move on.


4 Q. You also mentioned that Car was one of those killed early on. Did

5 you know him before the war or knew him by sight?

6 A. Yes.

7 Q. [Previous translation continues]...

8 A. I did know him. I don't know what his profession was. We knew

9 each other superficially in the cafes.

10 Q. [Previous translation continues]... once and a while in a

11 restaurant.

12 A. With him, his brother, his sister. Occasionally I also met his

13 father. We called them all Car. That was a nickname for all of them

14 except for his sister whose name I cannot remember.

15 Q. [Previous translation continues]... reasonably to say that you

16 knew him well because you knew the whole family?

17 A. I did not know all of them, but I knew part of the family. One of

18 the brothers worked as a waiter in the bar called Jedinica.

19 Q. His name was Jusufovic Sead, wasn't it?

20 A. I don't know the exact full name, but I only know that his

21 nickname was Car.

22 Q. But you couldn't -- you were not drinking with him regularly. You

23 were drinking with him on and off. You would see him, but then he

24 wouldn't be there, but you would see him, but he wouldn't be there. Isn't

25 that correct?

Page 1365

1 A. Yes, exactly.

2 Q. And that is the reason because he has been constantly in trouble

3 with the law in the years prior to the war, wasn't it? He's been in court

4 in and out for ten years.

5 A. The fact that he had -- was in trouble with the law was no reason

6 for anyone to kill him. There is law to deal with that.

7 Q. I certainly agree with you. I mean I couldn't agree with you any

8 more. But I'm just asking whether he had this reputation of being a

9 criminal?

10 A. I don't know what criminal may mean for someone. I don't know his

11 dealings with the police, with the judiciary. That, I don't know. We

12 only knew each other superficially. I knew his father who was also Car.

13 He had a leg missing. And all the male members of that family we called

14 Car.

15 Q. I have something that might help refresh his recollection. That

16 is a rap sheet from the Prijedor police station indicating about all the

17 convictions that that man has had, if he can read it and refresh his

18 recollection. If it refreshes his recollection that's --

19 MR. RYNEVELD: With respect, if I understand the witness'

20 evidence, he says he knew nothing of it. To show him a document now in

21 the hopes it may refresh recollection, there has to be recollection to be

22 refreshed. And from what I understand the witness to say, he knows

23 nothing about that at all.

24 MR. VUCICEVIC: Your Honours, if I may respond.

25 [Trial Chamber confers]

Page 1366

1 JUDGE ROBINSON: Mr. Vucicevic, you can produce that through

2 another witness. The witness has said that he has no recollection. So

3 produce that document through another witness.

4 MR. VUCICEVIC: Your Honour, I really appreciate your ruling and I

5 will certainly do that. However, I am a little perturbed that when we

6 are -- when my learned friend is making these statements, that is not

7 being referred to the transcript and to the line. Because if I am going

8 to my recollection when I agreed absolutely with the witness, the witness

9 said, "So what if he was a criminal, what has it to do with him being

10 killed," and I agree with him. That is horrendous. It shouldn't have

11 happened. But, you know, if we are going to have this colloquy with

12 witness being present, then it becomes, you know, -- it's not a side bar

13 but I do thank you.

14 JUDGE ROBINSON: Yes, please proceed.

15 MR. VUCICEVIC: I have no more questions, Your Honours.

16 JUDGE ROBINSON: Thank you. Mr. Vucicevic, the document that you

17 showed the witness, what do you intend to do with that?

18 MR. VUCICEVIC: I would respectfully ask you to admit it as

19 Kolundzija Defence Exhibit number 1 because that was a document that was

20 already pre-admitted by -- a document that was produced by the Prosecutor

21 and I would just like it to be admitted into trial evidence.

22 JUDGE ROBINSON: Yes, Mr. Ryneveld?

23 MR. RYNEVELD: No objection whatsoever. As a matter of fact, I

24 think that document may already be part of the binder that has, as I

25 understand it, already been admitted in evidence by some other number as

Page 1367

1 part of the Prosecution's case. But I have no objection to it going in or

2 being referred to by a Defence exhibit number should that be the court's

3 wish.

4 JUDGE ROBINSON: Yes. We admit it as Defence Exhibit number 1.

5 THE REGISTRAR: Defence Exhibit D1/3.

6 JUDGE ROBINSON: Mr. Ryneveld, re-examination?

7 MR. RYNEVELD: No questions, thank you.

8 JUDGE ROBINSON: Witness E, that concludes your testimony. You

9 are released.

10 MR. RYNEVELD: Before we call the next witness, Your Honour, there

11 is an issue I would like to raise, if I may, before we call the next

12 witness. Do you want me to wait until the witness leaves the courtroom?

13 JUDGE ROBINSON: Yes. We will just wait until he leaves.

14 MR. RYNEVELD: Thank you.

15 [The witness withdrew]

16 JUDGE ROBINSON: Yes, Mr. Ryneveld?

17 MR. RYNEVELD: Your Honour, I neglected earlier to ask the court's

18 permission for one of our investigating officers, who is on our witness

19 list, to be permitted to either watch the proceedings by some means? As I

20 understand it, there is a practice that has developed at this Tribunal

21 that in the event there are potential witnesses on the list who happen to

22 be investigators, that we should be seeking the court's permission to

23 allow them to either from time to time view the proceedings, or to watch

24 it by closed circuit transmission on the television broadcast. I might

25 say that this witness is on our witness list, near the very end of the

Page 1368

1 list, for the sole purpose of assisting the court with respect to the

2 exhumation areas, some of the reports that are being put in, and this

3 investigator, of course, is important to us, to be of assistance to us

4 throughout the course of the trial. It's my understanding that other

5 courts have granted such permission, and I have simply forgotten up until

6 now to make an application for the court's consent.

7 I don't know whether my friends take objection to this matter but

8 that is my application.

9 JUDGE ROBINSON: Are there some rules on this?

10 MR. RYNEVELD: My understanding is there is not a rule per se, but

11 it is certainly within our policy that we are to ask the court's

12 permission. I suppose there is technically an issue as to a matter of

13 weight to be placed on that witness' evidence. My understanding is there

14 is a rule that just because a witness may have heard evidence or have been

15 present in the courtroom does not preclude him from being able to give

16 evidence, but it's always a matter of weight. This is something that's

17 quite different. He will be dealing with the issue of exhumation reports

18 and perhaps being asked some questions. He may not be called but he is on

19 our witness list

20 [Trial Chamber and legal officer

21 confer]

22 JUDGE MAY: Mr. Greaves, before you begin, let me deal with this.

23 As far as the rules are concerned, I think they are silent, but you can

24 tell me if I'm wrong about that.

25 MR. GREAVES: I believe that to be the case. I'm aware of the

Page 1369

1 practice that has developed in some cases. I'm not sure that all cases.

2 JUDGE MAY: I was going to say certainly in cases which I've been

3 in we have allowed the investigator into court in these circumstances.

4 Thinking aloud about it, the objection can only be if it might affect his

5 evidence, and if it's on a limited area, I don't know what that objection

6 can be, if it's really --

7 MR. GREAVES: Can I offer another problem?


9 MR. GREAVES: Which is if that investigator is going to be engaged

10 in the proofing of future witnesses, or is going to be briefing other

11 investigators on the proofing of witnesses, that would be undesirable.

12 It's got to be somebody who is independent of that process, in my

13 submission.

14 JUDGE MAY: Perhaps I could add one other thought. It may be

15 that, in due course, the Defence will want their investigator in court.

16 MR. GREAVES: There is of course that. We have much more limited

17 resources than the Office of the Prosecutor and are only allowed to have

18 one investigator, so that the objection that I've raised is a problem for

19 us. I hope I'm speaking, as it were, more as amicus curiae than making a

20 specific objection. I'm just concerned that an investigator can be

21 sitting there watching how the Defence is trying to develop its case and

22 in some ways influencing witnesses. That's something we ought to try and

23 avoid. It's a danger. It's not a specific allegation, I hasten to add,

24 but it can be done unconsciously.

25 JUDGE ROBINSON: Any other counsel wish to speak on this matter?

Page 1370

1 MR. PETROVIC: [Interpretation] Your Honour, I do not wish to

2 waste your time but I fully endorse Mr. Greaves's objection. I think

3 equality of arms might be brought into question if Prosecution's

4 investigator were allowed to be present whereas we are not. Rather we

5 simply cannot for various reasons to bring in an investigator, even tender

6 documents through him, let alone something more, let alone have him

7 admitted to the courtroom or admitted to the proceedings or to respond, to

8 use on the ground what he heard in the courtroom, to be present in the

9 courtroom. So I'm afraid that Prosecution's investigator would seriously

10 bring into question the equality of arms, which is always at peril.

11 JUDGE MAY: Mr. Petrovic, I wasn't suggesting that the Prosecution

12 would be allowed to have their investigator into court but you would not.

13 What I was suggesting was that, in due course, you may want to have your

14 investigator into court, in which case, of course, we would be no doubt

15 minded to allow it if we had allowed the Prosecution investigator into

16 court. The equality of arms would work in that way.

17 MR. PETROVIC: [Interpretation] Your Honour, we would be the

18 happiest if we could have our investigator present from the very

19 beginning, equally as the investigator of the Prosecution, but the

20 Registry does not allow that and explicitly forbids it. They do not allow

21 us to have a legal adviser here or a legal assistant here, let alone an

22 investigator. We accept with due respect what you are telling us and we

23 accept that, but the Registry's practice is different. And as far as I

24 know, it holds true of all the cases. No Defence team has had -- have had

25 their investigators present in the courtroom or present at parts of the

Page 1371

1 proceedings here. If I'm wrong, I stand to be corrected, of course.

2 JUDGE MAY: That's not my experience. I remember cases in which

3 we have allowed the Defence investigator into court. But let's not argue

4 about that. That's not the point at the moment.

5 JUDGE ROBINSON: Mr. Vucicevic?

6 MR. VUCICEVIC: I object on principle because in jurisdiction that

7 I'm coming from, the very first motion at the beginning of the trial is

8 motion to exclude witnesses. And if this man is -- or woman is going to

9 be witnesses, then I would like them excluded. If they are going to

10 testify about any particular matter, they have --

11 THE INTERPRETER: Can the counsel slow down, please?

12 MR. VUCICEVIC: [Previous translation continues]... witnesses whom

13 they are going to hear on their own because that's the witness they are

14 going to produce anyway? So their presence in the courtroom is

15 superfluous, you know. They want to waste their time, that's fine, but I

16 think the principle is something that matters. There must be something

17 else that he wants to find out. And that's what I'm wondering what it

18 is. Coming about the equality of arms, with the highest regards for

19 learned Judge May, we indeed, judge, don't have that equity of arms when

20 it comes to the investigators. Might have been just an exceptional

21 instance that it did happen, but it's impossible for us to have the

22 investigation, the very nature of the organisation --

23 THE INTERPRETER: Will the counsel slow down, please?

24 JUDGE ROBINSON: Mr. Vucicevic, please slow down for the

25 interpreter.

Page 1372












12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.













Page 1373

1 MR. VUCICEVIC: They all sit here with the --

2 THE INTERPRETER: Switch on his microphone, please.

3 MR. VUCICEVIC: And our investigators are in Bosnia and never come

4 here, or very seldom, and, you know, it might have some theoretical

5 implication but rather none practical. And equity of arms is a lot more

6 practice than -- for us, theory is for the court and we appreciate it.

7 Thank you.

8 JUDGE ROBINSON: Mr. Ryneveld, why do you need to have the

9 investigator in court?

10 MR. RYNEVELD: Not necessarily in court, Your Honour.

11 JUDGE ROBINSON: Well, I mean to hear the proceedings.

12 MR. RYNEVELD: Well, there are often situations where we are

13 working on our closing brief that the officer may be of assistance to us.

14 There are situations that need to be checked out. In other words, we

15 don't have unlimited resources either. There are very few investigators,

16 and those that have been assigned to us need to be available to us in

17 order to assist us throughout the course of the trial.

18 I might just say that when I made reference to my understanding of

19 the Rule, I was referring -- I didn't have it out, but I've since looked,

20 it was 90(D) that I had in mind when I made the application. And the

21 witness would not be called as an expert so he would fall outside that

22 category.


24 [Trial Chamber confers]

25 JUDGE ROBINSON: We'll take time to consider this and give a

Page 1374

1 ruling later.

2 There is a matter I'd like to raise, it's the question of

3 exhibits, and the requirement that exhibits be in both languages, both

4 working languages, English and French. I want to remind both parties,

5 although principally at this stage it might affect the Prosecution more

6 directly than the Defence of this requirement, and it has to be observed.

7 MR. RYNEVELD: Yes. I understand that the exhibits filed thus far

8 are in English only and that there could be a considerable delay before we

9 were able, physically, to have the interpreters who are busy, as I

10 understand it. There are finite number of French interpreters, and they

11 are backed up with doing judgements on other cases and other commitments.

12 I realise that we are in trial and it is our obligation, but I'm

13 just indicating to the Court that I see some practical difficulties as we

14 speak in terms of getting those immediately to the Court. We'll have to

15 make some extra special attempts to do that. Thank you for reminding me.

16 JUDGE ROBINSON: Yes, we have to work hard to meet this

17 requirement because it is very important for the efficient functioning of

18 the Court.

19 Your next witness.

20 MR. RYNEVELD: Yes, Ms. Baly will take this witness.


22 MS. BALY: Your Honours, the next witness is a witness for whom

23 protective measures were granted on the 27th of December last year, they

24 being a pseudonym and facial distortion.


Page 1375

1 MS. BALY: We call the next witness.

2 THE REGISTRAR: The pseudonym for the next witness will be Witness

3 F.

4 [The witness entered court]

5 JUDGE ROBINSON: Let the witness make the declaration.

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

7 whole truth, and nothing but the truth.


9 [Witness answered through interpreter]

10 Examined by Ms. Baly:

11 Q. Witness, can you take a look, please, at this piece of paper that

12 you are about to be handed. On that piece of paper, do you see your

13 name?

14 A. Yes.

15 Q. Your date of birth?

16 A. I do.

17 Q. And you understand, Witness, that you, during these proceedings,

18 are to be referred to as Witness F?

19 A. Very well.

20 MS. BALY: That document is Exhibit 16.

21 THE REGISTRAR: Prosecution Exhibit 18.

22 MS. BALY: 18.

23 JUDGE ROBINSON: Yes, Ms. Baly.

24 MS. BALY: Thank you, Your Honour.

25 Q. Witness F, is it the case that you graduated from high school in

Page 1376

1 1984?

2 A. Yes.

3 Q. And you completed a period of compulsory military service in an

4 engineering unit in Karlovac; is that correct?

5 A. It is.

6 Q. After your period of military service, were you unemployed for a

7 couple of years?

8 A. That's right.

9 Q. And in 1988, did you start to work as a taxi driver?

10 A. I did.

11 Q. Can we go, please, to 1991. At that time did you own a cafe in

12 Prijedor?

13 A. That's right.

14 Q. Did you, in fact, live in the Puharska area in the town of

15 Prijedor?

16 A. That's right.

17 Q. At the end of 1991, did you sell your cafe?

18 A. That's right.

19 Q. Why did you sell your cafe?

20 A. I didn't hear the question. Well, the situation was such that one

21 had to sell it.

22 Q. What was the situation?

23 A. Well, the war was in the offing in that sense, and there was

24 already war in Croatia.

25 Q. Is it the case that there were elections held in Prijedor at the

Page 1377

1 end of 1990?

2 A. That's right.

3 Q. At that time, were you a member of any political party?

4 A. No.

5 MR. VUCICEVIC: Your Honours, just an objection. I'm kind of here

6 at loss. Witness is answering "Ja, Ja, Ja". That's not a word that's

7 known in B/C/S, and translation is going "That's right. That's right."

8 And that, as a matter of fact "J-a", it's a personal pronoun for the first

9 indicating "I", like "I am in the courtroom." So I don't know what he's

10 referring to.

11 JUDGE ROBINSON: Thanks for the elucidation. We rely on the

12 interpreters. Please proceed.

13 MS. BALY: Thank you, Your Honour.

14 Q. Were you interested in politics at that time?

15 A. No.

16 Q. Did you, however, read newspapers and listen to the radio?

17 A. Correct.

18 Q. Which radio did you listen to?

19 A. Radio Prijedor, the local radio station. And naturally I watched

20 television.

21 Q. What newspaper or newspapers did you read?

22 A. Kozarski Vijesnik.

23 Q. Can you describe, briefly, the nature of that newspaper?

24 A. It was a local paper of the town that I lived in.

25 Q. After the elections, did the population begin to gather on an

Page 1378

1 ethnic or national basis?

2 A. Yes, you could say so.

3 Q. Can I take you now to the beginning of 1992. What was the

4 situation insofar as politics and advertising politics on the -- through

5 the media?

6 A. That -- I don't really know how to answer that question.

7 Q. Did any of the political parties advertise their policies through

8 either the radio, the newspaper, or the television?

9 A. That's right, yes, they did mostly.

10 Q. Just briefly, what were the political parties that existed at that

11 time?

12 A. There were the SDA, SDS, and the HDZ in Prijedor.

13 Q. Dealing firstly with the SDA, what type of a political party was

14 that?

15 A. Most of these parties were ethnic parties. So the SDA was

16 practically all Muslim.

17 Q. And what about the SDS?

18 A. That was the party of the Serb people.

19 Q. And the HDZ?

20 A. Of the Croat one.

21 Q. And so far as advertising on the media is concerned, which party

22 was it that used the media to advertise?

23 A. SDS by and large.

24 Q. And what kinds of things were being said by the SDS through the

25 media?

Page 1379

1 A. Well, it was for the most part propaganda from the front lines in

2 Croatia where the war was already on.

3 Q. And what was the nature of that propaganda? What sorts of things

4 were being said?

5 A. Well, how shall I explain it now? Well, that one should go and

6 wage war in Croatia, that the Croats, ustashas, would come and slaughter,

7 something to that effect, that all the people had to be mobilised and go

8 to fight in Croatia.

9 MS. BALY: Your Honour, I'm about to move to another subject.

10 Would it be a convenient time?

11 JUDGE ROBINSON: Yes. As a matter of fact, yes, it would be.

12 Witness F, we will now take a break and resume at 11.30. During

13 the adjournment, you are not to discuss your evidence with anybody, and

14 that includes members of the Prosecution team.

15 MR. VUCICEVIC: Your Honour, if I may, with all due respect,

16 because witness is feeling uncomfortable, if he may want to leave the

17 jacket for the rest of the session or something, that would be helpful.

18 JUDGE ROBINSON: That will be a matter for him to determine.

19 Yes. We are adjourned.

20 --- Recess taken at 11.00 a.m.

21 --- On resuming at 11.30 a.m.

22 JUDGE ROBINSON: Yes, Ms. Baly.

23 MS. BALY: Thank you, Your Honour.

24 Q. Witness F, can I take you now, please, to the 30th of April,

25 1992? Was that the day on which the Serbs took over the power in

Page 1380

1 Prijedor?

2 A. Yes.

3 Q. What happened in so far as the power of -- of Radio Prijedor and

4 the newspaper were concerned?

5 A. After the takeover of power, they appointed their own people to

6 all key positions.

7 Q. In so far as the radio station that you listened to, that is Radio

8 Prijedor, what happened in so far as that was concerned, after the

9 takeover?

10 A. It was also -- it was also transferred to the Serb, I don't know

11 how to put it, to the Serb authority.

12 Q. And what kinds of things were broadcast over the radio after

13 that?

14 A. From that day on, everything was only Serb propaganda. You could

15 not hear anything else. Serbian songs, Serbian everything.

16 Q. In so far as propaganda is concerned, was there any particular

17 propaganda that was broadcast?

18 A. Yes. They were saying that everybody had to go to the war in

19 Croatia, to defend Yugoslavia, in that sense that everybody had to be

20 mobilised.

21 Q. What was the situation in so far as the newspaper that you read?

22 A. The same. Everything was the same as that.

23 Q. Can I take you now to the period of late May or around the 23rd of

24 May in particular? Did an incident take place in the village of

25 Hambarine?

Page 1381

1 A. Yes.

2 Q. What was the nature of that incident?

3 A. Two Serb, I don't know what they were, policemen or civilians,

4 were killed there.

5 Q. Was there anything announced on the radio concerning that

6 particular incident?

7 A. Yes.

8 Q. What was it?

9 A. That the renegades at Hambarine had killed those two, I don't know

10 what they were, policemen or civilians, but they were labelled as Muslim

11 rebels.

12 Q. Was there any announcement over the radio in so far as weapons are

13 concerned?

14 A. Yes. It was ordered that all the weapons that were there would be

15 turned in and that some automatic rifles be returned.

16 Q. Witness F, are you familiar with what is called a Crisis Staff?

17 A. I heard that such Crisis Staffs existed, but I did not know what

18 their role was.

19 Q. When you say you heard that they existed, when did they come into

20 existence?

21 A. I don't know.

22 Q. Witness F, you mentioned earlier in your evidence that key

23 positions were taken over by Serbs. Can you just please explain what you

24 meant by that?

25 A. Before this takeover of power, there were the elections in which

Page 1382












12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.













Page 1383

1 the SDA party won the majority. So from this party, these SDA people were

2 appointed to the leading positions, and then after the takeover, the Serb

3 or the SDA members got to these positions.

4 Q. And when you refer to the leading positions or the key positions,

5 what exactly, what precisely were those positions?

6 A. The president of the municipality, the police commander, the

7 person the head of the health services, school services, things like that.

8 Q. In relation to firstly the police commander, prior to the

9 situation, the crisis, what was the ethnicity of the person who held that

10 position?

11 A. He was a Muslim.

12 Q. What about after the takeover?

13 A. A Serb.

14 Q. Was that the situation insofar as all of the positions that you've

15 mentioned are concerned?

16 A. Yes.

17 Q. Witness F, you, yourself, are a person of Muslim ethnicity; is

18 that correct?

19 A. No.

20 Q. What is your ethnicity?

21 A. Croat.

22 Q. Witness F, after the takeover, you remained residing in the

23 Puharska area; is that correct?

24 A. Yes.

25 Q. Were you watching what was going on in the area?

Page 1384

1 A. Yes.

2 Q. What did you notice insofar as the population of non-Serbs?

3 A. What did I notice? The ethnic groups started separating out. The

4 stratification started in town. The people with whom I socialised, I no

5 longer socialised with, and other people did that too.

6 Q. Did you notice Serbs dressed in uniforms in the area?

7 A. Yes.

8 Q. Were you able to recognise the nature of those uniforms?

9 A. Those were military police, all kinds of uniforms. They were

10 different.

11 Q. What sorts of things did those persons do?

12 A. For the most part they walked around about town without doing

13 anything, and most of them had come back from the front in Croatia.

14 Q. Did they, on any occasions, attend the homes of persons who were

15 of non-Serb ethnicity?

16 A. Not with me. I don't know.

17 Q. When you say not with you, did it occur with any other persons to

18 your knowledge?

19 A. I don't know what period you are referring to.

20 Q. Witness F, I'm referring to a period after the takeover and, in

21 particular, after the incident in Hambarine, that is, late May of 1992.

22 A. It depended on the part of town. This Keraterm camp was open and

23 they started gathering there, the non-Serb population.

24 Q. And was that non-Serb population concentrated in a particular area

25 of town?

Page 1385

1 A. Yes. These areas were the outlying areas, the villages around

2 town, and the town itself, in that sense.

3 Q. When you say they were gathering the non-Serb population, how were

4 they doing that?

5 A. I can say how they did it in my area.

6 Q. How did they do it in your area?

7 A. Simply they -- armed soldiers entered the street and rounded up

8 everyone.

9 Q. Witness F, were you yourself rounded up?

10 A. No.

11 Q. Were you concerned, Witness F, that you would be rounded up?

12 A. Yes.

13 Q. What did you do because of your concern?

14 A. My Serb neighbour protected me and we hid at his place.

15 Q. For how long did you hide at his place?

16 A. When it was over, we could go back home.

17 Q. Are you able to put a date on when you say it was over?

18 A. I don't know the exact date, but it was over the same day.

19 Q. At some stage, Witness F, were you in fact rounded up?

20 A. Yes.

21 Q. Do you know when that was?

22 A. 12th of June.

23 Q. Witness F, where were you?

24 A. I was at home.

25 Q. Can you just describe to the court, please, what happened?

Page 1386

1 A. An unknown person called me from the Zarko Zgonjanin barracks to

2 report to the barracks for an information interview.

3 Q. How did you receive that call? Was that on the telephone?

4 A. I was simply -- they simply called me on the phone. I picked up

5 the phone and I was told to report to the barracks.

6 Q. Did you in fact report to the barracks?

7 A. Yes.

8 Q. What was the name of that barracks?

9 A. Zarko Zgonjanin.

10 Q. What happened after you reported to the barracks?

11 A. I was met by a guard at the reception office and he told me to

12 wait. Five or ten minutes later, a Golf vehicle came with a driver and an

13 escort, and they drove me over there.

14 Q. Witness F, where was that barracks in relation to the Keraterm

15 camp?

16 A. Keraterm was on the Prijedor-Banja Luka road and the barracks was

17 on the Prijedor-Bosanska Dubica road.

18 Q. Witness F, is it the case that you have in fact drawn a sketch or

19 a map indicating the position of the barracks?

20 A. Not the Zarko Zgonjanin barracks.

21 Q. I show you, please, a document.

22 MS. BALY: I have, Your Honours, copies of those -- of that map in

23 both English and B/C/S. I apologise at this stage, Your Honours, I do not

24 have a French translation of that document. It has been requested.


Page 1387


2 Q. Just before it's placed on the ELMO, Witness F, for how long did

3 you remain at the army barracks?

4 A. I did not enter the barracks at all.

5 Q. What happened after you arrived at the barracks?

6 A. I was met with a soldier -- by a soldier at the reception office,

7 and five to ten minutes later, a driver and an escort arrived in a Golf

8 vehicle, and then they took me to Keraterm. That is, to the military

9 police building behind Keraterm.

10 Q. And, Witness F, in so far -- the map might be placed on the ELMO

11 at this stage. Just look, please, Witness F, at the map. Is that a map

12 that you in fact drew?

13 A. Yes.

14 Q. May we have the B/C/S version placed upon the ELMO? Do you see,

15 Witness F, that upon that -- on that map, you've drawn a building or a

16 square that has "VP1" written on it?

17 A. Yes.

18 Q. Is that the building to which you were taken?

19 A. VP2.

20 Q. You see on that map, you've also drawn a building and you've

21 marked it "VP2."

22 A. Yes. That is where they brought me.

23 Q. What is VP1?

24 A. VP1 was the other military police facility.

25 Q. Did that facility afford a view of the Keraterm camp?

Page 1388

1 A. Yes. From VP1.

2 Q. From VP2 is it the situation that you couldn't see the camp

3 because, in fact, VP2 was behind the camp; is that correct?

4 A. Yes, but only from the back.

5 Q. Only what from the back?

6 A. That was a building -- you could only see the back of the

7 building. In other words, you were not able to see the inmates in there.

8 Q. Are you saying, Witness F, that from the building you've marked

9 VP2, that is the military building that you were taken, you could see the

10 back of the Keraterm camp but not in the camp; is that correct?

11 A. Yes.

12 Q. What happened when you arrived at the police headquarters?

13 A. The two soldiers who had brought me, took me to their

14 interrogator, to their commander whose name was Dragan Radetic.

15 Q. What ethnicity was Dragan Radetic?

16 A. A Serb.

17 JUDGE ROBINSON: Ms. Baly, there is a question mark after VP1 and

18 a slash, and also VP2 and a slash in the English version. Is there any

19 significance to that question mark?

20 MS. BALY: Your Honour, those are translator's notes. I do intend

21 to clarify with the witness at a later stage some of the markings on the

22 document that appear to have been difficult to read to the translators.

23 JUDGE ROBINSON: Proceed. Yes.

24 MS. BALY:

25 Q. Did you know that person Radetic prior to arriving at the police

Page 1389

1 headquarters?

2 A. Yes.

3 Q. In what circumstances and how did you know him?

4 A. Dragan Radetic was a lawyer in Prijedor.

5 Q. What did Dragan Radetic do at that time, that is, when you arrived

6 at the police headquarters?

7 A. He was in that room in his office there.

8 Q. Did you go into the office?

9 A. Yes. Those two soldiers brought me over to him.

10 Q. And what happened after you were taken over to him?

11 A. Nothing. He ordered me to sit down, and then he asked me where I

12 was, what I did, where my car was, what party I had financed. Questions

13 in that vein.

14 Q. Did you answer his questions?

15 A. Yes, I had to.

16 Q. Why, Witness F, do you say you had to answer those questions?

17 A. Because the guards were out there and he had all the power.

18 Q. Insofar as your -- the questions you were asked about your car,

19 can you expand, please, on that? What were you asked and what did you

20 say?

21 A. He asked me where my car was. I said that it was at home. And he

22 said that this car would be taken away for the needs of the Serb military,

23 that I had to turn it over.

24 Q. Did you have your car keys with you?

25 A. Yes.

Page 1390

1 Q. Did you do something with your car keys at that time?

2 A. Yes, I turned them over to him.

3 Q. Do you know what happened to your car?

4 A. He sent me with the escort of two soldiers to go home and show

5 them where the car was. Then we went to get the car, and I was brought

6 back to Radetic.

7 Q. When you say, "We went to get the car," who took the car?

8 A. We drove there. We drove in their military vehicle there.

9 Q. And what happened to your car after you arrived there?

10 A. They simply took my car away.

11 Q. You said you were then taken back to Radetic. What happened after

12 that?

13 A. Then he said that there would be no problems whatsoever, but that

14 I had to stay in Keraterm in any event for one day.

15 Q. For one day; is that correct?

16 A. Yes.

17 Q. Did you go to Keraterm?

18 A. He directed me there with the -- and he sent one guard with me to

19 escort me to the camp.

20 Q. Going back for a moment, Witness F, did you ever get your car

21 back? Have you ever had your car returned?

22 A. No.

23 Q. How did you get to Keraterm, did you walk or were you transported

24 in a vehicle?

25 A. On foot. The distance is a few hundred metres.

Page 1391

1 Q. What happened when you arrived at Keraterm camp?

2 A. The guard brought me to the corner of what has been marked on the

3 sketch as Room 1. And he ordered me to report to the guards on duty there

4 who were lined up in front of Room 3 as marked on the sketch.

5 Q. Did you recognise any of those guards?

6 A. I recognised the majority of those guards because I knew them

7 before the war. I knew them from before.

8 Q. Can you name, please, the guards that you recognised.

9 A. Yes. Zoran Zigic; Dusan Knezevic, Duca; Zoran Vokic; Zeljko

10 Timarac; and a number of others whose first and last names I did not know.

11 Q. How did you know this person Timarac before the war?

12 A. I knew him from the town because it is a small town and

13 practically everybody knew one another, and he also played football in a

14 club.

15 Q. What about the person Zoran Vokic?

16 A. I also knew him. Well, we were friends before the conflict.

17 Q. And the person Zoran Zigic?

18 A. I knew him because we worked together for a couple of years.

19 Q. What did he do prior to the conflict? What was his occupation?

20 A. Before the -- before it broke out, he was a taxi driver, and for a

21 while, he worked in Pula, in Croatia.

22 Q. What about the person Dusan Knezevic? How did you know him prior

23 to the war?

24 A. Well, same thing. I knew him by sight from various coffee shops

25 and other places.

Page 1392












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13 English transcripts.













Page 1393

1 Q. When you were taken to the outside of Room 1, did you notice

2 anything going on at that time in the camp?

3 A. Yes.

4 Q. What was it that you saw?

5 A. In front of Zigic and those others, inmates were lined up, and

6 they were beating them.

7 Q. What were they beating them with?

8 A. Baseball bats, batons, rods, hands, feet.

9 Q. Whereabouts on the bodies of the inmates were they being beaten?

10 A. All over.

11 Q. At that time, did you have any contact, that is when you first

12 arrived in the camp, with Zoran Zigic, and if so, what happened?

13 A. Yes. The guard who brought me there ordered me to report to

14 them. That is, to cross the concrete pista and report to them.

15 Q. Did you in fact do that?

16 A. I did.

17 Q. When you say "them," to whom are you referring?

18 A. Well, those persons whom I named, who were beating over there.

19 Q. What time of the day was it? Are you able to say that?

20 A. Sometime in the afternoon.

21 Q. During daylight hours?

22 A. Yes, yes. It was summertime so there was daylight until 10.00,

23 but it was in the afternoon.

24 Q. Witness F, what happened after you reported?

25 A. So I reported down there, that I had arrived, and Zigic asked me

Page 1394

1 what was I doing there and who had brought me? And Dusan Knezevic, Duca,

2 started to beat me immediately, and Zigic told me to let me be because I

3 was his. And what he meant by that, whether that I was his friend or that

4 I was his responsibility, I don't know.

5 Q. Witness F, did you eventually go to Room number 1?

6 A. First they told me to sit down with them because there was a bed

7 there where they took a rest after beating, so that I had to sit there and

8 watch them beat those prisoners.

9 Q. For how long did you remain seated there watching the prisoners

10 being beaten?

11 A. Half an hour, an hour.

12 Q. Was anything said to you during that time by any of the -- any of

13 the guards?

14 A. They offered me to drink with them and they told me to confess

15 everything I had to confess and then nobody would harm me.

16 Q. Did they offer you -- what were they offering you in so far as

17 drink is concerned?

18 A. Yes, brandy, cognac.

19 Q. Was there brandy, cognac there at the time?

20 A. Yes.

21 Q. And was it being consumed? Was it being drunk by any of the

22 guards?

23 A. Yes.

24 Q. Who was drinking it?

25 A. All those who were doing the beating.

Page 1395

1 Q. Is it the case, Witness F, that you were then -- you then went to

2 Room number 1?

3 A. Yes, Zigic told me to go to the rear part of the dormitory

4 because, he told me, at night people came to beat, so it was better for me

5 to be in the rear part of the dormitory, and he told me to go to number 1

6 because it was the best.

7 Q. Did he say why it was better for you to go to the rear part of

8 Room number 1?

9 A. He told me that at night-time there were some who came and beat.

10 Q. When you went to Room number 1, did you recognise any of the other

11 detainees in that room?

12 A. Yes. In that Room number 1 most detainees were my neighbours.

13 Q. Can you name those whom you recognised?

14 A. Well, I can, if I have to. It's their safety.

15 Q. Yes, thank you, Witness F. In so far as Room number 1 is

16 concerned, can you briefly describe that room in relation -- in so far as

17 its size is concerned, and in relation to the nature of the door, those

18 kinds of features?

19 A. I see. Well, the room was 10 by 20 metres. The door was -- it

20 was a metal door, a metal door, an iron door.

21 Q. What about the ceiling of that room? How high would you say the

22 ceiling was?

23 A. Oh, three, four metres, perhaps.

24 Q. For how long did you remain in that room? Were you in that room

25 the entire time that you were detained at Keraterm?

Page 1396

1 A. No.

2 Q. Did you move to another room at some stage during your detention?

3 A. Not to another room, to the hospital.

4 Q. Apart from your stay in the hospital, was Room 1 the room that you

5 were detained in during your time at Keraterm?

6 A. You mean -- no, but when they beat me, I was in a different room.

7 I was in Room 1 all the time except when they beat me. At that time, I

8 was in a different room.

9 Q. Witness F, how many other inmates would you say were in Room 1

10 when you arrived?

11 A. The room was already full.

12 Q. When you say it was full, can you just estimate, and we appreciate

13 you can't be exact, but can you give an approximate number of the other

14 inmates?

15 A. 200, 300.

16 Q. What was the situation insofar as the space that you had in that

17 room. Was it crowded, was it not crowded. Can you just describe that,

18 please?

19 A. There was no space at all. On one pallet used for tiles, there

20 were four or five men sleeping. And because it was overcrowded, I found a

21 place for myself in the rear part of the dormitory below the wash basin.

22 Q. Now, Witness F, can you look, please, again at the map that you

23 drew. Can I direct your attention, perhaps with the assistance of the

24 usher. Firstly, Mr. Usher, to the -- what appears to be a room between

25 Room 4. Sorry, two rooms along to the left of Room 4.

Page 1397

1 Can you point, please, with the pointer?

2 A. I didn't understand the question.

3 Q. Do you see there where you've written "military prison"?

4 A. Yes.

5 Q. You see the room next to that where there's something written?

6 A. Yes, I do.

7 Q. Can you point to that?

8 A. [Indicates].

9 Q. Yes, what is that? What have you written there, please?

10 A. It was a warehouse which belonged to a private company called

11 Grosist.

12 Q. Was that room used for any particular purpose during the time that

13 the Keraterm camp was there, to your knowledge?

14 A. Yes. Yes. Yes. Yes.

15 Q. What was it used for?

16 A. It was a warehouse for foodstuffs, and it was owned by Grosist,

17 which was a private company.

18 Q. You'll also see, Witness F, that there are what appear to be a

19 question mark, two question marks. In fact, one just behind Room 3 and

20 one just behind that warehouse room. Can you see those?

21 A. I can, yes.

22 Q. Can you point to those, please.

23 A. [Indicates].

24 Q. And the other one, the other question mark.

25 A. [Indicates].

Page 1398

1 Q. Yes. What do those question marks represent?

2 A. I didn't know what was it, what rooms, what facilities were those.

3 MS. BALY: Yes, I tender that map.

4 THE REGISTRAR: Prosecution Exhibit 19.


6 MS. BALY: That can be removed from the ELMO.

7 Q. Witness F, when you arrived in the camp, that is, on the 12th of

8 June 1992, how many prisoners in total were detained at Keraterm camp?

9 A. I couldn't give you the exact figure, but dormitories 1 and 2 were

10 already full.

11 Q. What about dormitories 3 and 4?

12 A. I couldn't say, because I don't know how many people were there in

13 those early days.

14 Q. Can you describe, please, the toilet facilities that existed and

15 the access that you, as inmates, had to the toilets?

16 A. The toilets existed but were not in working order because all

17 those sewage pipes were blocked. So that if one wanted to go in there, he

18 would have to walk -- to wade through urine which was 20, 30 centimetres

19 deep.

20 Q. How many toilets were there?

21 A. Well, there was one facility with several booths, several stalls.

22 Q. Were the inmates able to use the toilets during the night?

23 A. Sure, but it was hazardous.

24 Q. Why was it hazardous?

25 A. Well, some never came back.

Page 1399

1 Q. Do you know what happened to those who never came back?

2 A. Well, they were killed as likely as not.

3 MR. VUCICEVIC: Objection to the question and the answer. Calls

4 for speculation. With speculation, move to strike it from the record.

5 JUDGE ROBINSON: Well, it's a matter of fact for him to say

6 whether he knows what happened to those who never came back. Either he

7 does or he doesn't.

8 Do you know?

9 A. I do not know. I'm guessing what happened. They simply vanished

10 into thin air.

11 MS. BALY:

12 Q. Thank you, Witness F. Did you receive food while you were in the

13 camp?

14 A. Yes.

15 Q. How often were you fed, and can you describe the food, the nature

16 of the food, that you received, both in terms of its quality and its

17 quantity?

18 A. We were given food once a day, but we would get only so many

19 rations so that the last dormitory would not get anything at all. The

20 food tasted bad. It was just water. It was just warm water with some

21 cabbage or some beans, perhaps a bone or two, but no meat or anything.

22 Q. Did you receive drinking water?

23 A. Yes.

24 Q. What was the quality of that drinking water, from what you could

25 ascertain?

Page 1400

1 A. Well, it was good, seeing that for a long time we had absolutely

2 none.

3 Q. For how long did you have absolutely none?

4 A. We did have water. I mean water is -- water was the best thing we

5 had because we simply had nothing else. That is what I meant. There was

6 no food or anything else and there was water.

7 Q. Did you have free access to that water?

8 A. At times we did; at times we didn't.

9 Q. Now, going back to the food for a moment, can you just describe

10 fairly briefly, please, the nature of the process of receiving the food

11 and how long you had to eat and that kind of thing?

12 A. Well, the procedure was as follows: Every day, or rather every

13 second day, a different dormitory would be the first, so that we had to

14 line up in front of the table from which the food was distributed, and

15 then each one of us would pick up that plate, have to eat very quickly,

16 leave the plate, and go back to the dormitory.

17 Q. Why did you have to eat very quickly? Were you given some order

18 or some instruction in so far as the length of time you were allowed to

19 eat?

20 A. As we waited, as we queued for food, the guards beat us.

21 Q. Did any of the inmates suffer any kind of health problems that you

22 could observe?

23 A. Yes.

24 Q. What? What were the problems?

25 A. Well, lice appeared, all sorts of other vermin. People had

Page 1401

1 diarrhoea. Many people had already been beaten. They had open wounds and

2 such like.

3 Q. What happened to your body weight during the time that you were

4 detained at Keraterm?

5 A. During my stay there, I lost 22 kilograms.

6 Q. Now, Witness F, I'm going to ask you some questions about the

7 guards and the personnel who were taking care of you at the camp.

8 Firstly, was there any structure that you could observe?

9 A. Yes.

10 Q. Can you describe how the guards were structured?

11 A. They alternated. There were three guard shifts and they then

12 changed at some intervals. Each shift had its own commander and they were

13 all subordinated to one guard commander.

14 Q. How many guards were on each of these shifts?

15 A. About ten.

16 Q. Witness F, you referred to one commander being in charge. Do you

17 know who that person was?

18 A. Yes.

19 Q. Who was it?

20 MR. LONDROVIC: [Interpretation] Objection, I apologise. The

21 witness said -- Your Honours, the witness said that all shifts were

22 subordinated to one guard commander. He never mentioned the commander of

23 the facility when he was answering the previous question asked by Ms.

24 Baly.

25 JUDGE ROBINSON: Yes, Ms. Baly.

Page 1402












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13 English transcripts.













Page 1403

1 MS. BALY: Yes, thank you.

2 Q. Witness, who was the person that you referred to as the one

3 commander?

4 A. Dusko Sikirica.

5 Q. And just for clarity, what was his role in the camp?

6 A. His role was to organise the camp.

7 Q. And how did these shift commanders relate to him?

8 A. Well, there wasn't a special relationship, I mean submitting

9 reports. But it was a fact that he was their superior.

10 Q. What did you see, Witness F, or hear, Witness F, that drew you to

11 conclude that he was their superior?

12 A. When he arrived, we were always ordered to go back into the

13 dormitories. There were other details. The hierarchy in the camp was

14 evident. One knew who was subordinated to whom.

15 Q. Just do the best you can and take your time. What were those

16 details that you observed?

17 A. Well, as often as not he -- I don't know how to explain it. What

18 do I say? Well, it was -- it was -- the inmates knew how it worked.

19 Q. Well, are you able to say how in fact it did work? What was it

20 that the inmates knew?

21 A. Every shift had its system, treated -- had a special system

22 according to which they treated us, the detainees. That is, some were

23 better and some were worse. They were all bad.

24 Q. Going back to this person Sikirica, did you know him prior to your

25 detention in Keraterm camp, and if so, in what circumstances did you know

Page 1404

1 him?

2 A. I can, yes. He was the boyfriend of a school fellow of mine at

3 the time when we met, and I believe he married her in the end. I mean,

4 when we came out of school.

5 Q. When was it that you met?

6 A. At the time when I went to school, at school.

7 Q. Following your school days, did you have any further contact with

8 this person Sikirica?

9 A. No, but I used to see him, to come across him.

10 Q. Just briefly, in what circumstances did you see him or come across

11 him?

12 A. I've already said, it is a small town so everybody knew

13 everybody. We would meet every night.

14 Q. Going back to 1992 when you were in the camp, can you describe

15 what the person Sikirica looked like, in terms of his age, height, build,

16 and general appearance?

17 A. Yeah, sure. Well, a little bit different than I look today.

18 Q. How old would you say he was? That's in 1992.

19 A. Just a moment. I have to do my math. 30ish.

20 Q. How tall would you say he was?

21 A. He was rather tall. He wasn't short.

22 Q. Was he taller than you?

23 A. Yes.

24 Q. How tall are you?

25 A. I don't know.

Page 1405

1 Q. What about his -- the build of his body? How would you describe

2 that?

3 A. He was quite strong.

4 Q. What did he wear when he was in the camp?

5 A. He -- I mean not he alone, most of them had different types of

6 military uniform.

7 Q. Just concentrating on him, that is Mr. Sikirica, what kind of

8 uniform did he wear, are you able to say?

9 A. That military uniform -- well, it was something olive green-grey.

10 I don't know. A military uniform.

11 Q. Did he wear any kind of hat or anything on his head?

12 A. Sometimes he did, sometimes he didn't.

13 Q. What kind of a hat was it?

14 A. Well, I know that at times he would have a black beret.

15 Q. Now, how often did you see this person while you were in the camp?

16 A. Often.

17 Q. What kinds of things did you see this person Sikirica doing?

18 A. He mostly came to the reception office before going to work and

19 there was the record of the inmates, where all the names of the inmates

20 were. There he would talk to shift leaders and guards, that is, he came

21 to do the visit, the tour of the camp.

22 Q. What do you mean when you say he came to do the tour of the camp?

23 What did he actually do?

24 A. I wouldn't be able to say exactly what he did.

25 Q. Did you ever see him with persons other than camp personnel in the

Page 1406

1 camp?

2 A. Yes.

3 Q. Who were those other persons?

4 A. These were some civilian persons who came to visit the camp, and

5 when they arrived, we had to go to the rooms and we had to sing these

6 provocative songs or Chetnik songs.

7 Q. Do you know the names of any of those civilian persons?

8 A. No.

9 Q. You say you had to go to your rooms and sing Chetnik songs. What

10 did the persons do when they came to the camp?

11 A. They were just walking about in -- outside of the rooms.

12 Q. And what was Sikirica doing?

13 A. He was escorting them.

14 Q. Witness F, do you think that you would be able to recognise this

15 person Sikirica if you were to see him today?

16 A. Yes.

17 Q. I'd like you to look around the courtroom and indicate whether you

18 can see him.

19 A. Yes.

20 Q. I'd like you to indicate where you see him by reference to the

21 seat that he's sitting in, and the row of that seat. And insofar as the

22 seat is concerned, can you count from the left and indicate which seat

23 he's sitting in.

24 A. The last row to the left, the fifth.

25 Q. When you say the fifth --

Page 1407

1 A. I also counted the policemen.

2 Q. From which side of the room are you counting, Witness F?

3 A. From the left.

4 Q. The person --

5 A. From right to left.

6 Q. Can you count, please, from left to right, and indicate which seat

7 he's sitting in?

8 MR. GREAVES: Your Honour, with respect, the witness has given the

9 answer and that should be the end of it. What is now happening is an

10 attempt to get him to identify somebody else, in my submission.

11 JUDGE ROBINSON: No, I don't agree. Go ahead, yes.

12 MS. BALY:

13 Q. Witness F, what I'd like you to do is what I first asked you to

14 do, that is, count from left to right and indicate which seat he's sitting

15 in.

16 A. The second.

17 Q. Thank you.

18 MS. BALY: For the record, I'll ask that the witness has

19 identified the accused Mr. Sikirica.


21 MS. BALY:

22 Q. Now, Witness F, you referred to there being three shifts and

23 three -- I'll withdraw that. Were those shifts commanded by any

24 particular guards or led by any particular guards?

25 A. These three shifts each had its own shift commander. Shall I name

Page 1408

1 their names?

2 Q. Please, Witness F.

3 A. The commander of one shift was Kajin, another shift Kole, and the

4 third shift Fustar. These were all nicknames.

5 Q. Was the full name of the person you referred to as Kole, Dragan

6 Kolundzija?

7 A. Yes.

8 Q. Did you know that person prior to being detained in Keraterm camp?

9 A. Only by sight.

10 Q. Can you describe his appearance, please, as it was in 1992 when

11 you were in the camp?

12 A. He was tall, very tall, and thinner.

13 Q. Thinner than what or whom?

14 A. Thinner than Sikirica.

15 Q. What did he wear?

16 A. Also a military uniform.

17 Q. Did you know what his employment was prior to being a guard at the

18 camp?

19 A. I think he was a driver at the AutoTransport company.

20 Q. Why do you say -- what did you see about him that made you

21 conclude that he was one of the shift commanders?

22 A. Each shift commander had the keys to the rooms so that the rooms

23 could be locked if they wanted them locked. And he decided, when we were

24 getting water, who would go to get it, and which room would go first so

25 that there wouldn't be any problems with the distribution of water and

Page 1409

1 things like that.

2 Q. Witness F, what I'd like you to do -- well, firstly, do you think

3 you'd be able to recognise that person if you saw him again?

4 A. Yes.

5 Q. Witness F, can you look around the courtroom and indicate whether

6 you can see that person, that is Kole?

7 A. Yes.

8 Q. Now, counting from left to right, can you indicate where this

9 person is seated?

10 A. Yes, number 5.

11 Q. And which row?

12 A. Last row.

13 MS. BALY: Again for the record, Your Honour, I'd ask that the

14 record reflect the witness has indicated -- has identified the person

15 Dragan Kolundzija.


17 MS. BALY:

18 Q. Turning now, Witness F, to the person you've described as Kajin,

19 do you know his full name?

20 A. I knew him best of all of the accused, but only by the nickname

21 Kajin. I think that his last name was Dosen.

22 Q. In what circumstances did you know him prior to your detention in

23 Keraterm camp?

24 A. He worked with my father in the same company, and we were

25 acquaintances from town. I thought that we were friends.

Page 1410

1 Q. Can you describe his appearance as at 1992, please? That is

2 height, build? Just describe him.

3 A. He was also thinner but taller, yes, skinny.

4 Q. Witness F, do you think you'd be able to recognise him if you saw

5 him again?

6 A. Yes.

7 Q. Again, can you look around the courtroom, and if you see this

8 person, can you indicate where he's seated by reference to the row and the

9 seat number, counting from left to right?

10 A. Last row, number 3.

11 MS. BALY: I'd ask that the record reflect that the witness has

12 identified Kajin, Damir Dosen.


14 MR. PETROVIC: [Interpretation] Objection, Your Honour. The

15 witness does not know the full name of the person whom he has just

16 identified. In this way, it has been suggested to him, even though in all

17 these statements that he has given, including the summary, he mentions a

18 different first name as the name of the person identified.

19 JUDGE ROBINSON: Those are matters that we will take into

20 consideration when we come to assess the evidence.

21 MR. PETROVIC: [Interpretation] Thank you, Your Honour.

22 JUDGE ROBINSON: Yes, Ms. Baly?

23 MS. BALY:

24 Q. Now, Witness F, concentrating on the person Kajin, what kinds of

25 things did you see him do in the camp that led you to conclude that he was

Page 1411

1 one of the shift leaders?

2 A. As I said, shift commanders had keys with which they could lock

3 the doors to the rooms.

4 Q. Did they in fact lock the doors to the rooms?

5 A. Sometimes they did; sometimes they didn't.

6 Q. Was there any particular time of the day or night when the doors

7 would be locked?

8 A. As I said, sometimes yes, sometimes no.

9 Q. What about the time of day or night? Was there a specific time of

10 day or night when the doors would be locked?

11 A. For the most part the doors would be locked after 10.00 or 11.00

12 at night.

13 Q. You said you knew the person Kajin well. Did he have a brother

14 that you knew?

15 A. Yes.

16 Q. Did you ever see that brother in the camp?

17 A. I wouldn't be able to say.

18 Q. Now, I want to ask you, Witness F, about the daily activities and

19 things that would go on during the camp -- during the day. Firstly, at

20 the day -- in the daytime hours, what would happen to the prisoners? Were

21 they left in peace or what would happen to them?

22 A. During the day, we had -- each prisoner had to go through a

23 civilian interrogation, that is interrogation by civilian policemen in a

24 room that was above Room number 1.

25 Q. Were you yourself put through that process?

Page 1412












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13 English transcripts.













Page 1413

1 A. Yes.

2 Q. How many times?

3 A. Once.

4 Q. Can you just describe what happened, how you got to the room and

5 what happened when you were in the room?

6 A. One of the guards took me to that room upstairs where those

7 civilian policemen from the former police were, and they were keeping

8 these records with all the data, who you were, and where and when you were

9 born, what ethnic background you were, et cetera.

10 Q. Were you asked questions?

11 A. Yes.

12 Q. What kinds of questions were you asked and by whom?

13 A. The questions for the most part concerned where I was before the

14 war, where I was during the attack on Prijedor, that line of questions.

15 Q. For how long did that process last?

16 A. About 15 minutes to half an hour.

17 Q. What role, if any, did the guards in the camp play during that

18 process?

19 A. While I was interrogated, there were no guards in the room.

20 Q. Did the guards play any role in escorting you to the room in which

21 you were interrogated?

22 A. The guards who were the camp guards would take me to a guard who

23 would take people around to that room. There was another guard who had

24 nothing to do with the camp guards.

25 Q. Who was that guard? Do you know that person's name?

Page 1414

1 A. No.

2 Q. Why do you say that that guard had nothing to do with the camp

3 guards?

4 A. We knew who the camp guards were, and that person we would never

5 see.

6 Q. Well, Witness F, you did see that person on at least one occasion;

7 is that correct?

8 A. Which person now? I didn't understand.

9 Q. I'm referring, Witness F, to the person you said was a guard who

10 was not one of the camp guards. Do you understand?

11 A. No.

12 Q. Witness F, earlier when you were -- when I was asking you

13 questions about your interrogation, I asked you whether the camp guards

14 were involved in the process, and you indicated that the camp guards would

15 take you from the room to another person, another guard, who was not

16 connected with the camp. Do you recall saying that?

17 A. Yes, yes.

18 Q. What I'd like you to focus on is the nature -- the identity of

19 this other person who you say was not connected to the camp. Do you

20 understand?

21 A. Yes.

22 Q. You said you don't know who that person was by name. My question

23 is: How do you know that he was not connected to the camp?

24 A. Because the interrogators who would come, those civilian

25 interrogators in the rooms above the rooms, every inmate went through this

Page 1415

1 questioning. They had a separate unit, so to speak.

2 Q. And Witness F, was this person a part of that separate unit, from

3 your observations?

4 A. Yes, yes.

5 Q. Witness F, apart from being interrogated during the day, what

6 other things would happen to the inmates?

7 A. There were beatings every day. That was a daily life, daily

8 occurrence, in the camp, and of course people died.

9 Q. Just in general, not focusing on any specific beatings of any

10 specific persons at this stage, just in general, what types of things were

11 people beaten with?

12 A. Baseball bats, police truncheons, rifle butts, metal piping,

13 cables.

14 Q. Who did the beating?

15 A. Guards.

16 Q. Did you ever see any of the shift commanders present during any of

17 the beatings?

18 A. They were always there. They were always present.

19 Q. Where would these beatings take place? Did they take place in the

20 rooms or did they take place somewhere else in the camp?

21 A. Throughout the camp. Less so in the rooms, and during the period

22 when I was there, it didn't happen in the rooms that much, but outside was

23 plenty of it. And there was a room which was for beating.

24 Q. Did you mark that room on your map?

25 A. Yes.

Page 1416

1 Q. What did you mark that room with? Will you just have a look,

2 please, at your map?

3 A. "X".

4 Q. Now, Witness F, you said that the shift commanders were present

5 during the time that the beatings would take place. Just concentrate,

6 please, if you would, on Kole. Did you ever see him specifically present

7 during any of the beatings and, if so, where was he in relation to the

8 beating taking place?

9 A. I did not see.

10 Q. What about the person Kajin?

11 A. He was present.

12 Q. Was he present on more than one occasion?

13 A. I am talking about my own case.

14 Q. We'll come to that in a moment. What about any other case, did

15 you see him present?

16 A. I can mention one other case.

17 Q. Just for a moment, can I return to the shift leaders. Who was the

18 leader of the other shift. You've referred to three shifts. Who was the

19 leader of the third shift?

20 A. I don't know the name, but the nickname was Fustar.

21 Q. Can you name, please, Witness F, any of the guards who you saw

22 actually beating the prisoners?

23 A. Yes.

24 Q. Who were they?

25 A. These were the Banovic brothers, a man called Keli, Kondic, Rodic,

Page 1417

1 someone nicknamed Cupo, someone nicknamed Civerica, and in addition to the

2 guards, there were those who were not guards but who would come and beat

3 the inmates.

4 Q. You've referred earlier to a person by the name of Zoran Zigic.

5 Was he one of those persons?

6 A. [No interpretation].

7 Q. And you also referred to a person by the name of Knezevic, was he

8 also one of those persons?

9 A. He was not a guard, but they both were coming and beating.

10 Q. Insofar as the Banovic brothers are concerned, how many brothers

11 were they?

12 A. Two, twins. Yes, two.

13 Q. Were they identical twins?

14 A. No, not like Siamese twins.

15 Q. Did they look the same?

16 A. Yes.

17 Q. Were you able to tell them apart in any way?

18 A. Yes. One had his hair longer and the other one shorter. One was

19 more -- better looking than the other one.

20 Q. Do you know the names? Do you know their names?

21 A. I think that one of their names was Predrag.

22 Q. What kinds of things did you see Predrag doing in the camp?

23 A. I don't know which one of them was Predrag, of the two, but I knew

24 them as the Banovic brothers.

25 JUDGE ROBINSON: Ms. Baly, we are at the time when we will take

Page 1418

1 the adjournment. We will resume at 2.30.

2 Witness F, I remind you during the adjournment not to discuss your

3 evidence with anybody including the members of the Prosecution team. We

4 are adjourned until 2.30.

5 --- Luncheon recess taken at 1.00 p.m.





















Page 1419












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13 English transcripts.













Page 1420

1 --- On resuming at 2.30 p.m.

2 JUDGE ROBINSON: Ms. Baly, you are to continue with your

3 examination-in-chief. Yes.

4 MS. BALY: Thank you, Your Honour.

5 Q. Before the break, I was asking you some questions about the

6 Banovic brothers.

7 MS. BALY: I'm sorry. Excuse me, Your Honours. These are not

8 working.

9 Q. Witness F, before the break, I was asking you questions about the

10 Banovic brothers, and you said that you could tell them apart because one

11 had longer hair?

12 A. That's right.

13 Q. Was there any other features about the Banovic brothers that

14 allowed you to tell them apart?

15 A. The one with the longer hair was the one who usually carried a

16 baseball bat. That was his staple tool when he did the rounds or walked

17 around, and that is how you could tell him apart. And as for the physical

18 appearance, I couldn't really explain it in detail.

19 Q. What did you see the one with the longer hair and the baseball bat

20 doing in the camp?

21 A. He beat prisoners with that. He beat me too.

22 Q. What about the other Banovic brother with the shorter hair? What

23 did you see him doing in the camp?

24 A. He was there, but I did not see him beat, but he was in the camp.

25 Q. Witness F, did you see new prisoners arriving in the camp?

Page 1421

1 A. I did.

2 Q. What would happen to those new prisoners when they arrived?

3 A. New detainees would come to the reception office where their names

4 were taken down, and already there they would be beaten and battered.

5 Q. Did you ever see the commander of the camp, Sikirica, present when

6 that was happening?

7 A. Yes.

8 Q. How often?

9 A. Several times.

10 Q. I want to take you now, Witness F, to some specific occasions when

11 you saw beatings taking place. Firstly, did you know a person with a

12 surname Dizdarevic?

13 A. I did.

14 Q. Was that person an inmate of the camp?

15 A. No, he wasn't. His sons were.

16 Q. Did he ever come to the camp when you were there?

17 A. He came before that once, and second time he came he was killed at

18 the entrance to the camp.

19 Q. Did you see that take place?

20 A. I couldn't see all of that.

21 Q. Did you see any of -- any of what took place?

22 A. Yes. I saw him pass by the dormitory riding a bicycle, taking the

23 path, and I heard a shot. I couldn't see anything else.

24 Q. How did you find out that he'd been killed?

25 A. The detainees were saying that he had been killed and that he

Page 1422

1 never came back. And a few days later, his sons said that he had been

2 killed.

3 Q. You've described some beatings that took place during the day.

4 Did anything take place at night-time?

5 A. At night-time there were also beatings, and it went on by day or

6 at night-time.

7 Q. Do you know or did you know a person by the name of Drago

8 Tokmadzic?

9 A. I did.

10 Q. And who was he?

11 A. He was a policeman in Prijedor.

12 Q. Was he also an inmate at the camp?

13 A. He was.

14 Q. Did anything happen to him during his time at the camp?

15 A. Yes. He was beaten one night, and then he died due to the

16 injuries.

17 Q. Did you actually see that beating, Witness F?

18 A. No.

19 Q. Did you see his body?

20 A. The body? No.

21 Q. How do you know, Witness F, that he was beaten and died?

22 A. We, the detainees, could communicate between us and talk, and that

23 is how.

24 Q. Did you know a person by the name of Fikret Avdic?

25 A. Yes.

Page 1423












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13 English transcripts.













Page 1424

1 Q. How did you know him?

2 A. He was a good friend of mine.

3 Q. Was he also an inmate at the camp?

4 A. He was.

5 Q. Did anything happen to him?

6 A. Yes. He, too, died as a result of beating.

7 Q. Did you see his body?

8 A. I did.

9 Q. Where did you see his body?

10 A. On the garbage dump opposite Room 3.

11 Q. Do you know or did you know a person by the name of Besim Hergic?

12 A. I did.

13 Q. Did that person have a nickname?

14 A. I don't know.

15 Q. Was that person also detained in the camp?

16 A. He was.

17 Q. Did anything happen to him during his time at the camp?

18 A. He was also beaten and died.

19 Q. Did you see that person's body?

20 A. No.

21 Q. Did you know a person by the name of Car?

22 A. I did.

23 Q. And how did you know him?

24 A. By sight from around the town.

25 Q. Did you see him in the camp? Was he an inmate in the camp?

Page 1425

1 A. He had already died by the time I arrived there.

2 Q. You mentioned a place where the bodies were dumped. Have you

3 marked that on your map? Did you mark that on your map?

4 A. Yes, I did.

5 Q. What did you call that place? What was the name of it as you

6 marked it on the map?

7 A. I think garbage dump or something like that.

8 Q. Witness F, was there a person who was -- who had formerly been a

9 butcher detained in the camp with you?

10 A. He was.

11 Q. What was his name?

12 A. Zehro Causevic.

13 Q. Did anything happen to him when he was in the camp?

14 A. He was beaten daily, I could say, so that worms developed in his

15 arm. And after that, he was transferred somewhere and he did not return.

16 Q. Witness F, were you, yourself, ever beaten while you were in the

17 camp?

18 A. Yes.

19 Q. When was that?

20 A. It was on the 12th -- I'm not sure, 12th July I think -- no, 5th,

21 the 5th.

22 Q. Can you describe to the Court, please, what happened on that

23 occasion?

24 A. Around 6.00 in the afternoon, through the camp gate entered in a

25 car Dusan Knezevic, Duca, Zoran Zigic, Zoran Vokic, Zeljko Timarac, and

Page 1426

1 some others whom I did not know. They fetched up in front of the

2 dormitory and called out my name. And then they took me to that room

3 where they usually beat, and it is there that they beat me.

4 Q. What did they beat you with?

5 A. Dusan Knezevic had a baseball bat, Zoran Zigic had a police baton,

6 Zeljko Timarac had a kind of a rod, a stick with a metal ball on it, and

7 Vokic only had an automatic weapon.

8 Q. Whereabouts on your body were you beaten?

9 A. All over.

10 Q. Whose shift was on duty on that occasion?

11 A. Fustar's.

12 Q. Was anything said to you during the beating?

13 A. Yes. They were asking me questions while they beat me; where was

14 my money, where is my gold? Where was I during the attack on Prijedor,

15 what was I doing, and along those lines. But their first questions were

16 about money and the rest.

17 Q. For how long did the beating continue?

18 A. About half an hour.

19 Q. And what happened to you, to your body as a result of that

20 beating?

21 A. My arm was broken, my nose was broken, injuries on the head,

22 injuries to my leg, on the back, all over my body.

23 Q. Immediately after the beating, did you return to your dormitory,

24 that is, Room 1?

25 A. Yes.

Page 1427

1 Q. How did you manage to get back there?

2 A. Across the yard, I somehow made it to the barrel which was in the

3 centre where we used to have lunch, and there I washed my face. I somehow

4 made it to the dormitory, and fainted.

5 Q. Were any other prisoners beaten on that night or on that day?

6 A. Yes, quite a number of them.

7 Q. Did you receive any medical attention that night, that is after

8 the beating?

9 A. No.

10 Q. Did you or anyone else request any medical attention?

11 A. We dared not ask for it.

12 Q. On the next day, did you receive any medical attention?

13 A. No.

14 Q. In so far as the injuries you received as a result of that

15 beating, did you receive any medical attention at any time?

16 A. I did, yes.

17 Q. When was that?

18 A. It was two days after the beating, but that night, when I was

19 beaten, very many other prisoners also received beatings, so that the

20 dormitories were full of men who were only half alive. And when Kajin's

21 shift on duty -- came on duty, he saw what state we were in and ordered

22 that a doctor come to examine us.

23 Q. And did a doctor in fact come to examine you?

24 A. He did.

25 Q. Do you know the name of that doctor?

Page 1428

1 A. Dr. Barudija.

2 Q. After being examined, were you removed from the camp?

3 A. Dr. Barudija said who was to be hospitalised, that is, and those

4 who had sustained more injuries, he ordered that we be taken to the

5 hospital.

6 Q. How many were taken to the hospital?

7 A. About 15 of us.

8 Q. Which hospital did you go to?

9 A. It's in Prijedor. We called it the new hospital, at Urije.

10 Q. How many hospitals at that time were there in Prijedor?

11 A. There were two hospitals in Prijedor, the old hospital and the new

12 hospital. And there was the health centre.

13 Q. Did that new hospital to where you were taken have any -- have a

14 name?

15 A. I couldn't say, no.

16 Q. How did you get to the hospital?

17 A. The inmates who could walk, they were taken in an army van, but I

18 couldn't walk, and there was another guy, Edin Ganic, who could not walk

19 either, and we were taken in an ambulance there, because he had a broken

20 leg.

21 Q. Witness F, can you name any of the other inmates who were taken to

22 the hospital, apart from Edin Ganic at that time?

23 A. I can, yes.

24 Q. All right. Can you do so, please?

25 A. With me there were also Edin Ganic; Abaz Ganic, his father; Eso

Page 1429

1 Islamovic; Alisic, I believe his first name was Admir; and there was an

2 Albanian. That's it, yes. And there were a couple of others, too, but

3 they went back and we were left in the hospital.

4 Q. For how long did you remain in the hospital?

5 A. About ten days or so.

6 Q. Did you receive any treatment in the hospital, and if so, what

7 treatment did you receive?

8 A. The treatment boiled down to x-rays and a plaster cast on my arm,

9 and that was it.

10 Q. Do you know the name or names of any of the doctors or other

11 persons who treated you?

12 JUDGE MAY: Does it matter what the names of the doctors were?

13 MS. BALY: Thank you, Your Honour.

14 Q. During your time at the hospital, were there any soldiers of

15 Serbian ethnicity at the hospital?

16 A. What do you mean? Guards or wounded?

17 Q. Wounded.

18 A. Yes, there were.

19 Q. Did you have any contact with them while you were at the

20 hospital?

21 A. Yes.

22 Q. Can you describe what happened in relation to those soldiers?

23 A. We were on a floor -- I mean, the inmates were on one floor and

24 those Serb wounded were on another floor, and they would come to our floor

25 and beat us.

Page 1430

1 Q. Now, while you were at the hospital, did you -- were you spoken to

2 by some military interrogators?

3 A. I was.

4 Q. What did they ask you?

5 A. They introduced themselves and said that they were the military

6 police from Banja Luka and said that they had come to investigate who had

7 beaten us, who had done it to us.

8 Q. And did you tell them?

9 A. I did, I did, yes.

10 Q. Did those interrogators make notes during that interrogation?

11 A. Yes.

12 Q. Did you ever see those interrogators again? That is, after that

13 time they asked you questions about who had done --

14 A. No.

15 Q. I think you said you were in the hospital for a period of ten

16 days. What happened after you were released from the hospital?

17 A. They took me back to Keraterm from the hospital. A van arrived

18 and took me back to Keraterm.

19 Q. Now, did you ever see any of the persons who had beaten you in

20 Keraterm camp again, that is after you returned?

21 A. I did.

22 Q. Who did you see?

23 A. I saw them all again. They never stopped coming.

24 Q. I want to take you, Witness F, to an incident known as the Room 3

25 massacre which occurred on the night of the 24th of July 1992. Where were

Page 1431

1 you on that night?

2 A. I was in dormitory 1.

3 Q. Can you describe, please, what happened?

4 A. Well, it was a day like any other, that is, beatings, battery, and

5 the night fell. And then some -- I don't know, two army trucks arrived,

6 and those soldiers began to take their positions and there was noise among

7 them. The commander that night was Kole. And we heard him shout that he

8 would not allow that.

9 We didn't know what it was all about. And when it was all over

10 and when it went quiet again after midnight, after midnight they started

11 rounds of fire and we heard Kole shout not to fire at number 1. And as

12 they were taking positions before that fire, they had a machine-gun nest

13 which they did not use which was there, but there was -- it wasn't manned

14 ever. So they moved it to in front of Room 3 where that massacre

15 happened.

16 Q. Did you see the massacre or did you just hear what was going on?

17 A. We could not see anything. We only heard it.

18 Q. The following day, did you see a number of bodies?

19 A. Yes.

20 Q. Where did you see those bodies, and what happened to those bodies?

21 A. The next day -- well, those bodies were in front of the

22 dormitories. The next day a truck came belonging to AutoTransport

23 company, a trailer, and they ordered those who were fitter to come out,

24 stronger individuals to come out and load those bodies. And when they

25 were loaded, the truck left, and all the wounded who were helpless were

Page 1432

1 also put on those trucks and they were taken away together.

2 After that a water system arrived to wash off the blood which had

3 poured down the sides of the truck. There were hydrants in the yard, and

4 they used them also to wash away the blood.

5 Q. Who gave the order to load the bodies?

6 A. I cannot tell you the -- who exactly that was.

7 Q. Was Sikirica present when those bodies were being loaded?

8 A. He was.

9 Q. Where were you at that time?

10 A. Dormitory 1.

11 Q. Witness F, do you know how many bodies were loaded on that truck?

12 A. That truck was full, and it is assumed, that is, those who were

13 there said it was 200 or 300, I don't know, but the truck was full.

14 Q. The occupants of Room 3, where had they come from?

15 A. They came from neighbouring villages around Prijedor; Zecovi,

16 Carakovo, from somewhere there, from those villages around Prijedor.

17 Q. Prior to the massacre, how were they treated in the camp?

18 A. They were locked in that room for two or three days. They got no

19 food or water.

20 Q. The following date, did something occur on the following night?

21 A. The following night a similar thing happened.

22 Q. Did you see what happened?

23 A. Well, they were killing again like the previous night.

24 Q. Did you see them killing or did you hear it or how did you know

25 that -- what had happened?

Page 1433












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Page 1434

1 A. One could hear the gunfire and how people cried for help.

2 Q. Were you in your dormitory at that time?

3 A. Yes.

4 Q. And did you see any bodies following that incident?

5 A. Yes, the next day.

6 Q. What happened to those bodies?

7 A. They were loaded onto an army truck and taken away.

8 Q. Now, is it the case, Witness F, that you were eventually, that is

9 on the 6th of August, transferred from the Keraterm camp to the Trnopolje

10 camp?

11 A. Yes.

12 Q. How were you transported there?

13 A. First two buses arrived in Keraterm and a list of 120 inmates was

14 read out. And they were taken in the direction of Omarska. And for the

15 rest of us, buses came and they put us on to those buses and took us to

16 Trnopolje.

17 Q. Who read out the list of 120 inmates who were taken to Omarska?

18 A. Dusko Sikirica.

19 Q. When you arrived in Trnopolje camp, did you see the person Zoran

20 Zigic?

21 A. Yes.

22 Q. What did you see him doing?

23 A. That was the first day when they brought us there. He was again

24 beating a prisoner but later on, he did not appear.

25 Q. Do you know who the camp commander of that camp was?

Page 1435

1 A. Slobodan Kuruzovic, who was a teacher from Prijedor.

2 Q. Witness F, were you eventually released on the 13th of August from

3 Trnopolje?

4 A. Yes.

5 Q. How did you manage to get released? What did you have to do to

6 get released?

7 A. I was not the only one who did this. We all had to do this. The

8 procedure was that you had to go to the municipal building. We had to say

9 that we were leaving the territory because -- due to the financial

10 situation, and that everything was then turned over, all the property, to

11 the Serb Republic, and this had to be signed by Slobodan Kuruzovic.

12 Q. Did you sign that document voluntarily?

13 A. No. My mother had to do all this for me.

14 MS. BALY: That's the examination-in-chief. Thank you, Your

15 Honours.

16 JUDGE ROBINSON: Thank you, Ms. Baly. Mr. Greaves?

17 Cross-examined by Mr. Greaves:


19 Q. Witness F, if you don't understand the question which I ask you,

20 please stop me, won't you, and ask me to repeat it for you so that I can

21 put it again to you? Witness F, it's right, isn't it, that in connection

22 with the events which happened to you in 1992, you've made a number of

23 different statements or have given a number of different accounts to

24 various people? Do you accept that?

25 A. I did give statements, but later on I distanced myself from one of

Page 1436

1 these statements.

2 Q. Yes, we are going to come back to that in a moment, Witness F, but

3 let's just make sure that we know exactly what it is you've done. There

4 was a newspaper interview which you gave to a Bosnian newspaper in July,

5 1995; is that right?

6 A. Yes.

7 Q. And then in January, 1998, did you write out in hand a document

8 which you headed "Statement" and did you send that to the Tribunal here in

9 the Hague?

10 A. Yes.

11 Q. Did you sign that document?

12 A. Yes.

13 Q. Together with that document, did you send to the Tribunal a copy

14 of the newspaper article which had appeared as a result of your

15 interview?

16 A. Yes.

17 Q. Sometime after sending the handwritten statement to the Tribunal,

18 were you interviewed by an investigator?

19 A. After a period of time.

20 Q. About a couple of months later? Would that be right?

21 A. I cannot say exactly. I don't --

22 Q. If I suggested to you it was in -- on the 27th and 28th of March,

23 1998, and the person who interviewed you was a lady, I think Kari

24 Seppanen, does that refresh your memory?

25 A. Yes, Kari, yes, but the date, no.

Page 1437

1 Q. Then you made a further written statement in a formal way to the

2 Office of the Prosecutor on the 15th of September of last year; is that

3 correct?

4 A. I did not write it down. They did it.

5 Q. Of course. But did you at the end of it have it read back to you

6 and did you acknowledge that it was true to the best of your knowledge and

7 belief -- knowledge and recollection, I'm sorry?

8 A. Yes.

9 Q. Between being interviewed by the lady whose named we mentioned,

10 Kari Seppanen, and making the written statement in September of last year,

11 did you -- were you interviewed on any other occasion by the Office of the

12 Prosecutor?

13 A. No.

14 Q. When you wrote out in hand and sent the Tribunal your statement

15 and you attached to it a copy of the newspaper report, why did you attach

16 the newspaper report to the statement, Witness F?

17 A. I simply thought that it might be of value to them.

18 Q. Were you not, by attaching that newspaper article without any

19 further comment about it, telling the Tribunal that what was in that

20 newspaper article was a true account of what had happened to you? Isn't

21 that what you were saying to the Tribunal?

22 A. No.

23 Q. Your position now as regards that document is this, isn't it, that

24 the newspaper article -- the article was not written by you and "the

25 journalist has mixed up some details on some aspects of my story"?

Page 1438

1 A. Yes.

2 Q. And secondly, this, "I can tell you today that the story published

3 in the newspaper differs from my own and that I did not write the

4 article. Where there is a discrepancy in the stories, I stand by my

5 statement. The journalist did not have all the details correct. I did

6 not see the newspaper article before it was published." Is that the

7 position you take today about the newspaper article?

8 A. Yes.

9 Q. Did you read the article again before attaching it to your

10 handwritten statement?

11 A. I did read it, but it wasn't important at all.

12 Q. It wasn't important? You didn't think that the details contained

13 in that were at all important; is that it?

14 A. Certain details were important, but the details were -- where

15 there is discrepancy between my account and his article, that was not

16 important at all.

17 Q. When you were interviewed by Kari Seppanen, I suggest not long

18 after sending your handwritten statement in, why didn't you tell that

19 person that the newspaper article contained discrepancies, Witness F?

20 A. Because he asked me that.

21 Q. I'm sorry, he asked you -- he asked you what exactly?

22 A. He asked me whether that article was truthful. I told him that I

23 had not read the article before it was published and that the journalist

24 confused the names and events. He -- his interest was simply to have this

25 published.

Page 1439

1 Q. Witness F, we have established that the person who interviewed

2 you, Kari Seppanen, was a lady. Did you tell the lady interviewer from

3 the OTP that the article which had appeared and which you had attached to

4 the handwritten statement -- did you tell the lady investigator that there

5 were discrepancies in it?

6 A. Kari Seppanen is not a woman. It is a man.

7 Q. It may well be that I've been misled by something I was told by

8 the Prosecutor, who referred to her as a woman; not any of the people who

9 are sitting there at the moment. It's Rebecca, who is the case manager,

10 told me it was a woman. I apologise, Witness F, I will withdraw that

11 question. Why -- can you help us about this, please: Did you describe

12 the newspaper article in your handwritten statement of January, 1998, why

13 did you describe it in this way? "My eyewitness report on the murder and

14 torture committed in the Keraterm concentration camp was published in a

15 newspaper in Sarajevo and Frankfurt? There I described and listed by name

16 the persons who killed and tortured in Keraterm." Why did you describe it

17 as your eyewitness report, Witness F?

18 A. I said that so that the Court -- actually, that the people here in

19 the Hague would believe that I was a detainee in Keraterm, because at that

20 time it was difficult to get on a list for testifying. You had to prove

21 that you had been an inmate. This is why, in addition to the article, I

22 sent off other documents which proved that I had been a detainee.

23 Q. Witness F, I suggest that what you meant by the phrase my

24 "eyewitness report" is this: That this newspaper article represents the

25 truth of what happened to me. That's what you were suggesting to the

Page 1440

1 Tribunal, weren't you?

2 A. No.

3 Q. And this is the situation: You have now realised several years

4 later that it did, indeed, contain discrepancies and that that might

5 reveal you to be someone who was not a truthful witness, Witness F, isn't

6 that right?

7 A. No.

8 Q. And what is happening in the year 2000 when you see the Office of

9 the Prosecutor is you are desperately trying to back-pedal from those

10 discrepancies which would so reveal you to be an untruthful and unreliable

11 witness.

12 A. And what is the question?

13 Q. What you are doing in the year 2000 is you are desperately trying

14 to back-pedal from the discrepancies which, I suggest, will reveal you as

15 someone who is not truthful and reliable. That's what you are trying to

16 do in the year 2000, isn't it, and now?

17 A. No, that is your opinion.

18 Q. Just have a look at one or two details, Witness F. Let's discuss,

19 for a moment, the accounts which you have given about the beating which

20 you received from Zoran Zigic. Would you accept that this is what you

21 told the newspaper, "I was to be taken to Keraterm. The moment I arrived

22 to Keraterm, Zoran Zigic, formerly a taxi driver, and Dusan Knezevic,

23 Duca, came to collect me. Those two had 'treated' almost all of the

24 prisoners. They were worse than beasts. They simply enjoyed in human

25 sufferings and bloodsheding."

Page 1441

1 Do you accept that is what you told the newspaper?

2 A. I said their names and he treated them in a journalistic way. He

3 asked me who they were, I told him, and then they did the rest.

4 Q. But do you accept that you told the journalist that you were

5 beaten, you were collected and beaten the moment you arrived at Keraterm?

6 A. No.

7 Q. Let's go on. "Zigic was beating me with everything he could find,

8 a police club, a chain, an iron ball, a knife. On that night, he broke my

9 nose, my jaw, and both supraorbital arches were broken too. Dusan

10 Knezevic, Duca, broke my arm." Did you say that to the journalist?

11 A. Not in such a comprehensive way.

12 Q. But in a general way, that's what you told him; is that right?

13 A. But not that much. I said that Knezevic had broken my arm, and

14 that Zigic had broken my nose, and he filled in the rest.

15 Q. Did you tell the journalist what weapons had been used on you?

16 A. No.

17 Q. Why didn't you tell the journalist that?

18 A. Was it important?

19 Q. Would you just please answer the question. Why didn't you tell

20 the journalist what weapons you'd been beaten with?

21 A. Perhaps he didn't ask me.

22 Q. So the journalist simply made that up; is that right?

23 A. I did say that he had magnified things.

24 Q. Let's move, if we may, please, to your handwritten statement which

25 you made in 1998. You wrote in that, "At about 6.00 in the afternoon of

Page 1442

1 the 5th of July 1992, he," referring to Zoran Zigic, "and the

2 above-mentioned group," which you named Dusan Knezevic, Zoran Vokic,

3 Zeljko Timarac, and another person, "... he and the above-mentioned group

4 came and asked me to come out of the dormitory. They took me to a part of

5 the hangar where they ordered me to kneel and then started to vent, to

6 torment me. Dusan Knezevic, Duca, had a baseball bat. Zoran Zigic had a

7 police truncheon, and the other three had automatic rifles. They beat me

8 with whatever they could lay their hands on."

9 Do you remember that?

10 A. Yes, and I stand by it.

11 Q. So according to you, they took you from the dormitory, took you

12 straight to a part of the hangar where they made you kneel, and at that

13 point you were beaten. That's what you were saying in 1998?

14 A. Yes.

15 Q. Why did you then tell the Office of the Prosecutor in the year

16 2000 that they began to beat you whilst you were still outside on the

17 pista?

18 A. Because they also did beat me. It was that important -- they beat

19 me while I was walking. Perhaps I forgot to mention that the first time.

20 Q. Again you told the Office of the Prosecutor that they were asking

21 you out on the pista for money, gold, and other valuables. Why didn't you

22 mention that in your statement, your handwritten statement of 1998,

23 Witness F?

24 A. I did not remember it, perhaps. But they did ask that of me.

25 Q. There was talk about you having been involved in supporting rebels

Page 1443

1 by transporting food and financing the SDA, and there being a sniper who'd

2 shot from your house. That's what you told the Office of the Prosecutor

3 in the year 2000, isn't it?

4 A. These were questions that they were asking me, Dusan Knezevic and

5 company, while he were beating me.

6 Q. Again, why didn't you put that into your written statement of

7 January 1998, Witness F?

8 A. I did not remember it.

9 Q. You were interviewed by some military interrogators at the

10 hospital as to who had beaten you in Keraterm. That was only on one

11 occasion when they made a visit?

12 A. Yes.

13 Q. They had plainly come as a result of a request to investigate the

14 incident; is that right?

15 A. No. What request?

16 Q. Well, perhaps we'll move on. Did the military investigators,

17 military police come on any other occasion whilst you were in the

18 hospital?

19 A. Not to my room.

20 Q. Why did you tell the Tribunal in your handwritten statement then,

21 Witness F, this: "The military police from Banja Luka came to interrogate

22 us every day." Why did you tell them that?

23 A. Perhaps I wrote it that way. I may have been thinking about daily

24 interrogations.

25 Q. I suggest that what you have just told us about the military

Page 1444

1 interrogators coming only once and what is written in your handwritten

2 statement, those two things are completely different, Witness F, and I

3 suggest to you that you are, at best, exaggerating greatly in your

4 evidence and at worst, you are simply lying to us, aren't you?

5 A. No. That is your view.

6 MR. GREAVES: If Your Honour would just give me a moment, please?

7 Q. After you were beaten by Zoran Zigic on the 5th of July, Witness

8 F, it was the following day that a doctor came and examined you, decided

9 you should go to hospital, and you went to hospital almost immediately; is

10 that right?

11 A. No.

12 Q. How soon after being examined did you go to the hospital?

13 A. The examination took place two days later.

14 Q. Between you being beaten and your going to hospital, were any

15 other prisoners beaten?

16 A. Yes.

17 Q. And they were taken out and beaten but none of them died?

18 A. That I don't know.

19 Q. Did you hear of any of them dying?

20 A. People were dying every day.

21 Q. As a result of those beatings, Witness F, did you hear of anybody

22 dying?

23 A. Many died due to beatings.

24 Q. Witness F, I think the question is quite clear. You've told us

25 that between your beating and your being taken to hospital, that prisoners

Page 1445

1 were taken out and beaten. The question is clear. Did you hear of any of

2 those dying as a result? Please answer the question.

3 A. Yes, they died.

4 Q. How many?

5 A. I don't know.

6 Q. How many prisoners were beaten?

7 A. Many, about 15.

8 Q. Why, then, did you in your handwritten statement tell the Tribunal

9 this? This comes immediately after you've described your own beating.

10 "About 30 prisoners were beaten that night and a couple of them died from

11 beating and internal bleeding." And then you name two doctors and said

12 that "they came in the morning and found that all the inmates had died a

13 natural death. The guards threw them on the garbage dump." Why did you

14 put that in your handwritten statement, Witness F?

15 A. I thought it would be important.

16 Q. Just turning for a moment again to the detail of your newspaper

17 interview and your beating. You told, did you not, the newspaper that you

18 were accused of cooperating with the leadership of the SDA? You remember

19 that?

20 A. Do I remember what?

21 Q. Do you remember telling the journalist, the one who published or

22 got -- wrote the article, that you had been accused of cooperating with

23 the leadership of the SDA? Do you remember that?

24 A. Yes, I do.

25 Q. Printing their propaganda material? Did you tell them that?

Page 1446

1 A. He added that.

2 Q. He added that. Transporting food for rebel Muslims, together with

3 another man? Do you remember that, telling him that?

4 A. Yes.

5 Q. That you --

6 A. I did -- what I said was that I had been accused of that whilst

7 being beaten.

8 Q. Yes. That's exactly what it says. "I was also accused of

9 shooting at Serbs with a sniper and financing the SDA party in Prijedor."

10 Did you tell him that?

11 A. I said it.

12 Q. Did you tell the journalist this? "That was my indictment and

13 Serb justice was done accordingly. For 74 days I was in the hands of

14 Chetnik beasts. Today I cannot believe that I used to live with those

15 people, socialise with them, and even had friends amongst them. They are

16 sick people. It is some kind of genetic disorder." Did you tell the

17 journalist that?

18 A. No.

19 Q. Did you use the phrase "Chetniks" to describe people who were on

20 the other side?

21 A. Yes.

22 Q. Did you -- do you recall telling the newspaper journalist about

23 the death of Mr. Dizdarevic?

24 A. I just mentioned it to him.

25 Q. And you told him some of the details of what you'd seen and how

Page 1447

1 you'd seen it, did you?

2 A. Yes, as individual details. To him what was important was only

3 the names of those who had been killed.

4 Q. Regardless of what he thought was important, let's look at what

5 you told him, Witness F. Did you tell him how you'd seen an older man

6 through a hole in your sleeping room?

7 A. Yes, I knew that man personally.

8 Q. And that you'd seen him through a hole in your sleeping room? Is

9 that how you told the journalist what you'd seen?

10 A. I don't remember what I told him, but I did see him, through a

11 hole or from the pista where we were, but I saw him.

12 Q. What size was this hole through which you saw Mr. Dizdarevic?

13 A. The door to the dormitory was the size of the dormitory.

14 Q. So you're not talking about a hole, small hole in the wall, you're

15 talking about a door, are you? That's what you call a hole, is it?

16 A. I never said a hole. Everybody knows what a hole is.

17 Q. Why didn't you mention the death of Mr. Dizdarevic in your

18 handwritten statement, Witness F?

19 A. Perhaps I did not think it important.

20 Q. You plainly thought it important enough to put into your interview

21 and to mention it to the Office of the Prosecutor, didn't you?

22 A. I knew of other cases which seemed better for the Prosecution than

23 that one.

24 Q. You were anxious to become a witness in this case, weren't you?

25 A. Yes. And I will continue to testify in other cases.

Page 1448

1 Q. Why were you so anxious, if I may ask, please, Witness F, to

2 become a witness?

3 A. Because I went through a great deal and I want it to come out. I

4 want justice to be done.

5 MR. GREAVES: May we go into closed session, please, Your Honour?


7 [Private session]

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 [Open session]


Page 1449

1 Q. I'd like to ask you now about the village or small town of

2 Hambarine, Witness F.

3 A. Yes.

4 Q. Did you hear of or know of an attack which took place on some

5 Serbs at a checkpoint manned by Muslims in that village?

6 A. Yes, I heard about it.

7 Q. And did you hear how many Serbs were killed as a result of that

8 incident?

9 A. It was said that there were two.

10 Q. And did you also hear that as a result of that, a demand was made

11 by the Serb authorities for the surrender of the people who'd carried out

12 the shooting?

13 A. That's right. They issued an ultimatum to turn over the weapons.

14 Q. To turn over the weapons and the people or just weapons?

15 A. Weapons. They said to turn over the weapons and issue them with

16 an ultimatum.

17 Q. And was that ultimatum, as you understand it, and you have heard,

18 the cause of the attack on Hambarine?

19 A. That's right, yes, something like that. But I had nothing to do

20 with this ultimatum because I lived in a completely different part of the

21 town.

22 Q. I'm not suggesting that you did have anything to do with it,

23 Witness F. Don't misunderstand me.

24 A. You asked me if I had something to do with the ultimatum. I think

25 that was the question or the drift of the question.

Page 1450

1 Q. I'm not going to argue about that. Between the takeover and the

2 date of your arrest, Witness F, some assistance was given to you by some

3 people. They were of Serb ethnicity; is that right?

4 A. When they were rounding up people in my part of the town, yes,

5 they helped me. They were of Serb ethnicity.

6 Q. Turning now to the time of your arrival at Keraterm, initially

7 it's right, isn't it, that Zoran Zigic prevented your -- stopped anybody

8 from beating you at that point; is that right?

9 A. Knezevic hit me straight away, and Zigic told me [as interpreted]

10 not to touch me because I was his. Now, what he meant by this word

11 "his" --

12 Q. You told us in evidence that you had seen other detainees being

13 beaten upon their arrival at that point, and that that was done with the

14 following implements, Witness F: Batons, baseball bats, rods, hands, and

15 feet. Why did you tell the Office of the Prosecutor in the year 2000 that

16 you could see how other guards beat prisoners with their batons in the

17 vicinity? In other words, why have you now added all those other

18 implements?

19 A. Because I remembered that they were also used then. I stand by

20 that, that they were also used.

21 MR. GREAVES: Again, may we go very briefly into private session,

22 please.


24 [Private session]

25 [redacted]

Page 1451

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]

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18 [redacted]

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21 [redacted]

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23 [redacted]

24 [redacted]

25 [redacted]

Page 1452

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 [Open session]

19 JUDGE ROBINSON: Yes, we are back in open session.

20 MR. GREAVES: Thank you very much.

21 Q. I'd like to ask you now about the water truck, please, Witness F,

22 that was kept at Keraterm. It's right, isn't it, that there was a regular

23 supply of water using that water truck; do you accept that?

24 A. Yes. The water truck brought the water, but there were also

25 hydrants in the compound from which water could also be used.

Page 1453












12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.













Page 1454

1 Q. And so the detainees were able to use the water from the water

2 trucks and had no restriction on use of the water hydrants; is that

3 right?

4 A. Well, there were certain restrictions as far as hydrants were

5 concerned.

6 Q. As far as food was concerned, where was food prepared, Witness F?

7 A. The food was prepared outside the camp. It was brought there, and

8 we heard -- we heard that it was prepared in the canteen of the Ljubija

9 mine.

10 JUDGE ROBINSON: We can go to ten past 4.00 with the cooperation

11 of the interpreters.

12 MR. GREAVES: Thank you very much. I hadn't been actually

13 watching the time, and I'm sorry for that.

14 Q. Witness F -- I'm sorry, just give me a moment please, Your

15 Honour.

16 No question of the kitchens at Keraterm being used. The food came

17 from outside the camp prepared by others who were not at the camp; is that

18 correct?

19 A. It is.

20 Q. Can you explain then, please, why you said in your handwritten

21 statement this: "We were fed once a day with a piece of bread and .2 of a

22 litre of cabbage or bean soup. Sometimes the kitchens would not work

23 because of power cuts so that we got our food once every day, every two

24 days," implying, I suggest, that the food was being prepared on the

25 premises. Why did you say that in your handwritten statement, Witness F?

Page 1455

1 A. Not the kitchen in the compound, a kitchen in the town. There was

2 no kitchen in the compound. The town was without electricity.

3 Q. I'd like just now to return, please, if we may to the killing of

4 the man called Dizdarevic. As far as you could tell, was that man killed

5 off the premises of Keraterm, off the grounds of Keraterm?

6 A. I cannot be absolutely sure, but he was killed outside the

7 Keraterm camp, next to the reception hut. Whether it was in front of the

8 camp or inside, but it was right next to the reception hut.

9 Q. So let's just be absolutely clear. You cannot say whether it was

10 inside or outside the perimeter that that killing took place; is that

11 correct?

12 A. I did not see him being killed. I heard about it, and he -- but

13 his sons said that he had been killed because he never came back and all

14 trace of him is missing, and his sons were with me in the camp, and we all

15 watched as he would ride on his bicycle past the dormitory.

16 Q. So you cannot say, either of your own observation or of your own

17 knowledge, whether it was somebody on the camp staff who killed him or

18 somebody who was not part of the camp staff, can you?

19 A. Well, there were guards at the entrance into the camp.

20 Q. Please answer the question, Witness K. You'll get away from here

21 a lot quicker if you listen to the question and answer the question which

22 you have been asked. I'll repeat it for you. You cannot say, can you,

23 either from your own observation or from knowledge given to you, whether

24 it was somebody on the camp staff or somebody who was not on the camp

25 staff who carried out the killing. You simply cannot say, can you?

Page 1456

1 A. I cannot, no.

2 Q. The people who administered the beating to you were all people who

3 came from outside the camp; is that right?

4 A. No.

5 Q. Who do you say of those was somebody who was inside the camp?

6 A. Zoran Karlica or Goran Karlica.

7 Q. Can I turn now, please, to your interrogation and indeed

8 interrogations in general? When you were interrogated in Keraterm, did

9 you know the names of the interrogators?

10 A. I knew names. I even knew some of those investigators.

11 Q. Were they people who were part of a group who were designated as

12 specialist interrogators?

13 A. What do you mean?

14 Q. Yes. Was there a specialist group of people who were civilian

15 policemen who were designated as interrogators at Keraterm?

16 A. Yes. Above Room number 1.

17 Q. The people who interrogated you, did you know their names?

18 A. Yes.

19 Q. What were the names?

20 A. Bane Siljegovic, Branko Bucalo and others elude me right now.

21 Q. Would you please help Their Honours about this, Witness F? You've

22 just told us that you knew the names of them. Why did you tell the Office

23 of the Prosecutor in September 2000 this: "After ten days I was taken

24 back to the Keraterm camp and interrogated. I did not know the names of

25 those interrogators." Why did you tell the Office of the Prosecutor that,

Page 1457

1 if you did, in fact, as you've now told us, know the names?

2 A. I learned them later on.

3 Q. Since September, 2000? You've learnt the names since September,

4 2000? Is that what you're saying?

5 A. No.

6 Q. What did you mean by, "I learned them later on," then, Witness F?

7 A. After that first interrogation.

8 Q. You see, when you made your handwritten statement in January,

9 1998, you were able to tell the Tribunal this: "Apart from the guards at

10 the camp, there was a special interrogation commission made up of civilian

11 policemen. Their task was to gather data on all prisoners. They

12 processed all the prisoners." And then you named four people. Now, help

13 us again. Is it a case of you having forgotten in the meantime, when you

14 were interviewed by the Office of the Prosecutor, who had interviewed you,

15 who had interrogated you, and you've now remembered again? Is that it?

16 A. Possibly.

17 Q. The problem is, Witness F, you can't get your story right two

18 occasions running, can you, because you're not being very truthful with

19 this Tribunal, are you?

20 A. That is what you think.

21 Q. The guard who escorted people to the interrogations, did you know

22 that person by name?

23 A. No.

24 Q. Was it obvious from what you could see of him that he was somebody

25 who was from a separate unit from the personnel of the -- of Keraterm?

Page 1458

1 A. He wore the uniform of the reserve police.

2 Q. I'd like to turn now briefly to the incident of the killings at

3 Room 3, Witness F. Would you accept this, that prior to it happening, you

4 heard Kolundzija, Kole, with soldiers who had come from outside the camp

5 and he was arguing with them? Do you remember that?

6 A. Yes.

7 Q. And you heard specifically this, Kole saying, "I cannot let this

8 happen."

9 A. One could hear it.

10 Q. And did you overhear one of the soldiers from outside the camp

11 saying that they would take full responsibility for what was about to

12 happen?

13 A. One could hear it.

14 Q. And did you also hear during the shooting Kole, at some distance

15 from you, telling them not to shoot?

16 A. On -- at number 1, "Don't shoot at number 1."

17 Q. Can I now ask you, please, about the day after that incident? You

18 claim that you were outside during the course of the day following. Apart

19 from those you have already discussed, did you see somebody called Zivko

20 Knezevic in the camp that day?

21 A. No.

22 Q. Is that a name with which you are familiar, Witness F?

23 A. No.

24 Q. You see, I suggest to you that he was, in fact, the man who was

25 the commander of the camp; isn't that right?

Page 1459

1 A. I don't know that.

2 Q. And that you are incorrect when you allege that Dusko Sikirica was

3 the commander.

4 A. I affirm it and I stand by it.

5 Q. And I suggest to you that he never conducted delegations about the

6 place, delegations of civilians.

7 A. This is what you say.

8 Q. And he wasn't, was he, present at the closing of the camp, reading

9 out any names?

10 A. He was present, he was present, and he read out 120 inmates'

11 names.

12 Q. He certainly wasn't the commander on that day, was he?

13 A. I don't know who the commander was, but he read it. He is the one

14 who decided who was going to go. And who the commander above him or

15 underneath him was, that I don't know.

16 Q. Are you, by your answer, at that point, Witness F, saying that he

17 was not, as far as you know, the commander on the day when those people

18 were sent to Omarska?

19 A. I do not say that, and I did not say that.

20 Q. Well, your evidence is that Dusko Sikirica was the commander of

21 the camp. Are you asserting today that on the day when the camp was

22 closed, that Dusko Sikirica continued to be the commander of the camp?

23 A. I assert that because he read that list.

24 Q. Do you know somebody by the name of Fikret Hedic?

25 A. No.

Page 1460

1 Q. If such a person were to suggest or say, rather, that the calling

2 out of the names had been carried out by an army captain first class, you

3 would say that's incorrect?

4 A. Yes.

5 Q. Do you know somebody called Karanfil Aliskovic?

6 A. No.

7 Q. If he was to assert that it was a man called Kondic who'd called

8 out the names, that would be incorrect, would it?

9 A. I would say that it was not correct.

10 Q. Returning to Senad Kurbegovic, if he was to assert that the

11 commander of the camp, the entire camp was Zivko Knezevic, who he knew

12 before the war, he'd be wrong about that, would he?

13 A. That is his opinion.

14 Q. Help us about this, please, Witness F: In your handwritten

15 statement, you described on two occasions Dusko Sikirica and you use this

16 phrase "commander of all the guards". What I suggest to you is that the

17 role that Dusko Sikirica played in Keraterm was commander of security, not

18 commander of the shifts, not commander of the guards who were inside the

19 camp, but commander of security. That's the position. That's correct,

20 isn't it?

21 A. I'm not an expert in these military matters.

22 MR. GREAVES: Your Honour, I believe I can finish even if we go

23 slightly past ten past 4.00 I think that's a sensible thing rather than

24 have a dribble move over into tomorrow.

25 JUDGE ROBINSON: Yes, that would be acceptable.

Page 1461

1 MR. GREAVES: Thank you very much. I don't want to start gabbling

2 and hurrying.

3 Q. Again, I suggest to you that he was not present on the day after

4 the incident in Room 3 at all. That's correct, isn't it?

5 A. No.

6 Q. In evidence you told us today that at the time when these events

7 were taking place, he was around 30ish in age.

8 A. That is -- that was my estimate. Now he looks twice that age, as

9 if he were 130.

10 Q. Can you tell us, please, the name of the person with whom you were

11 friendly at school, who you believed married him?

12 A. Yes.

13 Q. Would you tell us, please, what the name was?

14 A. Yes, Mira Sekulic.

15 Q. And at which school were you and she?

16 A. The construction technical school.

17 Q. On the map which you have produced of the camp, you have put the

18 words "military prison". Is that a place where Serb prisoners were kept?

19 A. Yes.

20 Q. How many prisoners were kept there?

21 A. I don't know. We had no access there.

22 Q. And did you hear nothing -- nothing about it whilst you were

23 there, no information given to you?

24 A. Who was to give us the information?

25 Q. The -- just help us about this, please, Witness F. The total

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1 number of people detained at Keraterm whilst you were there, can you tell

2 us, roughly speaking, how many they were?

3 A. 1.000 to 1.200. Each room contained 300 to 400 or 200. It

4 depended.

5 Q. Were people released from the camp whilst you were there?

6 A. Where were they releasing them?

7 Q. From Keraterm.

8 A. Sometimes they would line up and call out names and they would

9 take people away, but they were not releasing anyone so far as I know.

10 Q. Would this be correct, Witness F, that during your time at

11 Keraterm, you and the other more than 1.000 prisoners were at all times in

12 the power of the Serb authorities?

13 A. Yes.

14 Q. And they could have killed you at any time, you and all your

15 fellow detainees?

16 A. Yes.

17 Q. I just want to return briefly to the issue of the title and

18 function of Dusko Sikirica. Could you please just have a look at a copy

19 of a document, please. Having looked at it, could you perhaps put it on

20 the monitor. There are some copies for my learned friends and for the

21 Court in the English version thereof.

22 Witness F, firstly can you tell us, please, have you ever seen

23 that document before?

24 A. No.

25 Q. Can you just do one thing with me, please, would you look at the

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1 bottom right-hand corner and just indicate it by putting your finger on it

2 on the monitor, do you see in the bottom right-hand corner in your

3 language, I think, a signature right at the bottom and some typed words

4 written above it; do you see that?

5 A. Yes, I see it, yes.

6 Q. Would you be so kind as to read out what is written there, please,

7 nothing else, just that corner signature and note?

8 A. "Record compiled by commander of the Keraterm security."

9 Q. Signed Dusko Sikirica, is that right, or it appears to be signed

10 Dusko Sikirica?

11 A. Dusko Sikirica, yes.

12 Q. Does that refresh your memory in any way, Witness F, as to the

13 proper title and role of Dusko Sikirica in the camp?

14 A. No.

15 MR. GREAVES: Thank you very much for letting me go slightly past

16 ten past 4.00, Your Honour. It's most kind.

17 JUDGE ROBINSON: Thank you, Mr. Greaves. We are going to take the

18 adjournment now and we will resume on Monday morning at 9.30.

19 Witness F, you are reminded that during the adjournment, you are

20 not to discuss your evidence with anybody, including members of the

21 Prosecution team.

22 We are adjourned.

23 --- Whereupon the hearing adjourned at

24 4.13 p.m., to be reconvened on Monday the 2nd day

25 of April, 2001, at 9.30 a.m.

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12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.