101110IT

Page 7512

1 Examination by Mr. Thayer: [Continued]

2 Q. Good morning, sir.

3 A. Good morning, sir.

4 Q. I know you've been here not too long ago, but you probably need

5 to spell your -- state and spell your name for the record.

6 A. My name is Tomasz Blaszczyk, B-l-a-s-z-c-z-y-k.

7 MR. THAYER: Now, before we begin working with the book, Your

8 Honours have obviously seen large portions of the Petrovic video recently

9 and heard Ms. Gallagher's testimony about portions of that; for example,

10 how Mr. Petrovic recorded over two key portions of the original footage

11 that he shot during those days in Srebrenica, how he turned over that

12 altered version to the OTP, but at the same time you also heard how the

13 OTP is in possession of a version of that original footage that includes

14 the portions which Mr. Petrovic recorded over. So we won't go into too

15 much detail about -- about those matters, but we will get to some of

16 that.

17 Q. So perhaps, Mr. Blaszczyk, could we start off talking a little

18 bit about Mr. Petrovic. Could you tell the Trial Chamber a little bit

19 about who is he, what was he doing in the Srebrenica area in July of

20 1995?

21 A. Mr. Zoran Petrovic, using the name also Pirocanac, he was a

22 Serbian journalist. He was in the Srebrenica area on the 13th and 14th

23 of July, 1995. During his presence in Srebrenica AOR, he recorded some

24 events which had happened at that time in Srebrenica area, mostly in

25 Potocari and on the road from Bratunac towards Konjevic Polje, mostly on

Page 7513

1 the part of this road Kravica, Pervani, Sandici meadow, and Lolici, and

2 he spent only these two days in -- in Srebrenica area in fact in this --

3 this -- this area. The first day in Potocari he recorded events in

4 Potocari. He recorded group of the people who were in Potocari on the 13

5 of July, 1995, and he moved to the part of the road between Bratunac and

6 Konjevic Polje, mostly, as I said, Kravica, Sandici, Lolici, Pervani,

7 this road. And on the following day, on the 14 of July, he returned to

8 Srebrenica. He recorded some footages in Srebrenica and also in Zeleni

9 Jadar.

10 According to his statement and his testimony, he arrived to

11 Srebrenica with the help of Mr. Ljubisa Borovcanin who facilitated him to

12 pass the border between Serbia and Bosnia-Herzegovina in the place called

13 Ljubovija, this is near Bratunac.

14 Q. And just remind us again who is Mr. Ljubisa Borovcanin.

15 A. Ljubisa Borovcanin is the deputy head of the Special Police

16 Brigade of Bosnia-Herzegovina and he serves in Republika Srpska at that

17 time, and he was commanding officer of the police forces in this area.

18 Q. And during this period of time, was Mr. Petrovic travelling alone

19 with Mr. Borovcanin or did Petrovic bring anybody with him from Serbia.

20 A. Mr. Petrovic, Pirocanac, was alone in Bosnia-Herzegovina but he

21 was always -- most of the time he was together with Mr. Borovcanin and

22 was travelling with his car and with his driver.

23 Q. And when you say his car and his driver, just to be precise,

24 whose car and whose driver?

25 A. I mean the car of Mr. Borovcanin used by Mr. Borovcanin, and

Page 7514

1 driver of Mr. Borovcanin was the police officer called Nedjo Jovicic.

2 Q. Okay. And have you met Mr. Petrovic?

3 A. Yes, I met Mr. Petrovic. The first time I met him in this is

4 February 2006. I met him in Belgrade. We interview him in Belgrade

5 field office. And later on in later stage I met him here in The Hague

6 also.

7 Q. And again, Your Honours, Mr. Petrovic, who is Witness number 183,

8 was a proposed 92 bis witness. Pursuant to Your Honours' order, he will

9 be appearing for cross-examination probably sooner than later given

10 Mr. Blaszczyk's accelerated testimony. We'll try to bring him in before

11 too long.

12 Now, sir, when you interviewed Mr. Petrovic in February of 2006,

13 did he physically hand anything over to you at that time?

14 A. Yes. When we met him in February 2006, he made available for us

15 the raw material of the material recorded by him in Srebrenica and

16 Bratunac area on the 13 and 14 July 1995. And he made available this

17 material to us and we, in his presence, we copied this material using our

18 equipment, the material was copied by our video assistant, and

19 Mr. Petrovic confirmed the authenticity of the copied material.

20 Q. And in what format was the -- we'll refer to it as the original

21 raw material that he handed to you for you to copy.

22 A. It was -- it was 8-millimetres tape.

23 Q. And when you copied it, into what format did you copy that

24 8-millimetre video?

25 A. We did it in the same format and we made a copy also on DVD. As

Page 7515

1 a spare copy on the hard drive of the -- of the video recorder.

2 Q. And do you recall the name of the video assistant who accompanied

3 you and assisted you in this process?

4 A. Yes, of course I remember his name, his name is Zoran Lesic.

5 Q. Okay.

6 MR. THAYER: The Trial Chamber's already heard a little bit about

7 Mr. Lesic and we'll hear more about his involvement in putting together

8 this road book and some of the other features which Your Honours will see

9 before too long.

10 Q. Now, when you reviewed this so-called raw footage that

11 Mr. Petrovic gave to you in February of 2006, was it complete and

12 unaltered, or could you tell whether there had been portions that had

13 been altered in some fashion?

14 A. According to Mr. Petrovic, he handed over to us at that time the

15 entire material he recorded in -- in Srebrenica and Bratunac area, but

16 this material was somehow redacted. It's mean that this material has

17 some blank spaces, recorded overs spaces, and is visible that few

18 footages were also played but with edited material of Mr. Petrovic in

19 Belgrade in July 1995, not at this material.

20 Q. And during this interview with Mr. Petrovic, how did he account

21 for these portions that, as you said, had some blank spaces or there were

22 portions that had been recorded over by Mr. Petrovic? What explanation

23 did he have, if any, for that?

24 A. Yes. He explained this -- this redacted portion that he -- he

25 justified it by his unexperienced working as a cameraman. He said that

Page 7516

1 the tape was used several time. He doesn't know, in fact, you know, how

2 it happened that this portion had been redacted or recorded over.

3 Q. And now as an investigator with a fair amount of experience and

4 certainly with the experience that you've gained as being a key

5 investigator in the Srebrenica investigation, did you believe

6 Mr. Petrovic when he told you this? Did you find his explanation

7 credible? And if so, why did you, and if not, why did you not?

8 A. It's really very hard to believe it, and personally I have a lot

9 of objection to his explanation why this material was redacted or

10 recorded over, because as we know, that the portion which was redacted,

11 there are a lot of incriminated material, you know, just showing the dead

12 bodies, showing the prisoners. And in fact, we are in possession only of

13 very few footages of this -- this material, this sensitive material, and

14 this is visible for me that they should be more such material on this raw

15 material, but unfortunately it's redacted or recorded over, but I -- I

16 think that during my testimony I will try, Your Honour, to explain you in

17 which place the material was redacted and how many seconds are missing.

18 Q. And again, let's talk a little bit about as an investigator on

19 this case, can you tell the Trial Chamber how it was that you came to

20 believe that there was material which Mr. Petrovic had shot, and to use

21 your term, incriminating material that Mr. Petrovic had shot but which

22 was missing from this so-called raw material that he gave to you? Can

23 you just provide a little bit more detail about the sources of your

24 belief that he was not telling you the truth when he explained that he

25 simply accidentally recorded over certain portions?

Page 7517

1 A. We are in possession also of the edited material of so-called

2 Petrovic video, we are calling this Petrovic video, this Petrovic

3 material. The material was broadcasted in the Serbian TV, television

4 on -- I believe on 17 July already in 1995, and this material contains

5 also this let's say very sensitive footages showing us bodies in Kravica

6 warehouse and showing us the prisoners in white house in Potocari. We

7 are in possession of this broadcasted material, redacted material, and

8 what we did, we compared in edited material which was broadcasted from

9 Serbian TV and we compared this material with the raw material handed

10 over to us by Mr. Petrovic, Pirocanac.

11 Q. And did you have this material which showed in incriminating

12 footage before you interviewed Mr. Petrovic in February of 2006?

13 A. Yes. We -- OTP received this material first time it was -- I

14 believe it was March 2002 from Mr. Ljubisa Borovcanin during his

15 interview conducted by OTP. Mr. Borovcanin handed over the VHS tape with

16 this broadcasted material to the OTP.

17 Q. And you've referred to this material as being broadcast. Can you

18 tell the Trial Chamber what outlet broadcast that material and exactly

19 where, if you know, and when, if you know.

20 A. If we -- if we look at the material on the right corner, top

21 corner of the footage we see the sign of the station who broadcasted this

22 material. This is Studio B from Belgrade, situated in Belgrade. We know

23 that this material was broadcasted shortly after Mr. Petrovic returned to

24 Belgrade in July 1995. As far as I remember, it was 17 July 1995.

25 Q. And can you share with the Trial Chamber how it is that you

Page 7518

1 recall that it was broadcast be on the 17th of July.

2 A. I believe it also we were -- I don't remember exactly, but I

3 think we were also informed by -- by we got this information from

4 Mr. Borovcanin as well as Mr. Petrovic.

5 Q. Okay. And we'll talk about this in a little more detail when we

6 get to this portion of the road book. So as you said, we'll refer to the

7 so-called raw video given to you by Mr. Petrovic as the Petrovic video,

8 and we'll refer to the full video or fuller video that incorporates or

9 contains the unredacted incriminating portions as the Studio B version

10 since it was broadcast by Studio B. So we'll really be talking about

11 Petrovic video and Studio B version of the Petrovic video.

12 Did the OTP obtain other versions or copies of this Petrovic

13 video from any other sources during the course of its investigation?

14 A. Yes, we did. The first time we obtained a copy of -- of the

15 Petrovic video, Petrovic -- in fact, later on we compared with the raw

16 material handed over to us by Mr. Petrovic. The first copy we received

17 from -- from BBC, and this material didn't contain the footages from

18 edited version Studio B. This is one copy of this raw material, let's

19 say raw material Mr. Petrovic. Another one we received from Ministry of

20 Defence of Bosnia-Herzegovina. We did receive this material in 2007 on

21 our request. It was this also -- this is another copy of the raw

22 material of Mr. Petrovic. Doesn't contain the -- the sensitive material

23 like the prisoners and bodies in Kravica warehouse.

24 Q. And do you recall in which year you obtained the copy of this

25 video from the BBC?

Page 7519

1 A. I think we got this copy in 2002. If I remember correctly, but I

2 think it was April 2002.

3 Q. Okay. And I think you've suggested this in your prior answer,

4 but have -- have you or one of your colleagues actually sat down and

5 compared the BBC version and the BiH Ministry of Defence version against

6 the raw Petrovic video or the Studio B version?

7 A. Yes. It was one of my colleague who compared this -- this

8 versions, and of course me as well, but in little bit later stage.

9 Q. Okay. And just to make it perfectly clear, are the BBC

10 versions -- the BBC and BiH MOD versions identical to each other?

11 A. Yes, the BBC [realtime transcript read in error "B/C/S"] version

12 and BiH MOD version plus the raw material of Mr. Petrovic are identical.

13 Q. Okay. So the redacted version, as you put it, given to you by

14 Mr. Petrovic is the same thing that BBC and then BiH MOD gave you; is

15 that fair to say?

16 A. Yes, this is correct.

17 JUDGE FLUEGGE: We see on transcript at line 6 of page 11, B/C/S

18 instead of BBC.

19 MR. THAYER: Thank you, Mr. President. That should have been

20 BBC.

21 Q. Now, do you recall whether the BBC version, although it was

22 identical to the other two versions that you just mentioned, had any

23 features to it which helped you in the process of putting together the

24 road book and the transcripts, for example?

25 A. Yes, this is video material and also audio is recorded on this

Page 7520

1 material, and it's a very useful one. It's good quality material.

2 Q. Okay. Now, this copy that you requested from the Ministry of

3 Defence of Bosnia and Herzegovina, can you tell the Trial Chamber a

4 little bit about the circumstances which led up to your request, what was

5 going on in the investigation that prompted you to make this request to

6 the MOD?

7 A. In 2006 in October our team from -- OTP team went to Banja Luka

8 to look at the archive of MOD in Banja Luka, and they had access to this

9 archive, and during this visit, they copied several material, several

10 documents, a lot of documents, and then the team returned to The Hague.

11 The material was put in the system. Everybody has access to the

12 system -- to this material, and I found -- we found in this -- this

13 material scanned the MOD archive one document where is video material raw

14 material Petrovic is mention this document. This document was prepared

15 by Milovan Milutinovic. It was the head of the press centre of the Main

16 Staff of Republika Srpska Army, and there is the information about --

17 about the raw material of Petrovic video, material -- material recorded

18 in Srebrenica and Bratunac area in July 1995 during the operation in

19 Srebrenica in July 1995, and when I received the copy or the scanned

20 version of this document, I immediately requested Ministry of Defence of

21 Bosnia-Herzegovina for original documents and also for the tape which,

22 according to this document, this scanned document, should be in their

23 hands. And as far as I remember in the following year in January we

24 received the original documents, I mean, Mr. Milovan Milutinovic

25 document, plus receipts of -- of -- of this -- this raw material and tape

Page 7521

1 itself.

2 Q. Okay. Well, let's look at a couple of documents, sir. The first

3 is 65 ter 2179, please.

4 Okay. We see the English version on the left, and it's headed

5 "Centre for Information and Propaganda Activities of the VRS Main Staff."

6 The date is 22 June, 1996. The subject is "Report on Television Footage

7 from Srebrenica," and it's addressed to the VRS Main Staff Security Body,

8 and it's signed Chief Colonel Milovan Milutinovic. Can you tell us what

9 this document is, sir.

10 A. Yeah. This is document I mentioned just awhile ago. This is

11 information of Colonel Milovan Milutinovic to information directed to the

12 security body of the Main Staff of VRS that raw material of the Pirocanac

13 or Petrovic video exists and is in the possession of Vesna Hadzivukovic,

14 and this person is willing to -- to hand over this material to VRS, and

15 this material contains footages from operation in Srebrenica from July

16 1995.

17 MR. THAYER: Mr. President, the Prosecution would tender 65 ter

18 2179.

19 JUDGE FLUEGGE: It will be received.

20 THE REGISTRAR: As Exhibit P1337, Your Honours.

21 MR. THAYER: May we have 65 ter 2180, please.

22 Q. Can you tell us what this document is, sir.

23 A. This is receipt for temporarily seized objects. This receipt is

24 signed by Vesna Hadzivukovic who handed over the video-tape to naval

25 captain Ljubisa Beara, or Colonel Ljubisa Beara, who was head of the

Page 7522

1 security of the Main Staff of the Republika Srpska. And this document

2 and the documents we seen previously, I seen first scanned version of

3 these two documents and later on I requested for originals and requested

4 for the tape mentioned here in this -- this receipt. And I received

5 these three objects.

6 JUDGE FLUEGGE: Sorry for interrupting you. I have heard you

7 saying naval captain Ljubisa Beara or Colonel Ljubisa Beara. Is that

8 correct?

9 THE WITNESS: Yes, this is correct. Naval captain, this is the

10 rank he used in navy, but colonel, this is respective ranking name in the

11 land forces.

12 JUDGE FLUEGGE: I mentioned that, because that part was missing

13 in the record.

14 MR. THAYER: Thank you, Mr. President.

15 Q. And we can see that the date on this document is two days after

16 the prior document, that is, this document is dated the 24th of June,

17 1996.

18 Now, sir, based on your work as an investigator on the Srebrenica

19 case, have you seen other documents bearing the signature of

20 Colonel Beara?

21 A. Yes, I've seen quite many documents signed by Colonel Beara.

22 Q. And -- and just based on your experience having reviewed, if you

23 can just give us some just ballpark estimate of how many thousands of

24 documents you've -- you've reviewed in the course of your investigation?

25 A. On daily basis I working with the documents from VRS, and

Page 7523

1 thousands.

2 Q. Based on your review of these thousands of documents and seeing,

3 as you describe, many documents with Mr. Beara's signature, can you tell

4 the Trial Chamber just based on your familiarity with his signature and

5 that of others, does this appear to be the signature that you have come

6 to identify as Colonel Beara's?

7 A. The signature here in these documents appear to me that this is

8 signature of Colonel Beara, and I have no doubts that this is

9 Colonel Beara's signature.

10 MR. THAYER: Mr. President, the Prosecution would tender 2180.

11 JUDGE FLUEGGE: It will it be received.

12 THE REGISTRAR: As Exhibit P1338, Your Honours.

13 MR. THAYER:

14 Q. Okay. Let's get started with the book. I note, as the

15 Presiding Judge has, that the cover bears the title of the prior case.

16 Unfortunately, if we were to monkey around with this at all and try to

17 even change the cover, the whole thing has to get re-ERN'd and a new

18 document has to be produced, so we figured it'd probably save a little

19 bit of trees and time and just use exactly what we used in the last

20 trial. So it does bear the prior case name and number on it.

21 Sir, please give the Trial Chamber just a brief overview of how

22 you set this book up. What is the basic approach?

23 A. Okay. May I ask for the hard copy of this notebook?

24 JUDGE FLUEGGE: With the assistance of the Court usher, it should

25 be handed over.

Page 7524

1 THE WITNESS: As I said -- may I? As I said, in February 2006 we

2 interview Mr. Petrovic, Pirocanac. He made available for us the -- his

3 raw material. We made a copy of this material, and together with video

4 assistant Zoran Lesic who did it personally because he's expert of this

5 field. And when we return to The Hague, we just -- I play personally

6 these -- these raw materials -- the copy of these raw materials several

7 times and I asked Zoran Petrovic to pause -- to pause this material in

8 particular places and copy the still images from -- from this material to

9 the hard drive, and I also ask him to print out the still images from the

10 material. We did it for our further action. It's mean that we got the

11 copy of the raw material, the printed version of the stills from this --

12 from this material, and we went together on mission to

13 Bosnia-Herzegovina, to the area where the material was recorded, which

14 means to Potocari, Srebrenica, Zeleni Jadar, the road leading from

15 Bratunac towards Konjevic Polje, Sandici, Kravica, all this area.

16 Having these stills from the raw material of Mr. Petrovic, a hard

17 copy of the stills, and having also the copy of the video -- video

18 recorded by Mr. Petrovic, we drove the same way which was driven by

19 Mr. Pirocanac together with Mr. Borovcanin, and using the features of --

20 of the terrain and -- we located all the places which were recorded by

21 Mr. Petrovic, Pirocanac, and when we already located these places we took

22 our own pictures of these places. Also, we recorded GPS readings of

23 these places, and then when we did it, we returned to The Hague, and we

24 unloaded all the pictures we took on this mission. I think this mission

25 occurred in May 2006. We unloaded all these pictures to the computer of

Page 7525

1 visual unit, and then we started to create -- I started to create this --

2 this book with the technical help of Mr. Zoran Lesic, our video

3 assistant. And as you see, this is -- I divided this book for five

4 chapters. The five chapters contains information and pictures from the

5 Petrovic video, and the pictures taken by me and Mr. Lesic on the mission

6 in 2006 in Bosnia-Herzegovina.

7 Q. Let me stop you right there if I could.

8 JUDGE FLUEGGE: Before you put your next question, may I ask a

9 simple thing. At the beginning of this lengthy answer you said -- you

10 referred to an interview in February 2006 with Mr. Petrovic, Pirocanac.

11 Earlier this morning you said Mr. Zoran Petrovic also known as Pirocanac.

12 Can you tell us how do you know that this is the same person?

13 THE WITNESS: This person used these two names in fact, and he

14 confirm that he using these two names, and most of the people know him as

15 Pirocanac -- Pirocanac, and during the interview in 2006, he confirmed

16 that he's using also nickname of Pirocanac.

17 JUDGE FLUEGGE: Pirocanac is his nickname and he used it in his

18 profession as journalist --

19 THE WITNESS: Yes --

20 JUDGE FLUEGGE: -- is that correct.

21 THE WITNESS: Yes, this is correct, Your Honour.

22 JUDGE FLUEGGE: Thank you very much.

23 Mr. Thayer.

24 MR. THAYER: Thank you, Mr. President.

25 Q. Let's go back to this mission in 2006 just for a couple moments.

Page 7526

1 Prior to that mission, can you give the Trial Chamber an idea of how many

2 times you'd already been to the areas recorded in the Petrovic video

3 Srebrenica, Potocari, Kravica, Sandici, Lolici, Pervani, and Zeleni

4 Jadar?

5 A. Prior to this 2006 mission I was -- I'd been in this area many

6 times. It difficult for me to count how many times I was there. I'm

7 very familiar with this area.

8 Q. You mentioned that you brought a GPS to assist you in this

9 project. How many GPS devices did you in fact bring, sir?

10 A. We used in fact to avoid any errors or mistakes we took with us

11 two GPS devices with us. We compare each GPS readings on each devices

12 when we -- I recorded personally the readings from these devices.

13 Q. And can you tell it us a little bit about some of the specialised

14 equipment that Mr. Lesic used on this mission?

15 A. Yes. He used his own photo equipment. He had also the video

16 player with him, which -- on which we could play the copy of the raw

17 material of Mr. Petrovic, and he -- he had also the various lenses of --

18 of this -- this photo camera. And I had also my own photo camera.

19 Q. And did he also photograph some of these locations with what's

20 referred to as a fish-eye lens?

21 A. Yes, he did, and later on I will show Your Honour the

22 presentation which we prepared using -- using the material recorded by --

23 also by Mr. Lesic, or photos used -- made by Mr. Lesic and by me.

24 Q. Okay. Before I interrupted you, you were about to tell the Trial

25 Chamber about the five chapters of the book. Can you -- can you tell us

Page 7527

1 what those chapters are?

2 A. Yes. As I said, I divided this book for five chapters, but at

3 the beginning of the book I have three maps of Bosnia-Herzegovina, as you

4 see, and also aerial image of -- of -- of Bosnia-Herzegovina depicting

5 the area where the Petrovic material was recorded. And I divided this

6 material for five chapters, the first chapter is in fact related to

7 Potocari, to the Petrovic material recorded at Potocari, and our photos

8 also recorded at Potocari, or made in Potocari; and the second chapter is

9 related to the road, Sandici -- Kravica-Sandici-Lolici-Pervani; the third

10 chapter is about Srebrenica itself; and fourth chapter is in Zeleni

11 Jadar; and the fifth one is -- I call it mosque Azemina. This is the

12 mosque located at the exit of Srebrenica when we are driving from

13 Srebrenica towards Bratunac. And the first two chapters, Potocari and

14 the road Sandici-Pervani-Lolici was created base off the recordings of

15 Mr. Pirocanac, recording from the 13 July 1995. The third chapter

16 Srebrenica-Zeleni Jadar and a mosque Azemina is related to the recordings

17 from the 14 July 1995.

18 And as I said, at the beginning of each chapter I attached the

19 map with the help of one person from our GIC unit, and on the map I

20 marked the position with the yellow dots, I marked the position of --

21 of -- of spotted location recorded by Mr. Pirocanac and later on spotted

22 by me. I plotted this location on this map.

23 Q. Okay. Now, you've referred to maps a couple of times it. Let's

24 just open the book itself to pages 2 and 3. And again, this is P1251. I

25 think pages 2 and 3 are fairly self-explanatory. And if we turn the page

Page 7528

1 to pages 4 and 5. Can you tell us just a little bit about what you have

2 here depicted on -- on the map -- on these two maps.

3 A. Okay. On the page 4 we have general map of the area where the

4 material was recorded, and in the boxes, in the four boxes in this --

5 this map we marked exactly the area where the material -- that Petrovic

6 recorded his material. We see these and from the top we see the

7 Kravica -- Kravica area. We see in the -- going to down we see Potocari,

8 we see Srebrenica and Zeleni Jadar area. On the right side we have more

9 or less the same, but this is aerial image of the same area. I mean, I

10 am referring to the page 5 of this map.

11 Q. Okay. So page 5 is an actual photograph of that same area as the

12 map depicted on the prior page, page 4; is that correct?

13 A. Yes, it's correct.

14 Q. Now, you refer to another unit here at the Tribunal, and I'm not

15 sure if the transcript caught the acronym you used. Could you repeat

16 what that unit was that helped you with this making these maps?

17 A. This is GIC, geographic information data unit, but I think it's

18 rather too big word, unit, only one person works for this -- for this

19 project. Let's say you're -- dealing with the maps.

20 Q. Okay. And in the course of putting these maps together with this

21 person from the geographic information unit, did you make use of your GPS

22 readings, and, if so, can you tell the Trial Chamber how that played into

23 creating these maps and the presentation that we'll be seeing.

24 A. Yes. I said I -- when we spotted the location we recorded also

25 the GPS readings from this location, and when I returned to The Hague,

Page 7529

1 with the help of this person from geographic information unit, I plotted

2 these -- these GPS readings on the maps prepared also by the person from

3 this unit.

4 Q. So is it fair to say that using the GPS data that you obtained,

5 this person with the geographic information unit obtained imagery and

6 helped you plot the exact locations based on information that she had

7 available to her to precisely locate these locations?

8 A. Yes, this is correct.

9 Q. Now, just to jump ahead a little bit, when we get to the

10 interactive CD that allows the operator to open up various links, can you

11 tells us how, for example, this map on page 5 will work in that

12 presentation?

13 A. When we come to this presentation I will show you that we can use

14 the links, you know, also clicking in particular portion of the maps, we

15 can use the links getting us to the particular location like Kravica,

16 like Sandici, like Potocari, or like Srebrenica. Not Srebrenica because,

17 in fact, the presentation is related only to Potocari and -- and the road

18 Kravica-Sandici-Lolici-Pervani.

19 Q. Okay. Let's go move to the first chapter which begins on page 6,

20 and what we're going to do for a little while is Ms. Stewart will play

21 the Petrovic video in Sanction and stop it from time to time so we can

22 examine the hard copy of the road book in conjunction with what she is

23 playing on the video. So if we look here on the first chapter -- if we

24 look at page 7, we have another map, and there are a series of yellow

25 dots and numbers next to them. Can you tell the Trial Chamber what those

Page 7530

1 dots represent and how you were able to place those dots in those

2 particular locations on this map?

3 A. These maps, this is also created -- not created but -- I received

4 this map from GIC unit, and this map depicts the detail map of Potocari

5 area. These yellow dots, as I said, they are GPS -- GPS readings

6 recorded by me and by Zoran Lesic on the -- of the spotted location

7 during our mission, and -- and we plotted these location on this map, and

8 these map -- these dots -- these yellow dots on the numbers, they

9 reflecting the pictures or the stills, the still frames, recorded or just

10 copied from the Petrovic video and our pictures taken during our mission

11 in -- in May 2006.

12 In the following page, if I can explain. In the follow page, in

13 each chapter is followed by the page with the stills frames from Petrovic

14 video on the left side of the book, and the following page, following, we

15 have our picture depicting the same area, explaining us the location of

16 this area right now. Maybe not right now because it was done in 2006,

17 but how the area looks in 2006.

18 Q. Okay. So just so the record is clear, the -- pardon me. The

19 image on page 8 is a video still from the Petrovic video, and the image

20 on page 9 is a photo that you and Mr. Lesic took on your mission in 2006.

21 Is that how basically it's going to work in this book?

22 A. Yes, it's correct. On the left page of this book we have the

23 image from -- from Petrovic video. On the right side we have our photos.

24 Q. And if we look at the lower left-hand corner of page 8, we see a

25 little yellow dot which says "Position on map 1." Can you tell us what

Page 7531

1 that refers to?

2 A. This -- this yellow dot here in -- with mark as number 1, this --

3 this is exactly the location spotted by us and recorded by Mr. Petrovic

4 in 1995, and this location is marked -- is plotted on the map on the

5 previous page, on the page 7 from this book.

6 Q. Okay. So --

7 A. Using GPS readings, of course, we had in our possession.

8 Q. Okay.

9 JUDGE FLUEGGE: Mr. Thayer, to have the record clear, it says the

10 position on map, and this is the position 1 and not map 1 as it is

11 recorded on line 10, page 22. Because it's the map number 4.

12 If you look at line 10 of the current page.

13 MR. THAYER: Oh, I see. I'm a little slow. I see, Your Honour.

14 Yes. The --

15 JUDGE FLUEGGE: It is map 4, position 1.

16 MR. THAYER: Yes, that's right, Mr. President. I read that a

17 little too fast, I think, so it looks like it's map 1. You're absolutely

18 right. It's map 4, position 1, page 7.

19 Now -- and we can see on this map 4 on page 7 that these

20 locations are on this road that runs north-south, and we will see other

21 maps and images depicting this road to give you a better idea, Your

22 Honours, of some of these precise locations.

23 Q. Now, just looking at one other item of information on page 8. In

24 the lower left-hand corner of the video still, we see a series of

25 numbers, and it's basically 37:13. What does that depict?

Page 7532

1 A. This is the counter we used during the recording of the raw

2 material from Mr. Petrovic. Is exactly the same recording counter we

3 used during the copy of the material which was given to us by

4 Mr. Petrovic. And this refers, in fact, to 37 seconds and 13 frame of --

5 of -- of this recording.

6 Q. Okay. So that last -- the last group of numbers is going to

7 refer to the actual number of the frame and not some component of time

8 like a tenth of a second or anything like that. Is that what you're

9 telling us?

10 A. Yes, yes, it's correct. It's correct and -- yes.

11 Q. Okay. And if we look at page 9, at the photograph that you took,

12 we see in the middle of the image the letter A with an arrow pointing

13 down. Can you explain to us what that depicts?

14 A. Okay. On the page 8, as you see I marked this photograph on the

15 page 8. The still frame from Petrovic video as the frame A, and I

16 spotted this location while he'd been in Potocari, and I marked this

17 location as location A on the map and on the picture from the page 9.

18 This is the same -- the same building.

19 Q. And while we're here, can you tell the Trial Chamber what this

20 building was in July of 1995 and what it was used as or for?

21 A. This -- this building was used by the Dutch UNPROFOR. It was the

22 main Dutch UNPROFOR base in Potocari, but in each page I also mentioned

23 the location of the frame and of the picture taken by us, and you see

24 here on the page 8, on the bottom of page 8 and also on the bottom of

25 page 9, location Potocari, Dutch UNPROFOR base.

Page 7533

1 Q. Okay.

2 A. I marked also on this still from Petrovic video and our picture

3 direction of Bratunac and Srebrenica.

4 Q. Okay. And we'll -- we'll get to some of the direction issues in

5 a -- in a moment.

6 MR. THAYER: Let's run the Petrovic video, and I'll note for the

7 record that this is 65 ter 1413, video number V000-6747.

8 Ms. Stewart, if you'd go ahead and run the video, please. We'll

9 start.

10 [Video-clip played]

11 THE WITNESS: Sorry, I have no -- no broadcast on my screen.

12 MR. THAYER: Okay. That's a slight issue. Thank you. And while

13 we're getting Mr. Blaszczyk some video, I just note for the record, and

14 we always have this problem when we run videos in Sanction or, frankly,

15 from just about any programme, there will be a permanent four-second time

16 difference between what is shown on the video counter as Ms. Stewart is

17 playing it and what is shown on the time counter in the road book. So if

18 you were to look at the Petrovic video on the original machine or

19 whatever it was that we used to make this, it's the time that we've

20 recorded in the road book, but when you go ahead and play it, there's a

21 little bit of a delay. So you can basically add four seconds to every

22 counter time that you see on these images, and that's just something

23 we'll -- we'll live with, and Ms. Stewart is aware of that, and --

24 JUDGE FLUEGGE: Have you any idea about the reason?

25 MR. THAYER: Maybe it takes the electricity that long to get to

Page 7534

1 the computer, but I don't know, Mr. President. It's just one of those

2 weird mechanical things that we've encountered forever.

3 JUDGE FLUEGGE: Technical miracles.

4 MR. THAYER: Yes.

5 JUDGE FLUEGGE. Thank you. Please, perhaps you can help us with

6 that, Mr. Blaszczyk.

7 THE WITNESS: I will try, Your Honour. But, yes, this is

8 correct. This is just the counter of the exactly I use in this book

9 exactly which we used during the copy of the material from Petrovic. But

10 for some reasons the Zoran Lesic, he tried to explain me why using

11 different player or different machine the time counter is totally

12 different than -- than in our machine. It's related to the frames of --

13 of -- not to the seconds exactly but to the frames captured by -- by this

14 particular machine.

15 JUDGE FLUEGGE: Thank you.

16 Mr. Thayer.

17 MR. THAYER:

18 Q. Okay. You've already told us what is depicted in both the video

19 still we have on the screens in front of us as well as on page 8. Can

20 you -- and I know this is an obvious question, but for the record can you

21 tell us what village or location we're talking about here?

22 A. We are talking about Potocari, and we are in Potocari. It's on

23 the stop frame -- on the frame of this Petrovic video we see the UN Dutch

24 base in Potocari, and also more or less is the same picture I have in

25 my -- my book on the page 8.

Page 7535

1 Q. And we can see the DutchBat sign on top of that building. I take

2 it when you went on this mission in June 2006, that sign was no longer

3 on -- on the building; is that correct?

4 A. Yes, is correct. The sign is not any -- more long on this

5 building.

6 Q. And can you tell the Trial Chamber in which direction is the

7 vehicle travelling at this moment.

8 A. The vehicle containing Mr. -- with Petrovic and Borovcanin, his

9 driver is driving towards Potocari, towards Srebrenica from Bratunac.

10 Q. Okay. And just to give us some compass directions, can you

11 orient us in terms of where Bratunac is located in relation to

12 Srebrenica? Is Bratunac north or south of Srebrenica?

13 A. Bratunac is in -- north from Srebrenica. It's located few

14 kilometres from Srebrenica, about 15 maybe kilometres from Srebrenica.

15 Q. Okay. And so just to help us out a little bit as we see other

16 footage later on and other documents, if -- if the DutchBat Compound is

17 on your left, that means you're facing south and you're facing

18 Srebrenica; is that correct?

19 A. It's correct. It's --

20 Q. And if you see a photograph, if you're standing and the DutchBat

21 Compound is on your right and you're looking forward, that means you're

22 facing Bratunac and Srebrenica is behind you; is that correct?

23 A. Could you repeat that?

24 Q. If you're standing on the road and the DutchBat Compound is on

25 your right --

Page 7536

1 A. Mm-hmm.

2 Q. -- that means you're looking north towards Bratunac, and to your

3 back is Srebrenica; is that correct?

4 A. Yes, it's correct. It's correct.

5 Q. Now, we'll get to the white house in more detail in a little

6 while, but while we're on this photograph on page 9, can you just tell it

7 us approximately where the white house is located. We don't see it here,

8 obviously, but can you just give us a sense of where it's located in

9 relation to this photograph?

10 A. Okay. I -- if we look at this photograph from page 9, this photo

11 was taken exactly in the front -- from the front of the white house.

12 Behind back of photographer, there is a white house. We call the

13 building this white house.

14 Q. And in this photograph we see a -- please continue.

15 A. And during the presentation it would be very well visible just,

16 you know, where the location is.

17 Q. And in this photograph we see a small two-door car heading north

18 towards Bratunac. Can you tell us whether or how close that car is to

19 the entrance to the former DutchBat Compound?

20 A. It's about 15 metres.

21 Q. Okay. Now --

22 A. I mean 15 metres to the entrance to the DutchBat. You know, just

23 this is smaller road leading us to the entrance of the DutchBat, but at

24 the beginning of this -- this small road there is also at that time it

25 was the check-point of the Dutch. This car is about 10, 15 metres from

Page 7537

1 this check-point, Dutch check-point.

2 Q. Okay.

3 A. But the real entrance was a little bit further down.

4 Q. Okay. Now, let's turn the page in the hard copy to pages 10 and

5 11, and we'll continue playing the video, please.

6 [Video-clip played]

7 MR. THAYER:

8 Q. Sir, we have stopped at Sanction time 54:4, and we can see this

9 video still in -- sorry, video still A on page 10. Can you tell us what

10 is recorded here in still A?

11 A. As we see here on this still and on the -- also on the still from

12 my book, this is -- this still depicts the men walking along the road

13 towards Bratunac. The men using the right side of the road.

14 Q. And so --

15 A. If we are facing towards Srebrenica.

16 Q. Okay. So they are heading from south to north; is that correct?

17 A. It's correct. Yes. They are heading from south to north.

18 Q. And we see a number of vehicles, mostly trucks here, next to this

19 column of men, and if we look down, we can -- in video still D, we also

20 see a bus with some other trucks. Are all of these vehicles pointing in

21 the same direction?

22 A. Yes, it's correct. All these vehicles are -- are heading -- are

23 pointed to the same direction, direction to Bratunac north -- north.

24 Q. Okay. Let's continue playing the tape, please.

25 [Video-clip played]

Page 7538

1 MR. THAYER:

2 Q. Okay. We're at 1:02 in Sanction, and we can see this corresponds

3 with video still B on page 10. I note that you've identified the Feros

4 building in still B, and how are you able to do that, sir?

5 A. This is very characteristic building. You see the red bricks on

6 this building and the shape of the windows. Is very visible that this is

7 the same building in almost the same shape right now even, and also was

8 in the same shape in 2006.

9 Q. And if we look in the hard copy at page 11, photograph 2 --

10 A. Yes.

11 Q. -- do we see some kind of a sign on top of the building, and, if

12 so, can you read what that stays on top of that building in photograph 2?

13 A. Yes. This is still mark of -- it's local language "Tvornica

14 Feros." I believe this is in English Feros company. This is this Feros

15 building. And behind this building we see a little bit -- we call this

16 blue factory. It's also the blue building behind the Feros building.

17 Q. Okay. We're going to play a little bit more tape and then talk

18 about a couple other images.

19 [Video-clip played]

20 THE WITNESS: May I?

21 MR. THAYER:

22 Q. Please.

23 A. Just to letting you better view of this area. These pictures

24 of -- from the page 2 of this Feros building, and the picture number 2

25 was taken also from the position of where the white house is located,

Page 7539

1 just in front of the white house, crossing the road.

2 Q. Okay. We've stopped at 1:11 of Sanction, and we see a soldier to

3 the left in between two buses, and we saw him gesturing towards that

4 Muslim man who's facing him. Can you -- can you tell us, based on your

5 investigation, interviews of survivors, and other sources, what

6 eventually happened to these men as they were walking along this column

7 of vehicles.

8 A. This is visible from this video. You can come to the conclusion

9 that this is selection process. You know, the soldiers letting know to

10 the men that they have to walk on the left side of -- of the road, and

11 then during the course of our investigation, we -- we established that

12 this men -- most of the men were kept first at the white house and then

13 transported to Bratunac to Vuk Karadzic school soccer field in Bratunac,

14 and in the following day were transported to Zvornik area.

15 Q. Now --

16 A. If --

17 JUDGE FLUEGGE: Just a moment. Judge Nyambe has a question.

18 JUDGE NYAMBE: Thank you. Can you just play back this -- this

19 footage and let the investigator indicate the selection process. Thank

20 you.

21 MR. THAYER: Okay. And I would also invite the Trial Chamber

22 to -- it's difficult sometimes, but we have the subtitling at the bottom,

23 and actually if you look what we have right here on the still frame where

24 Ms. Stewart has stopped in Sanction, you can see the statements:

25 "No. You go left here, to the left. Let's go, in a column, one

Page 7540

1 by one, don't get jammed up like that, to the left."

2 And we'll back it up. It's a little hard to see, but you will

3 see an encounter between these two gentlemen, and we'll start maybe 15

4 seconds before where we are here.

5 JUDGE FLUEGGE: To have it clear on the record, I would like to

6 know, LJB seems to be -- I don't know. Perhaps the witness can explain

7 LJB, NMG 1, and NMG 2 and ZPP. What does that mean?

8 THE WITNESS: LJB, we recognised the voice of Ljubisa Borovcanin,

9 I believe, and ZPP, this is the voice of Zoran Petrovic, Pirocanac,

10 and -- and NMG 2 and NMG 1, they are the voices of unidentified soldiers

11 of VRS or police officer of VRS.

12 JUDGE FLUEGGE: Thank you.

13 MR. THAYER: I can tell the Court, I don't think there'll be any

14 dispute about this, that NMG is the acronym of "unidentified person" in

15 B/C/S. So if it were in English we would use UM for unidentified male or

16 UF, but we're using the B/C/S abbreviation so it doesn't immediately look

17 familiar to us.

18 And we've restarted at 59.8 in Sanction.

19 [Video-clip played]

20 MR. THAYER: Can we just stop there. I think you could see right

21 there, and we're at 1:06.5, we're a little beyond the portion, but I

22 think we could all see that there were some women that were heading in

23 one direction and all of a sudden you could see the men, some of the men

24 veering towards the left, and if you like, we can back up a few seconds

25 and look at that again.

Page 7541

1 [Video-clip played]

2 MR. THAYER:

3 Q. Go ahead, Mr. Blaszczyk.

4 A. And if you notice, Your Honour, you see on the right side you

5 see -- we see only the men, and a few of the men, they tried to cross the

6 road and to get to the right side of the road if you are heading towards

7 Srebrenica, but the soldiers were standing next to the trucks, they

8 didn't let them pass by.

9 MR. THAYER: And we are at 1 minute 11.3 in Sanction, and

10 we've -- we can see this soldier gesturing, waving with his left hand at

11 these men, and again the audio has picked up somebody, we're not sure who

12 it is, saying:

13 "No, you go left, here, to the left. Let's go, in a column one

14 by one, don't get jammed up like that, to the left."

15 And we can just keep playing it here, please.

16 [Video-clip played]

17 MR. THAYER:

18 Q. And where are we here, Mr. Blaszczyk? We're at 1:23.1 in

19 Sanction, corresponding to video still C on page 10.

20 A. Yes, you're right. This -- this footage from the screen

21 correspond to my book on the still I numbered as C. And we see the same

22 road, but we see the women walking on the left side of the road now.

23 MR. THAYER: And we can continue playing.

24 [Video-clip played]

25 MR. THAYER:

Page 7542

1 Q. Now, we've stopped at 1:38.6 in Sanction. This corresponds to

2 still D on page 10 of your book. And this will be my last question for

3 you before the break.

4 The men that we see in -- or the column of men that we see in

5 video still A on this page, where is that column of men located in

6 relation to the image, the video still, in video still D?

7 A. This column of men from the -- from the still A are located in

8 exact in opposite side of the road from -- from still D.

9 Q. So are they on the other side of that column of trucks and buses?

10 A. Yes, yes, you're right. This other side of the column of trucks

11 and buses.

12 MR. THAYER: Okay. Mr. President, I think we can safely break

13 now, and we'll pick up with this.

14 JUDGE FLUEGGE: We must have our first break now and resume at

15 11.00.

16 --- Recess taken at 10.32 a.m.

17 --- On resuming at 11.02 a.m.

18 JUDGE FLUEGGE: Mr. Thayer, the Chamber is considering the

19 possibilities of the best use of court time. Everybody knows that we

20 have seen most of these -- this video already. The Chamber has been in

21 this location during the site visit. You should think about how to use

22 the court time in the best and sufficient way. Perhaps you can shorten

23 some part of showing the video again, especially if we are facing the

24 possibility to see it again with another witness.

25 MR. THAYER: Yes, Mr. President. I'll certainly take that on

Page 7543

1 board.

2 Q. Now, sir, if we look at page 11 and your photo 3, and again this

3 is to really focus on why -- why you're here today with this project, can

4 you tell the Trial Chamber how it was that you were able to place video

5 stills A through D on photograph 3 on page 11? What enabled you to make

6 this determination?

7 A. As I said, I know this area very well. I compare the shape of

8 the road, I compare the location of the houses in -- in Potocari, on the

9 buildings in Potocari, and I noticed some details which are still exist

10 in Potocari. At least they were existed up in 2006 when I took these

11 photographs together with Mr. Lesic in Potocari.

12 Q. Okay.

13 A. And of course, as I said, you know, I played the video several

14 time and I noticed a lot of details which I used, you know, just to

15 locate exact location where the footage was recorded.

16 Q. Okay. Let's turn the page and we'll look at pages 12 and 13 in

17 the book. And we can dispense playing with the video for this force. We

18 can see on page 12 four still images. Can you tell us where this is

19 located?

20 A. This place depicted in these two pages and the page 12 and 13 is

21 located about 50 metres north of the Ekspres bus compound in Potocari,

22 and in fact just next to the -- we call it blue building, in Potocari,

23 and also about 50, 100, less even, metres from white house in Potocari.

24 Direction to Srebrenica.

25 Q. And we can see on page 13 in this photograph a large hill in the

Page 7544

1 background. Did this aid you at all in making some of these

2 determinations?

3 A. Yes. If you look at this hill from my photograph, from the page

4 13 and the hill in the background of the footage of Petrovic video, we

5 can compare. We can see that this is the same hill. And also if you

6 look at the strip on the right side, on the road, you know, on the right

7 side of -- almost in the middle of this photograph, my photograph, is the

8 same strip is visible on -- on still frame D from page 12.

9 Q. Okay. And when you refer to that strip, you're talking about a

10 strip on the road that we can see basically leads up to that UN APC; is

11 that correct?

12 A. Yes, it's correct. This is kind of -- it's difficult to say

13 bridge, but below there is a stream.

14 Q. Okay. So there is a stream that runs basically underneath the

15 road where we see that strip. Is that what you're telling us?

16 A. Yes, this is correct.

17 Q. And in the course of your investigation, have you heard

18 references from witnesses and -- about -- about such a stream or creek

19 and a bridge in this location?

20 A. Yes, I did. I did. I heard a story about stream and bodies next

21 to the creek or stream from the Dutch Battalion soldiers, but the bodies

22 were located not exactly in this place but behind -- behind the white

23 house, behind electrical -- behind the blue building and behind the

24 electrical power station.

25 Q. Okay. The last thing I want to do on this portion is if we look

Page 7545

1 at video still D on page 12, we can see visible here three UN APCs, and

2 we can see the two in the foreground have been tilted towards each other.

3 What can you tell us just briefly about that.

4 A. It's one of the -- one of the Dutch soldiers, officer described

5 us at this -- at this location. It was set up the check-point containing

6 these three APCs. UN Dutch check-point.

7 Q. Okay. And have you seen aerial imagery which reflects the exact

8 position of these APCs as depicted in video still D on page 12?

9 A. Yes, I've seen.

10 MR. THAYER: Okay. And we'll take a look at that a little later,

11 Your Honours.

12 Q. We're going to fast forward a little bit to 4 minutes, 49, in the

13 original counter, which will be 4:53 in Sanction.

14 Okay. We've stopped at 4:54, and we can see that there's a time

15 and date stamp on the video image here. What can you tell us about what

16 your investigation disclosed about the accuracy of this time and date

17 stamp of Mr. Petrovic's video?

18 A. Yes. This is time and date stamp from the -- originally from the

19 raw material of the Petrovic video, and we established and we are pretty

20 sure that reflects the correct time and the date in the video. We

21 establish on the base of the Petrovic interview and also from the

22 statements from other witnesses.

23 Q. Okay.

24 A. Although Mr. Petrovic wasn't sure whether -- whether -- whether

25 the -- the date and even time is -- is correct, because he explained that

Page 7546

1 he's not experienced man to operate with this video camera.

2 Q. And again based on your investigative experience and your

3 experience as a Srebrenica investigator, how credible did you find that

4 statement that he couldn't tell you whether the date and time was really

5 accurate or not?

6 A. In regards to -- it's difficult to say, because, in fact, you

7 know, he really -- he may have a problem to -- to operate the camera, and

8 maybe he didn't pay much attention for the date and time, but -- but --

9 but I am sure that -- that he knew that this is the correct time and

10 correct -- especially correct date.

11 Q. Okay. And just for the record, we have here reflected in the

12 time code 1500 hours, 26 minutes, and 50 seconds, 13 July 1995, and we'll

13 take a look at some aerial imagery later and see how that matches up in

14 terms of the time depicted on the aerial imagery.

15 Now, looking at this photograph that you've made on page 13, I

16 just want to orient us with identifying a couple of these buildings.

17 There's a building on the left behind the fence. What is that, and was

18 that there in July of 1995?

19 A. The first building on the left-hand side from the picture from

20 the page 13, this is new building, relatively new building. I think it

21 was building 2005 or even 2006. In July 1995, the building didn't exist

22 at this place. And behind this building, behind the fence, we see the

23 small building, white building, with -- and next to this building we see

24 the bus. This is the bus compound.

25 Q. And that's the compound of the Ekspres bus company?

Page 7547

1 A. Yes, that is correct. This is the compound of the bus Ekspres

2 company.

3 Q. And that's on the left hand part of the screen. If we look at

4 the right-hand part of the screen just above where we see the word

5 "Srebrenica" near the arrow that's turning to the left, there are a

6 couple of large buildings there. Can you tell the Trial Chamber what

7 those building are.

8 A. The first building on the right-hand side from the picture from

9 the page 13, this is Zinc Factory. And the following building, the

10 factory, the big factory, this is an Energoinvest factory in Potocari

11 behind the Zinc factory. On the right side we see the red car, and

12 behind this car this Zinc factory is visible -- partially Zinc factory,

13 and behind this Zinc factory we have Energoinvest factory, I think.

14 Q. Okay. Let's turn the page and look at the next series of photos

15 and stills. We're on pages 14 and 15 of the road book, and I think we

16 all recall Ms. Gallagher testifying about -- to some degree about this

17 footage where we have the water trailer hooked up to the tractor. We

18 have Mr. Borovcanin arriving, Colonel Kingori, then Major Kingori, also

19 arriving on the scene and pressing Colonel -- Mr. Borovcanin and others

20 about the situation of the men in the white house, which Colonel Kingori

21 described as no good.

22 Now, I think we can dispense with actually playing the video. If

23 we look at page 15 at your photos, can you tell the Trial Chamber,

24 please, how you were able to determine that, for example, in photo 1 that

25 location responds video stills A, C, D, E, and F from the Petrovic video.

Page 7548

1 A. At that time when we made these pictures, the building from the

2 picture 1, visible we call it as a blue factory, had the same shape as it

3 was in July 1995. What is visible, barely visible on the video, Petrovic

4 video, and also on the picture C from the page 14.

5 Q. Now let me just stop you there, Mr. Blaszczyk. You just referred

6 to the blue factory in your testimony, and I know the Trial Chamber was

7 recently in this location, but we've got tonnes of buildings and

8 factories and different names. Is this the blue factory or is this known

9 by another name to you?

10 A. No, it's my mistake. This was known for us as blue building in

11 Potocari, but when Your Honour had opportunity to -- to be in this area a

12 few weeks ago, this building has different colour now and was rebuilt.

13 The area was quite rebuilt.

14 Q. Okay. And is there in fact another building that you refer to as

15 the blue factory elsewhere in this area?

16 A. Yes, you're right. I referred to the blue factory. This is the

17 building from the -- is visible this building on the page, also on the

18 page -- sorry, on the page 15, the picture number 2 on the right-hand

19 side of this picture. Across the road next to the Feros building and

20 across the road from the white house.

21 Q. Okay. Now, if we look at some of these video stills on page 14,

22 we can see in, for example, in video stills D, E, and F what appear to be

23 some fences with wiring running along their tops. The fence posts are

24 shaped like upside down hockey sticks, I guess.

25 Were you able to relate those at all to what you found in 2006

Page 7549

1 and did that help you identify this location?

2 A. Yes, in 2006 in May when we were there they start to remove

3 this -- these poles, this fence from the area, but it was still visible

4 on the ground next to this blue building, and I depict the fence, the

5 poles are depict on the picture 4 from the page 15. And if we can

6 compare that the shape of this -- these remains are the same as -- as

7 visible on the page 14. I am referring to the picture, to the still

8 frame at E and F. And D.

9 Q. Okay.

10 JUDGE FLUEGGE: May I interrupt you for a moment. You are

11 recorded having said on page 39, lines 20 and 21:

12 "On the page 15 the picture number 2 on the right-hand side of

13 this picture. This should be the blue factory."

14 If you look at picture number 2 on page 15, is it -- are you sure

15 that this building is to be found on the right-hand side of this picture

16 number 2?

17 A. Yes, Your Honour. I am referring to the blue factory. We call

18 that building blue factory on the right side of this picture, but we are

19 talking right now about blue building which is located on the left-hand

20 side of this picture, visible a little bit.

21 JUDGE FLUEGGE: Yes. Now I understand. Thank you very much.

22 Mr. Thayer.

23 MR. THAYER: Thank you, Mr. President. It's -- I think we all

24 recognise that no matter how many times you've been there, it's difficult

25 to keep these locations straight, and it's -- I think it's safe to say

Page 7550

1 it's really important to, and it can't be repeated enough. And I am

2 trying to move it along but -- as I hope as you can tell, by dispensing

3 with a lot of the video, but this is exactly why Mr. Blaszczyk is here.

4 I get things all confused sometimes when I'm talking to him as well.

5 JUDGE FLUEGGE: Just go ahead.

6 MR. THAYER: Thank you.

7 Q. Now, let's look at photograph 3 on page 15. You've identified

8 this building as the blue building. Can you tell the Trial Chamber when

9 we're looking at this photo where the white house is in relation to the

10 blue building.

11 A. The white house -- we are talking about the white house from

12 Potocari is located about 50 -- 50, 100, even less, metres from this --

13 this is blue building in direction to Bratunac if you look at the picture

14 three, behind -- just behind -- behind this blue building next to the

15 road leading us to Bratunac.

16 Q. Okay. And again to orient ourselves, is the white house on the

17 same side of the road as this blue building or the other side?

18 A. The white house is on the same side as the blue building is.

19 Q. Let's turn the page and we'll look at pages 16 and 17. The Trial

20 Chamber also saw some of this footage with Ms. Gallagher. Can you tell

21 the Trial Chamber basically what has happened in terms of the filming

22 from the prior location we saw at the blue building that brings us to the

23 four video stills on page 16. Can you tell us where we are here on page

24 16 and how Mr. Petrovic and Mr. Borovcanin got to the location depicted

25 on page 16.

Page 7551

1 A. It's visible from the video that Mr. Borovcanin and Mr. Petrovic,

2 they walked along the road towards Bratunac, and they walk about 50, 100

3 metres, and they reached the point where white house is located, and the

4 still frames are captured exactly on this place. On -- on still frame B

5 and D, we see the part of the white house in Potocari and part of the

6 fence and gate of this white house. We see belongings of -- of the

7 Muslim men kept in this white house. And Mr. Borovcanin and Mr. Kingori,

8 we see him on the picture -- on the frame still C, A -- and A. We see

9 that they're standing next to the white house, and this little bit

10 junction is described on my next following page, on the page 17, the

11 location of Mr. Borovcanin and Mr. Kingori and one Dutch member and also

12 the member of the Special Police force. This location is marked here on

13 this picture 1 from the page 17 and A and C.

14 Q. And how were you able to make the determination that, for

15 example, Mr. Borovcanin was standing at the location where you've marked

16 in photograph 1 on page 17, so close to the white house? How were you

17 able to make that determination?

18 A. The first you have to follow the move of -- the movement of the

19 camera which recorded this -- this footage, and you will see that this is

20 located next to the white house, and in the background you see also the

21 hills. The hills are corresponded to the hills. And of course, they are

22 the same hills right now in the same area. And in fact, this area has

23 not been change at all, you know, even -- even few weeks ago it looks the

24 same.

25 Q. Now, what is depicted if photograph 2 on page 17, sir?

Page 7552

1 A. On photograph 2 we see the Feros building. I described this

2 Feros building before the break. It's visible also on the other part of

3 the video. And this building is located exactly across the road from --

4 from white house and will be very well visible on the presentation we are

5 going to play later on, I believe.

6 Q. Okay. Let's skip some video and we'll go ahead to 8 minutes, 16

7 seconds in the original counter and 8 minutes, 20 seconds, in Sanction.

8 Now, at this point in the filming in the vicinity of the white

9 house we saw the camera pan across the road, and again what do we have

10 depicted here at 8 minutes 20 seconds in Sanction?

11 A. This is Feros building, and behind we see the blue factory.

12 Q. Okay. And again we can match up that sign that says "Feros," and

13 we can just see that on photograph 2, page 17. Is that correct, sir?

14 A. Yes, it's correct. It is the same building.

15 Q. Okay.

16 A. In fact, the top of this building.

17 MR. THAYER: Let's roll the tape just for a couple of seconds

18 until we see the artillery shell that the Trial Chamber's already heard a

19 little bit about.

20 [Video-clip played]

21 MR. THAYER: Okay. We're at 8:52.6 seconds in Sanction.

22 Q. The Trial Chamber heard a little bit about this artillery shell.

23 Did Mr. Petrovic ever tell you anything about this shell?

24 A. Yes, he did. I think during the interview. He said that this is

25 the shell from -- recorded over on this tape from his balcony. The tape

Page 7553

1 is -- the shell is -- is located in his balcony, and in fact I seen this

2 shell on his balcony because when Mr. Petrovic came for interview in

3 2006, he came without raw material for this interview, and we asked him

4 to provide us the -- the raw material of -- recorded by him in July 1995,

5 and because of that, he had not this material with him. I went together

6 with him to his house when he collected this raw material, and I seen

7 also this shell on his balcony, and he pointed it out, in fact, this

8 shell to me.

9 Q. Okay. Now, briefly what we're going to do is play a very quick

10 split-screen comparison I don't think the Trial Chamber has seen, and

11 this is 65 ter 2182. The Trial Chamber has seen the Studio B version

12 with the missing footage that was recorded over by this footage of the

13 shell, but we're going to see something a little different.

14 [Video-clip played]

15 MR. THAYER: Just to orient ourselves. We're at 12.8 seconds of

16 the split screen.

17 Q. First of all, can you tell us what we're looking at?

18 A. As we see here, this is the gate or fence -- the gate of the

19 white house in Potocari. On the right side is the screen on the

20 right-hand side -- side we see the footage from raw material from --

21 Pirocanac, Petrovic raw material. On the left-hand side we see the

22 footage from Studio B broadcast. This is also Mr. Petrovic material but

23 edited material which was broadcasts in July 1995 in Serbian television.

24 Q. Okay. And you've used the term "edited material" a couple of

25 times to describe the Studio B footage. What do you mean by edited?

Page 7554

1 A. This means that this material was edited or was put together not

2 in the same order as was recorded. This mean up to the director or

3 what -- up to the person who edited the material who wanted to broadcast

4 this material. They -- they put what was convenient for them, what was

5 think by them that was better to be broadcasted in TV in this order, not

6 necessarily following the order from the raw material.

7 Q. Okay.

8 A. It was cut and not entire material contain -- not this Studio B

9 editing material not containing entire material from raw -- raw tape.

10 JUDGE FLUEGGE: Judge Nyambe has a question.

11 JUDGE NYAMBE: I think you may have answered my question, but

12 nevertheless let me ask it. Does editing of a video footage include

13 adding or removing material? Thank you.

14 THE WITNESS: This editing of -- of this footage, rather,

15 includes removing material, because as I said, the Studio B editing

16 material should contain the material what is on the raw tape but not

17 entire material from the raw tape. Is -- is not -- not -- not added any

18 new material for this particular broadcast.

19 JUDGE NYAMBE: Thank you.

20 JUDGE FLUEGGE: Mr. Thayer.

21 MR. THAYER: Thank you, Mr. President.

22 Q. The Honourable Judge Nyambe anticipated my next question to a

23 large degree, so just to be clear, the Studio B footage as it was

24 broadcast in Serbia, did that play the entire Petrovic video as we've

25 been watching it?

Page 7555

1 A. No.

2 Q. Okay. And did it broadcast to the extent it broadcasted portions

3 of the Petrovic video as we've been watching it, did it broadcast it in

4 the order in which we have been watching it and in which it was given to

5 you by Mr. Petrovic and by the BBC and by the BiH MOD?

6 A. No. This material broadcasted in Studio B doesn't reflect the

7 order from raw material or the material we received from BBC or from MOD.

8 You mean original material except the redacted portion of this material,

9 of course.

10 Q. And finally when Studio B broadcast this material, did they

11 insert anything that wasn't shot by Mr. Petrovic, Pirocanac during the

12 course of these dates?

13 A. No, they didn't except -- except if we play this Studio B

14 material we see that on the bottom there are also kind of the lines

15 involving information. Of course, this one is edited, added for -- for

16 this broadcast. Yes, but this is only material from Petrovic video

17 recorded by Petrovic.

18 Q. And when you refer to lines of information, what are you talking

19 about?

20 A. We should play this Studio B footage, and we see that on the

21 bottom we see the line going on, with information what is going on in

22 Belgrade about what concept, whatever, you know, just not related at all

23 to Srebrenica operation.

24 Q. I think sometimes we use the term "crawler" for that kind of

25 running information if you're watching CNN or a station. Is that

Page 7556

1 basically the same thing?

2 A. Yes, yes. I mean this thing.

3 Q. Okay.

4 A. But the footages are exclusively from Petrovic video recorded by

5 him in July 1995 in these two particular dates.

6 Q. Okay.

7 MR. THAYER: Let's continue running the video.

8 [Video-clip played]

9 MR. THAYER:

10 Q. Okay. Let's show that again.

11 [Video-clip played]

12 MR. THAYER:

13 Q. Now, the Trial Chamber's already heard that the image we have

14 here on the left is from the Studio B version, which was not part of the

15 Petrovic video that you were given, and this is at 21.6.

16 Can you tell us based on the comparison that you made of these

17 two versions how the actual time of the film that is used in each

18 corresponded to each other? How did they match up when you put them next

19 to each other?

20 A. You're referring to time, to time code?

21 Q. Not necessary a time code but in terms of -- if you want to

22 answer it that way, sure. Just trying to get at how in terms of the gap

23 that's taken up by the artillery, for example, on the right-hand side

24 fits in with the footage that was retained by the Studio B version and

25 how those matched up.

Page 7557

1 A. Yes. When we made this comparison together with -- with video

2 assistant, with Zoran Lesic, and is visible that if when we play the

3 Studio B footage and we play extract from -- from raw material, Petrovic

4 material is the same, except in one point in raw material the recording

5 is stopped, is over-recorded, is recorded over by this shell is visible

6 on the right-hand side of this -- this -- on the screen. And from

7 Studio B footage we see that the recording wasn't stopped. It's mean

8 that going on we see that Petrovic recorded except the gate of the white

9 house. The white house itself is here recorded. Also, the people on the

10 balcony of the white house. This footage was cut off from the raw

11 material or was recorded over on the raw material.

12 MR. THAYER: Okay. If there are no additional questions on -- on

13 this split-screen comparison.

14 JUDGE FLUEGGE: I have only one question. It is your observation

15 that the -- this part of the video with the shell was taped over the

16 original one which we can see on the left-hand side of the screen, over

17 the part of the recording -- the video white house. That means that the

18 part with the shell on the balcony was taken later; is that correct.

19 THE WITNESS: Yes, it's correct. This is my analysis and my

20 opinion.

21 JUDGE FLUEGGE: The big thing in the middle on the right side of

22 the screen is the shell which you mentioned.

23 THE WITNESS: Yes, yes. This is the shell I mentioned

24 previously.

25 JUDGE FLUEGGE: Thank you.

Page 7558

1 THE WITNESS: If we compare these two materials, instead of the

2 shell in the raw material we should see the same still frame what we see

3 in Studio B broadcast.

4 JUDGE FLUEGGE: Mr. Thayer.

5 MR. THAYER:

6 Q. And when looking, for example, at this footage of the balcony

7 that we see in the Studio B version which Mr. Petrovic told you that he

8 recorded over with that picture of the shell that you saw on his balcony,

9 did you find any evidence that, for example, Studio B somehow took this

10 footage or took some footage of a balcony and itself spliced into the

11 Petrovic video this image of the balcony? Did your investigation

12 disclose that anything like that happened?

13 A. No. No. It was done -- this is -- this is material from Studio

14 B used only the raw material at that time the entire raw material of

15 Petrovic video, and even Petrovic, during the testimony and during the

16 statement, he admitted that this is footage recorded by him and should be

17 included in this raw material, but for some reason it's redacted from the

18 raw -- raw material.

19 Q. Okay. So again just to be clear, Mr. Petrovic, Pirocanac,

20 admitted to you and acknowledged that he in fact recorded the footage

21 that we see on the left that was broadcast by Studio B?

22 A. Yes, this is correct.

23 Q. Okay. If there are no other questions about the split screen

24 comparison, the Prosecution would tender 65 ter 2182.

25 JUDGE FLUEGGE: It will be received.

Page 7559

1 THE REGISTRAR: As Exhibit P1339, Your Honours.

2 MR. THAYER: Additionally, Mr. President, I note that the Studio

3 B version which we're seeing here is again P1250, V000-3826, and has been

4 MFI'd in connection with Mr. Petrovic's 92 bis package. The Prosecution

5 would tender that video as well at this time, just take it off the MFI

6 list.

7 JUDGE FLUEGGE: It will be received.

8 MR. THAYER:

9 Q. Okay. Let's switch now from the road book to the interactive CD.

10 And again I note for the record that that is 65 ter 2178. I know it

11 takes a couple moments for you to get set up.

12 A. I have problem, if possible, with this laptop.

13 MR. THAYER: We have the password. If we could maybe hand that

14 over, or write it down and just hand it to him.

15 JUDGE FLUEGGE: The court usher will assist.

16 THE WITNESS: Okay. It works.

17 MR. THAYER:

18 Q. Okay. Before we launch into this -- this CD, please give the

19 Trial Chamber an idea of what the idea was behind putting this

20 presentation together. What were you trying to provide?

21 A. Just making this presentation, I would like to let everybody who

22 were not at this area or they been only once or twice to better oriented

23 in this area. And I think this is very useful material to do it. And

24 creating this presentation, I used the maps which were used for creation

25 of this -- for this road book, and also I used the pictures we used for

Page 7560

1 creation of this road book and the stills from Petrovic material.

2 Q. Okay of the let's go ahead and -- and see how it works. Just

3 take us through the -- let's say the first portion of this, which is the

4 Potocari section. And again, there are --

5 JUDGE FLUEGGE: For a better understanding, the producer of this

6 CD is the witness. You produced this video -- this CD; is that correct?

7 THE WITNESS: Yes, is correct, Your Honour, but of course with

8 technical help of my colleague, video say assistant Zoran Lesic.

9 JUDGE FLUEGGE: Thank you.

10 MR. THAYER:

11 Q. So please, sir, just go ahead and take us through the first

12 portion of the presentation. We won't need to hit every link for sure,

13 but just give us an idea of -- of how one can operate this CD and the

14 capabilities it has of basically placing the user at the scene.

15 MR. THAYER: And again, Your Honours, you'll have your own

16 version of this to play with when the time comes.

17 THE WITNESS: To play this presentation, we use the programme

18 Quicktime Player, and you see on the screen the first page of this

19 presentation, and on the bottom you see the buttons. You can operate

20 these buttons. You see the button on the right-hand side with the

21 question mark over there, if we press this button, you see that the

22 portion of the material is getting blue. It's mean that this portion is

23 letting -- is leading to another picture, map, whatever material.

24 And the button with plus, we can enlarge the video, like enlarge

25 the picture over there on.

Page 7561

1 The other one with minus, we can -- we can minimalise and get to

2 the original size.

3 As I said, helping yourself, you can use this question mark

4 button to get into the presentation. If we press to this blue mark area,

5 we are going to the next page, and we see here a map. This map is also

6 visible on my road book. And again, we see the box marked here on the --

7 by -- in blue now if I use this question mark button. If we go in, if we

8 press to this part, we are going to another map showing us the area of

9 Bosnia-Herzegovina, and we've mark area of Bratunac, Srebrenica, Kravica,

10 Sandici, all these area.

11 Again, if you would like to -- to go to next page, we can press

12 to the blue field which shall link us to another page, and again we have

13 the map used in our road book, and we have several locations.

14 Then pressing -- if we will -- would like to -- to look at

15 Potocari, at the events we discussed just few minutes ago in Potocari,

16 what happened in Potocari on July 15 and are depicted in my road book,

17 let's go to this. And this portion -- and we see the map is also

18 depicted. In this -- this map is also from the same as we have in our

19 road book. And here we have few points here, few marks. Again, to be

20 sure that we can use this -- they are links to another portion of this

21 presentation, let's mark these signs, and let's go to the first one.

22 MR. THAYER:

23 Q. And before you do that, Mr. Blaszczyk, just so we have something

24 on the record, you are pressing that little question mark inside the

25 arrow to basically turn these features blue, and what we're looking at is

Page 7562

1 your map, and instead of the little yellow circles that we had before, we

2 now have arrowheads that you've turned blue by engaging that question

3 mark in the little control panel at the bottom. And in order to go

4 further, you simply do what?

5 A. Just to press the arrow, wherever you want to go. And right now

6 in the front of the white house. This is the most recent -- the

7 recent -- the picture taken by us in 2006.

8 We can move around.

9 Q. So basically by just sweeping with your cursor you can rotate the

10 image; is that correct?

11 A. Yes, it's correct. You can use this laptop pad or you can use

12 the mouse.

13 Q. And again we --

14 A. If we would have a mouse, of course.

15 Q. And again we see arrowheads floating around on this image of the

16 white house. Can you show us an example of what these arrowhead links do

17 for us.

18 A. Yes. If you would like to go in to another link, for example, to

19 the front of the white house, is leading us to the still frame from

20 Petrovic video. And as I said before, we can enlarge this picture using

21 this button. To get to the original size.

22 Okay. Let's go back. Okay. And if you would like to go back to

23 the previous picture, it's necessary only to press again this picture.

24 Going to next link, what is marked here on this picture on -- on

25 the white house balcony, it takes us to the Petrovic Studio B still.

Page 7563

1 Pressing once we enlarge the picture. We are getting better view of the

2 people who are sitting on the balcony of the white house. Pressing one

3 more, we see quite clear picture of the people from the balcony.

4 Pressing once again, we are returning to our, let's say, master picture.

5 And another arrow here getting us to the position where

6 Mr. Borovcanin, Mr. Kingori, and other people are standing in front of

7 the white house.

8 Coming back, we see exact location when this footage was

9 recorded, the still was recorded.

10 Q. Now, I -- if you can scroll to the -- okay. I was just going to

11 ask you, I saw the top of that arrow, there's a red and orange coloured

12 arrow that's pointing straight down in the middle of the road here. What

13 is that?

14 A. This arrow taking us to the opposite side of the road, opposite

15 side of the white house. And we see what is right now in -- what is

16 located across the road from the white house. We see here Feros

17 building. Behind we see the blue factory. On the left, if we go to the

18 left, we see here the UN DutchBat base, the road leading to Bratunac. If

19 we go to opposite side, we see the road leading to Srebrenica. On the

20 right side is not visible on this picture, but where we see the arrow

21 here there is the location in front of -- of -- of the blue building.

22 I forgot to tell that we can use also the button here to go back

23 if you have -- if anybody has difficulties to find the proper arrow to go

24 back to the previous picture.

25 Q. Okay. And just for the record, you're referring to the left-most

Page 7564

1 button in that little control panel at the bottom of the image, an arrow

2 facing left.

3 A. Yes. Yes, is correct. And as we seen before in our road book,

4 we can link to the pictures from Petrovic material. We see the people

5 walking towards Bratunac. This is exactly the location here. Near white

6 house, near the Feros building.

7 If we go to the -- another side of the road, it takes us to the

8 left side of the road, and we see women, children, and elderlies walking

9 on the other side of the road.

10 Okay. And of course we can go back to -- to the view of the

11 white house using this arrow. We see the white house. This is exactly

12 on the opposite side of the road.

13 Q. Okay.

14 A. Yes.

15 Q. Unless you had any other particular links that you think the

16 Trial Chamber should really see at this point, I think that gives us a

17 pretty good idea of how to operate this presentation. Did you have

18 anything else you wanted to add or explain to the Trial Chamber about

19 this portion, the Potocari portion, of the interactive video?

20 A. Generally it works in this way: You can use the arrows here to

21 link us to another part of the place, and we can see the pictures from --

22 taken by us, by OTP, and -- in 2006, and the stills from Petrovic

23 material, and you can compare the Petrovic material, the stills from the

24 Petrovic material, with the location I spotted on these places.

25 MR. THAYER: Okay. And if there aren't any questions from the

Page 7565

1 Trial Chamber at this time about the presentation, we'll move on and look

2 at a couple of aerials.

3 JUDGE FLUEGGE: I think we have received a good manual how to use

4 this CD.

5 MR. THAYER: Thank you, Mr. President.

6 Q. Thank you, Mr. Blaszczyk. I think we can shut that down for now.

7 MR. THAYER: May we have 65 ter 951, please. If we could blow it

8 up just a little bit. I don't know if that's possible. Oh, there we go.

9 Q. Now, we have here what's obviously an aerial image dated 13 July

10 1995 with a number of locations marked, including the white house, the

11 blue factory, the Feros building, the bus compound, the zinc factory, and

12 Energoinvest factory.

13 Based on your experience, sir, are the markings indicating the

14 various structures here accurate?

15 A. Yes, yes, they are accurate.

16 Q. Okay. I don't think we need to spend too much more time. Let me

17 just ask you again about the direction so we can again orient ourselves

18 if we're looking at this later. We see a road, and we can actually see

19 vehicles on this road that runs up and down right in the middle of this

20 image in front of the UN base. Can you tell us which way is north, which

21 way is south, or if you prefer, which way leads to Srebrenica and which

22 way leads to Bratunac.

23 A. Okay. South is at the top, and this is road leading us to

24 Srebrenica, and north is -- is down, at the bottom of this picture, and

25 this road leads us to Bratunac.

Page 7566

1 Q. Okay. A little bit of a trick question for you.

2 MR. THAYER: It's an upside down image compared to what we've

3 been seeing, but I thought it would be useful for the Trial Chamber to

4 have this kind of an aerial to see the proximity and other locations. So

5 the Prosecution would tender 65 ter 951.

6 JUDGE FLUEGGE: Before we decide, could you, Mr. Blaszczyk, tell

7 us who made these -- who produced all these indications about the

8 different locations.

9 THE WITNESS: We had received this picture from the US

10 government, and as far as I -- I believe we -- we got it from -- from --

11 from US.

12 JUDGE FLUEGGE: Is this the original version you received from

13 the US, or who produced, for instance, the inscriptions "white house,"

14 electrical station, and so on?

15 THE WITNESS: I believe we received this originally from US.

16 When I started to work with OTP, I formed this as part of the collection

17 we received from US government.

18 JUDGE FLUEGGE: Without any -- this version, or was it edited by

19 somebody of the OTP?

20 THE WITNESS: To be honest, Your Honour, I'm not 100 per cent

21 sure, but I seen only this version from US.

22 MR. THAYER: Okay.

23 JUDGE FLUEGGE: Mr. Thayer.

24 MR. THAYER: Mr. President, I think that's a certain amount of

25 testimony in the record already about who placed these markings in yellow

Page 7567

1 and the arrows, and I'll leave it at that. I mean, I think we already

2 have some testimony to that -- to that extent. It may have -- that

3 testimony may have come in through Mr. Ruez as to who actually placed

4 the -- these yellow markings. The image, obviously, came from the source

5 we all know about.

6 Q. But again, sir, based on your being at this location, do you have

7 any of question at all about the accuracy of the indicators here,

8 irrespective of who placed them on the image?

9 A. No. I am sure this is exactly reflect the situation.

10 JUDGE FLUEGGE: Judge Nyambe.

11 JUDGE NYAMBE: On line -- on page 56, lines 7 to 8, you are

12 recorded as saying -- Mr. Thayer asked you that:

13 "Based on your experience, are the markings indicating the

14 various structures here accurate?"

15 And you have replied:

16 "Yes."

17 Your conclusion that they're accurate is based on what?

18 THE WITNESS: This is based on my own assessment of my knowledge

19 of this area.

20 MR. THAYER: And I'll note for the record that -- I'm sorry.

21 Sorry, Your Honour.

22 JUDGE NYAMBE: Based on our recent site visit, are you able to

23 confirm the accuracy of these locations on this aerial picture?

24 THE WITNESS: Yes. Yes, we can, Your Honour.

25 JUDGE NYAMBE: Thank you.

Page 7568

1 JUDGE FLUEGGE: This photograph will be received.

2 THE REGISTRAR: As Exhibit P1340, Your Honours.

3 JUDGE FLUEGGE: Mr. Thayer, are you tendering the CD? We have

4 seen part of it.

5 MR. THAYER: I can, Mr. President. We have another section to

6 just look at very briefly now that Mr. Blaszczyk has -- has given us an

7 idea how to work it, but the Prosecution will go ahead and may as well

8 tender it now, thank you for the invitation. It's 2178.

9 JUDGE FLUEGGE: This will be received.

10 THE REGISTRAR: As Exhibit P1341, Your Honours.

11 MR. THAYER: And Ms. Stewart has helpfully tracked down a site

12 for us. Mr. Ruez testified on the 29th of March of this year, at

13 transcript page 914, lines 1 to 4, that he was the person who in fact

14 added these markings to the aerial imagery.

15 JUDGE FLUEGGE: Mr. Tolimir.

16 THE ACCUSED: [Interpretation] Thank you, Mr. President. I take

17 this opportunity to greet everyone present. I wish peace unto this

18 house, and may this trial end in keeping with God's will.

19 The Defence should like to know if this photograph the witness

20 mentioned now was received in the original from the Americans with

21 markings or not. Is it something else? We can't see the difference, and

22 we need to know for purposes of the cross-examination. We'd like to know

23 what the point is here.

24 JUDGE FLUEGGE: Mr. Thayer.

25 MR. THAYER: Mr. President, I think the record is now pretty

Page 7569

1 clear. Mr. Blaszczyk testified that his recollection is that this

2 document came this way from the United States government with all the

3 yellow markings. Mr. Ruez testified at the site that I provided for the

4 Trial Chamber that he received this image from the Rule 70 provider but

5 added himself the notations that we see in yellow. I think we can

6 comfortably leave it there.

7 JUDGE FLUEGGE: Mr. Tolimir, with the assistance of your legal

8 advisor, you will find the relevant part of the evidence of Mr. Ruez, and

9 then you may put questions to that to the witness during your

10 cross-examination.

11 Mr. Tolimir.

12 THE ACCUSED: [Interpretation] I followed carefully, but Mr. Ruez

13 did not consider this picture. He considered another picture related to

14 the stadium, and he said he made markings there, not here, whereas the

15 witness said he received this photograph together with markings from the

16 Americans. That's why I'm nonplussed a bit. Mr. Ruez spoke about

17 another photograph, not this one, and the witness is saying he received

18 this aerial photograph from the Americans with the markings already made.

19 So we don't know what to discuss in our cross-examination.

20 JUDGE FLUEGGE: Tolimir, I understand your position. I would

21 like to ask the witness.

22 You personally didn't produce any markings on this aerial

23 photograph we have on the screen in front of us now; is that correct?

24 THE WITNESS: Is correct, Your Honour, I didn't produce any

25 markings on this photograph. I said I used our set of the photographs we

Page 7570

1 kept in one place as part of the collection of the photographs received

2 from US government.

3 JUDGE FLUEGGE: When you are saying, "We received this photograph

4 from the US government," can I take it that you personally received it

5 from the government or the OTP. Are you referring to the OTP or to a

6 specific employee of the OTP.

7 THE WITNESS: Your Honour, it was -- I'm referring to the OTP,

8 and when we received this material I was not here at the Tribunal. It

9 was much earlier before I arrived to the Tribunal.

10 JUDGE FLUEGGE: Thank you. I hope that helps everybody.

11 Mr. Thayer.

12 MR. THAYER: And again, Mr. President, I just would refer the

13 accused to the citation that we gave. It's clear that Mr. Ruez was

14 talking about an image that is at page 10 of his own book of photographs

15 that the Trial Chamber may recall. Mr. Ruez has a book about two inches

16 thick, and it's P00094, admitted in through his testimony, and it's at

17 page 10 of that document. You can just go to it any time on e-court,

18 page 10. You'll see it right there. He spoke about it.

19 JUDGE FLUEGGE: Thank you very much, and please carry on.

20 MR. THAYER: May we have 65 ter 957, please.

21 Q. Pardon me. As you can see, we have another aerial image, again

22 dated 13 July 1995, at approximately 1400 hours. We can see that it has

23 many of the same markings as the previous image, but there are some

24 additional ones, and we can also see that this image is of a more focused

25 area than the image we just saw, a little bit further to the south, in

Page 7571

1 the direction of Srebrenica.

2 My first question for you, sir, is again based on your

3 familiarity with this area, the location, the features, can you tell the

4 Trial Chamber whether the notations on this image are accurate?

5 A. I am sure that the notation of this image are accurate. Is --

6 yes, is as you said, you know, is marked more places than before, on the

7 picture we seen before, but we see also the Feros building but is not

8 marked here but is visible on this picture.

9 Q. Okay. Well, while we have it up, maybe you can take the pen and

10 mark this exhibit and show us where the Feros building is.

11 A. I cannot mark it on the screen for some reason.

12 [Trial Chamber and registrar confer]

13 MR. THAYER: We may need to disconnect the computer.

14 JUDGE FLUEGGE: The technician will assist us in a few minutes.

15 I think you should carry on your examination, and then we come back to

16 that later on.

17 MR. THAYER: Okay. I do have a couple more questions on this

18 image, so -- so I'll do that, Mr. President.

19 Q. One of the structures depicted in this image that wasn't on the

20 prior one is the blue building. Do you see that here where it's marked?

21 A. Yes, I did see.

22 Q. Okay. And again is that the blue building that you testified

23 about in your earlier testimony with regard to the road book?

24 A. Yes, it's correct. This is the same building we see in the

25 picture of this building in my road book.

Page 7572

1 Q. Okay. And right across, a little bit diagonally across that road

2 we see the blue factory. Now, if we can go down -- I'm sorry, if we can

3 go up a little bit on the image to where we see "UN APC" marked. If we

4 could blow that portion up just a little bit, see if we can retain the

5 resolution. Just basically where the point of that arrow is, where it

6 says "UN APC."

7 Okay. We have here a zoomed-in view of an APC, and you can see

8 that it's -- you can see how it's positioned. Can you tell the Trial

9 Chamber how that corresponds to the video footage that you've seen from

10 that day and the other investigation you've conducted about the events of

11 that day?

12 A. Yes. Maybe it's not visible very clear here, but the position of

13 this APC corresponds exactly to the pictures we have from the -- from the

14 ground, recorded by Mr. Petrovic, and also the information we have from

15 various witnesses but that position of this APC is exactly the places

16 which were -- in the place where -- which was described by me during the

17 commenting this road book.

18 Q. And when you say it corresponds, in what way does it correspond?

19 How is it positioned?

20 A. That this is located on the road leading us to Srebrenica, and we

21 see at least one APC here just directed -- it's actually blocking a

22 little -- a little bit in the blocking position on the road, on the main

23 road, and this -- this location is not far from the blue building. It's

24 not visible on this blow-up of this picture, but the blue building is

25 located about 50, 60 metres from this position.

Page 7573

1 Q. And lastly, we see this circle with "People" written next to it.

2 Can you tell the Trial Chamber how that corresponds to the events of the

3 afternoon of 13 July and to what we were seeing in the video in Potocari

4 that afternoon.

5 A. We know from the various statements of the people who -- who were

6 at that time on the 13 July 1995 in this area that the crowd of the

7 people was located in this place, and we see also in various video that

8 the crowd of people exactly in this place which is mark here, and we see

9 on the Petrovic video. I think we see it in other videos as well. If we

10 play in this court this trial video they should be visible, the crowd of

11 the people there as well.

12 Q. Okay.

13 A. And if we look at the time the picture was taken, it's 1400

14 hours, but we see that Petrovic recorded -- recorded his material, it was

15 in later stage, about 4.00, afternoon, 3.00 or 4.00 afternoon. It means

16 that the people -- some of the people were moved -- removed already from

17 this location. The crowd is not such visible like in other videos from

18 the 12th.

19 MR. THAYER: Okay. The Prosecution would tender 65 ter 957. Oh,

20 before we do that, Mr. President, if we could -- I think we may be able

21 to mark that one item, the Feros building. So if we can zoom back to the

22 original size before we --

23 THE WITNESS: Would you like me to mark this building?

24 MR. THAYER:

25 Q. Please. Just mark the Feros building on this aerial, please.

Page 7574

1 A. Doesn't work.

2 Q. Okay. Well, maybe you can just describe where it is on the image

3 and we'll just live without marking it. Can you tell us where the Feros

4 building is on this image?

5 A. Yeah. We see -- we see the blue factory marked here. This is

6 the big building in the left bottom corner, and next to this building we

7 have this little bit grey long building next to the road. This is the

8 Feros building.

9 Q. Okay.

10 MR. THAYER: Mr. President, the Prosecution would tender now 957.

11 JUDGE FLUEGGE: I think the witness can try a last time. We'll

12 see if it works. I think it doesn't work. We will receive this aerial

13 image without marking by the witness.

14 THE REGISTRAR: As Exhibit P1342, Your Honours.

15 JUDGE FLUEGGE: Mr. Thayer.

16 MR. THAYER: Mr. President, I note that we're approaching the

17 break. It might be a good time so that the technician doesn't have to be

18 on his hands and knees while we're all watching to just take the break

19 now a couple minutes early.

20 JUDGE FLUEGGE: Thank you very much. We will do that.

21 We have our break now and resume five minutes before 1.00.

22 --- Recess taken at 12.28 p.m.

23 --- On resuming at 12.57 p.m.

24 JUDGE FLUEGGE: Yes, Mr. Thayer, please continue.

25 MR. THAYER:

Page 7575

1 Q. Okay. Let's try it one last time, Mr. Blaszczyk. If you would

2 give it a shot.

3 A. [Marks]

4 Q. Success.

5 MR. THAYER: Mr. President, the Prosecution would tender the

6 marked exhibit as well.

7 JUDGE FLUEGGE: And I would like to state for the record we see

8 in red a marking by the witness "Feros" and a "B" indicating

9 Mr. Blaszczyk, is that correct.

10 THE WITNESS: It is correct, Your Honour.

11 JUDGE FLUEGGE: This marked photograph will be received.

12 THE REGISTRAR: As Exhibit P1343, Your Honours.

13 MR. THAYER: Okay. One last aerial. If we could have P1279,

14 please. This has been MFI'd in connection with the 92 bis with cross

15 testimony of Dobroslav Stanojevic, Witness number 122. It might take a

16 moment to load up. If we could rotate that, please. Great. Thank you.

17 Q. Now, we have here an aerial image, I believe shot by J. R. Ruez,

18 from a helicopter. Sir, can you recognise what this image depicts --

19 this photograph, I should say?

20 A. This image -- this photograph depicts the area of Potocari. We

21 see here the UN Dutch base, Feros building, blue factory, blue building,

22 zinc factory, bus compound, white house, yes, all the places we described

23 before the break.

24 Q. And can you give the Trial Chamber an approximate time period or

25 year when this photograph might have been taken.

Page 7576

1 A. But it was 1998 or 1999. I am not exactly sure, but I -- I

2 remember I seen this photograph. It was taken by Jean Rene Ruez.

3 Q. What I'd like you to do, please, is just take that pen and mark

4 the following locations because now we're seeing the Potocari area from

5 an angle that we haven't seen before.

6 A. As --

7 Q. But start moving from the left to the right.

8 A. Okay.

9 Q. I'll do it this way. Wherever you see the Ekspres bus compound,

10 could you mark that, please.

11 A. I will mark this bus compound as number 1. Oops.

12 MR. THAYER: We need to zoom back out.

13 JUDGE FLUEGGE: We zoom out again.

14 MR. THAYER:

15 Q. We need to return to the original image before you mark anything,

16 Mr. Blaszczyk, or else we're going to lose it.

17 JUDGE FLUEGGE: Please zoom out again. We need the full area

18 photograph.

19 MR. THAYER: Okay. Thank you.

20 JUDGE FLUEGGE: And wait a moment so that the court usher can

21 assist you with the marking.

22 MR. THAYER:

23 Q. So please mark the Ekspres bus compound with a 1.

24 JUDGE FLUEGGE: I don't know what happened. When you touched the

25 screen with the pen --

Page 7577

1 THE WITNESS: I promise I didn't touch it.

2 JUDGE FLUEGGE: But we have to test your credibility. Even

3 further now. I don't know what happened.

4 THE WITNESS: I have no pen in my hands.

5 JUDGE FLUEGGE: This is now absolutely trustworthy. I can see

6 it.

7 MR. THAYER:

8 Q. Okay. But we've -- thank you.

9 A. Would you like me to --

10 Q. And -- freeze. Okay.

11 A. I touch it. I don't know --

12 JUDGE FLUEGGE: I knew it.

13 MR. THAYER: Okay. There must be something ...

14 THE WITNESS: [Marks]

15 MR. THAYER:

16 Q. Okay. So we have number 1 marked at what location, sir?

17 A. I marked this location with number 1 as the location of -- the

18 position of the bus, Ekspres bus compound, in Potocari, of course.

19 Q. Okay. Let's say the zinc factory. Can you mark that with a

20 number 2, please.

21 A. Number 2, this is the zinc factory.

22 Q. And let's say the blue building. Can you locate that and write a

23 number 3 next to the blue building?

24 A. Yes. The blue building is visible here also.

25 Q. And how about the Feros building. Can you mark the Feros

Page 7578

1 building with a number 4, please.

2 A. Number 4, this is Feros building. And next to him is blue

3 factory.

4 Q. Can you mark that with a 5, please.

5 A. [Marks]

6 Q. And the white house with a 6.

7 A. And white house is here.

8 MR. THAYER: Okay. And I think we're safely done with this

9 exhibit. If we could quit while we're ahead, and we'll tender the marked

10 aerial, please.

11 JUDGE FLUEGGE: This marked aerial photograph will be received.

12 THE REGISTRAR: As Exhibit 1344, Your Honours.

13 MR. THAYER: And, Your Honours, I mentioned at the outset the

14 unmarked version has been MFI'd as 1279, and the Prosecution would go

15 ahead and tender that as well at this time, the unmarked version.

16 JUDGE FLUEGGE: Mr. Blaszczyk, you told us that Mr. Ruez has

17 taken this aerial photograph; is that correct?

18 THE WITNESS: Yes, Your Honour. I remember that Mr. Ruez took

19 the tour, you know, by helicopter, around this area, and he also made

20 some pictures of this area.

21 JUDGE FLUEGGE: Thank you. This will --

22 THE WITNESS: But I -- sorry, sir.

23 JUDGE FLUEGGE: Go ahead.

24 THE WITNESS: But I not remember now the date, exact date, but it

25 was much before I arrived to the Tribunal. It was 1998 or 1999, but I'm

Page 7579

1 not sure.

2 JUDGE FLUEGGE: Thank you. This photograph will be received. As

3 P1279.

4 MR. THAYER: Thank you, Mr. President.

5 Q. Now, before we --

6 JUDGE FLUEGGE: One moment, please.

7 [Trial Chamber confers]

8 JUDGE FLUEGGE: Thank you. Please carry on, Mr. Thayer.

9 MR. THAYER:

10 Q. Before we leave this Potocari section of the road book, you

11 testified in the Popovic case - and this is at page 18607, in case

12 anybody wants to go back - you testified that you had been to these areas

13 in Srebrenica, Potocari, Kravica, Zeleni Jadar, about 40 to 50 times, and

14 this was when you testified at the end of 2007. Do you recall that, and

15 was that an accurate estimate back then?

16 A. I don't know exactly how many times I was there, but it was

17 around this number, about 40, 50 times. Each time at this period when I

18 joined Tribunal in 2003 up to 2007 or 2006, I've been quite often in

19 this -- this area, Bratunac, Srebrenica area. It's been almost every few

20 months or two months or three months I was this area.

21 Q. And since your testimony in Popovic in 2007, can you give the

22 Trial Chamber a rough idea of how many times you've been back to these

23 areas, including Potocari?

24 A. After 2007, in fact I was there just a few times more but not --

25 not many as before.

Page 7580

1 Q. Okay. More than 10, more than 20? Can you just give us an

2 estimate?

3 A. I would say that about ten times more.

4 Q. Okay.

5 A. Maybe 10, 15, 20.

6 Q. Now, we're going to turn to the second chapter. If we could all

7 turn to pages 20, 21 of the hard copy road book. Again, for the record,

8 that's P1251.

9 We see on page 21 again your positions marked with the yellow

10 circles. Just to move things along a little bit, are -- are those based

11 upon your GPS readings on this mission that you took in 2006 as we saw

12 with the map before the Potocari section, Mr. Blaszczyk?

13 A. Yes, you are correct. Dealing with these yellow dots, I -- I

14 just put these yellow dots on exactly the location I spotted during my

15 mission and location where I got also the GPS readings of these

16 particular places.

17 Q. And this map is a little bit more crowded than the Potocari map.

18 We see, I think, 19 positions marked, and will we see those positions 1

19 through 19 further identified as we go through this chapter by particular

20 photographs?

21 A. Yes, yes, okay. There are so many -- so many dots here because I

22 used more photos from Petrovic video and my -- my own photos. More in

23 this chapter than in previous chapter.

24 Q. Okay. Well, then let's turn the page to pages 22 and 23. Now,

25 we see on page 22 a photograph that you've identified as being taken by

Page 7581

1 yourself in June of 2006, and just to clarify one thing, I think you've

2 mentioned on a couple of occasions today that your recollection was that

3 mission was in May. We have here in the book that it was June. Do you

4 have any recollection of whether it was May or June, just so we have a

5 little bit of clarity.

6 A. Yes, Your Honour. I was there in May, end of May, I believe, in

7 this area, but these photos June 2006, this entry refers to -- to the

8 folder we created when I returned from mission. We created on the

9 computer of visual unit, and we -- we used this date in June 2006 that

10 the photos were located in this particular folder which was used later to

11 create this particular book.

12 Q. Okay. And just before we start getting into the guts of these

13 two pages, again if we look at the next page, 23, we see your little

14 yellow dots with the following notations: "Position on map: 4 and 3."

15 Again, just to save some time, do those refer back to the previous page,

16 21, where you've numbered these 19 locations along this road?

17 A. Yes. These -- these yellow dots are referred to -- to the

18 position marked on the map from the page 21.

19 Q. Okay. Now, the Trial Chamber has already heard testimony from

20 Ms. Gallagher about this destroyed white house opposite the Sandici

21 meadow, again not to be confused with the white house in Potocari, but

22 before we begin -- or before we resume playing a couple of portions of

23 the Petrovic video, can you explain why you thought it was important to

24 include these two pages which don't have any video stills from the

25 Petrovic video in them?

Page 7582

1 A. Especially for the persons who have never been in this area or

2 been there only once or twice, it's rather quite difficult to -- to be

3 orientated in this -- this area, and my reason, my -- my idea was to --

4 to make it as best as possible the general view of the area and the

5 location of the particular houses or features in this area. This is why

6 I put -- I just dedicated these two pages to my notebook, not like the

7 previous chapter, to showing Your Honour and to everybody who is looking

8 on this notebook, to showing them the best idea how the area looks or

9 looked in 2006, and later on we can compare this area with Petrovic

10 footage. It would be easier, much easier, having these entire pictures,

11 all the pictures here in these two pages.

12 Q. Okay. And just to orient ourselves a little bit, if we look at

13 your photograph on page 22, we see you've provided the directions

14 Konjevic Polje to the right of the photograph and Kravica-Bratunac to the

15 left. Can you tell us which direction Konjevic Polje is from this

16 location?

17 A. This is direction to the west, this is Konjevic Polje. And to

18 Kravica and Bratunac, this is east direction.

19 Q. And do you hit Bratunac -- I mean -- I beg your pardon. Do you

20 hit Kravica before you hit Bratunac if you're travelling from this

21 location?

22 A. Yes, first the Kravica is located about 1 kilometre from Sandici

23 meadow in the direction to Kravica to the east.

24 Q. Okay. Tell us a little bit about what page 23 is designed to

25 show us. Help us out with some of these photographs that you've included

Page 7583

1 here. Just explain in -- as best you can.

2 A. On 20 -- on the page 23 I -- I -- we put the pictures of the --

3 the more detailed pictures of the area of Sandici meadow, including the

4 destroyed white house located just across the meadow, and another

5 picture, picture 2, showing us the meadow, and also destroyed house which

6 is located on Sandici meadow. We can't see this house later on in -- in

7 Petrovic video. And on the page 3, we see panorama picture. This

8 picture was taken from the Sandici meadow and showing us the location

9 which is located across the road from Sandici meadow. We see the

10 destroyed white house and the road leading us to Konjevic Polje and

11 Kravica Bratunac.

12 Q. Okay. And just to clarify one thing. You said page 3. I

13 presume you meant photo 3 on page 23, Mr. Blaszczyk?

14 A. Yes, I meant photo 3 from page 23.

15 Q. And just to make clear one thing. If we look at photograph 2 on

16 page 23 --

17 JUDGE FLUEGGE: Another error occurred, line 2, page 74, the

18 witness said:

19 "I meant photo 3 from --"

20 Now it's corrected. We can carry on.

21 MR. THAYER:

22 Q. If you look at photo 2 on page 23, there is a reference or you've

23 pointed out what you refer to as a destroyed house which is on the same

24 side of the road as the Sandici meadow, and I take it that if we look at

25 the prior page, page 22, you've got an arrow pointing down with that same

Page 7584

1 photograph to a destroyed house that's sitting along the road there on

2 the same side of the road as the Sandici meadow. Is that what you've

3 done here?

4 A. Yes. You are correct. And on the page 22, I have the general

5 view of the Sandici area, and I use the same photograph. From the right

6 top corner on the page 23 showing us the same destroyed house on Sandici

7 meadow.

8 Q. Okay.

9 A. And we see the location of this house if we look at the general

10 view of the Sandici area.

11 Q. And we'll be very careful to distinguish when we're talking about

12 this larger destroyed white house as opposed to this smaller destroyed

13 house that we see here.

14 Let's just go to pages 24 and 25. We don't need to play the

15 video. The Trial Chamber heard the testimony from Ms. Gallagher

16 identifying the individual on page 24 as Milenko Trifunovic, also known

17 as Cop, a member of the Special Police Brigade Sekovici.

18 You've -- well, if we look at the next page, page 25, can you

19 tell us who that well-built man in the blue jeans is in photograph A?

20 A. It's me.

21 Q. Okay. Now, you've identified the structure that you are facing

22 as the destroyed house, and you've linked that to the video still on the

23 prior page in the upper right corner of that video still A. Just to be

24 clear, if you had wanted to completely replicate the position of

25 Mr. Trifunovic, you should have turned around and faced the camera; is

Page 7585

1 that correct? Would we then be looking at -- at an exact image?

2 A. Yes, you're right. I could be mistaken by 1 metre, maybe half a

3 metre, but, yes.

4 Q. But when you're looking at the white house here --

5 A. You mean --

6 Q. -- you're not facing the same direction as Mr. Trifunovic. I

7 just want to make that clear for the report. Is that correct?

8 A. Yes, it's correct, but I'm not looking at the white house,

9 destroyed white house, but I'm looking at destroyed house. We have to

10 distinguish this.

11 Q. I violated my -- thank you, Mr. Blaszczyk. You're absolutely

12 right.

13 You -- in the video still, Mr. Trifunovic has his back to the

14 destroyed house. In your photograph you are facing the destroyed house;

15 is that correct?

16 A. Yes, this is correct. I am facing to this destroyed house, and

17 Mr. Trifunovic is -- is in back side from this house.

18 Q. Okay. Now, if we look at photograph 2 on page 25, we can see

19 that the road bends in a couple of places. Can you tell the Trial

20 Chamber a little bit about the topography in this area of the road and

21 how, if at all, that assisted you in determining the locations of these

22 various features and buildings and people during the course of this

23 project.

24 A. As you see on this photograph number 2 from page 25, the road is

25 bending, and here is helping us a lot to -- to assist to locate the

Page 7586

1 particular places. If we play the video, we can locate the particular

2 places following the movement of the camera and following also the shape

3 of the road and the surrounding hills and surrounding houses. And this

4 is the picture number 2. This is the general view of Sandici meadow but

5 from the west direction, from the hill located on the west from Sandici

6 meadow.

7 Q. And if we stay with this photograph 2 on page 25, you've also

8 identified the destroyed white house and the Kravica warehouse as being

9 visible. How were you able to do that?

10 A. Maybe it's not visible very well on this particular photo in this

11 road book, but if you place this -- these photos or original photo on the

12 computer and you zoom in the picture, the Kravica warehouse is visible.

13 As I said, the Kravica is located from this destroyed white house less

14 than 1 kilometre. And destroyed white house is located on little bit

15 hill. I don't know, Your Honour, if you noticed when you were there that

16 the warehouse is located from this location.

17 Q. Let's turn the page and we'll look at pages 26 and 27. The Trial

18 Chamber's no doubt familiar with this footage of Mr. Ramo Osmanovic's

19 calling out to his son, Nermin, from seeing it with Ms. Gallagher not too

20 long ago.

21 Can you tell the Trial Chamber how you were able to determine the

22 locations in the two photographs on page 27 of the video stills on page

23 26.

24 A. As I said, I followed the movement of the camera, and in these

25 pictures, in my pictures I choose the most significant things that --

Page 7587

1 showing us that this is the same location. This is the small house

2 depicted on the picture -- on the still B from the page 26. We see the

3 same small house on my picture from the page 27 as the picture number

4 marked here as picture number 1.

5 Q. Okay. And if we look at video still B on page 26, we can see

6 that directly above the head of Mr. Osmanovic, as it were, there appears

7 to be a rise, a horizontal rise or ridge extending from left to right.

8 Were you able to use that or did that help you at all in locating this

9 position?

10 A. Yes, it -- it helped me very much.

11 Q. And where can we see that in photo 1 or 2 on page 27?

12 A. Yeah. If you look -- if you look at the photos number 1, you

13 see. You see exactly the same shape of the hill here, but the picture

14 number 2 from the page 27, this is the picture taken from the position

15 when the man is depicted from the previous page, page 26.

16 Q. Okay. So that ridge is not visible in photo 2 because it's --

17 the photo is being taken from the perspective of the men in photo, say,

18 C, for example, or B, looking towards the destroyed white house; is that

19 correct?

20 A. This is correct. This is totally different direction. We are

21 back to this hill, you know, depicted on the -- on the page 20 -- 26.

22 Q. Okay. We can move along a little bit and then dispense with

23 playing some of the video. If we go to the next page, page 28, and then

24 page 29. The --

25 JUDGE FLUEGGE: Judge Mindua has a question.

Page 7588

1 JUDGE MINDUA: [Interpretation] Thank you, Your Honour. I have a

2 question to put to the Prosecutor.

3 Mr. Thayer, will we be hearing a witness had will come to talk to

4 us again about Mr. Ramo Osmanovic's fate who was calling out to his son

5 Nermin? Will somebody come to talk to us about these two men?

6 MR. THAYER: Your Honour, off the top of my head, I can't recall

7 whether we have a Bosnian Muslim witness who is still a viva voce,

8 92 ter, or 92 bis with cross witness who talks specifically about

9 Mr. Osmanovic or his son. I can tell you that we have two witnesses who

10 are 92 bis with cross witnesses who were among this group that we see

11 here of Muslim men sitting on the meadow who will talk about the events

12 that took place on the meadow, and we will have testimony from

13 Ms. Gallagher as early as perhaps tomorrow about the fate of

14 Mr. Osmanovic in connection with the DNA identifications, the men who

15 still remain on the missing list reports from family members, for

16 example, that they are still missing. So you will hear some testimony

17 concerning Mr. Osmanovic, but I can't tell you whether we have any

18 witnesses who are available to come tell you specifically about him based

19 on their observation of him at the time, but I will get back to the Trial

20 Chamber on that, certainly.

21 JUDGE MINDUA: [Interpretation] Fine. Right. You will get back

22 to us on this at a later stage. Thank you.

23 JUDGE FLUEGGE: Mr. Thayer.

24 MR. THAYER: And for the record, the two witnesses who will be

25 coming to talk about their experiences at the Sandici meadow are

Page 7589

1 Witnesses 51, who has been assigned the pseudonym PW-14, and Witness 52.

2 JUDGE FLUEGGE: The last part of the transcript is the answer of

3 Mr. Thayer and not mine.

4 MR. THAYER: And I think as I alluded to, of course, part of

5 Ms. Gallagher's testimony about the -- what we refer to as the Muslim ID

6 book will, of course, to some degree rely on the evidence of Mr. Janc

7 concerning the DNA identifications of these men from mass graves.

8 Mr. Janc's report is P00170.

9 JUDGE MINDUA: Thank you very much.

10 MR. THAYER:

11 Q. Now, looking at page 28, we have some stills of various armoured

12 vehicles in A and B, a truck in C, and a tank in D, and you've made some

13 determinations on page 29 in your photograph of where some of these

14 vehicles and the tanks were located.

15 I first note for the record that these images are spread out over

16 several minutes of the Petrovic video, and we don't need to play those

17 again, but if we note photograph A is at 9:28, and photos C and D are at

18 21:31.

19 Again, sir, how were you able to make the determination with

20 respect to the locations of A and B which you've marked here?

21 A. As I said, I carefully analysed the movement of the camera which

22 recorded these -- these events, and also I analysed the features of --

23 of -- of the hills in the background of -- from the Petrovic video and

24 also when I was on the spot. The shape of the hill.

25 Q. Okay. Now, for example, we don't see video still D, the tank,

Page 7590

1 marked anywhere on your photograph on page 29. Why not?

2 A. This tank is definitely on Sandici meadow, and also the truck

3 on -- from the page 28, still C, but I was not able to -- to spot the

4 exact position of the tank and truck. I know that this is in Sandici

5 meadow. I have my own assumption, but I was not able to determine the

6 proper location of this tank and truck.

7 Q. Okay. Let's just turn the page and go to pages 30 and 31. I

8 don't think the Trial Chamber has actually heard any identification of

9 the individuals in video still A. I -- I believe that they are included

10 in Ms. Gallagher's ID book that she referred to during her testimony.

11 Mr. Blaszczyk, do you have any idea off the top of your head of

12 the identities of these two individuals in video still A? If you don't,

13 that's fine.

14 A. I know that these two men depicted on the picture A are brothers.

15 One of them is the member of the Special Police Brigade. Another one is

16 the member of 1st Company of PJP, but I don't remember their names.

17 Q. That's fine. And the Chamber probably remembers that the brother

18 on the right showed Mr. Borovcanin his pistol and said something to the

19 effect of, "Boro, do you want to swap guns?" We don't need to see it

20 again. But how were you able to pinpoint the location of these two men

21 as you have on page 31 showing A and B?

22 A. The same, analysing the pictures, the still captured from

23 Petrovic video and looking at my picture from the page 31. On the

24 left-hand side we see the destroyed white house. If you look carefully

25 on the picture B from the page 30, you see part of this house on the left

Page 7591

1 corner, top corner, behind, above the head of Mr. Borovcanin.

2 Q. Okay. Let's --

3 A. It's maybe better visible if we play the video, but we are using

4 these photos here.

5 Q. Okay. Well, to save some time, we'll just keep moving in the

6 couple minutes we've got left here.

7 If we go to pages 32 and 33. Do you recall, based on your

8 reviews of the Petrovic video, what's going on with the camera with

9 respect to stills A, B, and C on page 32?

10 A. Yes. The operator, it's Mr. Petrovic is recording this event,

11 the people on Sandici meadow. He is recording them from the location of

12 the destroyed white house. On the picture B is visible here aerial of --

13 of the car. The car belonged to Mr. Borovcanin. He -- and on -- on

14 picture A as well. And in this raw material we have the part of -- of --

15 of -- of this event, but I believe that in raw material we have the blank

16 portion of -- of this material and also of the recorded material. But

17 this picture, the frames from page 32, frames A, B, C, are visible on

18 this raw material, Petrovic raw material.

19 Q. Okay.

20 A. Copied by us in 2006.

21 Q. Well, we can -- in the minute we have left, I think we can maybe

22 play just that minute or two of video. And this would be -- let's start

23 at 10:15, which is 10:19 in Sanction. Okay. Yes. We can start. We're

24 at 10:18 in Sanction.

25 [Video-clip played]

Page 7592

1 MR. THAYER: We've stopped at 10:33.7. The screen's blank. We

2 hear voices. Can you tell the Trial Chamber what's going on,

3 Mr. Blaszczyk.

4 A. This is over-recorded material from Petrovic raw material, and

5 during the interview he confirmed that this is his voice in this part,

6 and for some reason it was over-recorded.

7 Q. Okay.

8 A. And this -- this -- this record that voices are coming from his

9 house, and this is his conversation with his families member.

10 JUDGE FLUEGGE: If we see an abbreviation ZZP, it should be ZPP I

11 think, if it is Mr. Petrovic.

12 THE WITNESS: You are right, Your Honour. It should be ZPP,

13 Zoran Petrovic, Pirocanac.

14 JUDGE FLUEGGE: Please carry on.

15 MR. THAYER: Thank you, Mr. President. I think we can leave it

16 there for the day and we'll resume with it tomorrow.

17 JUDGE FLUEGGE: Judge Nyambe has a question.

18 JUDGE NYAMBE: Just a clarification at page 81, line 22 -- or if

19 you said, from line 21:

20 "On the picture B is visibile here, material, area of the car.

21 The car belonged to Mr. --" whatever.

22 I didn't see the car. Do you think you could assist me to see

23 the car?

24 THE WITNESS: Yes, Your Honour. I will try to explain. On that

25 picture A, you see the roof of the car and the part -- and the aerial on

Page 7593

1 this roof. This is the car used by Mr. Borovcanin, his driver,

2 Mr. Petrovic. And then the camera moved to the right, and we see only

3 the aerial of this car. It is just on the little bit right, little bit

4 right from the middle of this picture, from picture B. We see only the

5 aerial of this care.

6 JUDGE NYAMBE: Thank you.

7 THE WITNESS: Which roof is visible on picture A.

8 JUDGE FLUEGGE: Thank you very much. We have to adjourn now for

9 the day. We will continue your examination tomorrow, Mr. Blaszczyk.

10 Thank you very much. Please be reminded no contact with the parties

11 about the content of your testimony in the meantime.

12 We adjourn and we resume tomorrow morning at 9.00 in this

13 courtroom.

14 --- Whereupon the hearing adjourned at 1.47 p.m.,

15 to be reconvened on Thursday, the 11th day

16 of November, 2010, at 9.00 a.m.