Tribunal Criminal Tribunal for the Former Yugoslavia

Page 2881

1 Wednesday, 21 November 2001

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 9.31 a.m.

6 JUDGE HUNT: Call the case, please.

7 THE REGISTRAR: Case number IT-98-32-T, the Prosecutor versus

8 Mitar Vasiljevic.

9 JUDGE HUNT: Mr. Tanaskovic.

10 MR. TANASKOVIC: [Interpretation] Thank you, Your Honour.

11 WITNESS: ZIVORAD SAVIC [Resumed]

12 [Witness answered through interpreter]

13 Examined by Mr. Tanaskovic: [Continued]

14 Q. Mr. Savic, good morning.

15 A. Good morning.

16 Q. We broke off yesterday with my question and your answer that you

17 went to visit Mr. Vasiljevic in an ambulance in Uzice. My next question

18 would be: Do you know how long Vasiljevic stayed in the hospital in

19 Uzice, or maybe you don't know?

20 A. I know that he stayed more than 30 days.

21 Q. And did you, perhaps, drive him back home with an ambulance from

22 the hospital?

23 A. No, I don't remember when he went back.

24 Q. Did you, and after how long, see Mr. Vasiljevic in Visegrad?

25 A. I would see him about two months after that when he was walking

Page 2882

1 around with some crutches.

2 Q. Let me go back to another point. Do you remember that the day you

3 drove Mr. Vasiljevic to the hospital in Uzice, that it was a holiday?

4 A. Yes, it was a holiday known as the Trinity, because both I and my

5 father are religious people and on that day, you take wheat, boiled wheat,

6 to the church and some vegetables and then the priest blesses it and it's

7 a tradition; this was the tradition passed down from my grandfather - my

8 father was still alive - and this was meant to ensure the health of the

9 livestock and the harvest, a good harvest.

10 Q. As we have already heard, the Holy Trinity there consists of three

11 days. Which of those three days did you go to church?

12 A. On the Sunday, the first day of the Trinity. It's always a

13 Sunday.

14 Q. Thank you. Let me ask you something else. Do you know any other

15 person called Mitar?

16 A. Yes, I know Mitar Knezevic, also known as the Chetnik. That was

17 his nickname during the war.

18 Q. Could you describe this Mitar Knezevic?

19 A. He's rather short, of the same height as Mitar Vasiljevic. He had

20 a beard, and he had a faulty eye; he couldn't see on one eye.

21 Q. When you say a "faulty eye," do you mean he had an eye missing?

22 A. No, he had an eye but, I can't explain it, he couldn't see it. It

23 was sort of all white. It was damaged.

24 MR. TANASKOVIC: [Interpretation] I have no further questions, Your

25 Honour.

Page 2883

1 JUDGE HUNT: Mr. Groome.

2 MR. GROOME: Thank you, Your Honour.

3 Cross-examined by Mr. Groome:

4 Q. Good morning, Mr. Savic, my name is Dermot Groome and I represent

5 the Office of the Prosecutor, and I will be asking you a few questions

6 regarding your testimony.

7 I think you told us yesterday that before you drove an ambulance,

8 you were an ordinary driver; is that correct?

9 A. Yes. Before that, I worked on my own with a truck for ten years.

10 Q. And when you became an ambulance driver, did you receive any

11 special medical training or is it simply that you drive patients to the

12 hospital?

13 A. I would drive patients. First I started driving patients who went

14 for dialysis treatment from Visegrad to Foca. For a year, I was an

15 apprentice and then, after a year, I was taken off as permanent staff

16 member in the health centre.

17 Q. Now when you go out on a call as an ambulance driver, do you

18 administer any type of medical assistance at the scene or do you

19 simply carry that person back to the hospital where they can be treated?

20 A. If everything could not be done in Visegrad, I would drive them

21 on, and if it's a more serious case, then somebody from the medical staff

22 would accompany the patient [as interpreted] as an escort

23 with me.

24 Q. What I'm trying to get at is, if you respond to the scene of an

25 accident you, yourself, don't attempt to give medical treatment to the

Page 2884

1 person; you simply carry them back to the Visegrad Health Centre or to one

2 of the other hospitals; correct?

3 A. Yes.

4 Q. Now, let's say responding to a traffic accident, it is clear that

5 the person has already deceased, they are dead. Is it also your job to

6 bring that body to a funeral parlor or to morgue or does somebody else

7 have that job?

8 A. We would take the person from the spot because I can never be sure

9 whether the person is dead or not, so I would drive them to the closest

10 medical institution. I don't necessarily have to drive the person to the

11 medical centre.

12 Q. Is there anybody else in the town of Visegrad who has the

13 responsibility of moving bodies that -- it's confirmed that they've died,

14 wherever they are found; does anybody else have that responsibility in

15 Visegrad?

16 A. Of course, there's the funeral society. They would take care of

17 the dead. The company's called communal. They have the necessary

18 equipment and take care of the transport. They take them either to the

19 cemetery or to their home, to the village, wherever.

20 Q. Do you recall this past August speaking with an investigator from

21 the Office of the Prosecutor, a person by the name of Yves Roy? Do you

22 remember speaking with him?

23 A. Yes, I was in Sarajevo with him.

24 Q. And he interviewed you regarding knowledge you might have

25 regarding this case; correct?

Page 2885

1 A. Yes.

2 Q. And he asked you questions and you responded with however you

3 could, whatever knowledge you had on certain matters; correct?

4 A. Yes.

5 Q. And at the end of the interview, Mr. Roy gave you an opportunity

6 to add anything else that you wanted to add; is that correct?

7 A. Yes.

8 Q. And I think in response to that opportunity, you said, "No thank

9 you, really, I am just happy that you are so nice and kind." Did you say

10 that to Mr. Roy?

11 A. Yes.

12 Q. And Mr. Roy, he tape recorded this conversation. There was a tape

13 recorder on the table and it was tape recorded; correct?

14 A. He asked me whether he should write it down or tape record it and

15 I said it was up to him, and then he tape recorded it.

16 Q. You were aware that he was tape recording it and you consented to

17 that; correct?

18 A. Yes.

19 Q. Now, during the course of that interview, one of the things, I

20 believe, you said was that you had seen Milan Lukic's wedding; was that

21 correct?

22 A. Yes.

23 Q. Do you recall what day that was?

24 A. I'm afraid I don't know the exact date. I was also at the

25 wedding.

Page 2886

1 Q. And were you at the church part of the wedding or the part of the

2 wedding at the registrar's office in town?

3 A. I didn't attend either of those ceremonies. I was invited in the

4 afternoon, at 3.00, to the hotel. I didn't attend the actual ceremony

5 which took place in church and in the cultural centre. I didn't attend

6 those because there were guests invited to various parts of the ceremony

7 and I was among those who was invited to the hotel in the afternoon.

8 Q. And was there a party in celebration of his wedding in the

9 afternoon at the hotel?

10 A. Yes. That is where I attended.

11 Q. Can you give us some idea how much before the wedding did you

12 receive your invitation to attend Milan Lukic's wedding, one week, two

13 weeks; how much time?

14 A. A month.

15 Q. And when you attended this wedding, I take it that you dressed in

16 some nice clothes to go to the wedding; is that correct?

17 A. Yes. Everybody dresses up for a wedding.

18 Q. Did you see Mr. Vasiljevic there at the wedding?

19 A. He was there. He was at the wedding.

20 Q. And would we be correct in assuming that he, too, was dressed in

21 nice clothes to attend the wedding?

22 A. Yes.

23 Q. Now also in your statement, you were asked some questions about

24 the people from Kosovo Polje and you had -- you said in your statement

25 that there was a time when you went to Kosovo Polje and warned those

Page 2887

1 people about a possible attack by paramilitaries; is that correct?

2 A. Kosovo Polje had vegetables which was planted in May, tomatoes and

3 other vegetables, and every year, I would purchase from them tomatoes and

4 peppers. And I went over there and told them to flee, to take a boat and

5 cross the Drina and flee wherever. I know all the people who were there.

6 Q. And was that just one time that you went and gave them a warning

7 or were there -- was it more than once that you gave a warning to the

8 people of Kosovo Polje?

9 A. Once I went on that occasion. I had a cup of coffee with them, a

10 whole litre of coffee with them, and I begged them; I told them to flee.

11 They complained there was some paramilitaries coming and I said flee, seek

12 shelter. These were my old neighbours and friends and that is why I

13 warned them.

14 Q. When you went to Kosovo Polje, did you take your ambulance?

15 A. Yes.

16 Q. And can you give us an idea about what time of day, was it

17 daytime, night-time?

18 A. It was daytime. It was mid-day, maybe 1.00 or 2.00 in the

19 afternoon, broad daylight.

20 Q. And can you give us some idea of when you went to Kosovo Polje and

21 gave them this warning?

22 A. It could have been sometime around the 10th of May. That is when

23 the planting season is, in May, in the fifth month.

24 Q. Now I want to clear up something. Did they tell you about the

25 paramilitaries or you told them about the paramilitaries?

Page 2888

1 A. They told me that people they did not know at all came and one of

2 them said, "I hid ten litres of petrol in the field, and he found the

3 petrol," but he said he'd never seen those people before. And I said, "I

4 don't know them either. I'm afraid of them, too. We're all afraid. It's

5 better for you to seek shelter, to get away."

6 Q. Mr. Savic, I want to read you a portion of the statement from this

7 August and see, does it change your answer on this point. "I know that in

8 1992, in June, end of May or beginning of June, I went to Kosovo Polje,

9 pretending to get some vegetables because it is a known area for growing

10 vegetables and so when I go there and told them to move away from the area

11 because of these paramilitary guys who will be coming. Many of them are

12 thankful to me because they ran away that day across the river." And then

13 Mr. Roy said, "So you've been nice to the Muslim population during the war

14 and up to today?"

15 THE INTERPRETER: Slow down, please, Mr. Groome.

16 MR. GROOME:

17 Q. And you said, "They trusted me. And I told them they should move

18 away from that area because these guys are coming. They are going to

19 probably loot and who knows what you can expect from them so ..." So I

20 want to ask you the question again, Mr. Savic: Wasn't it you who told the

21 people in Kosovo Polje that there were paramilitaries planning to come to

22 Kosovo Polje and possibly commit crimes against those people? Wasn't it

23 you that told them?

24 A. I spoke to those people because one never knows. I didn't know

25 where those people would go, but it was safer for them to go away. One

Page 2889

1 never knew where they would crop up. Knowing these people, they all knew

2 me. I would carry material to their homes regularly and buy vegetables

3 from them, Bakima's mother. I knew each and every one of them by name. I

4 said -- I begged them to move away. They were grateful. We had coffee. I

5 sat with them. They asked me to stay longer, but I, too, was afraid to

6 stay longer, and that's how it was.

7 Q. The precise question that I'm asking you, Mr. Savic, is: Wasn't

8 it you who told them about paramilitaries rather than them telling you

9 about the paramilitaries? It was you that pretended to go and get

10 vegetables and to warn them about paramilitaries; isn't that correct?

11 A. Yes, but they had told me earlier on that they had already been

12 visited by them.

13 Q. Now, would I be correct in thinking that you had other friends

14 in the Visegrad area that were also Muslim; is that correct?

15 A. Yes. I had a colleague that I gave cigarettes to. I bought 20

16 boxes and gave them to him and told him to go away. His name is Mujo

17 Racic. I gave him these cigarettes and told him to seek shelter and he

18 went across the hills. His wife took the cow. I even wanted to drive him

19 to Priboj by car.

20 Q. Aside from the people in Kosovo Polje, did you at any other time

21 in May or June travel to another Muslim settlement and again warn those

22 people that paramilitaries might be coming? Did you ever do that in any

23 other settlement?

24 A. I did. In the street behind the cultural centre of Hamid

25 Besirevic, I took care of two children in my own home and then I took

Page 2890

1 their mother, too. I dressed her in black clothes, my wife's clothes. I

2 put them in my car, my vehicles, and took them to Priboj. Naila and her

3 two children. They are now in Denmark and we are in touch. She worked as

4 a cashier.

5 THE INTERPRETER: A doctor lady, I'm sorry, the interpreter

6 corrects herself.

7 A. No, a lady doctor from Sase. Osman and Jasmina and their mother,

8 I drove them to my sister's place in Uzice in June.

9 MR. GROOME:

10 Q. Mr. Savic, I don't mean to suggest that you were anything other

11 than kind to Muslim people. What I do want to know, however, is did you

12 warn any other people? Did you go to any other settlement, pretending to

13 be there on other business, to warn people, or was Kosovo Polje the only

14 time that you did this type of thing, this -- give this type of warning?

15 A. Whenever I came across a person in the street or in any

16 settlement, I told them, "Please flee." It wasn't safe for anyone. No

17 one could prove that he was a Serb or a Muslim or something. When unknown

18 people under arms were walking around, you couldn't tell them what you

19 were. I didn't have occasion to tell them who I was. So whenever I came

20 across anyone I knew, I would tell them, "Flee, go and seek shelter

21 wherever you can."

22 Q. Sir, can I ask you then how was it that you knew that

23 paramilitaries were planning to attack the village or the settlement of

24 Kosovo Polje? What did you see or hear that made you believe that the

25 people in Kosovo Polje were going to be attacked by paramilitaries?

Page 2891

1 A. There was fear that was widespread among all people and then

2 people were roaming around like cattle. They were ready to kill, to

3 steal. You don't know who that person is, what he is. He doesn't talk to

4 anyone. He behaves like an animal.

5 Q. Can you estimate for us the first time you saw people walking

6 around and behaving in this manner in Visegrad?

7 A. After the Yugoslav army had left Visegrad - they left on the 18th

8 of May - after that, they arrived, some strange people that had their own

9 laws. No one dared go out in the street, whether we were Serbs or

10 Muslims. It was an impossible situation of fear.

11 Q. Some people may have had the choice not to go out into the

12 streets. My question to you is: Because of your job as an ambulance

13 driver, did you have to go out and travel in the streets when these people

14 were roaming around the streets?

15 A. I had to. There were people who were ill. There were heart

16 patients. I had to go and pick them up and drive them to the centre. I

17 was the only one who had to move around willy-nilly.

18 Q. And during this time period, would it be fair to say that you,

19 yourself, saw some of these men commit crimes, crimes such as looting or

20 destroying property?

21 A. I would see them, but I don't know these people. I didn't know

22 them at all. They could do whatever they wanted. They could go wherever

23 they wanted. They would break into apartments; they would do whatever

24 they wanted. They were armed and they could do what they wanted.

25 Q. And did you, yourself, see them engage in this activity?

Page 2892

1 A. I would see them.

2 Q. Did you, in the course of your duties, ever have to respond to a

3 person who was the victim of a crime by some of these people, perhaps

4 beaten up, perhaps shot? Did you ever have to carry one of those people

5 to the Visegrad Health Centre?

6 A. I did, from Osanice. A woman came who had a bullet wound in

7 her nose. She was treated and discharged. Then I drove some people to

8 Priboj. The doctor would tell me, "Drive them there." It was at my own

9 risk. I'd turn on the engine and drive them to Priboj. From Zepa, I

10 took two or three children from a boat. They came in a boat. They had a

11 white flag with a red cross on it, and I picked them up from the boat at

12 the Drina and took them from Uzice. A man from Zepa called Osman had

13 brought them in a boat.

14 Q. And those children were injured?

15 A. I think they were. That is why I drove them.

16 Q. In the course of your duties, did you ever have occasion to remove

17 deceased, dead bodies, that it was clear to you people had been -- had

18 died as a result of violence?

19 A. Not me. Other people did that. But I never did that. I

20 couldn't. It was not my duty anyway. It was not my responsibility to do

21 that.

22 Q. During the course of your duties driving around the street, did

23 you see dead bodies lying in the streets of Visegrad around this time

24 period?

25 A. Not in the streets. There weren't people in the streets. There

Page 2893

1 would be some near the river, on the bank of the Drina.

2 Q. And can you approximate for us about how many bodies did you see

3 lying on the bank of the Drina?

4 A. I would see a couple of bodies, sometimes five, sometimes two,

5 sometimes three, depended, ten.

6 Q. And can you give us an idea of when the first time you saw bodies

7 on the bank of the Drina was?

8 A. I think it was the beginning of June, May, end of May, beginning

9 of June, maybe July even.

10 Q. And can you approximate in total how many bodies did you see on

11 the bank of the Drina, less than 100, more than 100?

12 A. I couldn't say, but perhaps 100 even.

13 Q. Would it be fair for me to, or would I be correct in thinking that

14 of the injured people that you had contact with and the -- any of these

15 dead bodies that you were able to recognise, that predominantly they were

16 Muslims from Visegrad? Would I be correct in saying that?

17 A. Yes.

18 Q. Now, the bodies along the bank of the river, would people passing

19 by on the streets of Visegrad, let's say in the square, over the bridge,

20 would they have been able to see these bodies as well?

21 A. That depended. Sometimes the river -- waters of the Drina would

22 rise several metres and then they would go downstream. The water would

23 take them downstream when the river was high, so that's what would happen

24 mostly. But people were afraid, they didn't like to look. Perhaps

25 somebody would look but mostly people were afraid.

Page 2894

1 Q. But the point is, if somebody did want to look, they were easily

2 visible to people walking across the bridge or on the streets of Visegrad;

3 correct?

4 A. If somebody wanted to see on purpose, they could see. Anybody

5 could see, whoever wanted to.

6 Q. Now, you said that when the river would rise, the bodies would be

7 washed downstream. The water level of the Drina in this particular point

8 is controlled by the dam. It's not a function of rain, but it's a

9 function of how much water is released from the dam; is that correct?

10 A. Yes.

11 Q. So would I be correct in thinking that from time to time, somebody

12 went to the dam, released an amount of water that then flushed these

13 bodies down, away from the town? Would that be correct?

14 A. Yes. Well, there were people working on the dam, who worked

15 there. They were on duty there.

16 Q. Now, would I also be correct in thinking that in the course of

17 your duties, you had to cross the old Drina bridge many times a day?

18 A. Sometimes I had to, depending on the requirements. Sometimes I

19 would have to cross five times, sometimes not at all and sometimes even

20 ten times. It all depended. But we tried to save on fuel, so if there

21 wasn't any great necessity, I wouldn't.

22 Q. And when you crossed the old Drina bridge, did you ever see any

23 indications of violence on the bridge, perhaps blood stains, perhaps

24 broken teeth or articles of clothing? Did you see anything that indicated

25 to you that there were violent acts being committed on the bridge itself?

Page 2895

1 A. There was blood, but I didn't see any clothing or anything like

2 that.

3 Q. And would the blood that you saw, was it concentrated in the area

4 of what's called the sofa and it's the stone seat that is on the bridge?

5 Is that where you saw the blood?

6 A. Just on the sofa, around there.

7 Q. And did you see blood on the sofa of the bridge throughout this

8 period from May throughout the summer of 1992?

9 A. Well, from May to July.

10 Q. Did you, yourself, ever see any crimes being committed on the

11 sofa of that bridge?

12 A. I didn't see that. They did that mostly at night.

13 Q. Sir, without -- you don't have to tell us the exact address of

14 your house, but can you give us an idea of where your apartment or where

15 your home is with respect to the bridge?

16 A. It's 1.300 metres in the direction of the bridge, upstream. I

17 can't see the bridge from my house. You can't see the bridge from my

18 house. If you were to go up on to the roof, you would be able to see it,

19 so it's about 1.500 metres. My house is not turned towards the bridge.

20 It doesn't face the bridge. It's in a more densely-populated area.

21 Q. And finally, during this period of time during your travels as an

22 ambulance driver, did you see homes that you knew belonged to Muslim

23 people that appeared to you to have been looted and then burned?

24 A. There were belonging to individuals, there were some burnt houses,

25 but not in my street, not a single one was burnt in my street. When the

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Page 2897

1 war began, two Serbs houses were burned town, Pecikoza and Mica Savic, a

2 neighbour of mine, and then later on, Murat Sabanovic's house, in the part

3 where I passed by.

4 Q. Can you approximate for us the number of houses that you knew to

5 be Muslim that you saw burning or burnt down during this time period in

6 Visegrad?

7 A. Around me, no houses were on fire. Opposite me, the first house

8 next door was burnt down. I wasn't at home at the time. It's a house

9 that's 15 metres away from me, so my next door neighbour's house.

10 Q. Aside from your immediate neighbourhood, in the areas of Visegrad

11 that you travelled, can you approximate for us how many houses you saw

12 burnt down belonging to Muslims?

13 A. Later on, I saw some, but I didn't know. You would see some smoke

14 rising from somewhere, but -- well, five or six houses, maybe ten.

15 Opposite me, the street called Pionirska, I think maybe one or two over

16 there. I saw that they had burnt down later on. I don't know when they

17 were actually burning, but I saw the effects later on.

18 Q. Are you familiar with the school up on Pionirska Street, the

19 Karadzic school?

20 A. Yes. Two of my sons went to that school. I went to

21 parent/teacher evenings.

22 Q. Can you describe for us where your neighbourhood is or where your

23 house is with respect to that school? How far away from that school is

24 your house?

25 A. As the crow flies, about 600 to 700 metres, and the way children

Page 2898

1 go, the route children take, a little longer because you have to go

2 through town. You couldn't cut across the settlement. So as the crow

3 flies, it would be 500, 600 metres.

4 Q. Are you familiar with a small creek that runs parallel to

5 Pionirska Street, or perhaps a sewage ditch?

6 A. A creek, I have my part of the creek there, too. My property

7 borders on the creek, the upper part towards the end of the creek. I have

8 my -- what I inherited from my father, the piece of land that belongs to

9 me now.

10 Q. So if somebody were to walk directly across from the school and

11 reach that creek, if they walked along that creek, they would reach your

12 property, your house; is that correct?

13 A. To the left, 100 metres from the creek. Towards the end of the

14 creek, then 100 metres away is my house.

15 Q. Now, you say you saw two houses burning on Pionirska Street. Can

16 you give us an idea of when you saw those houses burning?

17 A. Up above, one was burning on the 1st of May. It belonged to a

18 neighbour, Ibrahim was his name, Hodza, and his house was alight on the

19 1st of May, not the others.

20 Q. And then the other house that you described as having seen burn,

21 when was that?

22 A. I couldn't say when the other one was burning. They are lower

23 down from me and I wasn't at home even my neighbour's house was

24 burning. My neighbours tried to put it out. Now, I know that somebody

25 had set the Hodza's house on fire. As to the other one down -- further

Page 2899

1 down, I don't know. I know where they are, but I don't know when they

2 were burning.

3 Q. The neighbour that was a Hodza, did he have a horse or own a

4 horse?

5 A. I don't know. He had a house in the countryside and he had a

6 house there and he would come from time to time, and I know that people

7 from Serbia, from Yugoslavia, would come by and he would read them things.

8 It's across the road from my house. Ten or fifteen people would come from

9 Serbia and he would look through some books for them, read something out

10 of some books. And he had a house in the countryside, in Dobovik, near

11 the village of Dobovik. His wife and my mother are next door neighbours

12 there.

13 Q. And how far away is this village where he had the country house

14 from where he lived?

15 A. Eight or nine kilometres.

16 Q. And how would you -- if I were standing at the school, at Karadzic

17 school, how -- what would be the quickest way for me to get to his country

18 house? Would it be to continue walking up Pionirska Street or to go back

19 down into the town?

20 A. You would continue up the hill. You wouldn't go back towards

21 town. Selo, Babin Potok and then Dobovic, that's how you'd go.

22 Q. Now, the second house that you saw burning on Pionirska Street,

23 could you give us an idea where that house is with respect to the school?

24 Could you help orient us as to where that house was?

25 A. In front of the school, 50 metres, 100 metres in front of the

Page 2900

1 school to the left, on the left-hand side.

2 Q. And was that house close to the creek?

3 A. Close to the street.

4 Q. It was close to the street?

5 A. Nearer the street.

6 Q. Do you know the name of the person that owned that house?

7 A. He was a policeman, Memic Mujo.

8 Q. And how did you learn about his house being burnt?

9 A. When I would go towards my own house, the street -- my street is

10 up above, his house is down below, and it's 50 metres away and you could

11 see it, and I knew where everybody's house was all over Visegrad.

12 Q. So did you actually see that house the night that it was set

13 afire?

14 A. No. No, I didn't see it then.

15 Q. Would it be fair to say that you first learnt of that house being

16 burnt when you looked down from your property and saw the house and saw

17 that it was burnt? Is that how you learnt about that house being burnt?

18 A. Yes. Yes.

19 Q. Now, I want to ask you a few questions about Mr. Vasiljevic. In

20 addition to giving a statement to Investigator Roy, you also gave a

21 statement to Mr. Tanaskovic; is that correct?

22 A. Yes.

23 Q. And that was in May of the year 2000; correct?

24 A. 4th of May, 2000, is when I gave the statement.

25 Q. Now, do you remember when you gave that statement to

Page 2901

1 Mr. Tanaskovic that you told him that Mr. Vasiljevic had proclaimed

2 himself to be the chief of hygiene in Visegrad. Do you remember telling

3 that to Mr. Tanaskovic?

4 A. No. Not chief of hygiene. I had my own chiefs of sanitary or

5 hygiene department.

6 Q. Let me read you a portion of that statement and see whether or not

7 it refreshes your recollection: "During the war, I saw Vasiljevic in

8 civilian clothes, with an arm band. He introduced himself as a chief of

9 hygiene in the town of Visegrad." Do you remember telling Mr. Tanaskovic

10 that?

11 A. Yes.

12 Q. Now, when you told that to Mr. Tanaskovic, was that based upon you

13 hearing Mr. Vasiljevic say, "I am the chief of hygiene," or was it based

14 on something that somebody told you?

15 A. I didn't hear Mitar say that, but I heard that he had been

16 assigned, I don't know how, but he was for cleaning the town.

17 Q. But you would agree with me that there's a difference between

18 somebody who is assigned to cleaning the town and somebody who is the

19 chief of hygiene for the town. There's a difference between those two

20 positions, isn't there?

21 A. Yes, but there wasn't anybody there. Had Mitar not cleaned it,

22 nobody would have cleaned it.

23 Q. But what I'm interested in is this title of chief of hygiene. How

24 did you come to learn or believe that he was the chief of hygiene?

25 A. That's what people would say, "Mitar is for the cleaning of the

Page 2902

1 town." And some individuals gave him that kind of title. People were

2 saying that.

3 Q. Now, when you spoke with Investigator Roy, you said something a

4 bit different. Do you remember saying to Investigator Roy that

5 Mr. Vasiljevic had proclaimed himself as mayor of the town? Do you

6 remember saying that to Mr. Roy?

7 A. Possibly, I might have said that, for hygiene, for the

8 cleanliness.

9 Q. So when you told Mr. Roy that Mitar Vasiljevic had proclaimed

10 himself mayor of the town, what you really meant was that he was in charge

11 of hygiene; is that what you're saying today?

12 A. Yes.

13 Q. And in the course of your travels around Visegrad during this

14 period, did you see Mr. Vasiljevic clean the town?

15 A. Yes, I did. And he would make the women and the men and everybody

16 to clean in front of their own store or house where they were, that they

17 should clean up in front of their own door because there were different

18 party posters stuck over walls and everywhere. There was graffiti, so in

19 one night you would have 100 new slogans written up, and he would tell

20 people to clean up. He told my wife to clean up. He told Ranko

21 Knezevic's wife and Bogdan Stanicic to clean up. He made him clean up,

22 too. When he was passing by, he said, "Sir, you have to clean up what is

23 in front of your place." So everybody did clean up. Nobody minded. They

24 would clean everything up nicely. It wasn't a threat of any kind or

25 anything like that, he would just tell them to clean up in front of their

Page 2903

1 own door.

2 Q. And approximately how many times did you see him engage in this

3 cleaning activity?

4 A. Well, whenever I would pass by in the car, almost daily, every day

5 when I would drive past. I didn't have much contact with anybody because

6 I didn't have time so my movements were restricted and I would have -- I

7 would pass by, but I would see him there in the centre whenever I passed

8 by.

9 Q. And can you give us an idea over what period of time did this

10 clean up occur, for one week, two weeks, a month? What was the period of

11 time?

12 A. Well, it lasted from as soon as the Yugoslav army left, and then

13 he saw to it regularly. He cleaned it regularly until he was injured and

14 had to go to hospital.

15 Q. Let me ask you, can you help us? You've testified about how you

16 took him to hospital. Can you help us, orient us regarding the time.

17 This fire at Mr. Memic's house, did that occur before or after you took

18 Mr. Vasiljevic to Uzice hospital?

19 A. I think it was after I had taken him, after that. Mitar went to

20 hospital first, and then that was afterwards.

21 Q. And can you approximate the time between the fire that you saw at

22 the Memic house and your taking Mr. Vasiljevic to the hospital?

23 A. When I took him, I came back at around 23 hours and the next day,

24 whether it was the next day or the day after, I saw that the house had

25 been on fire. I wasn't there when it was -- when it was set fire to, but

Page 2904

1 you know when you set fire to a house, the house smokes for the next three

2 days. There's smoke coming out of it. It was summertime. Nobody

3 bothered to put out the fire. It could even smoke for seven days. It has

4 sort of this -- it sort of goes on, it's a process, and I think it was

5 after that. I think that Mitar was transported first, transferred first.

6 Q. When you saw the house, was it smoking?

7 A. Well, I'm telling you some houses smoke for three days

8 afterwards. Nobody put the fires out. Well, the neighbours do so that

9 the fire wouldn't expand to them, catch theirs, but the -- the furniture

10 inside and the clothing or whatever is in the house can go on smoking for

11 days, three days or more.

12 Q. But what I'm asking you is this particular house, did you see this

13 particular house smoking when you first saw it?

14 A. I don't remember. I saw that the roof had burnt down, that there

15 wasn't a roof on the house.

16 Q. Is it possible that the house that you saw burning was set on fire

17 perhaps one, two, or even three days before the time you saw it? Is that

18 possible?

19 A. No. No.

20 Q. How many days before you saw it do you believe that the house was

21 set on fire?

22 A. Well, when I saw it, it was -- it could have still been -- it

23 might have been a day before. I didn't come home regularly. I spent the

24 night in the hospital. I took Mitar there, and I had somewhere to sleep

25 and have meals there, so I stayed there. And then when they would let me

Page 2905

1 have a day off, I would go back home and then come back. So but for 30

2 days, sometimes, I didn't go home. I could sleep there, wash there. I

3 had all the facilities over there.

4 Q. The night that you took Mr. Vasiljevic to the hospital, did you

5 sleep at the hospital that night?

6 A. Yes, when I came back.

7 Q. Do you recall if you slept at the hospital the night before?

8 A. Yes, because I couldn't leave the health centre. You never knew

9 when you would have a case, because there were only two drivers, so one

10 would go off somewhere and the other one would be there if the need arose.

11 Q. After you drove Mr. Vasiljevic to the hospital, when is the next

12 day that you were able to go home?

13 A. Well, I can't tell you exactly. I can't remember. I would go

14 when the doctors said I could go or I would ask, because it's only two

15 kilometres by car. Was it the next day or perhaps -- I don't know, to

16 visit my children. My children were small, they were 10 years old -- one

17 was 6, one was 8, actually. So I would rush back home to see if they

18 would need anything and that kind of thing. Sometimes I would go twice a

19 day, sometimes once, sometimes not at all. I could rush back. So I can't

20 actually say when I went home.

21 Q. So you don't know how many days went between bringing

22 Mr. Vasiljevic to the hospital and your next trip home; correct?

23 A. That's right. Because I had to drive some patients the next day.

24 Sometimes you would go three times during a day and night to Uzice and

25 back, I would keep going.

Page 2906

1 Q. Back to the cleaning for a moment. Do you remember telling

2 Mr. Roy that it was your impression that the people that were cleaning for

3 Mr. Vasiljevic, that they were scared of him? Do you remember telling

4 Mr. Roy that?

5 A. Well, I can't remember saying that, but they respected him. They

6 had to do the work when -- well, not that they had to, he didn't force

7 them in any bad sense, but it was good for all our health and for hygiene,

8 so it was a sort of citizen's duty to listen to him and to clean up.

9 Q. Well, let me read you a portion of that tape-recorded statement

10 and see if it does refresh your memory. "Really, people were scared of

11 him and they would do that, and the town was never cleaner."

12 Does that refresh your memory as to whether you told Mr. Roy that

13 you believe that these people were scared of Mitar Vasiljevic?

14 A. He would have a drink too many sometimes so he might have been a

15 bit bossy, "You have to do that and then you can go home." So everyone

16 considered this to have been an order.

17 Q. But you'll agree with me that that's somewhat different from

18 people being afraid of him, correct? Being bossed by somebody and being

19 afraid of them are two different things, wouldn't you agree?

20 A. Yes, but he had no weapon to threaten with or anything. But he

21 tried to make people see that it was their duty, but people were afraid of

22 everything, you could say. We were all scared. I don't know how I could

23 explain it to you.

24 Q. Well, what I'm interested in is what do you yourself observe when

25 you would see Mr. Vasiljevic and his cleaning crew? What did you,

Page 2907

1 yourself, observe that made you believe that these people were frightened

2 or scared of Mr. Vasiljevic?

3 A. Well, mostly women, including my own and others, one's house one

4 lives in and works in and it provides you with a living, and he would say

5 to her, "You have to clean it up." Then when he came back, he would see

6 that it was clean, and they had to do what they were told. And that was

7 the kind of fear I was referring to.

8 Q. You've told us that when he drinks, he would get a bit bossy.

9 Would it be possible that some of these people who were working for him

10 perceived his conduct when he was drinking as a bit aggressive? Would

11 that have been possible?

12 A. He would be a little more noisy, but he would never fight, or he

13 would be a bit lighthearted. He would speak more loudly. We men knew

14 his nature. He would sort of behave bossily but he wasn't dangerous.

15 Q. I want to ask you a bit more about your duties as an ambulance

16 driver. Can you give us an idea of, on average, how many calls would you

17 go out on a day during this time period?

18 A. It depended on the day. Sometimes two, three, five, ten because,

19 after all, most of the people had moved out. There weren't that many

20 inhabitants. The number of the population had gone down, so up to ten,

21 sometimes two, sometimes five, sometimes three. It depended on the day.

22 Q. And during this time period, I think you've told us that it was

23 possible for you to work every day, that you may not have had a day off

24 during the week; is that correct?

25 A. Sometimes after 20 days or a month. I was under work obligation,

Page 2908

1 and I wasn't allowed to move anywhere else. I had to be on duty, attached

2 to the medical centre nonstop. It could go on for three months.

3 Q. Now, during this time period, can you give us an idea of these

4 patients between two and ten per day, how many of them would you say were

5 Muslim patients, or were they predominantly Serb patients that you would

6 carry to the health centre during May, June and July of 1992?

7 A. As regards the patients, they didn't come to see me, they went to

8 see the doctor, and the more serious cases, by instructions from the

9 doctor, I would have to drive them somewhere else. Sometimes I would have

10 two, one or two to drive somewhere. Sometimes none. A lot of people came

11 for medication to see the doctor. There would be up to 50 people waiting,

12 depending how they felt. Most people were complaining of breathing

13 problems, heart problems. They would come on foot and using whatever

14 means they had to the medical centre.

15 Q. Would I be correct in saying that most of those patients were

16 Serb, they were not Muslims, during May, June and July of 1992?

17 A. Yes. Yes. In May, there were Muslims, but in June, Muslims no

18 longer came, in June and July.

19 Q. And would I also be correct in saying that of the people you

20 carried to the hospital during that period of time, by and large, most of

21 them were Serb as well?

22 A. In June and July, yes.

23 Q. Now, we've heard a great deal of evidence during this trial that

24 could lead us to believe that during the June and July of 1992, a large

25 number of Muslims were injured. Were you ever called to respond and carry

Page 2909

1 an injured Muslim to the hospital in Visegrad?

2 I'm sorry, could you repeat your answer a little louder? I don't

3 think it was picked up by the microphone?

4 A. I did not ever, never.

5 Q. And we know of at least two quite notorious fires in Visegrad

6 where people were injured and died. Were you ever called, perhaps as part

7 of a fire brigade, to respond to locations of two fires and to help

8 transport injured people to the

9 hospital?

10 A. I was not. I know that my colleague, I think he was killed, this

11 colleague of mine. He drove a little girl to Titovo Uzice.

12 Q. Let me ask you this, Mr. Savic: It seems from your testimony that

13 you've always been kind to Muslims. Would it have been safe for you

14 during this period to go out and to help an injured Muslim, perhaps one

15 that was injured by these paramilitaries you told us about? Would it have

16 been safe for you to go out and to transport that person to either

17 Visegrad hospital or Foca hospital or Uzice hospital? Would that have

18 been safe for you?

19 A. If I was driving alone to Uzice, it wouldn't be safe. I would

20 have to hide someone. If the doctor gives me instructions, but even he

21 didn't feel safe, so I did it on my own risk.

22 Q. I'm not as concerned as to where you might bring them as the

23 simple fact of was it safe for you to give assistance to injured

24 Muslims, Muslims injured by paramilitary activity or some other physical

25 violence during this time period? Was it safe for you to respond and

Page 2910

1 carry them?

2 A. It was not.

3 Q. And, sir, why was it not?

4 A. I didn't dare because I was as afraid as they were.

5 Paramilitaries would attack anyone. How can I prove who I am and who is

6 he and why are you doing this or that? And then I would be exposing

7 myself to danger, so it wasn't the same to me what would happen.

8 Q. Well, sir, am I correct in thinking that your ambulance is somehow

9 marked as an ambulance, it has a red cross and lights to indicate that it

10 is an ambulance?

11 A. Yes.

12 Q. And am I correct in thinking that you are now telling us that even

13 in a marked ambulance, you did not feel it was safe to go and render

14 assistance to Muslims injured by violence; is that correct?

15 A. I was never safe. There would be a rotating light; there was a

16 red cross. People got killed here near Rude, a doctor, a driver and a

17 nurse, they all got killed. They would shoot at them, too. It depends

18 what area you got into. Nobody paid attention to anything anymore.

19 Q. Mr. Savic, it seems that I can conclude from what you are telling

20 us that you were able to go out and render assistance to between two and

21 ten Serb people during this period, but that it was not safe for you to go

22 out and render assistance to any Muslims during this period. Is my

23 conclusion correct?

24 A. It is. In the street and in town, I couldn't.

25 Q. And my question to you now is: Why was it not safe for you to

Page 2911

1 give assistance to an injured Muslim?

2 A. There were people coming from the outside, people I didn't know,

3 and you couldn't negotiate with them. You couldn't say to them, "Look,

4 here, friend" - I don't even know how to address him - sir, gentlemen,

5 there's no explanation. He won't let you talk, he's just not interested.

6 They didn't care about us either. As the local people of

7 Visegrad, they didn't care. They didn't know people by name. I would

8 have to take out my ID to show them who I was.

9 Q. Mr. Savic, were you ever given an instruction through the health

10 centre or perhaps through some of the politicians or government people in

11 town, was an instruction ever conveyed to you that Muslim people should

12 not be assisted if they were injured during this period of time?

13 A. No. No. Never. No one ever said that we shouldn't assist. In

14 fact, the doctors felt we should assist everyone, and whoever came to the

15 health centre, the doctors would treat them and assist them.

16 Q. Did you know a person by the name of Behija Zukic?

17 A. I did. She worked with my brother in France for six years. They

18 were good friends and we were on very good terms.

19 Q. And were you familiar with the shop that she owned?

20 A. Yes, I was. She gave me vegetables sometimes. When my brother

21 came from Belgrade who used to be with her in France, she would give me

22 some vegetables to take to my mother because he helped her with the

23 documents in France. When she came to France, he helped her with the

24 administration and with the authorities, and we were on very good terms.

25 Q. And were you familiar with a red Volkswagen Passat car that she

Page 2912

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6

7

8

9

10

11

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

13 English transcripts.

14

15

16

17

18

19

20

21

22

23

24

25

Page 2913

1 owned?

2 A. Yes. I do know, of course.

3 Q. There's been testimony in this case regarding a day at which her

4 body was brought to the Visegrad health centre. Do you recall if you were

5 working the day that Mrs. Zukic's body was brought to the health centre?

6 A. No. I don't think it was brought there at all.

7 Q. Do you recall when she died?

8 A. I don't know when, but I heard that she had been killed.

9 Q. And who did you hear had killed her?

10 A. Probably whoever was driving the Passat.

11 Q. And who did you see driving the Passat after her death?

12 A. Lukic.

13 Q. How many times did you see him driving that Passat?

14 A. For two months, he drove it nonstop.

15 Q. Would it be fair to say that during that two-month period, you saw

16 that car just about every day?

17 A. In passing. In passing, yes, I would see it.

18 JUDGE HUNT: Mr. Groome, is it important to know which Lukic?

19 MR. GROOME: I'm sorry, Your Honour. Thank you.

20 Q. Can you tell us the first name of the Lukic who you are referring

21 to now? Was it Milan Lukic?

22 A. [No audible response]

23 Q. I'd ask you to answer verbally so the --

24 A. Yes.

25 Q. And did you ever see --

Page 2914

1 A. Yes, Milan Lukic. Milan Lukic.

2 Q. And did you ever see Sredoje Lukic driving in that car as well?

3 A. No.

4 Q. Did you ever see Mitar Vasiljevic driving in that car?

5 A. Mitar never drove a car, nor did he ever drive in that car.

6 Q. Let me correct -- I mean, did you ever see Sredoje Lukic as a

7 passenger in that car?

8 A. I didn't. He may have been, but I didn't see him. He drove

9 another car, Sredoje did.

10 Q. Mr. Vasiljevic has told us about at least one occasion on which he

11 was in that car. Did you ever see Mr. Vasiljevic driving or as a

12 passenger in that car?

13 A. I did not. I didn't see him. I didn't see Mitar in that car.

14 Q. Would I be correct in saying that the Muslim population of

15 Visegrad was very fearful about that car?

16 MR. GROOME: The witness is indicating he's not hearing anything

17 through his headset.

18 A. Yes. Yes, they were indeed afraid. People fled from it.

19 Q. And can you tell us why people were afraid of that car?

20 A. I heard he would pick up people at night in that car and take them

21 off somewhere, where, I don't know.

22 Q. And was it your understanding that these people would then

23 possibly be killed?

24 A. Yes.

25 Q. Possibly be raped?

Page 2915

1 A. I don't know about that. I had my own suspicions that those

2 people might be killed. Everyone was afraid. I didn't see women, but I

3 did see people -- men being afraid.

4 Q. Did you hear that some of the people that were taken away in that

5 car were tortured?

6 A. I did not.

7 Q. Now, you've just told us about your own suspicion regarding what

8 happened when people were taken in that car. You seem like a very

9 reasonable person. Can you tell us upon what you base that suspicion?

10 Can you think of -- what did you actually see or hear that made you

11 suspicious of what would happen to people in that car?

12 A. He didn't care much about those people. That's why he picked them

13 up, I suppose. He picked them up to eliminate them. Surely, he didn't

14 take them out for lunch. I never saw anything like that in my life.

15 Q. The times that you saw him pick up these people, was Milan Lukic

16 armed with a weapon?

17 A. He always had an automatic rifle.

18 Q. Can you tell us when was it that you first became aware that this

19 red Passat and Milan Lukic were involved in this kind of conduct that

20 you're describing, taking people away and liquidating them? When did you

21 first become aware of that fact?

22 A. Almost immediately after the Yugoslav army left. Maybe it was the

23 beginning of June.

24 Q. And would you say that it became general knowledge in the town of

25 Visegrad that this red Passat was being used to take away people and

Page 2916

1 liquidate them?

2 A. Well, yes. Yes. As soon as I saw him driving it -- what he did,

3 I don't know, I didn't like to look. I didn't have occasion to look and

4 watch. But it's been proven now that that is what it was.

5 Q. Would I be correct in thinking that by the beginning of June, most

6 of the Serbs in the town of Visegrad were aware that this red Passat was

7 being used in this manner?

8 A. At first, the Serbs, too, feared him because he did these things

9 mostly at night, sometimes in the daytime, too, and every reasonable man

10 avoided it.

11 Q. Was it true that during this period of time after the JNA left,

12 that people would discuss this, perhaps at work, perhaps in coffee, cafes,

13 after work, that people would discuss what Milan Lukic was doing in the

14 town of Visegrad?

15 A. I don't know that. It depended on what people said. Everyone was

16 responsible for himself and it was difficult for anyone to understand

17 that this was possible.

18 Q. Let me ask you this: Your suspicions of what happened with this

19 car, did you discuss that with any of your colleagues at work?

20 A. No, we couldn't. I don't know how to explain it to you. People

21 found it strange. People couldn't dream that any such thing was

22 possible. One didn't know what was going on. We didn't dare. These

23 people didn't care who was who or anything.

24 Q. Let me ask you this: Would you have been surprised if, after the

25 beginning of June, you met somebody who lived in Visegrad and worked in

Page 2917

1 Visegrad and they didn't seem to know about what Milan Lukic was doing

2 with this car? Would that strike you as odd?

3 A. There are people that don't know, quite a lot of them were there

4 and I wouldn't be surprised if half of them didn't know.

5 Q. I want to now draw your attention to the day that you responded to

6 a call for help in the square in front of the Visegrad Hotel. My question

7 to you is: When you arrived in front of the hotel and you saw

8 Mr. Vasiljevic, was it clear to you from the very beginning that

9 Mr. Vasiljevic had fallen off of a horse?

10 A. Yes. Yes. That's quite certain. I claim that. I think the

11 horse was standing somewhere, but I just sort of registered that the horse

12 was somewhere there.

13 Q. Do you recall any details of the horse?

14 A. I don't know. I don't know any details, how, when, where. I just

15 know that it was there. That's all I can remember.

16 Q. And correct me if I am wrong, but your recollection is that

17 Mr. Vasiljevic had on civilian clothes on that day; is that correct?

18 A. Yes.

19 Q. And that -- so from the very first moment you arrive, it's clear

20 to you that Mr. Vasiljevic, dressed in civilian clothes, is injured when

21 he falls off a horse in the middle of the town; correct?

22 A. That's what people told me, and we joked a little about it because

23 this was a mayor and this was Mitar, you know, and we made fun of the

24 whole thing a little.

25 Q. During the time that you are there and assisting Mr. Vasiljevic,

Page 2918

1 no one ever comes up to you and says, "Mr. Savic, Mr. Vasiljevic was

2 injured on a battle field." Nobody ever said anything to you of that

3 nature; is that correct?

4 A. No, no one.

5 Q. Now, yesterday, I believe you described the shirt that he was

6 wearing as a dark shirt; is that correct?

7 A. People wore different clothes that I drove around, so I -- there

8 are different clothes, but I gave this matter some thought today and I

9 think it was dark clothes. His uncle's son had got killed, and I think he

10 wore dark clothes -- because really, it's hard to remember. I don't know

11 what I was wearing the day before yesterday. I know what I wore yesterday

12 but not the day before.

13 Q. I want to ask you or recall for you a portion of the statement

14 that you made to Investigator Roy and see if that changes the answer that

15 you are giving us now. "If I can remember correctly, it was some very

16 colourful T-shirt and some normal trousers."

17 Do you remember telling Investigator Roy that on that day,

18 Mr. Vasiljevic was wearing a very colourful T-shirt?

19 A. I may have said that because I know in civilian clothes, he had a

20 T-shirt and a short windbreaker like this one, the one I am wearing. He

21 never wore anything long. He always wore a short jacket, a leather jacket

22 or something like this. But at the time, it was summer but it was

23 overcast and raining.

24 Q. Sir, just so that the transcript records what you are wearing, I

25 will describe it and maybe just tell me if I've described it correctly.

Page 2919

1 You are wearing a -- what appears to be a light jacket which comes down to

2 about your waist. It has long sleeves and it has a collar on. Would that

3 be a correct description of what you're wearing now?

4 A. This is sports clothes, casual clothing, you know, the same length

5 as this. And at the time, he -- as a waiter, he used to wear a normal

6 suit jacket and a suit and a white shirt when he was on duty, but when he

7 was not working, he would wear casual clothes like this, but short, a

8 short jacket like mine.

9 Q. Sir, just so we document what your jacket looks like, the

10 description that I just gave regarding it, would you agree that that's a

11 correct description of your jacket?

12 A. We call these jackets sports jackets, like this. Short ones.

13 JUDGE HUNT: Mr. Groome, it may be a foreign expression, but I

14 would call it a wind cheater.

15 MR. GROOME: I'm just trying to document the length.

16 JUDGE HUNT: Yes, the witness agrees with that.

17 A. Windjammer, yes.

18 MR. GROOME:

19 Q. Would you agree with me at least that it comes down to your

20 waist? Can we agree with that much before the break?

21 A. Yes.

22 Q. And it has long sleeves?

23 A. Yes.

24 MR. GROOME: Thank you.

25 JUDGE HUNT: We'll resume again at 11.30.

Page 2920

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

2 --- On resuming at 11.33 a.m.

3 JUDGE HUNT: Mr. Groome.

4 MR. GROOME: Thank you, Your Honour.

5 Q. Mr. Savic, just one or two more questions about what you recall

6 about Mr. Vasiljevic's dress that day. Do you remember him wearing an arm

7 band at this point in time when you first arrive and he's fallen off the

8 horse?

9 A. A red band. It was just a plain band, nothing on it, I don't

10 know what arm. I think it was the right that he had this band or ribbon

11 around here like this.

12 Q. And you've just indicated your right arm and above your elbow, in

13 the area of your bicep; is that correct?

14 A. Here, above the elbow, yes.

15 Q. And do you recall what colour that was?

16 A. Red.

17 Q. Now, did he appear to you, when you arrived, did he appear to you

18 to be drunk?

19 A. Yes, he was, a little. He wasn't actually "drunk drunk" like when

20 you're really drunk, but he was tipsy, judging by the way he was talking

21 and making a noise.

22 Q. When you say judging by the way he was talking, were his words

23 somewhat slurred; is that what you mean?

24 A. Well, they were clear, but loud.

25 Q. And when you spoke to him, was he able to describe for you how he

Page 2921

1 was injured and where he was injured?

2 A. I found him there. I don't usually ask people, I just ask people

3 to help me and to transport the patient as soon as possible. Possibly, he

4 was saying something but I don't remember. I know that he called me

5 "Zile," "What's up, Zile?"

6 Q. Other than that, do you recall having any other conversation with

7 him before you put him into the ambulance?

8 A. I don't remember. Mostly they're behind my back. There is a

9 partition between me, the driver, and the people behind, so whether he was

10 talking or what he was saying to the people that helped us, I don't know.

11 Q. Now, the people that helped you put him into the ambulance, can

12 you tell us the names of the people you recall helping you?

13 A. Well, I can't remember now, but I know that Pero was there,

14 Mitrovic, Pero Mitrovic, and the others who were with him, I don't know

15 whether somebody else I know was there, I can't remember because, you

16 know, lots of things have passed through my head since that time, lots of

17 people, lots of things.

18 Q. Do you know a person by the name of Ratko Simsic?

19 A. Yes, a teacher.

20 Q. And do you recall whether or not you saw him there at that time?

21 A. He wasn't there beside me. He wasn't there at all.

22 Q. Now, the drive from where you found Mr. Vasiljevic to the hospital

23 is a relatively short drive; is that correct?

24 A. Yes, two, three minutes.

25 Q. It's essentially just across the old Drina bridge?

Page 2922

1 A. Across the bridge and then another 300 or 400 metres.

2 Q. Now, when you arrived at the hospital, I would imagine that some

3 of the nurses or some of the doctors would have asked you what kind of

4 case you had and you would have responded you have somebody that fell off

5 a horse. Would I be correct in thinking that?

6 A. Yes.

7 Q. Do you remember specifically who it was that you told what the

8 condition of Mr. Vasiljevic was and how he got into that condition?

9 A. I told the nurse who was there, I don't know who it was, I know

10 that Goran Loncarevic, the doctor came down and while he was on the spot,

11 on the stretcher, he looked at him and concluded that the leg was broken

12 and then sent him further on. There were two or three young men who took

13 up the stretcher and took Mitar off to the, I think, X-ray department, but

14 I didn't actually go upstairs to see, but you have to carry them up the

15 steps 50 metres or so where the X-ray department is.

16 Q. Did you tell the nurse that you've referred to that you had

17 somebody who had fallen off a horse? Did you tell that nurse that fact?

18 A. Yes. Yes. We told her that, and the doctor that, too.

19 Q. And that's Dr. Loncarevic. You told Dr. Loncarevic that you had

20 somebody who fell off a horse; correct?

21 A. Yes. Yes.

22 Q. Now during this time period when you are transporting people, is

23 it true that you just transport civilians? You aren't working for the

24 Territorial Defence transporting injured soldiers, were you?

25 A. Well, I did transport wounded soldiers that came in from the field

Page 2923

1 up to the health centre and they would give them to us. We had two old

2 cars, a bigger van, which could accommodate an intravenous drip and so on

3 and, if necessary, a nurse and a doctor could accompany the wounded

4 person, and we used the kombi van where we would set up this drip and

5 soldiers would go to Uzice in that, regardless.

6 Q. But am I correct in saying that as far as transporting soldiers

7 injured on a battle field to town, there was a special unit that did that?

8 A. There was a special unit and a driver on the battle field, but I

9 would be assigned to the field, too, and if it was closer, if it was

10 quicker for me to get to the wounded person from town, then I would do

11 that, too. I would see that first aid was administered and then take them

12 further on to hospital. So I did that sometimes if I was closer.

13 Q. When you say that you would see to it that first add was

14 administered, would you, yourself, administer the first aid to soldiers?

15 A. No, no. There was a team of nurses and they would be on duty

16 assigned, five nurses, and it was their duty to see to all that. The

17 doctor would tell them what to administer, whether an intravenous drip or

18 painkillers, or whatever, and if there was a fracture or an injury, then

19 they would have to stop the bleeding and bandage the wound, put them into

20 the vehicle, pack them up and send them off, depending on the need.

21 Sometimes it would just be a nurse, nurses, sometimes a doctor, depending

22 on how serious the case was.

23 Q. And can you approximate for us how many times were you called to

24 do this duty, to go to the front line and transport injured soldiers?

25 A. Well, I can't give you an exact number. In a year, perhaps 20, 50

Page 2924

1 times in a year, depending who was closest, and then some vehicles would

2 break down so one vehicle would start off and break down. They were all

3 old. And then another car would have to come and take over.

4 Q. Now, while Mr. Vasiljevic was getting his leg X-rayed, did you go

5 out on other calls or did you remain at the hospital?

6 A. It depended. I think that day, I did go off somewhere because we

7 received information that somebody who was wounded was to arrive. So I

8 waited at least two hours, more than an hour, perhaps two hours, and while

9 he was having his X-ray done -- we have an old X-ray machine and you have

10 to do it all by hand. You have to have a solution which has to be heated

11 up, everything has to be dried by hand. It was an old X-ray machine. You

12 have to hang the x-rays up with clothes pegs, with pegs, and then it took

13 time for the X-ray, the negative to dry. So it all lasted a long time, an

14 hour, two hours.

15 Q. And where were you waiting, in the hospital or in the health

16 centre?

17 A. It's the health centre, the clinic. You wait there. It wasn't

18 the hospital. You wait there and then, if they have other work to do --

19 Mitar wasn't as urgent so I didn't have to take him off straight away, and

20 we'd take care of the fuel and waited to see if anybody else needed to be

21 transported, so that we didn't transport one person at one time if it

22 wasn't too urgent because there was a shortage of fuel. And the tyres

23 were not very good. I had a burst tyre hundreds of times.

24 Q. Now, did there come a time when you learnt that both legs or both

25 bones in Mr. Vasiljevic's leg were broken?

Page 2925

1 A. I think that was -- that is what the doctor said, that both, as

2 they call them fibula and the other one, that both bones were broken. I

3 think that's what was said.

4 Q. And did you hear the doctor say that?

5 A. I think Goran Loncarevic was there and that he said it. He said

6 it before the X-ray. He said that there's a fracture, two fractures of

7 the leg. He touched it. He examined it with his hand and he saw that

8 there was a fracture.

9 Q. You've described for us how X-rays are made in the health centre.

10 Did you actually see the X-rays that were made of Mr. Vasiljevic's leg?

11 Did you see them put up on any kind of reading machine or on a table

12 somewhere? Did you actually see the X-rays yourself?

13 A. I didn't see them. I didn't see the X-rays. And usually, the

14 X-rays are given to the patient to take with him so that in Uzice,

15 sometimes in Uzice they would repeat the X-rays, have them X-rayed again

16 sometimes.

17 Q. Can you tell us, are all broken bones treated in Uzice or Foca or

18 are some broken bones treated at the health centre? In other words, do

19 the doctors ever put on a plaster cast for some broken bones in the

20 Visegrad Health Centre?

21 A. Yes, in Foca or Uzice. Every fracture, because we don't have an

22 orthopaedic specialist so nobody wants to take the -- assume the risk and

23 take the responsibility.

24 Q. Now, is it the practice that when a patient is going to be

25 transferred from Visegrad to one of the other two hospitals, either in

Page 2926

1 Foca or in Uzice, that a referral letter is prepared by the medical staff

2 in the Visegrad Health Centre telling the other doctors or the hospital

3 what exactly they have determined is wrong with this person?

4 A. I don't go without a referral letter. A referral letter is always

5 written. They were two republics, you see, before the war and now. Now

6 they are almost separate states but they were always separate so it was on

7 the basis of the referral letter that they would see to the costs and

8 expenses, how many days in hospital, the number of the insurance booklet

9 and everything else. That's what it says. So I would drive them off with

10 the referral letter, and it says what ward, what department. And this is

11 a document for me, the main document for me.

12 Now I do things differently. I write down the facts now, but at

13 the time, I didn't write anything down and it was the referral letter that

14 was used for everything, all the information.

15 Q. And this referral letter, is it a standard form that is available

16 at the health centre that somebody fills out or is it just a doctor or

17 nurse picks up a blank piece of paper and writes out a referral?

18 A. The form, it's a form, and you enter everything in, the name,

19 Mitar Vasiljevic, the time, where he works, where he is employed, the code

20 for the type of work he does, the code for the patient, everything. It's

21 a form with everything, all the information needed.

22 Q. And with all the information needed, would that include the time

23 and the place that a person suffered an injury?

24 A. No, just from the time he is admitted onwards, not before, and

25 there is a protocol, a book, a register where the diagnosis is entered and

Page 2927

1 where he was sent to, the protocol that stays in the clinic or health

2 centre.

3 Q. Is there a copy kept of this referral letter?

4 A. No, because everything is entered into the protocol, that is to

5 say, the doctor, if he gives therapy, gives a prescription, for example,

6 injections, and then the nurse would enter this into the protocol, the

7 date, the time, on such and such a date, Mitar Vasiljevic was sent for

8 further treatment and so on. And that exists in a book and you can find

9 it now.

10 Q. Now you said a few minutes ago that you don't leave without having

11 this referral letter, and my question to you is: What did you do with

12 this referral letter when you arrived at Uzice hospital?

13 A. I give it to the reception desk, to the doctor. I give it to the

14 doctor at the reception desk in the hospital, in the larger health

15 institution, the hospital, and he looks to see what the doctor from

16 Visegrad wrote, and if he's not quite certain of something, he's not quite

17 sure, he would take him up to be X-rayed again. This was a referral for

18 the orthopaedics ward of Titovo Uzice and that's where it stays as their

19 own document. And on the basis of that document, they are able to

20 reimburse, be reimbursed to the institution that sent him and the health

21 fund.

22 Q. Would I be correct in thinking that if you brought a patient to

23 the Uzice hospital and you had no referral letter, that the hospital may

24 very well say to you, "We will not take this patient unless you have a

25 referral letter"? Am I correct in thinking that?

Page 2928

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8

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15

16

17

18

19

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21

22

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Page 2929

1 A. No, no, they would take them in, but somebody would then have to

2 send a referral letter as soon as possible. If I came across somebody, an

3 accident on the road, for example, and brought somebody in, I would, of

4 course, take the person in without a referral letter or without anything

5 and then somebody would send that in due course and the referral letter

6 would follow on afterwards, to say where he lay and so on.

7 Q. And is it your understanding that the referral letter is then kept

8 by the hospital, in this case, Uzice hospital, and made part of the

9 records of that patient's file? Is that your understanding of what

10 happens with this referral letter?

11 A. It stays there with them, yes. Yes. It stays in Uzice in the

12 hospital.

13 Q. Now, after you were given this referral letter, did you read it?

14 A. Well, not usually. Sometimes -- now they have sort of codes.

15 Mostly it's all in code, the diagnosis. They have numbers designating

16 what the patients are suffering from because there's some serious

17 illnesses which the patient himself is not always told so they write it

18 down in code, using numbers. And I rarely read it but I just saw it said,

19 "Mitar Vasiljevic,

20 orthopaedics ward, Uzice." I hand this to the patients, too, sometimes

21 because I lose it sometimes so I say, "Well, here you are, you are the

22 patient, you look after it," because it's difficult for me to look after

23 it, looking after the patient, referral letter and all the rest. I

24 usually give it to the patient himself.

25 Q. Do you recall or do you remember anything at all about what the

Page 2930

1 diagnosis said on this referral form?

2 A. Well, the doctors write down -- I don't know what they do, they

3 usually say "fracture," which means break. That's what they usually say.

4 When there is a break, bones broken, it says "fracture." I can't remember

5 what else it said but I remember that the word "fractura" is on it.

6 Q. Now, I want you to tell us how you drove out from the Visegrad

7 hospital on the way to Uzice and did you drive back across the bridge and

8 into the square where you originally picked up Mr. Vasiljevic?

9 A. I once again went via the old bridge and Miloje Novakovic, who

10 was the head accountant in our company, asked me -- he said that he had to

11 have a check-up and would I take him. There was something wrong with his

12 eyes and he wanted me to take him to see the internal medicine

13 specialist. So I crossed the bridge and stopped at the second bridge

14 where Novakovic lives because he had called me, and I picked Miloje

15 Novakovic up. He sat next to me. Mitar was lying on the bed, and we went

16 off together. The road wasn't very safe because it was wet, so we had to

17 go slowly and Mitar didn't insist that we should -- that I should drive

18 fast.

19 Q. The bridge that you picked up Mr. Novakovic, is that the bridge

20 over the Rzav river or the other -- the new bridge over the Drina? Which

21 bridge did you pick him up by?

22 A. No, the Rzavski bridge. He lives there. His flat belongs to the

23 Privredna Banka, Sarajevo.

24 Q. And you say that he called you at the hospital and asked for a

25 lift up to his appointment; is that correct?

Page 2931

1 A. No, I called him to come with me for my own safety and security,

2 and he had a check-up in hospital that he was due for. So I called him

3 when I was about to leave. I said, "Wait for me. Come out of your flat,

4 be waiting for me in front of the building," and that's what he did. He

5 was waiting for me and he got in and sat beside me.

6 Q. Did he have a weapon on the trip?

7 A. I don't know what you mean, who you're referring to.

8 Q. Mr. Novakovic.

9 A. No, no, he never had a weapon. He was an elderly man. He had a

10 work -- he never had a weapon of any kind, perhaps personal -- no,

11 nothing, no weapons. Because you couldn't take weapons into Serbia.

12 Q. Did you have a weapon?

13 A. No, I didn't.

14 Q. Why was it you felt safer with an unarmed person in the car? How

15 did that make it safer? It seemed that you told us before that you were

16 afraid that the car could be shot at. How was an unarmed person able to

17 protect you or make you feel safer?

18 A. I always insisted -- well, I left it to God and destiny. There

19 was no chance of me doing anything from the vehicle or protecting myself.

20 That's the -- what the terrain is like, and you don't need weapons. If

21 someone wants to shoot and kill you, well -- so I didn't need it for that

22 part. He would stand by the bank and I would drive on. There was nothing

23 I could do anyway.

24 Q. Now, you say that Mr. Novakovic had a check-up for his eyes. Do

25 you know what time his check-up was scheduled for up at Uzice?

Page 2932

1 A. Well, every ward had a physician on duty, an eye doctor, an

2 internal specialist, so they would see you. They would examine you

3 whatever time you came. There would always be a doctor, specialist on

4 duty to examine you.

5 Q. Now you told us yesterday that the ambulance stopped in Vardiste.

6 Can you tell us, how long did the ambulance stop there?

7 A. Vardiste, it was Mitar Vasiljevic's uncle, his mother's brother.

8 His mother's brother. And he asked us, he said, "Stop by my uncle's, I

9 feel cold." And me and Novakovic got out there. We had a refreshment

10 drink, a juice or something, and I think the lady took Mitar something to

11 refresh himself into the vehicle. He didn't move out of the vehicle. She

12 covered him with an extra blanket so he felt warmer.

13 Q. Now --

14 A. And, well, we were there about 20 minutes.

15 Q. Now, I want to ask you a question or two about the general

16 practice in Uzice, and am I correct in saying that when -- there was a

17 specific department in Uzice responsible for receiving new patients, and

18 in that department, there is a doctor and nurses and other medical staff

19 assigned for that purpose, to receive in new patients and to make some

20 determination of about where they should go to be treated. Am I correct

21 in saying that?

22 A. Yes. When you reach the admissions area, there are five nurses

23 and two men to carry patients to the wards, and a doctor who admits the

24 patient. And then whatever he cannot do, he sends on to the different

25 wards, where there are specialists and where they establish what it is.

Page 2933

1 He would call the doctor from the ward and then the nurses have to prepare

2 the patient, change them into pajamas and do everything else, and once the

3 patient has been admitted, then they take him to the ward that he should

4 go to, according to the diagnosis.

5 Q. Now, in looking over your statement last night, it seems that in

6 this particular case, the case of Mr. Vasiljevic, that when you arrived at

7 the hospital, he asked you not to bring him to this admissions doctor but

8 instead asked you to contact a specific doctor, a doctor that he knew. Is

9 that correct?

10 A. Yes. He asked for this man who comes from our area. He was born

11 in Visegrad. He specialised over there. And it happens even today, that

12 people like to see him. They look for Aleksander Moljevic, a doctor who

13 came down and admitted him.

14 Q. And when you say he was from Visegrad, how long -- well, sorry,

15 was he from Visegrad, was he born there?

16 A. Born in Visegrad. His mother is a teacher. His father, I think,

17 a locksmith.

18 Q. And did he work in the Visegrad Health Centre for sometime?

19 A. He worked with me in 1984. On the 27th of September, we started

20 working together, on the same day. He couldn't obtain specialisation and

21 we applied all over Yugoslavia for him and, finally, he was granted a

22 specialisation course in orthopaedics at Uzice and I think he went to work

23 there maybe in 1980. He didn't stay here long. He went off to Uzice and

24 he completed his specialisation in Belgrade and he worked there.

25 Q. I just want to clarify the dates. You said that he began work in

Page 2934

1 September of 1984. Can you give us the year that he left the Visegrad

2 Health Centre?

3 A. I don't know exactly, but he didn't stay for more than a year or

4 two, and then he left.

5 Q. And after Dr. Moljevic left, would he ever come back and perhaps

6 see patients that were friends in the Visegrad Health Centre, perhaps to

7 save them a trip up to Uzice? Would he ever do that?

8 A. No, they went to see him and he would schedule check-ups for them

9 to come to Uzice and they had to go there.

10 Q. I don't want you to get Dr. Moljevic into trouble, but would one

11 of the reasons be that patients from Visegrad asked to see him would be

12 that perhaps if there was a long queue or line at the admissions

13 department, he might be able to help them get there -- get themselves seen

14 by a doctor a little bit quicker? Would that be one of the reasons why

15 people would ask to see Dr. Moljevic?

16 A. That was one reason, but he's also a very good doctor. People

17 have a great deal of confidence in him.

18 Q. So after Mr. Vasiljevic asks you to see if you can find

19 Dr. Moljevic, do you go and find Dr. Moljevic? Is he working that day?

20 A. It's done by the nurses, by telephone. They have a telephone

21 exchange. They called him up, and usually they would meet the patient's

22 request. I couldn't intervene for everyone; I had enough to do over my

23 head, anyway.

24 Q. But you did intervene in this particular case. You did seek to

25 have Dr. Moljevic come and be the doctor that admitted Mr. Vasiljevic into

Page 2935

1 the hospital in Uzice; correct?

2 A. Yes, because he was on duty at the orthopaedics ward just then.

3 Q. And when you transfer a patient from your custody into the custody

4 of the medical staff of Uzice hospital, do you make them sign anything

5 that they've received the patient or do they make you sign anything to

6 signify that a patient has been transferred into somebody else's custody?

7 A. Then, no, but now, yes. In Foca, and everywhere else, there's a

8 stamp of the admissions department and I have to stamp it. But in those

9 days, nobody asked for any such thing.

10 Q. Back in those days, was there some kind of report or some kind of

11 report or some kind of medical form that the medical staff would begin to

12 fill out as soon as the person arrives in the admissions department?

13 A. For every patient, the name, the name of the mother, the father,

14 who he lives with, his address, street, house number, everything, his

15 relatives, who his mother and father are, his wife, who he resides with,

16 and his address. All that is typed out, and the protocol stays there.

17 Q. Did you see Dr. Moljevic write any type of medical note or fill

18 out any form when he admitted Mr. Vasiljevic into the hospital?

19 A. That is done in the admissions. Then he goes to Moljevic and he

20 opens a document. We call it a temperature list, which is a form for

21 hospitalised persons indicating what he is given every day, a temperature

22 chart. Moljevic just initials a document saying that he has been admitted

23 to his ward.

24 Q. Now, travelling from Visegrad to Uzice, what is the minimum amount

25 of time that you, as an ambulance driver, can travel that distance from

Page 2936

1 Visegrad to Uzice, assuming that you have no obstruction, you're not

2 stopped at a checkpoint, and nothing happens. It's a direct, quick run

3 between the two. How long does that take?

4 A. If I have a good car and everything else is all right, one hour.

5 If there's a great emergency and there are no obstacles on the way.

6 Q. Now, after this day, this day that you brought Mr. Vasiljevic to

7 the hospital, you would go up and visit him when you were up in Uzice on

8 other business; is that correct?

9 A. I would go to see him. Sometimes relatives would give me

10 something to take to a patient, food or clothing or underwear or

11 something, and that's what I would do because people couldn't travel. So

12 I would always carry something to someone as I went if I was asked to take

13 something. They'd come to the health centre and ask me to do a favour and

14 I'd do it for them.

15 Q. Well, let me ask you in this specific case. You've told us that

16 according to your recollection or estimation, Mr. Vasiljevic was in the

17 hospital for about 30 days; correct?

18 A. I think more than that even. I didn't see him again until August

19 on crutches, so I am sure he spent more than a month and a half there

20 because I heard from doctors that he went to other wards, to the

21 neuropsychiatry ward.

22 Q. For the purpose of the next couple of questions, could I ask you

23 to just think about the first 30 days, the first month that he is in

24 hospital. My question to you is: How many times would you estimate you

25 visited him in that first 30 days?

Page 2937

1 A. Possibly three or four times.

2 Q. And the first time that you visited him during that 30 days, can

3 you give us an idea of how many days had gone between the day you brought

4 him and the day you first visit him?

5 A. It depended when I had a chance to go there. Maybe the first time

6 was after a couple of days.

7 Q. And then can you estimate for us when the second time would have

8 been? Would it have been a couple of days after that?

9 A. Maybe ten days after that. I would drop in. If there were

10 several patients there, I'd go around and see all of them.

11 Q. Now, Mr. Savic, isn't it correct that in the three to four times

12 that you saw Mr. Vasiljevic in that first month, you never saw traction on

13 his leg; is that correct?

14 A. I think the first time, he had it. Well, you see, I can't

15 remember everything. The ward is full of such cases. If I could remember

16 everything, I think he had a traction, the man next to him. I would visit

17 five rooms on one occasion, and I can't remember everything.

18 Q. Let me read a portion of an earlier statement that you gave, and

19 in describing what you remember, you say, "In a cast," and then Mr. Roy

20 asks you, "But no traction that you can remember?" And your answer was,

21 "No."

22 Do you remember telling Mr. Roy that there was no traction that

23 you could remember ever seeing on Mr. Vasiljevic's leg during the times

24 that you visited him?

25 A. I don't know. I may have said that, but I know when they use

Page 2938

1 weights, there's no cast. First they put on these weights or traction,

2 and after that, a cast. So once they stretch out the leg, it's only then

3 that they put on a plaster cast.

4 Q. But is it a fact that you told Mr. Roy that during your visits to

5 Mr. Vasiljevic, that there was no traction on Mr. Vasiljevic's leg that

6 you could remember? Didn't you say that to Mr. Roy just a few months ago?

7 A. I am afraid I can't tell you. I may have said that. I feel much

8 more at ease now than then. It was the first time I had any such

9 contact. I went to Sarajevo for the first time then.

10 Q. So what is your best memory today regarding whether or not

11 Mr. Vasiljevic had traction on his leg? Tell us what you believe to be

12 true today.

13 A. I think he did have traction.

14 MR. GROOME: Your Honour, at this time, I'm going to be asking

15 that the following document, and it's a pseudonym sheet, be marked as

16 Prosecution document 158 and that it be shown to the witness.

17 JUDGE HUNT: Is it going to become an exhibit?

18 MR. GROOME: Yes, Your Honour.

19 And Your Honour, there are a number of people that I will be

20 referring to in my questions to Mr. Savic who are not witnesses in this

21 case; however, I think it would be most prudent not to refer to them by

22 name, and with the permission of the Court I'd like to refer to them to

23 those numbers, 201 through 203.

24 JUDGE HUNT: Yes. Have you any objection to this being an

25 exhibit, Mr. Domazet?

Page 2939

1 MR. DOMAZET: No objection, Your Honour.

2 JUDGE HUNT: It will be Exhibit P158 and it will be under seal.

3 Before you proceed with this new part of it, you've dealt with a

4 lot of records that this witness would have had some access to and been

5 involved in. There's one set of records which I tentatively suggested to

6 Mr. Tanaskovic that I would be interested in hearing about. I can

7 understand, perhaps, why he didn't take up the suggestion, but there are

8 usually some sort of a record filled in when an ambulance is sent to pick

9 up somebody, the time of the call, where it happened, what it is that has

10 been reported, and I'm still interested in that. So at some stage,

11 whenever it is convenient to you, may I suggest that you ask some

12 questions about the various records because that might give us some better

13 idea of the time.

14 MR. GROOME: I'll do that now, Your Honour.

15 Q. Mr. Savic, as an ambulance driver, do you keep a log book or any

16 kind of record indicating what calls you go out on?

17 A. No, that was never asked of me during the war, in wartime.

18 JUDGE HUNT: I had more in mind what the ambulance station, if

19 that's the right expression, would have. That's what I had more in mind,

20 myself. And he would be handed something.

21 MR. GROOME:

22 Q. Can you explain for us the procedure of what occurs if -- if I

23 were to call Visegrad Health Centre in 1992 and say that I needed an

24 ambulance, who would receive that phone call, what department?

25 A. Visegrad, you mean?

Page 2940

1 Q. Yes.

2 A. The nurse on duty or the doctor, whoever is first to answer the

3 phone. There's the driver, the doctor, the nurse. If the doctor is busy,

4 somewhat else would pick up the receiver, the nurse.

5 Q. Now, is there a book or are there forms next to the phone that are

6 filled out when somebody calls up, where somebody would mark down the

7 nature of the call and information? Is there any such record?

8 A. No. These are short distances, and afterwards, a note is taken of

9 who has been brought in and so on. Once the patient is brought in, only

10 then. Even to this day, no one takes note of having sent me to any

11 particular place.

12 Q. Let's say you are out on a call and another call comes in for

13 help. When you come back, does somebody hand you a slip of paper or some

14 kind of note indicating that there is somebody else in need of help and

15 you should go to a specific location?

16 A. No. Again, if there's a call, I would just be told, "Go to such

17 and such a place and pick up the patient." I would be given the address.

18 That's all.

19 Q. And when you come back from a call, are you responsible for making

20 a note of where you have been and what patient you have picked up? Do you

21 write that down anywhere?

22 A. Now, yes, I write down house calls and things like that, but in

23 those days, I didn't write down anything. Even now, when I am going

24 further away, I have to write it down, but in wartime I never took note of

25 anything.

Page 2941

1 Q. Well, during this period of time, wasn't fuel for the ambulance --

2 wasn't fuel in general a very scarce item? Wasn't it very important to

3 make sure that no fuel was wasted?

4 A. Of course we didn't waste fuel, but it depended on the doctor's

5 orders. If you have the fuel, you had to go. We would get some fuel

6 somehow. I don't really know who got it. It was kept in barrels in the

7 health centre.

8 Q. But anybody who wanted to check whether you or other drivers,

9 whether you were using the fuel well, that is, just for official business,

10 are you saying that there was no piece of paperwork that they could refer

11 to, to see where the drivers were going to and when they went when they

12 took ambulances somewhere?

13 A. There was a kind of instruction, and you would just write down the

14 route, Visegrad to the health centre. You'd write down the number of

15 kilometres, departure, arrival. I think that must exist somewhere. This

16 was an instruction order telling me where to go, indicating just the

17 distance.

18 Q. Now, can you tell us more about that record? Where was that

19 record kept?

20 A. I kept it in the car and I have this document. It says the

21 licence plate of the car, the driver, my name, Zivorad Savic, and that a

22 route from the health centre Visegrad, for example, Dobrun. These

23 distances over five kilometres, you have to write down and the number of

24 kilometres covered.

25 Q. Can I take from your answer that distances less than five

Page 2942

1 kilometres you did not have to make a note of in this record that you're

2 referring to now?

3 A. I didn't. I didn't have to make note of that.

4 Q. And just to be clear, in this book that you're referring to now,

5 could we expect to find an entry indicating the trip you made to pick up

6 Mr. Vasiljevic on that day?

7 A. Possibly. Possibly that those records could be found somewhere,

8 but all that would be written would be the date and the route

9 Visegrad-Uzice.

10 Q. And would it include the name of the patient?

11 A. In my record, no.

12 Q. And where are your records from the summer of 1992 today?

13 A. I think in the Territorial Defence. I think they are all there

14 because they were mostly the ones who issued these instructions for the

15 medical section and these instructions would be sent back to them. Once

16 you fill out the chart with the fuel, you'd have to send it back to them.

17 Q. This record you're referring to, is it a form book or is it simply

18 a notebook? Can you describe with greater detail this record that you're

19 referring to?

20 A. It's like this, a two-fold piece of paper, where it indicates

21 about me, information about me, about the vehicle, 291-13 I think the

22 licence was of the Lada.

23 Q. Sorry 291-13, is that the number of the licence plate?

24 A. Yes.

25 Q. Now, this record, does it remain with the vehicle or does it

Page 2943

1 remain with the driver of the vehicle? Whose record is it?

2 A. It's for me, with me. In those days, we would pour fuel at the

3 petrol station.

4 Q. Apparently, the paper is making some noise. Could I just ask you

5 just to -- thank you.

6 So the transcript is clear, you've taken a piece of ordinary A4

7 paper and folded it in half to show us the size of this record you're

8 referring to.

9 JUDGE HUNT: Just one moment. I gather that the witness is using

10 the list that he has there and he's holding it up sometimes for himself to

11 read it and the camera can pick it up.

12 Please, sir, just try and keep that document where it can't be

13 picked up by the camera so they can't read what is on that document.

14 Sorry to interrupt.

15 MR. GROOME: Thank you, Your Honour.

16 Q. I was just asking you to confirm the size of this record that

17 you're referring to is the size of an A4 sheet of paper folded in half, is

18 that correct, approximately?

19 A. This size but double, another sheet of paper of this size. On one

20 page, information about the vehicle, the name and surname of the driver.

21 Q. And if you can help me clarify something here, if after your shift

22 is over and it's my turn now to use your ambulance or this ambulance to

23 transport patients, do I have my own form or do we both use the same

24 form?

25 A. Both the drivers are indicated in the same vehicle and we take

Page 2944

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Page 2945

1 down our own information. Even now, the two of us drivers, we have two

2 vehicles that we use and both our names are written down.

3 Q. And at the end of your shift, do you leave that piece of paper in

4 the ambulance for the next driver to use during his work?

5 A. Yes. Yes.

6 Q. How often do you take this piece of paper and turn it over to

7 somebody? Is it every week, is it when the paper is filled? When do you

8 give that paper to somebody?

9 A. When you fill it in with the information about fuel and there is

10 no more space for entries of routes, then I go to the petrol station and

11 then he gives me another form. These were people who were issuing fuel to

12 people with priority, and the health centre had priority. So I'd leave

13 this filled-in form at the petrol station for him to write out a new one

14 for me.

15 Q. And the person at the petrol station was a member of the TO, is

16 that correct, the person issuing the fuel?

17 A. Yes, she did belong to the TO. Now, whether it was the

18 municipality or whoever obtained the fuel and they kept records in this

19 way of the consumption of fuel with the routes indicated.

20 Q. And can you tell us the name of the person that you gave this form

21 to, the form that you would have had for the time period that you brought

22 Mr. Vasiljevic to the hospital? Can you tell us the name of the person?

23 A. There were three or four men working there, whoever happened to be

24 there. He would just write down my particulars and give me the new form,

25 take the old one. I don't know exactly who it was. There were five or

Page 2946

1 six of them working there in shifts. Now who happened to have been on

2 that particular day, I don't know. Maybe I didn't even drop by at the

3 petrol station on that day.

4 Q. And my final question regarding this piece of paper is: What did

5 it say along the top of it? Did this form have a name?

6 A. There was a stamp, the date when the document was issued, my name

7 and surname, Zivorad Savic, my colleague's name, his name, too, and then

8 below that, information about the vehicle, licence plates and so on, and

9 then how much fuel he has poured for me, and I write down the routes and

10 the distances I covered, the date of the trip and where I'm going. So

11 Visegrad-Uzice.

12 Q. If you needed another one of these forms, what would you ask for?

13 Would you ask for a fuel form, a vehicle form? Did this form have a name?

14 A. It was called "nalog," an order form for the medical.

15 Q. Now, besides this piece of paper, is there any other piece of

16 paper where a notation of any kind is made prior to a patient being

17 brought into the Visegrad Health Centre, could be for any reason?

18 A. No, just that piece of paper.

19 MR. GROOME: Your Honour, I think I'll move on if that's satisfied

20 the inquiry.

21 JUDGE HUNT: Thank you.

22 MR. GROOME:

23 Q. Now, we've given a piece of paper to you before, put a piece of

24 paper before you. I'd ask that you turn over that piece of paper and

25 just take a look at it.

Page 2947

1 Now, we're going to refer to the people on this paper. I'm going

2 to ask you a few questions regarding them. I'm going to ask that you,

3 rather than call their name, that you simply refer to them by their number

4 which is to the left of their name. So, for example, if you want to tell

5 us something about the first person on the name, you would simply say,

6 "VG81 said this or did that."

7 Do you understand how we will use this piece of paper,

8 Mr. Savic? I need to hear you say your answer.

9 A. I've understood, yes.

10 Q. The person whose name appears next to VG81, you know this person;

11 correct?

12 A. I do.

13 Q. I'm also going to ask you not to tell us -- I'd ask you to keep

14 the piece of paper on the desk because of the cameras. I'm also going to

15 ask you not to tell us any information about that person regarding where

16 they live or where they work unless we ask you a specific question

17 regarding that. So in order just to protect their identity.

18 Did there come a time earlier this year that you and several

19 people, including that person VG81, sat around a table and had a

20 conversation?

21 A. Yes, once with 081, person 081.

22 Q. Were any of the other people on that list present during that

23 conversation?

24 A. Yes, once when they called me but I don't remember their names,

25 although I know them by sight.

Page 2948

1 Q. And you said when they called you -- was it VG81 who called you or

2 one of the other people who you know by sight but don't know their name?

3 A. 81.

4 Q. And can you give us an idea of when this happened, when earlier

5 this year?

6 A. Well, I can't say exactly, perhaps in June. When they were down

7 there. I don't know. It was summer, anyway. Perhaps May.

8 Q. And did you go and meet with these people?

9 A. She called me, said there was a patient. Nobody had come before

10 then, and I went there and we sat down and there and had a cup of coffee.

11 Q. And approximately how long were you together with VG81 and these

12 other people? I'm sorry, how long were you with VG81 and the other people

13 whose names you did not know but you recognised? How long were you with

14 them?

15 A. Twenty minutes, the time it took to make a cup of coffee, drink

16 the coffee, and have a cigarette or two.

17 Q. The other people who were present, can you tell us how many

18 people, other people aside from VG81 were present?

19 A. A man and a woman.

20 Q. Did you have any brandy to drink with your coffee?

21 A. The others did, but I didn't.

22 Q. After this 20-minute conversation, what did you do?

23 A. I went out, went outside, and I was going to go home.

24 Q. Did this meeting occur in the home of one of the people who you

25 were there speaking with?

Page 2949

1 A. Yes.

2 MR. GROOME: Your Honour, at this time I'm going to make an

3 application. I'm going to ask that we -- the remainder of my

4 cross-examination, and this is kind of an unusual request, but may elicit

5 information that might cause some jeopardy to both the witness before us

6 as well as a Prosecution witness, so I'm going to ask if we could do the

7 remainder of my cross-examination in private session.

8 JUDGE HUNT: Have you had any conversation about this with counsel

9 for the Defence?

10 MR. GROOME: Mr. Domazet is aware of what I'm about to -- what

11 area I am about to embark in. I have not asked him his position on

12 whether we go into private session or not.

13 JUDGE HUNT: But he knows about the nature of the

14 cross-examination.

15 MR. GROOME: Yes, and has known about since the beginning of

16 trial.

17 JUDGE HUNT: What do you say, Mr. Domazet, about going into

18 private session to protect both this witness and another one?

19 MR. DOMAZET: [Interpretation] Your Honour, I have nothing against

20 moving into private session. If this examination relates to the

21 examination-in-chief, if it is linked to that, if that's what it's about.

22 JUDGE HUNT: You're talking in a code that I do not know the key

23 to, but is this what you're dealing with, Mr. Groome?

24 MR. GROOME: Yes, Your Honour.

25 JUDGE HUNT: Very well. Then we'll move into private session.

Page 2950

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21 [Open session]

22 JUDGE HUNT: We are now in public session. You may proceed,

23 Mr. Tanaskovic.

24 MR. TANASKOVIC: [Interpretation] Thank you.

25 Q. I'm asking you this because in the statement which you gave to

Page 2958

1 Mr. Roy, you make no mention of the wedding or your presence at any kind

2 of wedding. I'm going to quote from your statement, the statement you

3 gave to Mr. Roy and which relates to that portion, that piece of

4 information about the wife and it is page 4 of the B/C/S text. I don't

5 know what page it is in the English version and it says, "In passing, he

6 went ..."

7 JUDGE HUNT: Just one moment, I'm sorry. First of all, I have to

8 ask you: Is this relating to the video that we saw in private session?

9 Is it where you mentioned the wedding?

10 MR. TANASKOVIC: [Interpretation] Well, the wedding was before.

11 Now, this is something separate and later on on the tape.

12 Your Honour, may I explain? The witness said that he attended the

13 wedding at the Visegrad Hotel. He attended the ceremony where the accused

14 Vasiljevic was and Mr. Lukic, and now we would have to clear up whether it

15 was a wedding or a birthday or a christening or what it was.

16 JUDGE HUNT: Are you asking him questions about what we saw on the

17 video? That's a very simple question. Now, I've only heard about one

18 wedding so far from this witness and that was the wedding that we saw part

19 of on a videotape. Now, if you are going to ask questions about that, we

20 would have to be in private session if it's going to reveal anything.

21 That's why I'm asking you.

22 The second question I would put to you is: How do you get this in

23 by leading it? You can ask him whether he said something else unless

24 you are attempting somehow to demonstrate he has said something contrary

25 to what has been put to him by the Prosecution in cross-examination.

Page 2959

1 Would you like to consider this over the lunch hour and we'll come

2 back to it at 2.30? I don't want you leading. You can't lead in

3 re-examination, just as you can't lead in examination-in-chief, and if

4 it's new material, then you should ask him in the usual way. How it

5 arises out of cross-examination, I'm not sure, but that can be cured by

6 giving Mr. Groome the right to cross-examine him further. But you better

7 sort out what it is and whether we should be in private session when we

8 return at 2.30.

9 --- Luncheon recess taken at 1.02 p.m.

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Page 2961

1 --- On resuming at 2.28 p.m.

2 JUDGE HUNT: Now, Mr. Tanaskovic, is this material that should be

3 heard in private session?

4 MR. TANASKOVIC: [Interpretation] We would like to begin with the

5 tape that we just saw, so I think we should be in private session, yes.

6 JUDGE HUNT: Very well. Into private session, please.

7 [Private session]

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18 [Open session]

19 JUDGE HUNT: We are now in public session.

20 MR. TANASKOVIC: [Interpretation]

21 Q. Could you tell us or could you remember what you told Mr. Roy, the

22 investigator, in this connection or what you failed to tell him?

23 A. I didn't tell him anything in connection with the wedding. He

24 just asked me whether I had the videotape, I said yes, and I gave it to

25 him. He didn't ask me anything more about it.

Page 2965

1 Q. A moment ago, in answer to a question from Mr. Groome about the

2 cleaning, you said -- you told us what Mr. Vasiljevic was doing. Among

3 other things, you said that your wife, too, was also engaged in the

4 cleaning. She cleaned up in front of her shop, and so on. Could you tell

5 us whether your wife complained to you or to anyone else that she didn't

6 want to do that work, that somebody was forcing her to do it, maybe

7 Mr. Vasiljevic, or did she tell you that someone else may have complained,

8 someone else who was engaged in the cleaning job?

9 A. No one complained because if they weren't very busy inside, they

10 were all in favour of cleaning things. She never said, "Somebody forced

11 me." She didn't say anyone forced me, not Mitar or anyone else. People

12 considered this to be their duty.

13 Q. A moment ago you mentioned work duty. What does that mean for

14 you?

15 A. All of us were under work duty in our companies, which meant that

16 I had to be available nonstop. I couldn't leave my work place. You had

17 to sleep there and eat there. That is what work duty meant in one's own

18 company or enterprise.

19 Q. What you have just told us applied to those who were employed?

20 A. Yes.

21 Q. What about those who were unemployed, did they also have work

22 duty?

23 A. The people who were not employed, there was an agricultural estate

24 and it was their duty to spend one or two days a week to participate in

25 the sowing, the planting of fruit and vegetables. So that, too, was

Page 2966

1 covered by work duty, obligatory work duty.

2 Q. So they, too, were covered by this work duty?

3 A. Yes.

4 Q. In your understanding, what your wife and others were doing and

5 Mr. Mitar Vasiljevic together with them, could that be considered work

6 duty?

7 A. Yes. Someone had to take care of these things. Apart from

8 working at home, you had to go into the fields to collect the fruits and

9 vegetables, to plow the fields and things like that. There was a

10 timetable when various companies would go there by bus, mostly along the

11 Drina, Kosovo Polje, Musici. That's where people were taken to work in

12 the fields.

13 Q. From what you have just told us, would it be right to say that

14 what your wife and others were doing with Mitar Vasiljevic was also a work

15 duty?

16 A. Yes, that was considered work duty.

17 Q. In answer to a question from Mr. Groome regarding the name or the

18 function of the chief of the cleaning or the hygiene, in addition to

19 explaining that this title was used jokingly, I would like to ask you

20 whether you know whether officially there was such a position as the head

21 of cleaning in Visegrad?

22 A. There is the head of the SUP, of the police, and things like

23 that. Now, we only have the Naklinik [phoen] or head of SUP, that is the

24 police.

25 Q. So there's no head of department for hygiene as an official title?

Page 2967

1 A. No, it did not.

2 Q. Let me now ask you a few questions about those bodies that you saw

3 in the Drina in Visegrad. Do you know that there is a lake next to the

4 Visegrad hydropower plant?

5 A. Yes, there is a lake next to the hydropower plant in Visegrad and

6 there's another lake further upstream. There's the Bajina Basta lake. In

7 those days, the water level was low because there was fear that water

8 would be released and there was fear of flooding. I started talking about

9 that yesterday. Also in the summer, there was a drought so the water

10 level was rather low. The water level of the Drina was rather low.

11 Q. Why was the water level low, what were they expecting?

12 A. They emptied the Perucac Lake because Murat was about to release

13 the water and there was fear that this could cause flooding if the water

14 were released from the upper lake. So they didn't always have enough

15 water to fill the accumulation lake, the lower lake.

16 Q. When you were talking about the bodies, that you were referring to

17 the period prior to when Murat captured the hydropower plant, took control

18 of the hydropower plant?

19 A. I don't understand what you mean.

20 Q. Is it right to say that you saw those bodies before Murat took

21 control of the hydropower plant?

22 A. No, after.

23 Q. My question is: Why, then, would the water level be lower in view

24 of the reasons you gave?

25 A. Well, this was regulated by the power plant in Perucac. I don't

Page 2968

1 know these things, I have no knowledge about these things.

2 Q. In view of the fact that you are living in Visegrad, do you know

3 whether there were bodies in the other lake that you mentioned, the upper

4 lake closer to Gorazde?

5 A. Yes, there were. On one occasion, we saw people being nailed to

6 wooden boards and they came from the upper lake, which was not territory

7 controlled by the Serbs. It was coming from Gorazde, from up there.

8 Q. On the basis of what you just said, can you assert that the bodies

9 that you mentioned, that all those bodies were of people from Visegrad?

10 A. I don't know. In the upper lake, there would be no one from

11 Visegrad, there would be people from Gorazde.

12 Q. Let me go on to a more specific question. You do your best to

13 answer it. Would it be possible for bodies, when water is released from

14 the hydropower plant at Visegrad to reach the so-called lower lake, the

15 Perucac or Bajina Basta Lake?

16 A. I don't know. I know when the water was released at Visegrad,

17 that half the town was flooded but I don't know any details about water

18 regulation. I am not in that field. So maybe they release more water. I

19 saw an enormous amount of refuse, plastics, rubbish, and then they

20 release more water to take it downstream. You can see that even now when

21 there is an overflow of water. There must be some system of regulation.

22 Q. The example that you gave, could a similar process have been

23 applied regarding the bodies and could they have come from the upper lake?

24 A. Yes, yes, because they released the water every day.

25 Q. Thank you. You told us that in Vardiste, that is near the border

Page 2969

1 with Serbia, you stopped the vehicle and you visited Mr. Vasiljevic's

2 uncle?

3 A. Yes. Mitar insisted that we drop by at his uncle and aunt's, and

4 we stopped there.

5 Q. So you went to your coffee bar?

6 A. His uncle has been running a facility called Vesela Bosanka, or

7 the gay Bosnian lady.

8 Q. And this part of the road from Visegrad to Vardiste, what's it

9 like in terms of the landscape?

10 A. It's a mountainous part of the road full of bends and there were

11 mudslides and nobody cleared the road. There were a lot of curves and it

12 was wet, and anyway, it wasn't safe. It would be sufficient for someone

13 to fire one or two shots, and there were people who were killed right

14 along that part of the road. There were anti-tank mines and people were

15 killed there. Four men were killed stepping on an anti-tank mine.

16 Q. In the course of the cross-examination, you mentioned a hodza. I

17 think you said that he was telling the future or something?

18 A. Yes. People came from Yugoslavia, and he was a fortune teller or

19 something. I would see them visiting him.

20 Q. What was his name, the name of this hodza?

21 A. They called him Ibrahim Aga.

22 Q. Is that a Muslim religious leader or was he self-proclaimed, if I

23 can put it that way, a self-proclaimed imam or hodza?

24 A. He wasn't a real hodza. He would come on Fridays and Wednesdays

25 and he would go to the mosque but he wasn't the real, the proper hodza,

Page 2970

1 the one I know from Visegrad. He was self-proclaimed.

2 Q. And did you know the real, proper hodzas in Visegrad?

3 A. Yes, I did, the old one, the old hodza Tabakovic, and then there

4 was another one who left for Sarajevo before, some 15 or 20 years ago. He

5 was friendly with somebody called Ljubinko, and then more recently I don't

6 know who it was.

7 Q. Can you remember where the proper hodzas lived until 1992?

8 A. They had their own houses, private homes. They lived in their own

9 homes.

10 Q. Was it in town or in the outskirts or in the villages?

11 A. No, they lived in town.

12 Q. If you know those hodzas - and you said you did, and you said that

13 they lived in town - do you know that any one of the two of them had a

14 horse, either of the two had a horse?

15 A. I don't know. They lived in town. They didn't need to have a

16 horse.

17 JUDGE HUNT: How does this arise out of cross-examination? It's

18 really new material that -- if you wanted to lead, you should have led it

19 in chief. There was a reference to a hodza in the cross-examination, and

20 from there you've launched into a completely new subject. Now, if you

21 want to do it by leave, then Mr. Groome has got the right to cross-examine

22 on it, if you want to go into this new subject matter.

23 MR. TANASKOVIC: [Interpretation] Your Honour, Mr. Groome did ask

24 the witness about the hodza Ibrisim, I think he called him, and I was just

25 going to ask the witness if he knows what happened with this hodza Ibrisim

Page 2971

1 as you called him, whether he is alive, whether he has left or whether he

2 has gone somewhere else.

3 JUDGE HUNT: If that's what you want to do, then do it, but that

4 wasn't your question. That's not the point. You are going into new

5 material and it's really, if I may say so, not very carefully done. Now

6 if you want to go into that additional material, you may do so but you've

7 got to understand that it is new material, and if he wishes to do so,

8 Mr. Groome can cross-examine on it. Now you proceed and we'll see what

9 happens, but this material is not something which is the subject of

10 cross-examination.

11 MR. TANASKOVIC: [Interpretation] We have nothing against having

12 Mr. Groome ask additional questions afterwards but I had to ask the

13 witness this question, that is to say, what happened to that hodza, the

14 one that told fortunes or did whatever, divination, or whatever.

15 Q. Mr. Savic, can you give me an answer?

16 A. That hodza, I heard, had left for Sarajevo and somebody told me

17 quite recently that he had died in Sarajevo.

18 Q. When you spoke about and answered questions about your trip to the

19 hospital in Uzice, that journey, could you ever -- that is to say, could

20 your patient be admitted into any hospital without having a regular

21 referral letter?

22 A. Yes, that could happen, but then, in the course of the day or the

23 next day, depending on the disease, they would require one to be sent. If

24 he was in a serious condition, then he would be admitted, yes. They would

25 be duty-bound to let him in and then the referral letter would be sent in

Page 2972

1 or brought in subsequently.

2 Q. This more serious condition that you mentioned, would that be

3 considered -- would a fracture, the kind that Mr. Vasiljevic had, be

4 considered a serious condition?

5 A. Well, his life was not in jeopardy. It wasn't considered that his

6 life was in jeopardy, and even today, somebody would wait for him or a

7 family member would come and get him or bring in the social insurance

8 booklet, health insurance booklet because nobody has the booklet with them

9 usually when something, when an accident happens. So usually we either

10 wait for the person to turn up. There was no external bleeding or

11 anything of that nature.

12 Q. Was a referral letter necessary for crossing the border?

13 A. No. No. No, it wasn't necessary. You didn't have to have a

14 referral letter, because usually at that time you knew if the ambulance

15 was passing and the referral letter from the doctor would be sent.

16 Q. You answered questions about admission into hospital, the Uzice

17 hospital. Did you happen to know and did you happen to see that the

18 procedure that you described with respect to admission into hospital at

19 the admission -- in the admission area, did you see that all that was seen

20 to, was the procedure completed?

21 A. That is done at the admissions department. If there is a

22 fracture, they usually take an X-ray, take him to the room where he can

23 change into pajamas, put his pajamas on, and then he would go on further,

24 and if necessary, they would repeat the X-rays and take him where he needs

25 to go. Once he enters the ward, the doctor would undertake his

Page 2973

1 treatment. He has a system for all that, of course. He follows standard

2 procedure.

3 Q. Mr. Savic, can a doctor, if I can put it this way, take a patient

4 and take him off to the ward without going through this procedure at the

5 admissions office downstairs?

6 A. No. He would have to record the data, the mother's name, the

7 father's name, the spouse's name, the place of residence, address, and

8 what we call the history, case history. That's what they call it.

9 Because if somebody were to die in hospital, for example, they use

10 those -- that information to send the relatives telegrams and all the rest

11 of it. So you have to take a case history. That was always done before,

12 then, and now.

13 Q. Thank you. During your examination, you said that you knew

14 Mr. Vasiljevic well and that you had, on several occasions, sat with him,

15 had a drink together, chatted, that kind of thing. Do you think that

16 Mr. Vasiljevic was prone to violence, theft, looting or any other criminal

17 acts of that nature?

18 A. In my opinion, no, he never was. He always liked to help people,

19 and I know that had I asked him anything at all, had I asked Mitar, he'd

20 have said, "Zile, if it is in my power, I will help you," and even my wife

21 would say he would never say anything -- he would never be angry with her.

22 If something was not in order, if she had handed out something, he would

23 have -- he would say, "Don't serve that meal like that. Mrs. Rada will do

24 that. You ought to learn from her." Service was always quick and

25 diligent. People respected him and even remunerated him, gave him a dinar

Page 2974

1 or two if they were satisfied with his service, and he would do his best

2 for them.

3 Q. You spoke at length today about paramilitary formations or at

4 least some of the members of the paramilitary. Now, my question for you

5 is the following: Did Mr. Vasiljevic in any way whatsoever -- was he,

6 rather, was he in those paramilitary formations in any way, a part of them

7 in any way?

8 A. Let me tell you, those people didn't trust any of us. I had

9 occasion, in my neighbourhood -- Dzevad was my neighbour's name, and he

10 asked me, "Who is that neighbour? What is he, is he a good man or

11 not?" Moljevic, and then once Moljevic, they wanted to kill him and he

12 said, "Who's that? Who's that?" And I said, "Wait a moment" and then he

13 brought his personal ID, and this Dzevad Becirevic, who was a close

14 neighbour of mine, said "Don't touch him," and he swore at me. He said,

15 "Don't you replace him. You'll replace him," and he said, "Watch out,

16 old man." He said that to me.

17 Q. Mr. Savic, I don't think your answer was quite clear and I don't

18 think you answered my question.

19 A. As far as Mitar, he never -- he was never involved with them. I

20 didn't see him with them or was he a part of them at all.

21 Q. Asked by Mr. Roy whether there was or did you hear that Mitar

22 Vasiljevic had ever done anything bad to Muslims, your answer was about

23 Mitar Knezevic, I did hear, but I never heard anything like that about

24 Mitar Vasiljevic?

25 A. Yes, exactly so.

Page 2975

1 Q. Do you still stand by that assertion?

2 A. Yes, I do. Quite certainly.

3 MR. TANASKOVIC: [Interpretation] Thank you. I have no further

4 questions.

5 JUDGE HUNT: Do you want to ask any questions about that

6 examination-in-chief that we got there?

7 MR. GROOME: Yes, Your Honour, but not regarding the hodza. I

8 believe a new matter was raised on page 78 at line 12 regarding a video

9 and the investigator. I'd like to ask a couple of questions, to see

10 exactly what this witness was talking about.

11 JUDGE HUNT: I would estimate about 50 per cent of that

12 re-examination was not re-examination. You let it go on and on and on,

13 but I suppose you get the benefit of it. Now you proceed.

14 Further cross-examination by Mr. Groome:

15 Q. Mr. Savic, I'm going to read you a portion of your testimony that

16 we heard a few minutes ago and I want to just be clear on what exactly it

17 is you mean. You said, "He just asked me whether I had the

18 videotape and I said yes and I gave it to him." You never gave

19 Investigator Roy any videotape, did you?

20 A. No, I didn't give it.

21 MR. GROOME: No further questions.

22 JUDGE HUNT: Any re-examination on that?

23 MR. TANASKOVIC: [Interpretation] No, Your Honour.

24 Questioned by the Court:

25 JUDGE JANU: Mr. Savic, Mr. Vasiljevic during his testimony told

Page 2976

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3

4

5

6

7

8

9

10

11

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13 English transcripts.

14

15

16

17

18

19

20

21

22

23

24

25

Page 2977

1 us that Milan Lukic was for quite a long time in the prison in Visegrad

2 and after he returned, he was -- he was given the fully furnished flat,

3 apartment, and I quote, "And they gave him a coffee bar, too." Do you

4 know something about this situation?

5 A. I heard that too. That's what I heard as well.

6 JUDGE JANU: And they gave him a coffee bar, too. What sort of

7 coffee bar; do you know where this coffee bar was located in Visegrad or

8 is located?

9 A. In the centre of town. The proprietor is somebody else now, it's

10 run by someone else now and it was renovated a few days ago when I left,

11 and it is Dzevad Bajranovic's cafe which has been rented out to someone

12 else now. He reclaimed it.

13 JUDGE JANU: So it doesn't belong any more to Milan Lukic, does

14 it?

15 A. No, no. No, it's rented out now. And I was with the real owner,

16 the owner whose it was in 1991, I was with that owner quite recently, a

17 few days ago.

18 JUDGE JANU: Thank you.

19 JUDGE HUNT: Any cross-examination arising out of that?

20 MR. GROOME: No, Your Honour.

21 JUDGE HUNT: Any re-examination?

22 MR. TANASKOVIC: [Interpretation] No, Your Honour.

23 JUDGE HUNT: Thank you, sir, for coming along to give your

24 evidence here and for the evidence which you have given. You are now free

25 to leave.

Page 2978

1 THE WITNESS: Thank you very much.

2 [The witness withdrew]

3 JUDGE HUNT: Whilst we are waiting for the next witness, I remind

4 you, on Friday, we will be sitting after the Judge's meeting is concluded.

5 I regret to say that we don't know what time that will be but I suggest

6 that you be ready at 11.30.

7 On Tuesday, the 4th of December, there is a somewhat unfortunate

8 double-booking that has occurred and we have been asked whether we would

9 take the morning shift, as it is called, which means starting at 9.00 in

10 the morning, sitting through until 10.30, and then from 11.00 to 12.30 and

11 then a half hour break and then from 1.00 to 2.00. It's actually half an

12 hour less hearing time than we otherwise would have but the circumstances

13 in which the mix-up happened down at the registry are such that there

14 seems to be no other way that the matter can be dealt with.

15 On Thursday, the 6th of December, unfortunately, we will not be

16 able to sit at all.

17 Now, Mr. Domazet, you were going to let us know whether there are

18 any problems arising out of obtaining this psychiatric examination on the

19 weekend. Have you been able to arrange it all right?

20 MR. DOMAZET: [Interpretation] Your Honour, it is this weekend,

21 this coming weekend, and Madam Doctor Zorka Lopicic is coming on Friday

22 and on Saturday and Sunday. As I have been informed by the registry, she

23 will be in a position to meet with Vasiljevic so that I hope on -- that on

24 Monday, we will have something new to report. So she'll be here on Friday

25 and we were talking about this upcoming weekend.

Page 2979

1 JUDGE HUNT: Yes, I realise that. My concern was whether you'd

2 had any problems because you were to come back to us if you did have any

3 but, obviously, you have no problems and it will proceed.

4 MR. DOMAZET: [Interpretation] No problems, no.

5 JUDGE HUNT: Thank you very much.

6 [The witness entered court]

7 JUDGE HUNT: Sir, will you please make the solemn declaration in

8 which the court usher is showing you.

9 THE WITNESS: [Interpretation] I solemnly declare that I will

10 speak the truth, the whole truth, and nothing but the truth.

11 WITNESS: GORAN LONCAREVIC

12 [Witness answered through interpreter]

13 JUDGE HUNT: Sit down, please, sir.

14 THE WITNESS: [Interpretation] Thank you.

15 JUDGE HUNT: Mr. Domazet.

16 MR. DOMAZET: Thank you, Your Honour.

17 Examined by Mr. Domazet:

18 Q. [Interpretation] Mr. Loncarevic, good afternoon.

19 A. Good afternoon.

20 Q. I'm going to be asking you some questions and I should like to ask

21 you to bear in mind that the two of us speak the same language but please

22 make a pause before my question and your answer. You have the monitor

23 switched on in front of you so you will see when the interpretation ends,

24 so please pause before question and answer to facilitate the work of the

25 interpreters and the Court as well to be able to better understand your

Page 2980

1 answers.

2 First of all, would you introduce yourself? Could you give us

3 your name and tell us where and when you were born?

4 A. My name is Goran Loncarevic. I was born on the 29th of April,

5 1962, in Sarajevo.

6 Q. By profession, you are?

7 A. I am a medical doctor, a specialist for pulmonary diseases and

8 tuberculosis.

9 Q. Could you tell us where you went to school and where you went to

10 university and when you graduated?

11 A. I went to primary school in Dobrunska Rijeka, in Dobrun. I went

12 to secondary school in Visegrad, and I graduated from the faculty of

13 medicine in Sarajevo. My specialist training, I completed in Belgrade.

14 Q. Where do you live and work today, Mr. Loncarevic?

15 A. I now live in Visegrad and I also work in Visegrad.

16 Q. Since when have you been employed in Visegrad?

17 A. I have been employed in Visegrad since 1989, or more exactly, the

18 end of 1989, and I had a small interruption of approximately a month and a

19 half and that was in 1992.

20 Q. If I understand you correctly, you have been working in Visegrad

21 from 1989 to the present day with just a short break -- continuously, but

22 with just a short break in 1992; is that right?

23 A. Yes, that's right. And that break or interruption was from the

24 beginning of April to sometime in mid-May. I don't know the exact date,

25 but that is for orientation purposes.

Page 2981

1 Q. So throughout that time, only from the beginning of April to

2 mid-May 1992, you did not work in Visegrad; is that right?

3 A. That's right, precisely so.

4 Q. Can you tell us where you were during that interval? Were you

5 working somewhere and, if so, where, Mr. Loncarevic?

6 A. I spent that period partially in Titovo Uzice, that's what the

7 town's name was at that time and in part, I was in Bajina Basta. I was

8 working in Bajina Basta for a short period of time in the emergency

9 medical centre.

10 Q. Mr. Loncarevic, when you talk about your work in Visegrad

11 throughout this period, could you tell us where you worked, what the name

12 of the institution you worked in is and what posts you held to date?

13 A. From the very beginning, as a trainee, I worked in the different

14 departments and services: the labour service, pediatric

15 service, general medicine service, and most of all, the emergency ward

16 service. The institution that I work in is the health centre or clinic of

17 Visegrad which is an institution of what we call the primary health

18 protection level, that is to say that it deals -- it deals in outpatient

19 services, outpatient department service within the frameworks of its

20 possibilities and it has several outpatients departments, including the

21 basic departments and services. That is to say, we do not have beds; it

22 is all outpatients. We have a diagnostics department and a small

23 laboratory and X-ray department and, of course, an emergency ward or

24 emergency service for first aid.

25 Q. All these services, do they come under this one institution which

Page 2982

1 is called the health centre or clinic? All the emergency service, the

2 X-ray department, first aid, laboratory and so on; is that all under one

3 roof and comprises the health centre?

4 A. Yes, everything that I have enumerated does. Perhaps I have left

5 something out, but those are the most important sectors. All that comes

6 under the hat of the health centre of Visegrad or health clinic of

7 Visegrad. It is one institution.

8 Q. When you say there are no lying-in patients, no beds, does that

9 mean that the health centre does not have wards with beds for patients who

10 are bedridden, that is to say, that patients don't stay in the health

11 centre for treatment in beds?

12 A. The health centre in the period before I began working there did

13 have an inpatient's department of sorts with about 30 beds, that's what I

14 heard, but it was before my time. Since I have been working there, there

15 were no inpatients treated in hospital beds, so we did not have any beds

16 to accommodate inpatients in the health centre itself.

17 Later on - I can't tell you exactly when - perhaps in the course

18 of 1993, we set up a kind of small ward with seven or eight beds for

19 patients with less serious conditions and they were able to be monitored

20 and supervised and they did not require what we call secondary health

21 protection, but that was short-lived.

22 JUDGE HUNT: Do we need this detail? This is the doctor, as I

23 understand it, who admitted him and sent him on to Uzice. His evidence

24 should take a very short time.

25 MR. DOMAZET: Yes. I just finish with this.

Page 2983

1 JUDGE HUNT: Yes. Well let's get on with what's relevant,

2 please.

3 MR. DOMAZET: [Interpretation]

4 Q. Dr. Loncarevic, in view of what you said, what would you do with

5 patients that needed surgery or hospital treatment? Where were they sent?

6 A. Patients who needed to undergo surgery or to be treated in a

7 hospital who required to be treated under secondary medical care were

8 mostly sent to the hospital in Titovo Uzice.

9 Q. I am particularly interested in the year 1992. Does this apply to

10 that year as well?

11 A. Yes. Yes, it does apply to that year, too.

12 Q. Telling us where and when you worked, you told us that sometime in

13 May 1992, you returned to the health centre. So could you please explain

14 how work was organised? Was it in any way different from what it used to

15 be before when you were working in the same institution?

16 A. The organisation of work was different. I left the health centre

17 in peacetime and returned when the war was already underway. In

18 peacetime, one knew exactly who did what, who gave orders to whom, and how

19 you filled in certain forms and reports, how you obtained medicines and

20 everything else.

21 During the war, a certain degree of chaos set in in which services

22 functioned, mostly thanks to the enthusiasm and initiative of individuals

23 employed in that service, so that the conditions were very hard. Most of

24 the treatment was given in the emergency service. The occupational

25 medicine service functioned only for a short time after the war broke out,

Page 2984

1 whereas the other services more or less withered away and all activities

2 focused primarily on treating serious and less serious conditions

3 according to a special timetable which I can describe, if necessary.

4 Q. Let me just ask you this, please, Mr. Loncarevic. Does that mean

5 that you and the other doctors and medical staff had to work longer hours

6 and to have -- be on duty longer?

7 A. Yes. The situation differed, depending on the various staff

8 members. The males, the men who were in the records of the Defence

9 department as able-bodied, and there were three of us on that list, three

10 of us colleagues, we were obliged to be at the health centre almost

11 continuously. We were given leave only occasionally to go home so as to

12 change, have a bath, and occasionally to spend the night.

13 The others, and I am referring in the first place to doctors who

14 were not military conscripts, that is, who were not fit for military

15 service, had assignments and they would be on duty in the emergency

16 service or wherever necessary, together with us who were there most of the

17 time, so that most frequently, we would have two, three, sometimes more

18 doctors present simultaneously, depending on the needs.

19 The nurses also had their own timetable of work which, in those

20 days, was probably compiled by the director. I'm not quite sure who was

21 in charge of the organisation of work, but I think it must have been the

22 general manager who drafted the timetables, and this also applied to the

23 other staff members.

24 JUDGE HUNT: Mr. Domazet, do we need this sort of detail? This

25 doctor is being called to prove one thing, that the accused came to him on

Page 2985

1 a particular day and time and he sent him on to Uzice. Now, we don't

2 need to know how the whole hospital works in order to establish that.

3 Please lead him to the part which is relevant.

4 MR. DOMAZET: [Interpretation] Maybe this was a slightly more

5 detailed answer than I expected but I thought it necessary to explain the

6 conditions under which this centre was operating.

7 Q. My only additional question was whether, in that area, there was a

8 military hospital separate from this institution.

9 A. As far as I know, there was no military hospital in that area.

10 Q. Thank you, Mr. Loncarevic. My next question is: Do you know

11 Mr. Mitar Vasiljevic or did you know him in the period we are referring

12 to, that is, in 1992?

13 A. Yes, I did know Mitar Vasiljevic. Before that time and during

14 that time.

15 Q. Since when have you known him and how?

16 A. I knew him several years before the war. I remember that he used

17 to work as a waiter in a small coffee bar called Mezalin, and I would

18 see him occasionally in other Panos establishments.

19 Q. A moment ago, Dr. Loncarevic, you told us that in 1992 you left

20 Visegrad in peacetime and you returned in wartime. That period when you

21 came back and when you were working in the health centre, did you have

22 occasion to see Mitar Vasiljevic primarily in town or somewhere else in

23 town or the surroundings?

24 A. I don't remember seeing Mitar Vasiljevic in that period of time.

25 Q. In view of what you told us a moment ago about your obligations as

Page 2986

1 part of your military duties, did you often go into the centre of town?

2 A. I already said that I rarely went home, but I live in an area that

3 is below the town, that is close to the second bridge, and you don't have

4 to pass through the town if you use that bridge. Very rarely, virtually

5 never, did I go on foot. I went by car, crossing that new bridge, so that

6 I didn't pass through the town centre. That may be the reason, if I may

7 have come across him, though I can't talk about that because I do not

8 remember, so my answer is I didn't come across Mitar.

9 Q. So during that period of time, did you see him in the health

10 centre in which you were employed?

11 A. Could you explain what particular time period you are referring

12 to?

13 A. Yes.

14 Q. Yes, I'm referring to the period from which you returned, that is

15 in May 1992 onwards. Since you have already told us that you didn't see

16 him in town, did you see him in any other area or situation?

17 A. Yes. I was present in the health centre when the injured

18 Vasiljevic was brought there. I don't remember whether we had any

19 conversations. Vasiljevic, as far as I can recollect the situation, he

20 was on a stretcher. Now, whether we first had contact within the

21 hospital, within the centre compound or in the actual doctor's office, I

22 can't say. It was a long time ago, but I seem to remember the image. I

23 have the image in my mind of the injured man and several men who were

24 carrying Mitar Vasiljevic towards the X-ray, because on the basis of an

25 external and superficial examination, I was able to reach the conclusion

Page 2987

1 that this was an injury or, rather, a fracture of the lower leg, and that

2 is why I gave instructions for an X-ray to be made.

3 Among the many images that have probably been wiped out of my

4 memory, one remains clear, and that is this movement towards the X-ray

5 from the steps to the door of the X-ray room.

6 Q. Mr. Loncarevic, if I understood you correctly, you first examined

7 Mr. Vasiljevic, and on the basis of your external examination, you

8 established that it was a fracture was involved and you sent him to have

9 his X-ray taken; is that right?

10 A. Yes, that's right.

11 Q. Was it -- I assume it was the leg. I don't know whether you

12 mentioned -- whether you told us what kind of fracture it was, of what

13 part of the body?

14 A. Yes, the leg was X-rayed. The X-rays were done from two

15 positions. I don't know whether it was all on one negative or two. I

16 also cannot assert with certainty whether it was one or two bones of the

17 left lower leg were broken. Judging by external signs, which I gave a lot

18 of thought to subsequently, it is more probable that both bones were

19 broken, but it is not something that I can assert with certainty.

20 Q. Would you please explain a little what you meant, two shot? Are

21 they two subsequent shots or two shots taken from different positions,

22 different angles?

23 A. The rule is, and that is a hard and fast rule, that every injury,

24 especially when a fracture is suspected, that two different directions --

25 from two different directions an X-ray should be made so as to get more

Page 2988

1 information about the time and type of injury. So it is possible to do

2 this on one negative, or you may use two negatives, but the rule is to do

3 so once from one angle, usually from the front, and a second time from a

4 different position, that is, from the side.

5 Q. Dr. Loncarevic, will you tell us when these X-rays were made, what

6 kind of x-ray equipment did you have in your health centre?

7 A. In the health centre, we had an old X-ray. I am unable to say

8 when this apparatus was manufactured, but it was operational, but the

9 procedure for X-raying was rather specific. That is not so much the

10 actual X-raying as the developing of the film itself.

11 To develop the film, we had a bowl, a copper bowl, that the

12 heaters were sunk into to warm up the chemicals used to develop the film.

13 JUDGE HUNT: Mr. Domazet, again, do we need this sort of detail?

14 Is there something that you have to explain about the quality of the

15 X-rays which were taken? The fact is we've been told X-rays were taken

16 and they were sent with him to Uzice. Do we need this?

17 MR. DOMAZET: [Interpretation] What I understand from the testimony

18 of this witness is that these films were developed by hand and that is why

19 I inquired as to the method of developing the film. Maybe the witness is

20 going into considerable detail but let me shorten his answer by asking:

21 Q. Was the developing done by hand and how long would it take for

22 such a film to be developed? How much time was needed from the moment the

23 X-ray was taken until you obtained the picture? Those are my questions

24 and I think that they are relevant for this case.

25 A. Yes, they were hand-developed, and to do this, you need about 20

Page 2989

1 minutes, sometimes longer, sometimes less, but around 20 minutes.

2 Q. After the developing of these X-rays, do you know what happened

3 then with Mr. Vasiljevic?

4 A. Mr. Vasiljevic was carried back to the room for treatment, where

5 he was given emergency treatment and prepared for transport which means

6 that the injured leg was immobilised and everything else that was

7 necessary was done.

8 Q. You mentioned immobilisation and preparation for transport. For

9 transport where, Mr. Loncarevic?

10 A. For transport to the hospital in Titovo Uzice, the orthopaedics

11 ward.

12 Q. For such transport, was it necessary for one of you in the health

13 centre in Visegrad to prepare a referral document?

14 A. Yes, it was necessary. The referral letter needed to be drafted

15 because the patient would not have been admitted to hospital without a

16 referral letter. I cannot remember who wrote that referral. I gave

17 instructions for this to be done and I knew that it was something that we

18 had to do. Now, whether I wrote that referral or one of my colleagues

19 did, I don't remember now even who it was among my colleagues that were

20 present so I can't assert that now.

21 In any event, a referral letter had to be written.

22 Q. In such situations, Mr. Loncarevic, when you are sending a patient

23 with referral to another institution, to the hospital in Uzice in this

24 particular case, in addition to the referral letter, does the patient

25 carry anything else with him as his documentation?

Page 2990

1 A. The rule is that a patient, in addition to the referral, should

2 carry with him any other documents he has. In this case, it must have

3 been the X-ray that was done. It is true that I didn't see it or see him

4 carrying it, so I can't claim that, but I wish to say that that is the

5 rule and it was never deviated from. Whether it was done in this case, I

6 can't claim.

7 Q. Dr. Loncarevic, talking about the X-ray, how is an X-ray picture

8 marked, if marked at all, before it is given to the patient?

9 A. Yes, certainly there are some markings made on the X-ray. The

10 first and last name of the patient must be written on the X-ray, the date

11 when it was done, and which side was filmed, was it the left or the right

12 side, which is marked with a capital "L" or a capital "D" in the Latin

13 script.

14 Q. In those days, how was -- were these markings made, with a

15 typewriter or by hand?

16 A. As far as I can recollect, we didn't have any equipment to be able

17 to make such inscriptions automatically so I think we used a water

18 resistant marker, a simple ordinary marker.

19 Q. And who would make those markings? Would it be the doctor or the

20 technician operating the X-ray machine?

21 A. These markings would be made by the X-ray technicians and he

22 carries out the actual filming and he makes the markings on the film too?

23 A. Mr. Loncarevic, can you tell us, to the best of your recollection,

24 what time of day it was when Mr. Vasiljevic was carried into the health

25 centre on a stretcher?

Page 2991

1 A. I cannot claim with precision because, after all, it was a very

2 long time ago so I can't remember the exact time. What I am able to say

3 is that it was daytime, that I am sure of. That is something I can

4 claim. As far as I am able to recollect, I think I had finished lunch and

5 it wasn't close to nightfall. It was a cloudy day. I think that it was

6 also -- there was a fine rain falling.

7 If I were to have to give some closer indication of the time, I

8 would prefer to say that it was sometime around 4.00 p.m. or between 4.00

9 and 6.00 p.m., sometime there.

10 Q. When you mentioned your lunch; as an orientation, around what time

11 would you normally have lunch in those days?

12 A. Then and now, my custom was to have lunch around 3.00 p.m.,

13 sometimes a little earlier, sometimes a little later, of course in the

14 afternoon.

15 Q. In those days, was it required that a vehicle belonging to the

16 health centre transport, in this case, Mitar Vasiljevic, to Uzice?

17 A. In view of the fact that a vehicle was required which allowed the

18 patient to be in lying down position, it had to be our vehicle and there

19 was no reason to use any other.

20 JUDGE HUNT: I think that might be an appropriate time,

21 Mr. Domazet.

22 MR. GROOME: Your Honour, can I make a brief request before we

23 finish business for the day? I make this request just in an abundance

24 of caution, not casting aspersions in any direction, but could I ask the

25 Court to perhaps direct the Victims and Witness Service to advise

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Page 2993

1 Mr. Savic that if he has any concerns for his safety now or upon his

2 return, that he should call them and discuss those concerns with Victims

3 and Witness Services.

4 JUDGE HUNT: Well, I'll ask the Court Deputy to pass on your

5 message, but it may be better if somebody from the Prosecution explained

6 it to them. I wouldn't expect us to buy into any conclusions, but there

7 are obviously great possibilities, and I would agree with you that the

8 warning would be very appropriate, but I think it might be a good idea if

9 you added the weight to the detail involved so they know what it is all

10 about.

11 MR. GROOME: I will do that, Your Honour.

12 JUDGE HUNT: Thank you. 9.30 in the morning

13 --- Whereupon the hearing adjourned

14 at 4.03 p.m., to be reconvened on Thursday

15 the 22nd day of November, 2001, at

16 9.30 a.m.

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