020115ED

Page 4498

1 [Open session]

2 JUDGE HUNT: The next witness we have given the pseudonym VG117

3 to, are there any other protective measures?

4 MR. GROOME: Yes, Your Honour, the Prosecution is asking for

5 facial distortion for this witness.

6 JUDGE HUNT: Very well, then. The pseudonym sheet will be Exhibit

7 P93 and it will under seal. A copy for Mr. Domazet, I hope, this time.

8 [The witness entered court]

9 JUDGE HUNT: Now, Madam, would you please make the solemn

10 declaration in the document which the Court usher is showing you?

11 THE WITNESS: [Interpretation] I solemnly declare that I will speak

12 the truth, the whole truth, and nothing but the truth.

13 WITNESS: WITNESS VG117

14 JUDGE HUNT: Sit down, please, Madam.

15 [Witness answered through interpreter]

16 JUDGE HUNT: Mr. Groome.

17 Examined by Mr. Groome:

18 Q. Good morning.

19 A. Good morning.

20 Q. Madam, to protect your identity throughout the course of your

21 examination, we will be referring to you as Witness 117 or VG117. First

22 question I'd like to ask you is: Do you know a person by the name of

23 Mitar Vasiljevic?

24 A. Yes.

25 Q. Can you tell us approximately how old you were the first time or

Page 4499

1 when you first knew Mr. Mitar Vasiljevic?

2 A. I may have had 12 or 13, maybe 12 or 13 years old when I completed

3 four years of elementary school.

4 Q. And how old would Mr. Vasiljevic have been at the time that you

5 first knew him?

6 A. I don't think he had started primary school yet.

7 Q. Can you describe for us the circumstances under which you first

8 knew Mr. Vasiljevic?

9 A. I can, because he was very close to my village, and the children

10 would get together as shepherds. Our elders knew each other. Everything

11 was fine in those days. Nobody did anything bad or said anything bad

12 about other people. We played together as children. We met each other.

13 We got together.

14 Q. So is it true that as a child, you played with Mitar Vasiljevic?

15 A. Certainly, I must have, because my property was called "jela" and

16 nearby were their properties. Then there were fairs where we would see

17 one another. Maybe even when I was 15, we would come across one another

18 and get together.

19 Q. Can you describe for us where you lived or where you grew up as a

20 child, how long would it take somebody to walk from where you lived as a

21 child to where Mr. Vasiljevic lived as a child?

22 A. Twenty minutes to my property, and the place where we would see

23 each other as shepherds, to his village, it's about one hour to get there,

24 though you could do it in less time.

25 Q. And you said that you used to see him as, or we used to see each

Page 4500

1 other as shepherds. Could you please give us a little bit more detail

2 about those circumstances?

3 A. We would play hide and seek. There wasn't just Mitar. There

4 would be up to 20 of us from these two or three villages, Blace,

5 Djurevici, Klasnik, Paocici. These are all neighbouring villages.

6 Q. Now, as you got older, would there be other circumstances under

7 which you would have occasion to see Mr. Vasiljevic?

8 A. Yes, indeed, when he grew up, when he went to school, and when he

9 worked as a waiter. On any number of occasions, he would serve me at the

10 hotel when we went to have lunch there at the Panos or at the Vilina

11 Vlas, at the Vilina Vlas spa.

12 Q. Can you describe for us in the period between or the period prior

13 to 1992, can you tell us approximately how often would you go to the Hotel

14 Panos to eat?

15 A. Sometimes every week. When I'd go to the market to sell my ware,

16 when I finished at the market, I would go and have lunch there. Sometimes

17 we would meet every week, sometimes once in a fortnight. It depended.

18 Q. And on those most occasions when you went to the Panos hotel,

19 would you see Mr. Vasiljevic?

20 A. He may not have been on duty just then. He wasn't always on

21 duty. But I would see him, that's for sure. If I wouldn't see him at

22 the hotel, I would see him in the street. I would travel by bus. We

23 would meet at the bus. I would be going to my village. He would be going

24 to his. He would get off at a stop before mine when he went to visit his

25 parents, because he lived in town.

Page 4501

1 Q. During the times or on the occasions that you would see

2 Mr. Vasiljevic in the Panos hotel, would he greet you by your name?

3 A. More often he would use the term [redacted],

4 [redacted]. That is how people called me, more by my second name

5 than by my first name. Most people called me by that name.

6 MR. GROOME: Could I ask that that maiden name be redacted?

7 JUDGE HUNT: Yes.

8 MR. GROOME:

9 Q. Now, you mentioned also that you would see him on the bus.

10 Approximately how often would you see him on the bus?

11 A. Well, let me tell you, in the summer, I didn't go that often.

12 During the winter, more often. Once a month, sometimes once in two

13 months, sometimes once in three months. I didn't make note of it. I

14 couldn't tell you exactly.

15 Q. Now, this past Saturday, the 12th of January, did an investigator

16 show you a group of 12 photographs and ask you whether you recognised

17 anyone?

18 A. Only Mitar Vasiljevic. I didn't recognise anyone else, only him.

19 I recognised him because I've known him since childhood and I would

20 recognise him even with one eye, if the other one was closed.

21 MR. GROOME: Your Honour, at this time I'm going to ask that the

22 witness be shown the original of PG20.VG117, and I have some black

23 and white copies for the Court. Unfortunately, time hasn't permitted us

24 to send it out for colour copies.

25 Q. VG117, I would ask to you take a look at an exhibit or a document,

Page 4502

1 I'm sorry, Prosecution document number 20.VG.117, and ask you whether or

2 not that is the group of photographs that you were shown this past

3 weekend.

4 A. I think it was. This is Mr. Mitar's photograph.

5 Q. What number is next to --

6 A. I don't know anyone else here.

7 Q. What number is next to the picture you're identifying as Mr. Mitar

8 Vasiljevic?

9 A. Number 11.

10 Q. And how did you -- did you sign your name to that document?

11 A. I did.

12 Q. And where did you sign your name?

13 A. On the front.

14 Q. And did you -- where did you sign your name in relation to

15 Mr. Vasiljevic's picture?

16 A. The signature is on his forehead, and the date is on the cheek,

17 and the time is between the nose and the lips.

18 MR. GROOME: Your Honour, at this time I would tender document

19 20.VG.117 into evidence.

20 JUDGE HUNT: Any objection, Mr. Domazet?

21 MR. DOMAZET: No, Your Honour.

22 JUDGE HUNT: Thank you. It will be Exhibit P20-VG117, and it

23 will be under seal.

24 MR. GROOME:

25 Q. Now, Witness 117, I'd ask to you take a look around the

Page 4503

1 courtroom. We are finished with -- I'm sorry, we are finished with that

2 exhibit. I'd ask you to take a look around the courtroom and tell us

3 whether or not you see the person you've described for us in the courtroom

4 here today.

5 A. I can see him. He's over there in the left hand corner, the

6 second person.

7 Q. Can you please describe what he's wearing today to help us know

8 who you are speaking about?

9 A. As far as I can see, he's wearing a brown jacket, a white shirt, I

10 think, and a tie. I'm not quite sure of the colour. He's got his

11 headphones on.

12 MR. GROOME: Will the Defence agree that the witness has indicated

13 Mr. Vasiljevic?

14 MR. DOMAZET: [Interpretation] I think that is absolutely not

15 difficult in my opinion, quite unnecessary, but if you insist, of course,

16 yes.

17 JUDGE HUNT: I think we can all agree that she has identified the

18 accused. We will adjourn in a moment. I just want to make an inquiry as

19 to whether I can sign the redaction document. I'll sign it during the

20 adjournment. We will resume again at 11.30.

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

22 --- On resuming at 11.32 a.m.

23 JUDGE HUNT: Mr. Groome?

24 MR. GROOME:

25 Q. Witness 117, I want to now ask you about something that happened

Page 4504

1 -- I'm going to ask you not to tell us the specific date but I just want

2 to draw your attention to June of 1992. Without telling us the specific

3 date, did there come a time when some Serbs came to your villages and told

4 you that you had to leave Visegrad?

5 A. Yes.

6 Q. The next morning, did some trucks come to your village and put

7 yourself as well as villagers from your village and two other villages on

8 those trucks?

9 A. Yes, they did.

10 Q. Where did they bring you?

11 A. They took us to Visegrad, in front of the Vuk Karadzic School.

12 Q. And did you get off the trucks at the Vuk Karadzic School

13 A. Yes, we did, all of us.

14 Q. And what did the trucks do after they unloaded all of these

15 people?

16 A. The trucks turned back and drove away. I don't know where to.

17 Q. All of the people that were brought there, were they Muslims?

18 A. Yes, all of them were.

19 Q. After the trucks left the Vuk Karadzic School, at the time that

20 you arrived, was there anybody else present at the school?

21 A. We arrived at the school and did not enter the school

22 immediately. Then all of a sudden, Mitar Vasiljevic showed up. He had a

23 book under his arm, when he came. He said, "Good afternoon. I work for

24 the Red Cross." And then he sat at the table. There was a table in front

25 of the school and some four chairs. My mother-in-law sat on one chair

Page 4505

1 because she had a broken leg. My father-in-law sat on the other chair and

2 the third chair was taken by a soldier that they called Cacanin. And then

3 Mitar sat at that desk as well and he told us that he needed to write down

4 our names into that book, and then he said, "Why don't you group together

5 within your families?" And then he started writing down names and as he

6 wrote down names, people would walk into the school together with their

7 belongings.

8 My family was the last one to get registered, because a man came

9 looking for transportation for us to go to Belgrade, because I had my

10 husband's brother in Belgrade, and my children -- he was an officer there,

11 and I was there with my children and my mother, and I came with the people

12 there to the school. And when everybody got registered, my family was the

13 one -- was the last one to get registered, Mitar counted us and there were

14 a total of 119 of us, and he stayed there for a little while longer and

15 then left. I don't know where to. My family remained there sitting for a

16 while, and then Ristic, called Gaga, came and told me, "You have to go

17 into the school together with the grandmother." We were unable to find

18 transportation for you. Miloje had to go somewhere. There was a problem

19 between your people and our people and he didn't tell us anything about

20 transportation.

21 Q. Let me just go back and we will go through it more slowly and ask

22 you for a few more details. When you arrived at the school, did you see

23 Mitar Vasiljevic as you arrived?

24 A. No, I didn't. When I arrived, he wasn't there, but he came

25 shortly. The people were there, mingling around, wondering where they

Page 4506

1 were going to go and so nobody dared leave, but Mitar was not there when

2 we arrived. He came shortly thereafter.

3 Q. Could you tell or could you see from what direction he came?

4 A. He came from the same direction as the one where the trucks drove

5 off. I didn't really pay attention. I don't remember whether he came in

6 his car or he came on foot. I saw him when he approached this group. I

7 recognised that it was Mitar, and he didn't introduce himself. He simply

8 said that he worked for the Red Cross and that he needed to register down

9 our names in that book, that nobody would get hurt, that this book would

10 be transferred to Geneva, and that's what he told us.

11 Q. Did he arrive or did you first see him arrive before or after the

12 trucks left?

13 A. After the trucks left, not before that, definitely not. I didn't

14 see him. Maybe he was somewhere waiting but I didn't see him.

15 Q. Now, after the trucks left, and Mitar Vasiljevic arrived, were

16 there any other non-Muslims or people that were not belonging to the group

17 that had been brought there by the trucks? Were there any other people

18 there?

19 A. Yes. There, in front of the school, there was some people there

20 waiting for the convoy. A convoy was supposed to leave, and there was

21 some people there who had left earlier, two or five or seven days earlier

22 because they felt safer there in the town, and I saw there Ruste Murtic

23 from our neighbourhood. He was there with his wife. And those people did

24 not enter the school building. They stood there waiting. They left with

25 convoy that day. And they were told Alija's state closed the border so

Page 4507

1 you can't go any further today, and so they were just standing there.

2 Q. These people that were waiting for a convoy, were they Muslims?

3 A. All of them were Muslims, all of them.

4 Q. Aside from them, were there any Serbs present at the time after

5 the trucks left and before Mitar Vasiljevic came?

6 A. Just those who escorted us on those trucks in that convoy. I

7 don't know these two men, don't know their names. I only know Cira

8 Dzuric. I don't know his real full name. We called him Cira when we were

9 children. I don't know his full name. So he remained there. He was

10 there even when Mitar came. Cira was there the whole time. He even

11 spent that night at the school building.

12 Q. And this person you're referring to as Cira, was he armed?

13 A. Yes. He was armed.

14 Q. And can you describe the weapon that he had?

15 A. He had an automatic weapon. It was hanging over his shoulder.

16 And all of those that came, five of them, they came in those trucks. When

17 they came into our village, they immediately dispersed through hills and

18 the soldiers were there on those peaks, looking for extremists, and then

19 they rounded us up into the trucks. They were in the trucks' cabin and

20 the Muslim people were in the back of the truck.

21 Q. I want to draw your attention to when you first saw Mr. Vasiljevic

22 and I want to -- if you can recall, can you describe for us what he was

23 wearing?

24 A. He had civilian trousers. He did not have a uniform. He also had

25 a white shirt on him that day, when we got there, when I saw him for the

Page 4508

1 first time, when he had that book in which he had to register our names.

2 Q. And do you recall if he was armed?

3 A. No, he was not. I didn't see any kind of weapon on him. Maybe he

4 had a pistol on him but I didn't see him. I didn't see any weapons on

5 him. I only saw that book that he had with him and he put it down on the

6 desk. I didn't see him carrying any weapons.

7 Q. Could you describe that book for us with as much detail as you can

8 recall?

9 A. It was a larger-size book. It looked like a school register

10 book. And our villagers were saying, "There goes Mitar with a book." And

11 when he came, he laid the book down on the desk and he told us to register

12 our names, that nobody would get hurt, that then this book would be

13 transferred on to Geneva. And I was standing close to the desk because my

14 mother-in-law had a broken leg so she was sitting on a chair, and I looked

15 at him leaf through this book. I didn't really count because -- had I

16 known I would have come here to testify, perhaps I would have paid more

17 attention. And he simply leafed until he found a clean sheet, a clean

18 page, and then he started registering names, and as he registered people,

19 people would enter the building. My family was the last to register

20 because we waited for transportation. Miloje was -- Joksima [phoen] was

21 looking for a means of transportation for our family and then when Mitar

22 registered all names, he counted us, there were 119 of us; he circled that

23 number. He remained sitting there. He didn't say anything bad to us

24 while he was there. And this is all -- I told you all about it. He

25 didn't say anything else. And then he left.

Page 4509

1 Ristic remained there and came to me shortly afterwards to tell me

2 that I needed to go in together with the grandmother. He told me there

3 was no transportation for you to take you to Belgrade. A problem emerged

4 between your people and our people. And then Miloje had to leave, went to

5 Rujista. So together with my mother-in-law and another relative, we

6 entered the school building. People were sitting in a huge hall on the

7 floor, on the concrete floor. Some managed to find some cardboard paper

8 to sit on it, and they had their belongings around them. When I entered

9 the room, it was a gym hall so I saw mats there; people were sitting on

10 mats, and I saw Ristic there.

11 Q. I just want to ask you a few more specific questions before we

12 speak about the time you were in the school. When you first saw

13 Mr. Vasiljevic, was he alone or was he with other people?

14 A. I saw him alone. He came alone. I didn't see anybody else other

15 than those people that came with the convoy of soldiers, and those that

16 came to fetch us. I also knew Cira, I mentioned him, but I didn't know

17 anybody else there.

18 Q. I want to ask you another question about --

19 A. I tend to speak loudly. I've always spoken a bit loudly but I'll

20 give it a try.

21 Q. I want to ask you one more question regarding what you recall

22 about what Mr. Vasiljevic was wearing. Do you recall on that day whether

23 you saw him wearing any type of armband or ribbon around his arm?

24 A. No, nothing of that sort. He didn't have anything of that sort.

25 Q. You told us a few minutes ago that Mr. Vasiljevic mentioned about

Page 4510

1 people getting into groups. Did he explain why he wanted people to get

2 into groups?

3 A. In order to register down names, so it would be easier for him to

4 register people by families, you know, in order. So that he wouldn't

5 register one member of the family and then switch to another, (redacted),

6 Mutic, and so on. So he wanted to just register whole families, from the

7 youngest to the oldest member.

8 Q. And as best as you can recall, can you estimate for us the time

9 when he began to record the names of the people there?

10 A. Well, let me tell you, convoys arrived perhaps at 7.30 or 8.00 and

11 then we arrived in town at 9.30 or 10.00, and he arrived at the school

12 before 10.00 and then he immediately, within a few minutes, started

13 registering down names and he remained there for perhaps an hour, perhaps

14 longer. I couldn't tell you exactly because I didn't keep track of it. I

15 can't tell you exactly.

16 Q. So are you saying that it's around 10.00 in the morning that you

17 saw Mr. Vasiljevic and he began to record names?

18 A. Yes.

19 Q. Can you tell us what --

20 A. Yes.

21 Q. What do you recall about that day, the weather of that day?

22 A. It was a fine day, couldn't be any better. It wasn't raining at

23 all, albeit in few preceding days, it was raining a lot but that day, the

24 weather was fine.

25 Q. And can you give us your best estimate of how much time you were

Page 4511

1 able to see Mr. Vasiljevic from the time that you first saw him until the

2 time that you went into the school and could no longer see him?

3 Approximately how much time transpired?

4 A. Well, as soon as he registered us down so after an hour or maybe

5 more than an hour, he, having finished this registration, stayed maybe for

6 a few minutes and then left and then he didn't come back afterwards. I

7 didn't go into the school building immediately until the Ristic came to

8 tell me that I had to go in together with my family. In the meantime, and

9 I don't know if I should tell you about this, my mother-in-law needed to

10 go to the bathroom.

11 Q. Okay. Let me just ask you some specific questions. Are you able

12 to tell us the period of time when you first see him arrive and when he

13 leaves?

14 A. Well, between 10.00 and 11.30, somewhere around there. Perhaps

15 it wasn't 10.00 yet when he arrived but maybe it wasn't even 11.30 when he

16 left, but he definitely left before noon. I know that for sure. Because

17 I went with this other soldier to look for the bathroom.

18 Q. So, ma'am, would that be approximately one and a half hours?

19 A. Hour and a half, could -- it's more likely less than that than

20 more than that. Because, you know, nobody really stayed there too long.

21 Q. Madam, now you told us that there were 119 people present. How is

22 it that you know the precise number of people that were present at that

23 time?

24 A. Because I stood right there by the desk. I told you that my

25 mother-in-law sat on the chair and my family was the last to register.

Page 4512

1 And upon finishing registration, Mitar counted all the names, wrote down

2 underneath "119," and circled it, the number. He said that nobody would

3 be hurt, that this book would be sent on to Geneva, and he didn't say

4 anything bad to us as he registered our names, not a single bad word.

5 Q. Was it your understanding that he was writing these names down to

6 make arrangements for a convoy to take you out of Visegrad?

7 A. Well, no. That's not how I saw it, and I listened prior to that,

8 to see who had left with the convoy. Over the radio, they were sending

9 messages to their families, brothers and sisters, and urging Muslims not

10 to join this convoy, especially men, that whoever left with the convoy was

11 taken off and went missing since, and --

12 Q. Ma'am, let me ask you this then: Your mother-in-law, you say that

13 she was sitting in a chair. Can you describe for us where the chair your

14 mother-in-law was sitting in was in relation to where Mr. Vasiljevic was

15 when he was taking the names of the people?

16 A. Well, this is how it was. Where I sit now is where my

17 mother-in-law sat. And over there to the side, Mitar sat and my

18 father-in-law sat to the left and this other soldier called Cacanin was on

19 the other side. And then finally, my father-in-law told him, "Well, let

20 me see, hero, how you prepared this knife of yours?" And he gave a knife

21 to my father-in-law. At that point, Mitar had already left. So he put

22 some water on the knife and my father-in-law tested it and said, "You did

23 a really good job. You prepared this knife well." And then he put it in

24 his boot.

25 Q. I want to ask you to be as precise as you can to describe the

Page 4513

1 distance between where your mother-in-law was sitting and where Mitar

2 Vasiljevic was, and perhaps if I could ask you if you were to walk from

3 where your mother-in-law was to where he was, approximately how many steps

4 would you estimate it would take to go from where your mother-in-law was

5 to where Mr. Vasiljevic was?

6 A. Well, I couldn't even make a step because my mother-in-law was

7 leaning against this desk. She was a sick woman, so she was leaning

8 heavily on one side of the desk and, see, he sat at the other side of the

9 desk, and I myself was not sitting. I walked and I stood there, and I

10 would perhaps go around the desk, make two or three steps to reach Mitar,

11 and that's all I could do. So there is nothing else I can tell you about

12 it.

13 Q. And during the time that Mr. Vasiljevic was writing down the 119

14 names, were you in that position by the desk that you're describing now?

15 A. Well, sometime I would be standing between my mother-in-law and

16 my father-in-law. And then if some other people approached the desk, then

17 I would help them with the -- carry their belongings, so I can't say that

18 I stood there, without moving, the whole time. I was sort of going around

19 and helping these elderly people approach the desk and carry their

20 belongings and I would go back to the desk, and this is how it was.

21 Q. And during that time, was there anything obstructing your view of

22 Mr. Vasiljevic's face?

23 A. No, nothing. There were others there that tried to mask their

24 face and put stockings over their face or paint their faces, but he didn't

25 do anything of the sort. He didn't do anything that would obstruct my

Page 4514

1 view. All I can say is that he was really skinny then. He wasn't as

2 chubby looking as he is now.

3 Q. Madam, at the time that he recorded your name, where were you

4 standing in relation to him?

5 A. Because I was the last one, and I stood right next to the desk,

6 and I stood between my father-in-law and mother-in-law. My

7 father-in-law's name was the first one to be registered, then my

8 mother-in-law. Then this relative who came with us and who was single and

9 stayed with us from the beginning of the war, and then she went with us to

10 (redacted) as well and then went back to Sarajevo and she is together with

11 my father-in-law to this day. And this is when I stood closest to him

12 because we were the last ones to register. And I saw him, I looked at

13 him, as he was registering our names.

14 Q. At that time, if you wanted to, would you have been able to touch

15 his hand? Were you close enough to touch his hand?

16 A. Well, certainly, certainly. When I stood next to my

17 mother-in-law, I could have touched both his hand and his back because his

18 hand was on his -- on the desk.

19 Q. Now, did you, yourself, see Mr. Vasiljevic leave that day?

20 A. Yes, I did. Because at that time I was still standing outside,

21 because my family had not entered the building yet, and I saw him few

22 metres away from the school. I didn't follow him further than that, so I

23 don't know whether he went on foot or got into a vehicle. I simply wasn't

24 interested. But he got up from the desk and left.

25 Q. What happened to the book that he recorded the names in? Did he

Page 4515

1 take that with him?

2 A. Just as he brought it under his arm, he put it back under his arm

3 and left, and as he got up, he talked to all three soldiers, I don't know

4 what about, and then he left. I wasn't as close at that point as I was

5 when he was registering names at the desk.

6 Q. And when he left, did he leave alone or did he leave with other

7 people?

8 A. He left alone, because those soldiers remained there, and he left

9 alone, he put the book under his arm. I followed him with my eyes for a

10 few metres and then that was it. So I don't know what went on afterwards.

11 Q. And it is true that that is the last time that you saw him in

12 person prior to entering this courtroom here?

13 A. Yes. That was definitely the last time I saw him. I never saw

14 him after that. He did not come back to the school after that.

15 Q. Ma'am, is it true that you did not leave on a convoy from

16 Visegrad, that you had to leave by foot? Is that true?

17 A. I didn't leave by foot. I went with Niva, and the following day,

18 Miloje and Ristic came back and told me they couldn't find transportation

19 for me to Belgrade, that I needed to go back to my village, and then the

20 following day, we would travel on foot to the Serbian border. And then he

21 said to the remaining people there that convoy would not be coming,

22 Alija's state had closed its borders and these people would have to stay

23 there for some seven or ten days, and if they wanted, they could go back

24 to their villages. And people were very eager to do exactly that. Then

25 this man left, and after a short time, he came back, and said, "You can

Page 4516

1 leave with convoy." Then Niva came to pick up me and my parents-in-law,

2 and we came there in three trucks, and when we were leaving, there were

3 only two trucks. They told us we could not find any more trucks so you'll

4 just have to be somewhat uncomfortable. And we sat in a really congested

5 way there. And as we left and entered the main street, all traffic

6 stopped to let the trucks pass, and then we headed towards my village, and

7 when we came to intersection to Vilina Vlas and Zupa --

8 Q. I'm going to ask you, my final question for you is the reason you

9 were asked to come here: Is there any doubt in your mind that the person

10 that you saw recording names of the villagers from your village as well as

11 the others, the 119, is there any doubt in your mind whether or not that

12 was Mr. Vasiljevic?

13 A. That it wasn't him? I didn't quite understand what you said.

14 Q. Do you have any doubt in your mind that it was Mr. Vasiljevic that

15 you saw that day writing down the names?

16 A. How could I have any doubt? It was Mitar. I know it was Mitar

17 himself. I have no doubt. What kind of doubt could I have when I've

18 known him as long as almost I know myself?

19 MR. GROOME: Thank you, Madam. I have no further questions.

20 JUDGE HUNT: Mr. Domazet.

21 Cross-examined by Mr. Domazet:

22 Q. [Interpretation] Madam, I will ask you perhaps not in the same

23 order but maybe in the reverse order as compared to the questions put by

24 Mr. Groome. And I would like you to tell me, this event that you

25 described in front of the school, the listing of names, when was that?

Page 4517

1 What day was it?

2 A. To tell you the honest truth, I don't know what date it is, though

3 I have been told not to mention dates but I will.

4 Q. Actually, I wasn't saying which day in the week. I was thinking

5 of the date.

6 A. It was the 22nd of June.

7 JUDGE HUNT: You understand, Mr. Domazet, that this does open up

8 the whole of that issue. Your cross-examination on that particular issue

9 raises now, as part of the case in reply, about the date. If you remember

10 in the Ruling the Trial Chamber gave, that the Prosecution was not

11 entitled to lead evidence of that date because it was not a matter in

12 reply. But I did add, the cross-examination may raise all sorts of

13 issues and the Prosecution will be entitled to deal with them if they are

14 raised.

15 MR. DOMAZET: [Interpretation] Your Honour, I understand that, but

16 I also understand that you accepted the testimony of this witness as new

17 evidence and not as reply because I think it was said that it cannot be

18 testimony in reply, and I don't see how we can discuss this without

19 mentioning the date, because the date when this occurred, in my view, is

20 the key issue, in order to be able to judge whether the witness was able

21 to see Mitar Vasiljevic or not.

22 JUDGE HUNT: You are right. I should not have used the word part

23 of the case in reply. It was part of their reopening of their case in

24 chief. And I understand why you want to do it, as long as you understand

25 the consequences of it. That's all I was concerned to raise at this

Page 4518

1 stage. Because we did limit the reopening to the issue of the Red Cross.

2 I'm not criticising you in any way, I'm just making sure you understand

3 where we are headed once you ask that question, which is a perfectly

4 appropriate question in the circumstances.

5 MR. DOMAZET: [Interpretation] I understand, Your Honour. But

6 truly, it is extremely important to establish the exact date that the

7 witness is referring to, and in the draft report, I had this, and I had to

8 ask this question regardless of what the consequences may be in the

9 re-examination. I'm not afraid of that but I really do think it is

10 important to establish this. And that is why I have started along this

11 course.

12 JUDGE HUNT: I understand that entirely. It's a matter for you.

13 My only concern was whether you did understand the consequences, and you

14 clearly do. So you proceed.

15 MR. DOMAZET: [Interpretation]

16 Q. So, Madam, you said that this was the 22nd of June, 1992?

17 A. Yes, I did.

18 Q. Before I go on to another question, let me ask you, since we are

19 speaking the same language, to make a short break between my questions and

20 your answers for the benefit of the interpreters, to help them in their

21 task.

22 A. As far as I'm concerned, yes, that's fine.

23 Q. So my next question, Madam, is: How is it that you remember that

24 it was that particular date, the 22nd of June, 1992?

25 A. Let me tell you how. Because the convoy came to fetch us on the

Page 4519

1 14th of June to take us to Visegrad and they told us then; the people were

2 ready for the convoy, and then again a problem arose, Alija's state is

3 closed. There is no transport, you will have to stay for another seven

4 days and we will come back for you. And I remember that. And on that

5 day, the people from Koritnik left on foot, not in a convoy to Visegrad.

6 Q. Let me just ask you this.

7 A. Yes, please do.

8 Q. When you say, "that day, when the people from Koritnik," what day

9 were you referring to?

10 A. The 14th, the 14th. June, the 14th of June.

11 Q. So, Madam, on the 14th of June, you remember well - just please

12 let me finish because of the interpreters - so you remember that on the

13 14th of June, the people from Koritnik left for Visegrad and that you left

14 on the 22nd, so a week later; is that correct?

15 A. They came to fetch us that day but we didn't go.

16 Q. When you said the convoy came to fetch us, what do you mean? You

17 mean the trucks to transport you?

18 A. Yes, I'm thinking of the trucks. The trucks came on that day, the

19 14th, and we were told. We came as we said we would, because two or three

20 men would come every other day to tell us that we had to leave, and the

21 arrangement was made for the convoy to come and fetch us on the 14th, and

22 we were ready and the trucks came, these same three trucks. And they told

23 us, you see, Alija's state borders have been closed today so you can't

24 leave. It's better for you to stay in your own village and we'll come

25 back for you in seven or eight days or at least you'll be informed.

Page 4520

1 Q. You remember well that on that day, the 14th, the people from

2 Koritnik left but you did not leave your village, you left eight days

3 later. Are you quite sure of that?

4 A. Yes. I'm as sure as I'm sitting here on this chair.

5 Q. Perhaps we'll come back to that, but let me embark upon a

6 different path now that you followed yourself. When you were speaking

7 about your childhood and your school days, you said that you completed

8 four years of elementary school, I think?

9 A. Yes.

10 Q. Where did you go to school?

11 A. I went to school at Odzak, and Mitar's cousin, his uncle's son,

12 Rade Vasiljevic, sat at the same desk as me, Rade Vasiljevic and Bozo, I

13 think his name was Kovacevic, not Vasiljevic, and Krsta Bozic. We were

14 the same generation and we went to the same school in Odzak for three

15 years and then the fourth year in Klasnik. The fourth year was in

16 Klasnik.

17 Q. It seems to me I'm asking you one question; you're giving me a

18 different answer. I asked you when this was. You're telling me who you

19 went to school with. My question was when was it that you -- you

20 completed your four year education?

21 A. In 1958, I completed four years of elementary school.

22 Q. So that would mean that you started school around 1954?

23 A. I think so.

24 Q. Could you tell us when you were born?

25 A. [redacted].

Page 4521

1 Q. You said that in your childhood, you took care of the livestock

2 in that area. When was this?

3 A. I may have been 15 and 16 and even more. I already had a

4 boyfriend. And Mitar must have been eight at the time. Our properties

5 were next to one another. I don't know whether Mitar had his own land but

6 I know that there was property next to mine and that is where we met

7 often.

8 Q. Which is your property that was closest to the Djurevici village,

9 what was the name? Because you know various locations have various

10 names.

11 A. Yes, it was called Jela and it was between Djurevici and my

12 village. If you were to measure it, maybe it would be seven kilometres.

13 This was the plot that was furthest away from my house.

14 Q. From that piece of land, how far is the closest piece of land that

15 may have belonged to the Vasiljevic family?

16 A. I don't know Mitar's plot of land. I just know that this man

17 bordering on my land, and I don't know whether Mitar's plot is closer or

18 further away. This man's name -- the person neighbouring on my plot was

19 his neighbour. So I don't know. I'm just telling you what I do know. I

20 don't know where his land was.

21 Q. I have been told by him, so I'm asking you whether you can

22 confirm, that not a single plot of land belonging to his father was not

23 any nearer than one and a half to two kilometres to your land.

24 A. I wasn't interested in who owned which piece of land. I just know

25 that this man who bordered (redacted). I don't know

Page 4522

1 where Mitar's plots of land are, whether they were one kilometre or five

2 kilometres away, I don't know. I just know that I would see Mitar there

3 on this meadow bordering on mine.

4 Q. Could you allow for the possibility that what he said regarding

5 the position of his land is correct?

6 A. I simply don't know where any piece of -- [French translation] I

7 had my land and they had theirs.

8 JUDGE HUNT: We are getting both the French and the English

9 together. I'm not sure whether that's on both channels, but certainly on

10 channel four, we are getting the French there as well as the English.

11 Mr. Domazet, I don't know where this is heading. Certainly, I

12 don't want to restrict you in any way in your cross-examination but I'm

13 wondering whether this even goes to a question of credit. We have to rely

14 upon you to a very large extent, I understand that. If you can assure us

15 this is going to be tied up somehow to a relevant issue, we'll let you

16 continue.

17 MR. DOMAZET: [Interpretation] Your Honour, yes. That is precisely

18 what it is, I'm trying to establish the reliability in view of the

19 information I have been given by my client and also in view of what the

20 witness has told us. At the beginning, answering Mr. Groome's question,

21 because she spoke about this, that she played with other children and that

22 among them was Mitar, as a young boy. So I wanted to check this in this

23 way, because I was told something quite different by him.

24 JUDGE HUNT: If that is an issue, then you proceed, by all means.

25 MR. DOMAZET: [Interpretation]

Page 4523

1 Q. If I understood you correctly, when you were answering

2 Mr. Groome's questions, you said that children would gather in the meadows

3 and also at fairs, up to 20 of you from three or four villages?

4 A. Yes, three or four villages.

5 Q. And you sometimes said there were up to 20 of you?

6 A. Yes, I did.

7 Q. Could you tell us who else you remember from the Djurevici village

8 of Mitar Vasiljevic's age roughly?

9 A. Let me see. Regarding his age group, I don't remember, but I do

10 remember Mitar, Mitar knows well. There was no bus transportation there,

11 and then we would go to Djurevici and we would meet at the gate in his

12 neighbourhood. There wasn't just me. There would be 10, 12 members. My

13 father would go on to Bajina Basta.

14 Q. Let me ask you once again to concentrate and answer my questions.

15 I shall try and be as concise and clear as possible. So my question was:

16 In view of the age difference between you, I'm talking about the children

17 playing that you told us about, do you remember anyone else from the

18 Dzurevici village of the same age? You said no.

19 A. How do I know what -- how old the other children were there? I

20 just don't remember. I remember Rade Most, Bosko, then Krsta. He was

21 not of our age. There were children of different ages.

22 JUDGE HUNT: Madam, please do remember to pause before the --

23 before you give your answer. You came in far too quickly then, and the

24 interpreters had to catch up to you.

25 THE WITNESS: [Interpretation] I'm sorry, that's my mistake. It's

Page 4524

1 a habit I have.

2 MR. DOMAZET: [Interpretation]

3 Q. My last question in that connection, the people that you

4 mentioned, Rade, Bosko, and these other names, were they roughly of your

5 age?

6 A. Yes, the same age as me. We went to school together and we sat at

7 the same desk.

8 Q. A moment ago, Madam, you said, I think that it was in 1958 that

9 you completed four years of education. Did you go on to any further

10 schools after that?

11 A. No. My mother didn't let me and I'm -- I regret that to this

12 day.

13 Q. Again, you're telling me more than I asked you. Does that mean

14 that you continue to live in your own village and that was the village of

15 Dzurevici, I think; is that right? When did you get married and when did

16 you move to another village?

17 A. When I got married, [redacted]

18 [redacted].

19 Q. And since then, where were you living with your husband?

20 A. In Velika Gostilja.

21 Q. (redacted), when you got married, until 1992, that you told us

22 about, were you living continuously in that village?

23 A. Yes. I lived in that village but also I had a house in town. My

24 children went to school and I would occasionally go to see my children, to

25 take them what they needed and so on.

Page 4525

1 Q. I think that you mentioned that you came to Visegrad, to the

2 market. I assume to sell agricultural produce that you yourself

3 manufactured in the village?

4 A. Yes.

5 Q. You probably remember when there was a market in Visegrad?

6 A. Yes, of course I do. It was a Wednesday. On Wednesdays.

7 Q. On the market day, would there be more people, more crowds, than

8 usual in town?

9 A. Yes.

10 Q. Answering a question by Mr. Groome, you said that occasionally,

11 when you went to the market to sell your wares, that after that, you would

12 go to the restaurant for lunch, and that you would see Mitar Vasiljevic

13 waiting on you?

14 A. Yes.

15 Q. Which restaurant were you referring to?

16 A. The Panos Hotel and Vilina Vlas. He worked there as well.

17 Q. Let me ask you something else. When you say Panos Hotel, which

18 hotel actually do you have in mind? Because as far as I know, the

19 enterprise owning a large number of hotels is called Panos, so could you

20 tell me exactly which hotel you had in mind when you said the Panos Hotel?

21 A. There was one in town, which was actually called Panos. Then

22 there was a grill. Then there was a new hotel called Drina. And I was

23 thinking of this particular hotel in town that was actually called Panos.

24 Q. Are you thinking of the hotel that was next to the old bridge on

25 the Drina or some other hotel?

Page 4526

1 A. No, the other one, the one next to the old bridge was called the

2 new hotel. So I wasn't thinking of that one.

3 Q. And where was this other Panos Hotel located that you went to

4 lunch?

5 A. It was in the centre of town. I think that the closest shop to it

6 was one selling nails and things, hardware shop. It was a hardware

7 shop.

8 Q. So this Panos Hotel that you're referring to, how far is it from

9 the market?

10 A. I never measured it. Half a kilometre or one kilometre, I don't

11 know. I didn't measure it. It was the closest for me. It was closer

12 than the grill or the new hotel. So it was the first I would come across

13 returning from the market.

14 Q. Does this reply you gave just now mean that there were no other

15 restaurants, closer restaurants to the market than this one?

16 A. Yes, there was one selling grilled meatballs. It was privately

17 owned. But my husband liked to go to the Panos Hotel and he

18 liked to have a good drink, and I think Mitar knew him well because he was

19 an alcoholic, and I would go where my husband went.

20 Q. My question was that there was this grill next to the market but

21 after that this was the closest?

22 A. I couldn't really tell you whether this hotel called Cadjava was

23 closer or the Panos Hotel. I really couldn't say. I never measured it.

24 It didn't interest me.

25 Q. But you went to have lunch in the Panos Hotel in Visegrad. That's

Page 4527

1 what you said?

2 A. Yes.

3 Q. A moment ago, you mentioned, and also in answer to Mr. Groome's

4 question, you said that you also went to the Vilina Vlas Hotel?

5 A. Yes, I did.

6 Q. Could you please describe that hotel for me?

7 A. I'll be glad to. It's a hotel down the Drina, three or four

8 kilometres. I couldn't tell you exactly. And then the road turned to the

9 right and led to the former old spa, the old hotel, and from the -- after

10 the old hotel, a new hotel was built called Vilina Vlas. It was about a

11 kilometre away. I can't be sure about that. And I would go that way on

12 foot very frequently because the bus transport was not regular, and that

13 was the path I took. You would go by bus to Vilina Vlas, and from there,

14 it would be about five kilometres to my village on foot. And that is why

15 I know it well.

16 Q. I understand you. That is why you know that hotel very well.

17 It's a new hotel about one kilometre away from the old hotel at the old

18 spa?

19 A. Maybe, it may be a little more, a little less. I never measured

20 it.

21 Q. Yes. It's not very important. But just in order not to confuse,

22 it is a new, large building with a swimming pool and all?

23 A. Yes.

24 Q. You said that Mitar Vasiljevic waited on you in that hotel as

25 well?

Page 4528

1 A. Yes, but not as frequently. In Vilina Vlas, maybe just few times

2 he waited on me. I didn't meet him there that often. And my daughter

3 worked at the new hotel, at the spa and Vilina Vlas, and this is why I

4 went there often.

5 Q. Yes, so if I understand you well, you didn't go to that hotel to

6 eat as often but you went -- you would stop by there frequently because it

7 was on your way to the village there and your daughter worked there?

8 A. Yes. My daughter was a cook and this is where she got her job.

9 JUDGE HUNT: Please, Madam, do pause before you answer. You

10 really are making it very difficult for the interpreters.

11 MR. DOMAZET: [Interpretation]

12 Q. So this is what I want to know now. Now we are speaking about

13 this new, large hotel in Vilina Vlas where you went for these two reasons

14 that you've just listed. So is this the hotel where you used to see Mitar

15 Vasiljevic?

16 A. Yes, but not as often as at the Panos Hotel.

17 Q. And when you say not as frequently, do you mean that you did not

18 go to that hotel as frequently or you didn't see him there as frequently?

19 A. I would see him less frequently on duty there. Other waiters

20 waited on me there more frequently, whereas he used to wait on me more

21 frequently at the Panos Hotel.

22 Q. Do you remember perhaps which year it was when your daughter

23 worked there or had her internship at that hotel's kitchen? Do you

24 remember what year it was?

25 A. She graduated in 1992 and started working immediately. So if you

Page 4529

1 go back four years, this is where she went for her internship.

2 Q. So can I take it that between 1989 and 1992, during those four

3 years, she went there for her practical training and that this is the time

4 when you used to go and visit her there and see Mitar Vasiljevic?

5 A. 1988. But even before that, I used to go to that spa and see

6 Mitar there, even before my daughter was there.

7 Q. Yes, I see. But I'm trying to establish this period which is not

8 disputed because of what you remember about your daughter. So this is

9 1988-1992 period, and you said that you went there even prior to that?

10 A. Yes.

11 Q. Can you tell us, can you fix a point in time when you started

12 seeing him there, either at Vilina Vlas or at the Panos Hotel?

13 A. Well, I can tell you about the Panos Hotel but I can't tell you

14 about the Vilina Vlas one because, you know, I didn't really pay attention

15 to this. I just know that I used to see him there, that he worked as a

16 waiter there, but I can't tell you exactly when it was.

17 Q. All right. So I asked you about the time period before 1988, but

18 as far as the period after 1988 is concerned, you said that you remembered

19 this well because of your daughter who had her practical training there?

20 A. Yes, that's right.

21 Q. So you remember him as a waiter. Do you remember any other

22 waiters, and how many of them from Visegrad can you remember?

23 A. Well, I couldn't say. I know there was another one there. I

24 can't remember his name now. I know many waiters. I wasn't interested in

25 their names. And perhaps I wouldn't even be interested in Mitar except

Page 4530

1 that I knew him from my childhood as a neighbour and, of course, I knew

2 his name, but I wasn't actually interested in their names.

3 Q. So other than this waiter from Nezuk whose name you cannot

4 remember, can you give us any other names?

5 A. Well, I know Pipa, who used to work near the Panos Hotel, and

6 sometimes I would pass -- sometimes I would go to that establishment as

7 well because it was cheaper and you could get your lunch there quicker.

8 They had chicken there and -- and children used to go there to get their

9 food there, and they would simply dip a piece of bread into the chicken

10 fat.

11 Q. So you can't remember any other names?

12 A. Well, I know them by their faces but I can't remember their names.

13 Q. Madam, as I understood you when you spoke of 1992, this is when

14 you left Visegrad, and we also discussed the day that you described here,

15 and then you mentioned that your family was the last one to register

16 because you were trying to provide your own transportation and leave. Did

17 I understand you well?

18 A. I didn't want to provide my own transportation. My entire family

19 was protected because my brother-in-law was in Belgrade. He is my

20 father-in-law's son. And he was an officer, I think a major there. So I

21 sent my children, my sons and daughters-in-law, on the 4th of May while

22 the regular army was still in Visegrad. This is when they went to

23 Belgrade. My daughter-in-law went on the 4th of May and she delivered

24 her baby on the 6th of May. I remained back with my parents in law. And

25 we were protected. We escorted everywhere we needed to go. Nobody said a

Page 4531

1 bad word to me. Wherever I went, wherever I passed through, all I needed

2 to do was say who I was and I would be granted free passage. So nobody

3 ever hurt me and I heard -- I heard that many others didn't have my fate.

4 So this is why my family had the special status; this man Miloje attempted

5 to provide transportation for us and he came back to say that he wasn't

6 able to do so that day. We spent the night at the school, went back to

7 our village. I -- he suggested that we go back to our village. I didn't

8 want to do so. I told him, "I want to spend the night in your house."

9 And he said, "I would rather that you become a victim. Muslim officers are

10 leaving the army, and if I attempt to help you, then I will be regarded as

11 a traitor." And my children were safe with him.

12 Q. So if I understood you well, your children were with your

13 brother-in-law who was in the military in Belgrade. You said that he was

14 a Muslim just like you?

15 A. Yes. He is in Belgrade to this day.

16 Q. But at that time, in June of 1992, he was on active military

17 duty? He was an officer of the then Yugoslav People's Army?

18 A. Yes, he was, and he remained there to this day.

19 Q. Let us go back to Visegrad again. So at that time, due to all

20 this, you felt rather safe; isn't that so?

21 A. Yes. And I was safe. Nobody threatened me in any way wherever I

22 went, and I went every other day to look for transportation for my

23 mother-in-law who had a broken leg. I would normally go to SUP. My

24 brother-in-law told me to look for the SUP commander because he was a

25 school friend of his from Visegrad. So he told me to go and see him about

Page 4532

1 it.

2 Q. Well, does this mean that this move of yours from Gostilja to

3 Visegrad was something that you did on your own free will, or were you

4 forced to do that?

5 A. Well, nobody forced me. They came to the village to tell us that

6 we have to leave, but I went to the SUP and they gave me a certificate

7 saying that I could remain there with my parents-in-law under the police

8 protection. So I was there when that certificate was issued to me, and

9 they stamped it, and then I asked this commander, "Well, is this all of

10 the protection you can provide me? This is no protection for me. If

11 somebody comes and says something to me and I give the certificate to

12 them, they can just tear it up. So this is no protection, as far as I'm

13 concerned. What I want is that one of your men comes over here and takes

14 care of us, provides protection for us." And Miloje would do that. I

15 came there with Miloje. I came -- we went there in a Niva car. Ristic,

16 called Vlada, was the driver, and he was always kind to us. He never said

17 a bad word to us. So Miloje and Ristic and other neighbours from the

18 village, Vukoman, Pecencic, and there was another colleague of my husband,

19 he came many times to escort me to my village from the 4th of April when

20 this started. So he would come a number of times by bus to Prelovo, and

21 then from Prelovo, Rade would take me on to the village or wherever I

22 needed to go. So he's one of -- he was a decent man. He would always

23 accompany me and never said a bad word to me. And this is why I always

24 felt secure. Others were told that they needed to leave the village

25 within a month or two. We don't know. We were told this many times when

Page 4533

1 they came to our village.

2 Q. Well, what you just told us, who was the one to come and tell you

3 this? What were other people told?

4 A. Well, everybody would come to my house, all of the people. If the

5 people saw a large truck coming, they would simply disperse into the woods

6 and only the women would remain, and these people would directly come to

7 my door and give a message to me, what I needed to say to other villagers,

8 and this is how it was. And then they would go back.

9 Q. So you were the one to convey messages to others. What is it that

10 they were saying? You were mentioning something, a month or two until the

11 government is stabilised?

12 A. Well, yes, they were telling us, "Until the government is -- has

13 stabilised and then you can go back," and this is what they used -- "You

14 would resume your normal activities." This is what they would say to me

15 when they came to my door. And I went to these neighbours that my

16 brother-in-law told me to go and see, and I would say to them, "Well, it's

17 better to go to Hamed's house than to the house of my father-in-law." And

18 then they would say, "Well, we can't do that, because Markovici would come

19 right away to us and say that we got rich quickly." Miloje used to tell

20 me, "Don't do this. Go bring any of your belongings to my house. Well,

21 here is a house of another man called Cica, and maybe the war will last a

22 year, two years, five years, ten years. Maybe your children will be in

23 Canada, in the (redacted), in Australia, but at any point, the road

24 would be passable, and you would be able to come and get your

25 belongings." This is what he told me on the last occasion. I came back

Page 4534

1 and my father-in-law said, "No, I will not do this. I did this in 1941,

2 and I will not do this again." So he was right. You know, we accumulated

3 all that property for that many years and we didn't want to leave that.

4 So the following day, I went into town and I asked a neighbour of mine to

5 round up the bulls and to --

6 JUDGE HUNT: Madam, I realise that it is a habit of yours, but you

7 really --

8 THE WITNESS: [Interpretation] This is my personality. This is my

9 personality.

10 JUDGE HUNT: You're even interrupting me. Now, please, you are

11 making it extraordinarily difficult --

12 THE WITNESS: [No interpretation]

13 JUDGE HUNT: Please, Madam, stop. Stop. Just let me finish.

14 This is the problem. While you are trying to answer me, the interpreters

15 are trying to interpret what I'm saying for you. Now, you really must

16 stop and wait before you answer. I know it's going to be difficult for

17 you, but you are making it extraordinarily difficult for everyone when you

18 bounce straight in with your answer, especially if you interrupt. Now,

19 please, Madam, we are anxious to know what you are saying but we are going

20 to lose what you are saying if it's not interpreted for us.

21 Now, I'm just giving you some idea of how long it takes. The

22 interpretation of what I was saying has only just finished now and yet you

23 answered me sometime ago. So just take a deep breath and wait before you

24 give an answer.

25 Yes, Mr. Domazet.

Page 4535

1 MR. DOMAZET: Thank you, Your Honour.

2 Q. [Interpretation] So Madam, please try to wait for some four or

3 five seconds after every question, just as I do after every reply of

4 yours. You just told us in reply to one of my questions, that somebody

5 said that White Eagles are out of control. That was just one sentence of

6 yours. Did I hear you well? And if it is so, who was the one to utter

7 these words?

8 A. Mr. Rade Dikic, when I spent the night in his house. One day, I

9 went to call Rade to ask him to come with his car and take my

10 mother-in-law to see a doctor. Shall I continue? I'm not done yet. So

11 when I came to see Rade Dikic, he wasn't there, he had gone to Uzicka

12 Pozega, to a funeral of two soldiers that had been killed as Ustipraca. I

13 waited there and then the night came, and I didn't go back home that

14 night. I spent the night there in their house. And sometime around 10.00

15 p.m., Rade arrived, and then he told me that he was unable to do that

16 because the White Eagles were out of control. And then I said, "Well, why

17 wouldn't they set fire to a Serb house?" And then they laughed at me and

18 said, "They have a plan, and they implement this plan." This is what he

19 told me. Miloje used to tell me the same story, as did Vukoman.

20 Q. When you mention Rade Dikic with whom you had probably a close

21 relationship, can you tell us what was his function, what post he held at

22 the time?

23 A. He worked at Centrotrans. I don't know whether he had an office

24 job or he was a guard there. I don't know. [redacted]

25 [redacted]. Rade was always

Page 4536

1 very polite to me. He would inquire about my husband, how he was, how he

2 was doing there, and so on.

3 Q. Please don't mention names of your family members, because you

4 were provided protection here. So don't mention anybody's name, just say

5 "my husband" and so on. I hope that this name mentioning here will be

6 redacted.

7 So this Rade Dikic was not a government official or a police

8 official?

9 A. Yes, he was. He was a chief of police at the time. And my

10 husband was also a policeman. I think that was a reserve police. So Rade

11 -- before the war. So Rade was in the reserve police, as was my husband,

12 and they attended trainings and lectures and so on. I don't know what it

13 was. But I know that this is how it was.

14 Q. So if I understood you well, Madam, this Rade Dikic worked at

15 Centrotrans, but before the war he was a reserve policeman just like your

16 husband, so they knew each other before the war, and during this time that

17 you described to us, Rade Dikic had a post -- had a role in the police?

18 A. Yes. When the war started, Rade Dikic was assigning people in the

19 police.

20 Q. When you say he was assigning or working there, does that mean he

21 had a command post, that he was some kind of a chief there, either with

22 respect to reserve policemen or regular ones?

23 A. Well, based on what I heard, he used to assign people and

24 determine who would go where, and based on what he did that, I don't know.

25 This is what I used to hear.

Page 4537

1 Q. So in that conversation, when he mentioned those White Eagles, did

2 Rade Dikic tell you who were these White Eagles, were they people who came

3 from elsewhere, who were they? Did he tell you anything?

4 A. Yes. He said that they came from somewhere else, that they were

5 volunteers who came from Uzice, Cacak and so on. There were two brothers

6 there, and one went to get food from refrigerator. They even called me to

7 go and make dinner for them. And the other brother sat at the table and

8 he was sharpening his knife. The two of them belonged to White Eagles.

9 One of their units stayed at the hotel on the Drina. Once they came and

10 confiscated weapons that people had, legal weapons. So few days prior to

11 that, they came and collected all of those weapons. My father-in-law had

12 a hunting rifle. I wasn't at home and my son gave that rifle away.

13 However, they collected weapons and didn't issue any kind of certificates,

14 and when I came back, I said, "Well, you know, they came to collect

15 weapons today and you don't have any certificate to prove that it was

16 collected, and then somebody else will come and ask the same thing." So I

17 went to the SUP to ask for this certificate. And I know the driver who

18 brought these scum bags to the village. His name was Rade Simic and he

19 used to drive a bus before the war. And when he brought these people, he

20 did not leave the van. When they came to our village, they were masked.

21 Their faces were painted and they had socks over their faces.

22 Q. So, Madam, you are now describing that incident when they were

23 looking for weapons and then collected weapons in your village; isn't that

24 right? I didn't understand you quite well because you also mentioned

25 regular authorities, so can you please tell us who it was? And please

Page 4538

1 wait for me to finish my question. So were those regular then authorities

2 or did you have in mind people that belonged to White Eagles?

3 A. Well, those were our local people who came to collect weapons,

4 Sefer Novak and young men with them. They were all young men. And I am

5 not about to list their names. I don't want to do this for my children.

6 One of them actually went to school with my son. And he saved him a day

7 prior to that. They were in the same group, and they went to telephone,

8 and then somebody met them there, and then something bad was about to

9 happen to them but he saved him because he said, "He's my school friend."

10 And my son said, "Mom, if you see this man, let me know, because I would

11 send him a gift."

12 And on that occasion, they collected weapons. I later on went to

13 the police station but they wouldn't do anything to me. And then I went

14 to the military department and then there, a man told me, "Listen, I'm

15 telling you as I would tell my sister, don't go before the new year. If

16 you do this, you will never come back." And I did as he told me. I just

17 simply walked around that place. And as I passed, the soldiers were lined

18 up there. All of them had blue berets, and a lady was their commander and

19 she had a red beret. And all of them were armed. And I simply turned

20 around and immediately went home. This was when I was scared the most,

21 because I knew I wasn't protected then. And prior to that, I always felt

22 safe. But then, on that occasion, I did not feel safe.

23 JUDGE HUNT: Mr. Domazet, we will take the break now, but I think

24 I shall have to ask you this: We do have to finish the evidence of this

25 witness by the end of this week. And I don't say that facetiously. Have

Page 4539

1 you got any idea how long your cross-examination will be? I'm not in any

2 way trying to limit you but I'm trying to see whether we should extend the

3 sitting hours.

4 MR. DOMAZET: [Interpretation] No, Your Honour. I think that we

5 will finish even before the regular hours for today.

6 JUDGE HUNT: I hope that you are not being unrealistic in that.

7 It's all right. If we go into tomorrow, it doesn't matter. I don't want

8 in any way to limit you but I am just seeing that the way in which we are

9 going into all of these issues may extend the hearing a little bit beyond

10 what we had anticipated. But tomorrow, the next day, it doesn't matter as

11 long as we finish by the end of the week. There are no other witnesses

12 that you intend to call, are there, Mr. Groome?

13 MR. GROOME: No, Your Honour.

14 JUDGE HUNT: All right. We will resume again at 2.30.

15 --- Luncheon recess taken at 1.00 p.m.

Page 4540

1 --- On resuming at 2.32 p.m.

2 JUDGE HUNT: Mr. Domazet, do you think that you could assist us at

3 least to this extent? Is it your client's case that he just simply does

4 not know this witness and that she can't know him?

5 MR. DOMAZET: [Interpretation] I don't think that she doesn't know

6 him at all, but I do think that she wrongly identified him on the occasion

7 she is referring to because she probably hadn't seen him for a long time

8 and she didn't know him well.

9 JUDGE HUNT: I can understand all of that. But what is the

10 relevance, then, of this very long and detailed examination at the moment?

11 MR. DOMAZET: [Interpretation] Precisely for me to perhaps obtain

12 some information that would help us to establish the truth, since the

13 witness is certain about the date, and on that date, I submit, he simply

14 couldn't have been there. I'm trying to obtain some information,

15 especially about the persons she has mentioned, though I must admit the

16 witness has given some descriptions of the events of those days which I

17 consider to be relevant, generally speaking, for an assessment, an

18 overall assessment of what was going on in Visegrad at the time. However,

19 I shall try and focus on this particular point of relevance, that is, the

20 relevance of her testimony.

21 JUDGE HUNT: I want to make it clear I'm not intending in any way

22 to try to limit you. We are just trying to understand how we should be

23 looking at it. And you certainly are in a position where you are entitled

24 to explore these avenues. We don't want to stop you. We only wanted to

25 know what was the underlying issue. So please don't feel that you have to

Page 4541

1 limit your cross-examination in any way. But what you have said is of

2 assistance to us. We now see that a lot of her answers, for example, are

3 of no particular value because they do not deal with the issues you want

4 to, although they are clearly matters which the witness herself thinks are

5 relevant to your questions. I don't want to be seen to be criticising

6 either of you, you or the witness, but it was becoming difficult for us to

7 understand just where it was we were going. You have been of great

8 assistance in explaining why it is you have taken this line, and you

9 proceed with it in what way you see fit. The circumstances in which you

10 have been called upon to deal with this witness are such that I would not

11 stop you.

12 MR. DOMAZET: [Interpretation] Thank you, Your Honour.

13 Q. Madam, would you be kind enough when it comes to questions and

14 answers, please to make pauses because of the interpretation so that our

15 performance should be a bit better than it was this morning.

16 Speaking about the day when you were in front of the Vuk Karadzic

17 School and inside the school, you frequently mentioned the Vuk Karadzic

18 School and inside the school, you frequently mentioned a person that you

19 appear to know well, Miloje. Could you tell us who that person was and

20 what he was doing on that day?

21 [redacted]

22 [redacted]

23 [redacted]

24 [redacted]

25 [redacted]

Page 4542

1 [redacted]

2 [redacted]

3 [redacted]

4 [redacted]

5 [redacted]

6 [redacted]

7 A. Yes, [redacted] in the village into which I had married.

8 Q. And what is his surname?

9 A. Joksimovic. I even took some of my things to his place and he

10 helped to do that. I wanted to burn them, and he says, "Madam, don't

11 do that. You can bring whatever you like over here and leave them here."

12 "My house is small," he said, "but there is a house next door that hasn't

13 been completed yet and you can leave everything in there."

14 Q. Tell me, please, this person, this Miloje Joksimovic, did he

15 come when you were in front of the school and in the school?

16 A. Yes, he brought my mother-in-law and father-in-law and he looked

17 -- he went to look for transport for us to Belgrade, and he came back

18 immediately.

19 Q. Did he come back afterwards, when the person who was making those

20 records that you identify as Mitar was still there?

21 A. No. He didn't. Mr Ristic came and he told me -- he didn't call

22 me Madam. He called me by name, and he said I should take my

23 mother-in-law inside because Miloje hasn't managed to get transport for

24 you. A problem has arisen between your people and our people, and he

25 still hasn't come back.

Page 4543

1 Q. So that means that you were expecting Miloje to provide

2 transportation and that is why you stayed outside, and you thought that

3 you would be leaving by special transport?

4 A. Yes, yes, that's right.

5 Q. And you told us that this Ristic was there, too. Who is Ristic?

6 A. I didn't know him well but he was a relative of Miloje's. I think

7 his grandmother was from the Joksimovic family. I know the Ristics

8 well. There was a Ristic who went to school with me, and I asked him

9 which Ristic he was. He told me his name. He told me his name but I

10 don't remember it. His nickname was Gara -- Gaga, I'm sorry.

11 Q. So you don't know his real name. You know he was Ristic known as

12 Gaga?

13 A. He gave me his name but I haven't remembered it.

14 Q. This Ristic, was he there at the same time as the person you have

15 identified as Mitar Vasiljevic?

16 A. No. He went off with Miloje. He drove. Ristic drove the Niva

17 car.

18 Q. But you said he returned before Miloje and told you that Miloje is

19 unable to provide transportation, so they didn't go together?

20 A. They left together but they didn't come back together. Ristic

21 came back alone. Miloje did not come back.

22 Q. Could you please tell me this? When you were telling us how close

23 you were to this book in which the names were being entered, and I think

24 you said that he leafed through the book until he found a clean page.

25 Does that mean that there were other entries?

Page 4544

1 A. I don't know whether there were two or three pages, whether -- I

2 didn't read what was on it, whether there were names or something else.

3 But I did see it with my own eyes, just as I'm looking at the screen. He

4 leafed two or three pages over and then he found a clean page and started

5 writing down names, the names of my neighbours from the village.

6 Q. Do you remember, on this clean piece of paper, whether there were

7 ordinal numbers, 1, 2, 3, 4, and what was actually entered in the book in

8 addition to the first and last name?

9 A. I didn't notice anything else, whether there were numbers 1, 2, 3

10 or 5. Just as people gave their names, I saw him writing them down.

11 Because I didn't stand there all the time. As somebody was entered, I

12 would go and help those people to carry in their things if they were

13 elderly or weak or --

14 JUDGE HUNT: Madam, I'm going to have to ask you to restrain

15 yourself again. Please wait before you start your answer. It's terribly

16 important. Otherwise, we are going to lose what you are saying.

17 MR. DOMAZET:

18 Q. [No interpretation]

19 A. [No interpretation]

20 JUDGE HUNT: I hope that that isn't because you're having so much

21 trouble.

22 THE INTERPRETER: No, no, I'm sorry.

23 A. There was a Cira from Loznica who saw him.

24 JUDGE HUNT: But we didn't have the translation of the question

25 either.

Page 4545

1 MR. DOMAZET: I will repeat the question.

2 Q. [Interpretation] Because of the interpretation which is missing,

3 let me repeat the question. Could you tell me the name of another person

4 who was present and who saw this person who you've identified as Mitar

5 Vasiljevic?

6 A. Cira Dzuric. He was a police -- he was armed and Mitar was not

7 armed. I mentioned him. Cira came with the convoy on the trucks with

8 us.

9 Q. This Cira Dzuric, where was he from?

10 A. From the village of Loznica. He worked on the roads, repairing

11 roads.

12 Q. Apart from him, do you know the other persons who were there in

13 the school? You mentioned somebody's nickname, Cacanin, I think?

14 A. Yes, we found him there in front of the school, sitting at this

15 small table when we arrived. He was sitting at the table. But I didn't

16 know him from before at all. And there was somebody called Ivanovic from

17 Paocici. He recognised me when he arrived in the convoy and he called

18 me. My (redacted) And he said, "I

19 saw your sister (redacted) when she left with her husband for Zepa. I was

20 on guard and I let her pass and she is safe and well. Nobody hurt her."

21 He's the only one I knew. I didn't know the others. This Cira and this

22 Jovanovic.

23 Q. Can you tell us anything more about this Ivanovic, his name?

24 A. I know that he's from the village of Paocici and his wife's name

25 is Milica, and I've forgotten his first name.

Page 4546

1 Q. Is his name perhaps Mirad?

2 A. There were three brothers, so I'd rather not say. I may get them

3 mixed up. One of the brother’s name was Milorad. Whether it was his or

4 his brother's, I'm not sure. Radenko and Milorad, I know those were the

5 names of two brothers. I don't remember the third name.

6 Q. Throughout that time while you were there in the school and in

7 front of the school, did you notice any of the policemen or any kind of

8 security people in addition to those who came with you?

9 A. No, just -- I did on one occasion only. A soldier came and

10 introduced myself. I know he's from Foca. He entered the room where my

11 family was and he pushed my father-in-law, "And you old people have

12 gathered here, where are your extremists? They are all left in the

13 woods." And ran out to look for Ristic or for Miloje to tell them what

14 was going on. Then Ristic came and he said to this man from Foca, "Don't

15 touch his family. This family is protected. Their son is in Belgrade."

16 And then he left.

17 Q. Since you mentioned this and you also mentioned the number of 119,

18 they are women, children and elderly people; is that right?

19 A. [No interpretation]

20 Q. Does that mean that in these villages that you mentioned, Gostilja

21 and the villages around, that at the time when you left for Visegrad, no

22 men were left?

23 A. I will tell you but this will take some time.

24 Q. No, just answer my question, please.

25 A. No. Because 64 able-bodied younger men went to Zepa. I went to

Page 4547

1 the woods to collect them, when Rade Dikic came and Vukoman Pecencic, and

2 they said, "By tomorrow, I will guarantee their lives if I find them here,

3 but as of tomorrow, our army is coming. They are bringing dogs. They

4 will set fire to the woods, and then no one's life will be safe."

5 Q. And when was this in relation to this day?

6 A. It was the day before we left, and as soon as they left, I and

7 another person who was at my mother-in-law's, while all the others were in

8 the woods, I, too, spent one night in the woods, and then I came back the

9 next day. I had left my mother-in-law alone. We couldn't carry her.

10 She stayed behind, crying. And when I was bringing food to put it close

11 to her so she would have something to eat, I didn't know whether I'd come

12 back the next day. I thought I may not come back at all. And whatever I

13 brought to the table for her, she threw it down. Then this woman put a

14 bag of stuff on the table and she hit me with it.

15 Q. Please don't go into such details. That was not my question.

16 When you were talking about your visits to Visegrad, your visits to the

17 market and going to restaurants and coffee bars, you said you did so with

18 your husband?

19 A. More often alone than with him. Sometimes if my husband was

20 off-duty, he was with me.

21 Q. Tell me this: Is it customary in the environment in which you

22 lived, whether we are talking about Serbs or Muslims, for a woman to go to

23 a coffee bar or to a restaurant alone?

24 A. Yes and no. Some went, some never. I did because my husband was

25 a communist. He was not a hodza or a hajra, and I went to cafe bars alone

Page 4548

1 but there were women who never entered a coffee bar alone, at all.

2 Q. Talking about these women that didn't go to pubs, would it be

3 right to say that they were in the majority?

4 A. Yes, the majority. Only those whose husbands were communists

5 would go to these pubs alone.

6 Q. Madam, I was never a communist but my wife went.

7 A. I'm talking about us villagers. Women from towns might go, yes,

8 indeed.

9 MR. DOMAZET: I'm sorry.

10 JUDGE HUNT: It's all right, Mr. Domazet. You are, I think,

11 provoked into that. Madam, the court reporters are having a great deal of

12 difficulty because of the speed at which you're speaking. So when you

13 come to the end of a sentence or even a comma, may I suggest you also

14 pause slightly. It is very important that we get all of this down.

15 MR DOMAZET: [Interpretation]

16 Q. Madam, if I understood you correctly, [redacted]

17 [redacted], did he not?

18 A. Yes.

19 [redacted]

20 [redacted]

21 A. Yes. I can tell you this. He came for the weekend. He returned

22 on the 1st of April. There were already barricades there and they were

23 stopped. There were checkpoints.

24 Q. You also said today that after this day, that is the 22nd of

25 April, 1992, that that was the last time you saw Mitar Vasiljevic. Let me

Page 4549

1 ask you when, and under which circumstances, did you see him for the first

2 time after that?

3 A. I couldn't really tell you exactly, but I know when the first

4 barricade was in front of his house, this must have been in March.

5 Q. Madam, you're talking about the period prior to this. I'm talking

6 about the period after the 22nd of April, 1992.

7 A. I don't know what you mean, April of 1992.

8 Q. No, the 22nd of June. I'm sorry, my mistake.

9 A. Yes, you've confused me. I don't know what you're asking me.

10 Q. I'm sorry, my mistake. You were talking about the 22nd of June as

11 the last time that you allegedly saw Mr. Mitar Vasiljevic. My question

12 is: After that, and before you saw him today in the courtroom, did you

13 see him and when, in the newspapers, on television or -- and when did you

14 hear that he had been arrested?

15 A. To tell you quite honestly, from Bosnia when I was speaking to my

16 family members on the phone and they are in Sarajevo, they were the first

17 to tell me. You know what's new? A man from our municipality was

18 arrested today. He is such and such, that there was something in his

19 house. I didn't know that. They told me that on the phone.

20 THE INTERPRETER: I'm sorry, "that SFOR was in his house."

21 MR. DOMAZET: [Interpretation]

22 Q. When you heard that, did you remember that you had seen that

23 person on that date in Visegrad?

24 A. Yes, I did. I can say that. He didn't say anything bad to us in

25 front of the school, and that is why I remembered. Because I would hear

Page 4550

1 all kinds of things from others, doing much worse things than Mitar did.

2 So I have nothing more to say.

3 Q. What you're telling us about happened almost two years ago, wasn't

4 it?

5 A. I'm afraid I don't know whether it is a year ago or two years

6 ago. I don't know. I didn't pay any attention.

7 Q. So you learnt about this very soon after his -- he was taken into

8 custody. My question is: How did it come about that you should be a

9 Prosecution witness in this case?

10 A. When a team from here came to [redacted] to investigate, they came to

11 see my son-in-law. His brother was taken away from the partizan company

12 and while I was at the school, because my daughter had also left for

13 Belgrade with her daughter, and then they called us on the TV and the

14 radio, "We are calling the population of Visegrad to go back. If they

15 don't come back, they will lose their jobs." And this son-in-law of mine

16 came back, and in the bus, when he reached close to Visegrad, at the

17 petrol station which is at the entrance to Visegrad, the bus was stopped

18 there. There was a checkup and my son-in-law was taken out of the bus.

19 My daughter held on to him and this man was pushing her away. In the

20 meantime her colleague, I know her father's name was Burdus -- I don't

21 know what her name was. She was the girlfriend of this young man who

22 had taken my son-in-law, and she opened the door of a car and said, "Come

23 with me. If you don't come with me now, I'll break off our relationship."

24 But he didn't answer. I'm only taking him for half an hour to question

25 him briefly.

Page 4551

1 Q. You must notice, Madam, that we have digressed considerably. My

2 question is: How did it come about that you became a witness? You said a

3 team came to [redacted] to investigate. When was this, please? Will you

4 tell me?

5 A. That was last year in March. I don't remember the date. I didn't

6 know I'd be coming here so I didn't make note of it.

7 Q. So then on that occasion, did you personally, not other members of

8 your family, did you give any kind of statement to investigators?

9 A. Yes, I did. I told them all of this that I have just told you and

10 perhaps even five times more. My daughter -- I went to fetch my daughter,

11 to bring her with me to Belgrade, and she gave a statement to

12 investigators saying, "Perhaps my mother could tell you a bit more." My

13 daughter stayed there perhaps just an hour or two.

14 Q. My question was: Did you give a statement? Did you give a

15 statement? Did you sign a statement? Did you give any kind of statement

16 on that occasion?

17 A. The only statement I gave was the one referring to who registered

18 our names in front of the school, just as like -- as I told you here

19 today. I don't know anything else. I didn't say anything else about

20 these things that you asked me about.

21 Q. Well, I don't know if we understand each other well. Did you give

22 a statement? Was that statement read to you? Did you sign that statement

23 or not?

24 A. I was given newspapers to look at, to see whether I could

25 recognise anybody on those pictures. They put newspapers on the table,

Page 4552

1 they spread them. I looked at the newspapers and I immediately recognised

2 the person that registered our names, and then I signed my name over that

3 person's forehead, and the man that led this -- conducted this interview,

4 he signed his name below.

5 Q. Was that the photo spread that was shown to you today?

6 A. No. Well, yes. It wasn't the same picture. I also looked at a

7 picture last year, and when I came here this time, I was given newspapers

8 again to see if I could recognise somebody. And I again recognised

9 Mitar.

10 Q. And was that the same photograph of his?

11 A. Well, perhaps it was taken a bit later, because he looked chubbier

12 to me than then. I don't know, but it's the same person.

13 Q. When you say "chubbier," what exactly do you mean?

14 A. Well, let me use a term we would use in our village: Fat. And by

15 this, I mean his weight.

16 Q. So you are saying that there was a difference between those two

17 pictures, that he was fatter on one picture?

18 A. Well, something like that.

19 Q. In addition to that occasion when you say various photographs were

20 shown to you in March, and this other occasion, other than that, have you

21 had a chance to see any other pictures of him or any TV footage of him?

22 A. No. Because I work in the second shift, and I really can't watch

23 much TV. You know, I never come home before 10.00 or 10.30, so I really

24 can't watch much TV. Other people have told me that they've seen him on

25 TV but I personally didn't. I didn't.

Page 4553

1 Q. As you were telling us this, did you mean that this was taking

2 place while you lived in [redacted]

3 A. Yes. I couldn't go to Sarajevo for a long time. My whole family

4 remained in Sarajevo. My father-in-law came back three years ago when we

5 also had to come back and I spent that whole time in [redacted].

6 Q. So that means that you lived in [redacted]. The fact that you

7 travelled back home for vacation to Sarajevo is quite a different matter,

8 but that whole time, you lived in [redacted]?

9 A. Yes.

10 Q. Well, let us summarise in a different way what you told us during

11 last ten minutes just to make sure that we understood it well. So after

12 the 22nd of June, 1992, you told us that you never saw Mitar Vasiljevic

13 either in the papers or on TV, until the -- until March of 2001 - and

14 please do not interrupt me - until that time when various photographs were

15 shown to you and you believe that in those photographs, he was skinnier

16 and different than on this photograph that you were shown today?

17 A. Yes. There was a slight difference there. He was somewhat

18 skinnier, his hair style is the same. He simply looked thinner to me.

19 Q. Since today, you are still telling us that the person you saw on

20 the 22nd of June was Mitar. You identified him as Mitar, and you told us

21 that this is the same person that you used to see in the preceding years

22 in Vilina Vlas and so on. If he were to tell you that he never worked at

23 the hotel in Vilina Vlas, would it in any way change your today's

24 statement?

25 A. I don't know. All I'm saying is that I used to see him personally

Page 4554

1 in Vilina Vlas and that he used to wait on me. I said straight away that

2 I used to see him less often on duty there. I said that at the very

3 beginning.

4 Q. I'm telling you that he never worked there, and we can prove

5 that. You claimed something different. I don't want to go into his

6 whereabouts on the 22nd of June. I just wish to say the following, to ask

7 you the following at the end: In addition to these problems of yours that

8 you described, is there any other motive with respect to Mitar Vasiljevic?

9 A. No. I never saw him from the 4th of April up until that time when

10 I registered our names in front of the school. I went around, I saw many

11 people, but I never, ever saw Mitar in that time frame, and I can't say

12 anything else other than that.

13 Q. And why is it that you believe that this person that came to

14 register names was in fact Mitar Vasiljevic?

15 A. Because I've known him since childhood. I can tell you that we

16 were on the bus many times. He would get off on one bus before me to go

17 and visit his wife's family, Milica, and I know this for a fact.

18 Q. Well, Madam, perhaps you know this or you think that you know this

19 but I'm telling you that he wasn't present there on the 22nd of June.

20 I don't have further questions.

21 A. Thank you. If I'm not here now, then he wasn't there then.

22 JUDGE HUNT: Mr. Groome?

23 Re-examined by Mr. Groome:

24 Q. Madam, Mr. Domazet asked you about -- or you, in response to one

25 of his questions, talked about a protection that you believed your family

Page 4555

1 had and you talked about a certificate. My question to you is: Can you

2 tell us, if you know, the name of the person who gave you that certificate

3 which you believed protected you and your family?

4 A. It was Tomic, commander of the police station, SUP commander.

5 Q. And Mr. Tomic, the commander of the SUP station, do you know his

6 first name?

7 A. Well, to tell you the truth, there were two brothers. We called

8 them Tomic, just like they called me by my last name. Nobody used my

9 first name.

10 Q. So do you know the names of the two brothers or you don't know the

11 names of either one?

12 A. I used to know them, but I forgot. I think that I passed him,

13 this Tomic, many times. He came in a car and I was standing with my

14 daughter and the young man that was with my daughter said, "Well, there

15 goes Tomic," and that was the first time I saw him. I never saw him prior

16 to that. And then I approached him. And prior to that I never went to

17 the SUP.

18 Q. Now, Mr. Domazet has asked you about other people that you saw at

19 the Vuk Karadzic School on the same day that you say you saw Mr.

20 Vasiljevic. What I want to ask you is: Do you know a person by the name

21 of Milan Lukic and did you see him present at the school on that day?

22 A. Well, to tell you that as well, I didn't know Milan Lukic by sight

23 but I do know his parents well, because when I got married, Milan Lukic

24 was six years old. My sister had a daughter and she was same age as him.

25 They went to school together.

Page 4556

1 Q. Ma'am, on the day that you were at the school, did anybody

2 identify themselves as Milan Lukic to you?

3 A. Two men came, Cira and another, in a police uniform. They came to

4 the door. And they said, "Selam Aleykum." He said, "Where is Avdija

5 Sabanovic? Where is Murat Sabanovic? May they all fuck you." And when

6 he said all this to us, then he rolled his sleeve up and from on his

7 police shirt, we could see it was written police, Milan Lukic, and then he

8 introduced himself and said, "I am Milan Lukic, the greatest butcher in

9 Visegrad. Take a good look at me. If you have a camera, take a picture

10 of me. And then you can look at me when I go to Alija's state."

11 Q. And this person who identified himself as Milan Lukic, did he say

12 anything to the people regarding their property?

13 A. No, nothing. He just brought a cardboard paper and then threw it

14 on the floor in the middle of the hall, and said, "Everybody, all of you,

15 if you have any metal items on you, put them on this paper here because we

16 are going to search you. We had problems with a previous group that was

17 here at school." Those were people from Zlijeb, and allegedly they had

18 found a bomb among them. And our people started throwing various spoons,

19 forks, small knives. Whatever they had, they started throwing on that

20 piece of cardboard. And then I did that too. I took one of the spoons

21 for myself because I'd forgotten to take with me when I left my house, and

22 then he left for coffee.

23 Q. Ma'am, can you estimate for us the time that elapsed between when

24 Mitar Vasiljevic -- when you saw Mitar Vasiljevic leave and when in the

25 day this person who identified himself as Milan Lukic arrived at the

Page 4557

1 school?

2 A. Well, yes, I can. Mitar left definitely before 12.00, and Milan

3 Lukic came, it must have been after 4.00, because they came to tell me

4 that we needed to go into the school because they did not find transport

5 for us. So I entered the school shortly before Milan Lukic came to

6 school.

7 Q. Now, I want to ask you -- Mr. Domazet has asked you a number of

8 questions regarding your certainty that this was -- that your observation

9 was on the 22nd, and I want to ask you one or two questions regarding that

10 before.

11 MR. GROOME: But before I do, I'm going to ask that Prosecution

12 document 95, it will be a supplemental pseudonym sheet, that I'd ask that

13 it be distributed to the Chamber and then to the witness.

14 JUDGE HUNT: When you say a "substitute" one --

15 MR. GROOME: No. I said a supplemental one, Your Honour.

16 JUDGE HUNT: So it will be Exhibit P95.1, and it will under seal.

17 MR. GROOME: Thank you, Your Honour.

18 Q. When you were talking about the dates in response to questions

19 Mr. Domazet was asking you, you testified that on the 14th, you were told

20 that the people in your village had to leave on a convoy but that that did

21 not occur. And then you were told -- you said you gathered at the school

22 on the 22nd. So am I correct in saying that on the 21st -- on the 21st of

23 June, once again you were told to prepare yourself to leave on a convoy?

24 A. Yes.

25 Q. Now, I'm going to ask you to look at the sheet in front of you.

Page 4558

1 The name of this person is protected, just as yours is, so I'll just ask

2 you to refer to them by their number 18. In between the time that you saw

3 or first were told -- please let me finish.

4 A. If I'm able to do so.

5 Q. Please tell us, in between the time on the 14th, when you say you

6 were first told you had to leave, and the time on the 22nd, when you were

7 at the school, did you ever see this person, VG18?

8 A. Yes. That person was the one who brought the major piece of news

9 to us. That person came to our village, and then in this neighbouring

10 village called Polje, women started crying. A daughter of one woman burnt

11 in the fire. She was just a baby, perhaps 24 hours old. So this person

12 went to see that mother first. And when we heard her -- when we heard

13 somebody crying in front of that house, this woman was mourning for her

14 daughter calling her "my little birdy," this daughter of hers, and

15 somebody from their village, me and two more people, went immediately to

16 that village of Polje - it is some 20 minutes away perhaps - and then when

17 we got there, this woman was just walking around the house hitting herself

18 and saying, "Brothers and sisters, go into mountains, go into water, but

19 don't go outside. I don't have anybody here in my neighbourhood. They

20 torched everybody. They burnt everybody yesterday." And then she told

21 us, and they wrote down the names.

22 Q. Do you recall whether VG18 -- without telling the names of any

23 people, did VG18, did she have anybody with her?

24 A. Yes, her child. And this person said that Mitar Vasiljevic wrote

25 down their names, that he took them to the house of Jusuf Memic in

Page 4559

1 Pionirska Street and put them up there and gave them a sheet of paper

2 saying, "This is safe for you. Nobody will touch you." They believed

3 him. They believed it was going to be so. This encouraged them. And

4 then they had dinner and went to bed, and then somebody knocked on the

5 door. They opened the door, and somebody said, "We have to come in and

6 have a talk with you." So they said that two people came in, collected

7 all of their money and gold, and I don't know what else, and then, well,

8 they remained there in that house. And then an hour or two later - at

9 least this is how this lady described this to us - they came again and

10 knocked on the door, and then said, "It is not safe for you here. Why

11 don't we transfer you into another house where it will be safe for you?"

12 And then all of those people collected their belongings. It was

13 night-time. One of them went in front, one went to the right, one went to

14 the left, and one was in the back, so nobody could escape from that column

15 until they got to this other house where they put them up. This house had

16 a roof. It was Adem Omeragic's house. I know where that house was. They

17 opened the door for them. She didn't tell us who took them and put them

18 up in that house. She said, "It was 11.00 in the evening. I couldn't see

19 well who took us to that house and put us up there. As soon as we got

20 into that house, all of a sudden there was a spark and there was smoke,

21 and people started screaming. I was next to the window. I hit the window

22 with my hand and the glass cracked but I was unable to break it

23 completely. I simply collapsed by the window. And my child was with me.

24 My child fell down by me, and I felt that two or three people skipped over

25 me and left alive. And then -- and then after that, it calmed down, and

Page 4560

1 then I started crawling, crawled across the road into a sewer, and I

2 remained there until it started to dawn."

3 Q. Ma'am --

4 JUDGE HUNT: I think you have to get it made clear that this is

5 what she's being told by VG18; that's the first thing. And the second

6 thing is when, because she said it seems as if this was the day after the

7 fire. When you asked her, "Between the 14th and the 22nd, did you see

8 VG18," she just said yes without saying when.

9 MR. GROOME: Yes, Your Honour.

10 Q. I want to first ask you -- you're telling a story to us now and

11 you're using the word "I." Are you telling us what VG18 told you?

12 A. Yes.

13 Q. And what is your best memory about the date upon when VG18 told

14 you this?

15 A. I don't remember the date. I just know that it was after the

16 14th, because we were supposed to go on that day as well, and she told us,

17 "You were lucky that you didn't go that day because you could have been

18 set on fire on that day as well." But they told us they would come in

19 week's time to fetch us, seven to eight days, and this is exactly how it

20 was. We were counting minutes. We couldn't wait for those seven days to

21 pass.

22 Q. Ma'am, are you certain -- let me ask you this: This conversation

23 you had with VG18, was it before the event that you've described for us

24 that you saw Mr. Vasiljevic?

25 A. It was before I saw Mr. Vasiljevic. This incident took place

Page 4561

1 before I saw him.

2 MR. GROOME: No further questions, Your Honour.

3 JUDGE HUNT: Thank you, Madam, for giving the evidence and for

4 coming here to give it. You're now free to leave.

5 [The witness withdrew]

6 JUDGE HUNT: Mr. Domazet, we've got here the English version of

7 Dr. Krstic's curriculum vitae. If I recall, there was some discussion

8 about this at the time of the tender of the report, which is Exhibit D42.

9 Should we add it to that as Exhibit D42.1?

10 MR. DOMAZET: Yes, Your Honour, I think that is the best solution.

11 JUDGE HUNT: Thank you.

12 Any objection to that?

13 MR. GROOME: No, Your Honour.

14 JUDGE HUNT: Okay. Well, the curriculum vitae of Dr. Krstic will

15 be Exhibit D42.1.

16 Now, Mr. Domazet, I think we understand very well that you aren't

17 able to give us any precise estimate, but can you give us at least a rough

18 estimate of how long you need to prepare your case in response to this

19 witness's evidence?

20 MR. DOMAZET: [Interpretation] Well, Your Honour, you said it

21 right, that it is difficult for me to estimate it at this moment.

22 JUDGE HUNT: I'm only asking for a rough estimate. I think that

23 we've got to have some idea of where we are headed.

24 MR. DOMAZET: [Interpretation] Especially since you said that we

25 should finish it by Friday, if I'm not mistaken.