International Criminal Tribunal for the Former Yugoslavia

  1. 1 Wednesday, 4th March 1998

    2 (10.00 am)

    3 (The accused entered court)

    4 JUDGE RODRIGUES: Good morning, ladies and

    5 gentlemen, shall we continue with our case? Before

    6 that, I should like the Office of the Prosecutor to

    7 introduce itself, to have the appearances, please.

    8 MR. NIEMANN: My name is Niemann and

    9 I appear with my colleagues, Mr. Marchesiello and

    10 Ms Erasmus, for the Prosecution.

    11 JUDGE RODRIGUES: And for the Defence?

    12 MR. MIKULICIC: Good morning, your Honours,

    13 my name is Goran Mikulicic and with my colleague,

    14 Mr. Joka, we represent the Defence on behalf of the

    15 accused.

    16 JUDGE RODRIGUES: The interpreters are

    17 ready? In that case, we can continue with the

    18 testimony of Mr. Sivro, I think it was.

    19 (The witness entered court)

    20 Good morning, Sir. Do you hear me? You may

    21 be seated. I wish to remind you that you read a solemn

    22 declaration yesterday pledging to speak the truth, the

    23 whole truth and nothing but the truth. You are today

    24 in the same -- under the same commitment, yes?

    25 Therefore, you are going to answer questions that are

  2. 1 going to be put to you by the Prosecutor in

    2 continuation of yesterday's proceedings.

    3 Mr. Prosecutor, you have the floor.

    4 MEHO SIVRO (continued)

    5 Examined by MR. MARCHESIELLO (continued)

    6 Q. We are in fact resuming the chief examination

    7 which had been stopped yesterday in the afternoon. May

    8 I please ask the Registrar to put on the ELMO the map

    9 that had already been introduced into evidence and

    10 which was shown yesterday to the witness?

    11 Can you hear me, Mr. Sivro?

    12 A. I do, I hear you well.

    13 Q. Thank you. Before resuming and in order to

    14 let the judges know where the -- the history, the story

    15 Mr. Sivro is going to tell us, will you please show on

    16 the map and sign and circle with the pen the area in

    17 which you were at the moment you were being taken away

    18 from the frontlines?

    19 A. I can. (Witness marked photograph).

    20 Q. You were on the way from Jelinak to Strane,

    21 is it not so?

    22 A. No, we were first going from Jelinak towards

    23 Loncari.

    24 Q. Now, we left you yesterday in a very

    25 distressing and painful situation. You all, guards and

  3. 1 prisoners as well, were fleeing away from what seemed

    2 to be a very heavy BiH shelling, so let us resume at

    3 that moment. You had already been in a way sentenced

    4 to death, because the commander of the guards you were

    5 under -- you were with, as you said yesterday, had told

    6 them to kill you and now the only problem was to choose

    7 the place where you should have been executed. Please,

    8 go on with your story now.

    9 A. After -- we escaped the first threat of

    10 death, so to speak, when we reached the house where

    11 I think their command was, we continued our way to

    12 Loncari, because this house was still in the village of

    13 Jelinak at the bottom of the village. When we started

    14 off towards Loncari from that house, the only thing

    15 I thought of was how to escape, because I heard orders

    16 being given up there to kill us in the village of

    17 Loncari in a place called Bare; whether it was some

    18 kind of a pool or wood called Bare, I did not know.

    19 When we had almost reached the village, the

    20 shooting started from HVO weapons -- whether it was an

    21 anti-aircraft gun or anti-aircraft machine-gun. It was

    22 still dark, and they probably could not see the tree

    23 and the bullets were hitting this tree and the shrapnel

    24 from these bullets started showering upon us. When

    25 I saw that the guard was the first to lie down, I took

  4. 1 advantage of the opportunity and started to run, but

    2 I was third in the line and, when I turned around,

    3 I saw that the prisoner behind me was not there, but

    4 that he was running towards the right. I did not want

    5 to follow him, so I turned left, and I was going up a

    6 slope, and I was running.

    7 When I reached the top of this little hill,

    8 I saw large fields -- it was already dawning and I saw

    9 that it was wheat that was growing there. I ran across

    10 the wheat fields for about a kilometre, and, as they

    11 were on a slope, there were large fences between the

    12 fields so I jumped over them and, when I reached the

    13 end of those fields, I took a rest and I looked up and

    14 I saw two HVO policemen standing above me.

    15 I immediately raised my hands. One of them started

    16 shooting immediately, whereas the other one was calmer

    17 -- he asked me where I was from and he said, "So you

    18 have come here to slaughter our women and children" and

    19 I said that I had been captured and that I had spent

    20 time at the Kaonik camp, that I had not killed anyone,

    21 that I was a civilian. However, they were emphatic,

    22 they ordered me to lie down. I did. They took off my

    23 belt and tied my hands with it. They kicked me in my

    24 body and one of them, who had this rifle, hit me with

    25 the rifle butt on the head.

  5. 1 I had my head fractured in 20 different

    2 places. Luckily the butt was covered with rubber at

    3 the end so that the blows did not inflict heavier

    4 damage and I remained alive. I begged them not to kill

    5 me and I do not know whom I have to thank, but anyway

    6 they took mercy on me and they did not kill me. They

    7 took me back to the village, because nearby was an

    8 additional unit that had come to the assistance and

    9 they wanted to boast of having captured me.

    10 Among those soldiers I recognised a number of

    11 them, but one in particular and I addressed him. He

    12 was from Novi Travnik. I begged him to help me since

    13 he knew me. He just waved his hand and said more or

    14 less, "Never mind." The father of this man used to

    15 work for me and I was his foreman in the past.

    16 Then they decided to take me to the command

    17 after all. I begged them to report to the camp that

    18 they had found me and to hand me over there, but they

    19 did not have time for that and they said that they

    20 would take me to the headquarters in the village of

    21 Strane, so we set off towards the village of Strane.

    22 At one point in time they told me to crawl,

    23 and the path was muddy, because trucks had probably

    24 passed along that track overnight and they forced me to

    25 crawl in the mud, but, as that is impossible to do,

  6. 1 I had to lean on my head as well to be able to crawl

    2 and I think that I only covered three metres and then

    3 the soldier --

    4 Q. Sorry, did you have your hands tied up behind

    5 your back at that time?

    6 A. Yes, yes, my hands were tied all the time

    7 with my own belt behind my back.

    8 Q. Then you arrived at Strane to the HVO

    9 headquarters and what happened then?

    10 A. I just wanted before that -- I did not finish

    11 the story, telling you how he stepped on my head. He

    12 tried to suffocate me in the mud. He probably thought

    13 that I was done for. This went on for 10 or 20 seconds

    14 but I survived. I probably inhaled some of that water

    15 or mud, and I felt I was choking. My lungs could not

    16 start working again before I managed to spit it all

    17 out.

    18 Anyway, we went on towards the village of

    19 Strane. We got close to the village in a copse and

    20 they said, "let us not take him like this", because my

    21 appearance was terrible, my head was fractured, my

    22 teeth were broken, I was dirty. The Muslims still had

    23 not left the village. They thought it better for them

    24 not to see me. They said, "let us kill him here

    25 anyway". There was a big oak tree there, and I stood

  7. 1 against it and he fired 3 to 5 bullets, but the bullets

    2 did not hit me --they whizzed by my head 2 or 3

    3 centimetres away. Of course, I wet my pants, my legs

    4 gave way under me.

    5 Then the soldier said, "I could have killed

    6 you, but I did not want to". I could not get up. He

    7 helped me get up. He took me out of this wood, and the

    8 village was nearby --the village of Strane. He ordered

    9 me to sing as I was entering the village and I sang, of

    10 course, and we reached the HVO headquarters in that

    11 village.

    12 In front of the building, I saw three

    13 soldiers and a half-roasted calf was leaning against

    14 the wall. The fire had not been extinguished yet.

    15 They were all drunk, there was no commander in the

    16 headquarters, so I had to wait for him to come to

    17 decide what he would do with me. In the meantime

    18 I asked who was the commander, because quite a number

    19 of these boys were in the same dormitory as me when

    20 I went to school in Zenica so I was hoping I could find

    21 someone who would help me. Then I heard the

    22 commander's name was Ivica Andrijasevic. That is how

    23 I knew his name. They came, all beat me, each and

    24 every one of them, but the worst beating was when they

    25 asked me, "what is the name of this State?". I said,

  8. 1 "Bosnia Herzegovina", I said "Croatia", whatever

    2 I said, they beat me. I just could not remember to say

    3 that the name of the State was Herceg-Bosna. They beat

    4 me, they thought I was stubborn and I did not want to

    5 give them the name of the State.

    6 In the meantime a Muslim came by. They

    7 ordered me to crawl under a vehicle, a very old vehicle

    8 with the tyres that were flat and even a cat could not

    9 crawl under it, but they insisted and they kicked me

    10 but I just could not.

    11 Then I started begging them to kill me.

    12 I did not feel the pain so much anymore because I was

    13 all swollen by then, I was all numb. Then one of them,

    14 drunk as he was, asked the commander, "Let me slit the

    15 throat of a balija for once in my life". He said, "Go

    16 ahead, do it, but at the end of the village and make

    17 him dig his own grave first". He accepted this with

    18 joy. He took me along their frontlines to the end of

    19 the village. All of them beat me, but I remembered one

    20 more than the others, a blond fair man, who sort of

    21 encouraged me, who swore at them and cursed their

    22 Ustasha mothers for mistreating me. When I started

    23 believing he was going to help me, he kicked me, in

    24 between the legs. Of course I fell. I do not know for

    25 how long I lay there. He lifted me up and we resumed

  9. 1 our way. Some soldiers followed us, probably to watch

    2 the spectacle of me being slaughtered. This soldier

    3 who was leading me took out a knife, and he --he had

    4 turned the blunt edge of the knife under my neck.

    5 Again, I wet my pants from fear. And that is

    6 how we reached the end of the village. I kept thinking

    7 of the horrible death awaiting me when he was going to

    8 slit my throat. He told me to turn around --I did

    9 --and he emptied his whole magazine. I just felt that

    10 I had been hit in the left arm. I stood there for a

    11 couple of seconds maybe. Whether I was dreaming or

    12 I really experienced something, and I heard a sound --

    13 it seemed to me -- saying "run", and this soldier who

    14 had emptied his magazine, he wanted to recharge and

    15 fire again, but as he was drunk, he just could not fix

    16 his rifle properly. So I jumped up and I threw myself

    17 over a fence.

    18 As it was very cold that morning, the grass

    19 was totally white from the frost and, when I threw

    20 myself over this fence, it was as if I was wearing skis

    21 and I skidded across down the slope. The people who

    22 had come to watch started shooting, but by then,

    23 because this was a slope, I had already put quite a

    24 distance between us and they started shooting at me.

    25 At about 80 metres away there was another fence,

  10. 1 I thought I would not be able to stop there, that

    2 I would hit against this fence, because I had gained a

    3 lot of speed, but it was as in a film, I managed to

    4 stop, to jump over the fence again, and I found myself

    5 among the houses of Gavro Katici. There is a petrol

    6 station there.

    7 I tried to cut off my arm there because I was

    8 still tied up. This arm was just hanging on the skin.

    9 But as I tried to break it off, the belt slipped away

    10 from my hands, so I rested a while and I saw that they

    11 were not following me. I realised that this was

    12 no-man's land and that is why they were not following

    13 me.

    14 I cleaned up a little bit, and I collected

    15 myself and ran across the road to the petrol station.

    16 I ran, but I heard shots. Because there was a

    17 clearing, and then I thought: what should I do? If

    18 I run to the left, where our territory was, the

    19 territory controlled by the BH army, an automatic rifle

    20 would be there waiting for me and, if I ran in their

    21 direction, then, again, I would probably reach Lasva

    22 before they noticed me. So I ran and close to Lasva

    23 they started shooting at me. I jumped into the Lasva

    24 River and wet, beaten up, my right hand would not

    25 function -- whether it was a cramp or what, I do not

  11. 1 know. I had on me a thin raincoat and I had shoved it

    2 into my trousers and, luckily, it swelled up a little

    3 and it served like a balloon and helped me surface.

    4 I went along the left side of the Lasva,

    5 because I was afraid on the right-hand side they would

    6 see me and shoot me.

    7 The Lasva was bloody with my blood -- I must

    8 have been bleeding a lot -- and when I felt that my

    9 right arm was coming to again, I went as far as the

    10 bridge, about 200 or 300 metres down river. I got to

    11 the right bank, I got hold of a branch and got out.

    12 They continued firing, and, when I got out, it was

    13 probably the BH army that realised what was happening

    14 and I heard voices saying, "Hurry up, there is a sniper

    15 following you." I ran across the ploughed fields,

    16 I heard the shots whizzing past me, but, luckily, they

    17 did not hit me. The distance between the Lasva River

    18 and the railroad is about 500 metres.

    19 I heard voices saying, "Cross the railway

    20 track and rest there", and that is what I did.

    21 I rested for a while on the other side of the tracks

    22 and I was probably unconscious for a while and, when

    23 I felt I had the strength, I started climbing up

    24 towards the village of Merdani. By then I knew that

    25 I was exposed to the sniper fire, but I thought to

  12. 1 myself: I will try and whatever happens will happen.

    2 I managed to reach the first house, and I kept hearing

    3 exchanges between members of our army -- there was

    4 somebody saying, "Do not run into that house, go to the

    5 fourth house" and I managed to reach the fourth house.

    6 There was a nurse waiting for me; she gave me an

    7 injection and after that I was transported to the

    8 Zenica hospital.

    9 Q. What about your arm, did you recover it?

    10 A. Yes, I had to undergo four surgeries.

    11 I think I can use it up to 60 per cent. I was also

    12 injured in my head.

    13 MR. MARCHESIELLO: I have no other questions,

    14 your Honour.

    15 JUDGE RODRIGUES: Mr. Mikulicic, do you wish

    16 to put any questions to this witness?

    17 MR. MARCHESIELLO: Can we suspend for

    18 5 minutes? I see the witness is in a difficult

    19 psychological situation.

    20 JUDGE RODRIGUES: Yes, maybe we could have a

    21 15 minute break then.

    22 (10.29am)

    23 (A short break)

    24 (10.50am)

    25 JUDGE RODRIGUES: Mr. Sivro, we have deep

  13. 1 respect for what you have been through. Are you able

    2 to continue? Are you feeling okay now?

    3 A. Yes, yes -- yes, we can -- I do apologise to

    4 the court, but I just could not help it.

    5 JUDGE RODRIGUES: We do understand.

    6 Mr. Mikulicic, do you wish to put questions to this

    7 witness?

    8 MR. MIKULICIC: Your Honours, my co-counsel,

    9 Mr. Joka, will be asking questions of this witness.

    10 JUDGE RODRIGUES: The floor is yours,

    11 Mr. Joka.

    12 Cross-examined by MR. JOKA

    13 Q. My name is Mr. Joka, I am Defence counsel for

    14 the accused. First of all, on my own behalf and on

    15 behalf of my colleague, I wish to express our deep

    16 sympathy for what you have been through and for what

    17 you are suffering and, also, that we are glad to see

    18 that you are well now, and do believe that it is really

    19 from the heart. We will not have many questions for

    20 you. I just wish to confirm something and see if

    21 I have properly understood you.

    22 After your first escape, when you were first

    23 captured -- after which you were captured?

    24 A. Yes.

    25 Q. Am I right in understanding that you were

  14. 1 detained in Kaonik and after that you asked to be

    2 returned to Kaonik?

    3 A. Yes, I did explain that. I explained to them

    4 that I was a detainee and that I came -- had come there

    5 to dig trenches and I begged them to take me back, or

    6 to call the prison, and I begged them to be returned to

    7 Kaonik.

    8 Q. Now, I have to ask you why you did that, why

    9 did you beg them to do that?

    10 A. Because I simply thought that there was no

    11 more life for me otherwise.

    12 MR. JOKA: Thank you, no more questions.

    13 MR. MARCHESIELLO: No questions, thank you.

    14 JUDGE RODRIGUES: Mr. Sivro, you have

    15 completed your testimony here. Thank you very much for

    16 having come here to the Tribunal. We wish you a safe

    17 return to your country and thank you very much.

    18 A. Thank you.

    19 (The witness withdrew)

    20 JUDGE RODRIGUES: Prosecution, do you have

    21 another witness?

    22 MR. MEDDEGODA: The Prosecution will call

    23 its next witness, Mr. Edib Zlotrg.

    24 JUDGE RODRIGUES: Do we have to apply any

    25 protection measures for this witness?

  15. 1 MR. MEDDEGODA: None whatsoever.

    2 (The witness entered court)

    3 JUDGE RODRIGUES: Good morning, Sir. Can

    4 you hear me? Would you please read the solemn

    5 declaration that the usher is tendering to you?

    6 A. I solemnly declare that I will speak the

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

    8 JUDGE RODRIGUES: Please be seated.

    9 Thank you for having come to the International Criminal

    10 Tribunal. You are now going to answer questions that

    11 will be put to you by counsel for the Prosecution,

    12 Mr. Meddegoda. Mr. Meddegoda, the floor is yours.


    14 Examined by MR. MEDDEGODA

    15 Q. Could you please state your full name for the

    16 purposes of the record?

    17 A. My name is Edib Zlotrg.

    18 Q. Your date of birth?

    19 A. 21st of October 1953.

    20 Q. You are Bosniak by ethnicity?

    21 A. Yes.

    22 Q. And your religion is Islam?

    23 A. Yes.

    24 Q. Witness, what is your current occupation?

    25 A. I am a forensic expert -- I work for the

  16. 1 police.

    2 Q. Have you followed any courses in forensic

    3 science or forensic technology?

    4 A. Yes, I have.

    5 Q. And what courses of study have you followed?

    6 A. I completed two courses -- two 6-month

    7 courses -- to be trained as a forensic technician.

    8 Q. Where did you follow these courses of study?

    9 A. In Sarajevo.

    10 Q. In what educational institution was that?

    11 A. It was an institution belonging to the

    12 Ministry of the Interior.

    13 Q. And, today, to which police station are you

    14 attached?

    15 A. The police station in Vitez.

    16 Q. And there you work as a forensic technician?

    17 A. Yes, since 1992.

    18 Q. Witness, in 1993, where were you residing?

    19 A. In Vitez, in Marsala Tita Street, number BB.

    20 Q. Do you recall the date 19th April 1993?

    21 A. That is the day I was arrested by members of

    22 the Vitezovi unit, which was an HVO unit.

    23 Q. What time of the day were you arrested by the

    24 members of the Vitezovi unit?

    25 A. I was arrested at 7.30pm.

  17. 1 Q. Do you know which members of the Vitezovi

    2 unit came to arrest you on that day?

    3 A. One of them was a colleague of mine from the

    4 police station, who used to work in the communications

    5 section, and his name is Drazenko Rados.

    6 Q. What was he wearing at the time he came to

    7 arrest you?

    8 A. He was wearing a camouflage uniform and had a

    9 coat of arms on his sleeve with "Vitezovi" written on

    10 it.

    11 Q. Do you know who the commander of the Vitezovi

    12 unit is -- or was at the time?

    13 A. Darko Kraljevic.

    14 Q. When the Vitezovi members came to arrest you,

    15 did they say to you why you were being arrested?

    16 A. No, they did not -- they just insulted me.

    17 They cursed me, my State and they asked me how come

    18 I was not in Stari Vitez to defend Alija State and

    19 similar things.

    20 Q. Could you tell this court what happened when

    21 they came to your house in Marsala Tita Street in

    22 Vitez?

    23 A. When they entered the building, I happened to

    24 be at my neighbours on the second floor and we were

    25 watching news. There was a shelling of Zenica on that

  18. 1 day and many civilians were killed in front of the

    2 department store. This colleague of mine came in and

    3 he attacked me -- he accused me of hiding from them,

    4 and it was impossible to hide from them in that

    5 apartment. So, from my neighbour's place, he took me

    6 to the fourth floor where I lived, together with

    7 another member of the Vitezovi unit and there they

    8 searched me. They asked me whether I had any weapons,

    9 because they knew I had weapons officially assigned to

    10 me, but, prior to that, I had handed over my weapons to

    11 the municipal headquarters of the Territorial Defence

    12 and I had a valid permission for that, a valid

    13 certification for that, which I produced to them and,

    14 again, they cursed me, my State, my President, and they

    15 wanted to know how come I was there, how come I was not

    16 defending my State in the place called Mahala, and that

    17 is how they referred to Stari Vitez, to the town of

    18 Stari Vitez.

    19 Then Drazenko was surprised that I was still

    20 alive and I said, "You can see for yourself, I am

    21 alive." So he told me to take my things with me and we

    22 left the building. They put me in a van, where there

    23 was some elderly men and, from there, we were taken to

    24 the Workers' University, to the basement of the

    25 building.

  19. 1 Q. Now, that is the building which is called the

    2 Radnicki University building?

    3 A. Yes.

    4 Q. Could you tell this court what this Radnicki

    5 University building was?

    6 A. It was a building with some offices --

    7 offices belonging to the League of Communists, to the

    8 union -- there were also premises that were used for

    9 adult education and there was also a cinema hall there.

    10 Q. When you were brought there, were there

    11 others already detained in the basement where you were

    12 brought to?

    13 A. That basement used to be the boiler room of

    14 the building, and it was crowded, so, from one end to

    15 the other, you really have to elbow your way through

    16 the room. It was completely crowded and I think that

    17 there were some 250 people there, maybe more, so, when

    18 I was brought in, I realised that there were many

    19 people I knew, many acquaintances, and they expressed

    20 their condolences to me because they heard my brother

    21 and my sister-in-law had been killed. But they were

    22 also laughing, because apparently they had heard that

    23 I was also killed, together with my wife, so they were

    24 actually glad to see me alive.

    25 Q. You said it was fully crowded with about 250

  20. 1 people. To what ethnic group did these people belong?

    2 A. They were all Muslims.

    3 Q. Did you happen to know any of those persons

    4 who were detained at the time you were brought in?

    5 A. Of course, yes.

    6 Q. And for how long did you -- were you detained

    7 in this basement of the Radnicki University building?

    8 A. Since they kept bringing more people every --

    9 all the time, the place became really crowded, so,

    10 after a few days, they offered to take a group of

    11 people to the cinema hall. There were no windows in

    12 the cinema hall, so I went to the cinema hall together

    13 with some other 50 or 60 detainees. It was maybe three

    14 or four days after we were detained.

    15 Q. Do you remember being taken out of this

    16 cinema hall during the period you were detained?

    17 A. Yes.

    18 Q. And, when was that?

    19 A. It was on the 24th, at about 10pm.

    20 Q. Were others taken out with you on the 24th --

    21 the evening?

    22 A. Yes, they were. There were two or three of

    23 us that were taken from the cinema hall and more people

    24 were brought from other camps, so there was a group of

    25 about 10 people.

  21. 1 Q. And do you know -- do you remember where you

    2 were taken to from that place?

    3 A. They took our names down, and they put us in

    4 a van, and transferred us to the village of Nadioci, to

    5 the location called "Bungalows", and we got off the van

    6 and the guards ordered us to march with our hands

    7 behind our back. The driver and the escort went to the

    8 Bungalow, and I heard my former colleague, Vladimir

    9 Santic, laugh at that time. He said something like,

    10 "I know him for a very long time, we are

    11 acquaintances", and things like that.

    12 Q. For how long did you spend at the Bungalow in

    13 Nadioci?

    14 A. We stayed there for about an hour, an hour

    15 and a half and from there we were taken to Kaonik.

    16 Actually, at that time we did not know where we were,

    17 but when we got off the vehicle, we found a lot of

    18 civilians there, 50 or 60 civilians were already there

    19 and they told us that it was a camp -- the Kaonik camp.

    20 Q. So what time was it when you reached the

    21 Kaonik camp?

    22 A. I -- it must have been some time after

    23 midnight.

    24 Q. Would you describe to this court what

    25 happened upon reaching the Kaonik camp?

  22. 1 A. When we arrived in Kaonik camp, the escort of

    2 the driver, who was a member of the HVO, gave the list

    3 with our names to the guard and they put us into a

    4 hangar. There was only one stove in that hangar, and

    5 in the right corner there was a row of wooden pallets

    6 and people were sleeping on them. Those who were not

    7 fortunate enough to have a pallet were -- had to walk

    8 around the hangar or try to warm themselves near the

    9 stove.

    10 From the conversation I had with people over

    11 there, I learned that there were some people who had

    12 been there for about 25 days -- people who were

    13 arrested while travelling on a bus, or a truck, and

    14 there were even some workers from the Bratstvo

    15 factory. Apparently they simply move the entire bus of

    16 people to the Kaonik camp. There were people from

    17 Busovaca there, from the village of Strane and other

    18 villages I do not know very well. But there were quite

    19 a few people from the vicinity of Busovaca.

    20 During my time in Kaonik, at the beginning of

    21 my time in Kaonik, there was a group of people who had

    22 just returned from trench digging, and they said that

    23 killings were quite usual and that people also often

    24 got wounded while trench digging.

    25 An elderly man whose name I cannot remember

  23. 1 told me a story about a young HVO soldier who took a

    2 sniper rifle, put it on his shoulder and started firing

    3 after that -- in the direction of the BH army lines,

    4 and, after he reacted, apparently this young HVO

    5 soldier then went together with him to the shelter.

    6 Q. You do not recall the name of this elderly

    7 man who narrated this story to you -- narrated this

    8 incident to you?

    9 A. No, I do not.

    10 Q. For how long were you kept in the hangar of

    11 the Kaonik camp?

    12 A. Until the 25th -- until 10, 11, and that is

    13 when they came back to pick us up.

    14 Q. When they picked you up around 10 or 11 in

    15 the morning, were you taken anywhere?

    16 A. Yes, we were. Again, they put us into the

    17 Volkswagen van and they took us to the place called

    18 Kratine; they took us to Miroslav Cicko, who was in

    19 charge there, and we were supposed to dig trenches

    20 there.

    21 Q. About how many people were taken in the

    22 Volkswagen van to the place called Kratine?

    23 A. There were 10 of us, but there was already

    24 one group of other people there, so there were about 15

    25 or 20 of us at Cicko's location.

  24. 1 Q. Do you know who this Cicko is, or Miroslav,

    2 or Cicko is?

    3 A. Yes, I do -- he is a member of the HVO

    4 Croatian Defence Council, who, in 1992, committed a

    5 crime in the village of Nadioci. He called Esad Salkic

    6 and I was in charge of the investigation on behalf of

    7 the BH army. On that occasion, members of the HVO

    8 police told us that Miroslav Bralo had been arrested

    9 and that he was in prison. There is a video recording

    10 of that.

    11 Q. Were you surprised to see Miroslav Bralo when

    12 you in Kratine that morning?

    13 A. Of course. According to the information

    14 I had, he was supposed to be in prison, because he had

    15 committed a heinous crime.

    16 Q. And did he speak to the detainees who had

    17 been brought for trench digging, or did he address the

    18 detainees?

    19 A. When we got there, he lined us up in sort of

    20 half a circle, and he stood in the middle and he said

    21 that we were not Muslims, that we had never been

    22 Muslims, and that we were Croats, that we no longer had

    23 our religious institutions, that everything had been

    24 demolished by them and that we would continue being

    25 Croats. So he said that he was having a kind of

  25. 1 competition with a member of the HVO in Busovaca as to

    2 who will kill more Muslims, and apparently he had

    3 killed about 80 women and children.

    4 Q. What else did Cicko Miroslav ask you to do?

    5 A. He wanted us to learn to make the sign of the

    6 cross. He made us do it several times and he made one

    7 man from the previous group show us how to do that, and

    8 after about half an hour, when his training was

    9 supposed to finish, he came back to see whether we had

    10 learned how to make the sign of the cross.

    11 So, my group, all 10 of us, except for one

    12 gypsy, we all knew how to make the sign of the cross,

    13 but he did not, this gypsy man, so Miroslav Bralo came

    14 back and some 10 or 15 metres away from the command

    15 building, he took an axe and he turned the blunt part

    16 of the axe above the head of that person and he said,

    17 "If you cannot do it now, this is it", so that person

    18 was probably frightened and he managed to do it the

    19 right way, he managed to do the sign of the cross. So

    20 Miroslav Bralo made him do it 10 times so that this man

    21 would make a mistake so that he could kill him, but he

    22 managed to do it properly all 10 times, so finally he

    23 had to give up.

    24 Q. Do you remember Miroslav Bralo bragging about

    25 one particular killing that he had committed?

  26. 1 A. Yes.

    2 Q. What was that?

    3 A. I think it is the incident that happened on

    4 the 26th in the afternoon, as we were resting during

    5 the lunch break, while we were digging trenches at the

    6 line in front of the command building, an HVO patrol

    7 brought three men to that place and they handed them

    8 over to Miroslav Bralo. The only thing we could

    9 observe at that time was that those young men were

    10 crawling across the field, and that he was taking them

    11 somewhere. After we came back, the guards told us that

    12 those three young men were from the village of Loncari

    13 and that they were hiding in a house and that they were

    14 caught by a patrol and brought over there, so Miroslav

    15 Bralo apparently tied their hands behind their backs,

    16 and they -- he made them clean up the field, and they

    17 had to do it with their teeth and their mouth and,

    18 after that, he took them to a pond in the vicinity of

    19 the headquarters, and the guard told us that whoever is

    20 taken -- whoever was taken to the pond to that location

    21 will never come back; and, indeed, we never saw these

    22 three young men again. They were probably slaughtered.

    23 Q. For how long did you have to dig trenches at

    24 Kratine, witness?

    25 A. On the 25th, at 11 o'clock, we started, and

  27. 1 we finished on the 26th at 10 o'clock, with short

    2 breaks for lunch, maybe one-hour breaks.

    3 MR. MEDDEGODA: Your Honours, may I seek your

    4 Honours' permission to show to the witness an excerpt

    5 of Exhibit P4? It is a map of the area where he was

    6 taken to for trench digging. There are copies for your

    7 Honours and a copy for learned counsel for the Defence,

    8 your Honours.

    9 (Handed).

    10 JUDGE RODRIGUES: Please, Registrar, could

    11 you give us the number of the exhibit?

    12 THE REGISTRAR: It is exhibit number 62.

    13 JUDGE RODRIGUES: Please, go on,

    14 Mr. Meddegoda.

    15 MR. MEDDEGODA: Witness, could you please

    16 look at the map on the ELMO and, using the pointer,

    17 point out the place, to the place called Kratine to

    18 which you were taken for trench digging on the 25th of

    19 April? (Witness indicates on photograph).

    20 MR. MEDDEGODA: Could you please, using one of

    21 the highlighters on the table, circle that area and

    22 mark the area with the letter "A". (Witness marked

    23 photograph).

    24 I move that Exhibit P62 be admitted into

    25 evidence, your Honours.


    2 MR. MEDDEGODA: After trench digging,

    3 witness, until the 26th, the morning, where were you

    4 taken to?

    5 A. In the evening of the 26th, around

    6 10 o'clock, I was returned to the cinema hall of the

    7 Workers' University, Radnicki University, in Vitez.

    8 Q. Whilst at that building, were you registered

    9 by the ICRC?

    10 A. On the 27th, a delegation arrived. There was

    11 one on the 26th as well, and they registered all of us

    12 except -- everybody except our group, who was digging

    13 trenches on that day, so they came back on the 27th to

    14 take our names down as well.

    15 Q. And you were registered on the 27th of April?

    16 A. Yes.

    17 Q. How many days thereafter did you spend in the

    18 Radnicki University building?

    19 A. We stayed -- I stayed there until 30th of

    20 April, when the BH army commander, Sefer Halilovic,

    21 signed an agreement with the commander of the HVO,

    22 Petkovic, where it was agreed there would be an

    23 exchange on the principle all-for-all, so he came to

    24 the university and he said that we were free and that

    25 we would be able to go wherever we wanted to. However,

  29. 1 the HVO police did not allow that to happen in my

    2 respect, because I used to be a member of the police,

    3 so I was simply returned to where I was before.

    4 However, this former colleague of mine,

    5 Zeljko Sajevic, he was a member of the staff of the

    6 local HVO brigade and he arranged for me to be released

    7 on 30th of April and that is when I went home.

    8 Q. You said that there was an agreement signed

    9 between the BH commander Sefer Halilovic and Petkovic?

    10 A. That is what was told to us by Mr. Halilovic

    11 when he came to the cinema hall and spoke to us.

    12 Q. What rank did Petkovic have at the time he

    13 signed the agreement? Are you aware of what rank he

    14 held?

    15 A. I do not know what rank he held. I know he

    16 was the commander of the main staff, but I do not know

    17 what rank he had.

    18 Q. Commander of the main staff of HVO, is it?

    19 A. Yes.

    20 Q. Do you know whether Petkovic was a Croat or a

    21 Bosnian Croat?

    22 A. I do not know.

    23 Q. Before being released -- before being

    24 released from the Radnicki building, did you have to

    25 sign any papers?

  30. 1 A. Yes, I had to sign a paper saying that I was

    2 leaving voluntarily, in one piece, safe and sound, and

    3 the president of the commission for the exchange of us

    4 prisoners on behalf of the HVO was Borislav -- I do not

    5 remember his surname -- he was a security officer in

    6 the special purpose industry in Vitez -- he was killed

    7 during the war.

    8 Q. After being released on the 30th of April,

    9 for how long were you at liberty?

    10 A. On the 1st of May about 3pm, Anto Kovac and

    11 Jurcevic, whose name I do not remember but his nickname

    12 was Butur, he came to fetch me allegedly for a

    13 statement and I would be immediately released and they

    14 took me to the cinema hall.

    15 Q. Who was Anto Kovac and Jurcevic, who were

    16 they?

    17 A. They were members of the military police who

    18 were in charge of the security at the camp in the

    19 Workers' University, because the Workers' University

    20 had people detained in the basement, in the cinema hall

    21 and upstairs on the first floor. Anto Kovac I think

    22 was a commander of the platoon.

    23 Q. To which army did they belong?

    24 A. The Croatian Defence Council.

    25 Q. That is the HVO?

  31. 1 A. Yes.

    2 Q. And you said you were again taken to the

    3 Radnicki University building?

    4 A. Yes.

    5 Q. Now, when you went there on the 1st of May,

    6 did you see others detained in that building?

    7 A. Yes.

    8 Q. About how many others were there?

    9 A. About 50 or so.

    10 Q. And could you describe to this court what

    11 happened when you were brought to this building on the

    12 1st of May?

    13 A. I think it was the next day, on the 2nd of

    14 May, that Kovac Anto and Jurcevic came into the hall

    15 and told us all to go to the bottom of the cinema. The

    16 two of them sat at a table on the stage. They were

    17 sitting facing one another, one of them had a red

    18 agenda, the other one had a blue one and all of us had

    19 to go up to them, one by one, and to give our

    20 particulars, and they would enter them, for some people

    21 in the blue agenda and for others in the red one.

    22 There were five or six of us whose names were entered

    23 in the red agenda and we were later moved from the

    24 cinema hall.

    25 Q. Where were you moved to, from the cinema

  32. 1 hall?

    2 A. With another six persons, who had been

    3 brought there from the premises of the SDK and the

    4 primary school, we were transferred to the premises of

    5 the chess club, which were close to my own apartment.

    6 Q. Witness, for how long were you detained at

    7 the chess club?

    8 A. A couple of days -- two or three days, until

    9 about the 5th, so two nights -- two nights and three

    10 days.

    11 Q. And what happened on the 5th of May?

    12 A. On the 5th of May, in the afternoon, around

    13 3pm or 4pm, a combi van was parked in front and we were

    14 told to get in and to leave our things and they drove

    15 us somewhere, we did not know where. When we reached

    16 our destination, the driver and co-driver left the van

    17 and we were surrounded by HVO members under full combat

    18 gear, helmet, flak jacket, long barreled rifles and

    19 they held us there for about an hour, an hour and a

    20 half.

    21 Later on, one by one, we were put in the

    22 prison -- first searched and the 13 of us were pushed

    23 into one cell.

    24 Q. Do you know -- do you know now to which cell

    25 you were put in on that day?

  33. 1 A. Yes, I do.

    2 Q. And which cell was that?

    3 A. Immediately to the right, right next to the

    4 premises where the policemen on duty were.

    5 MR. MEDDEGODA: Your Honours, may I seek your

    6 permission to show to the witness aerial photograph of

    7 the Kaonik camp? There are five copies for your

    8 Honours as well as for Defence counsel. (Handed).

    9 THE REGISTRAR: It is exhibit number 63.

    10 MR. MEDDEGODA: Witness, looking at exhibit

    11 number 63, which is now on the ELMO, could you please,

    12 using the pointer, point out to the building where you

    13 were taken to on the 5th of May, the building with the

    14 cells? Could you please circle that building and mark

    15 it with the letter "B". (Witness marked photograph).

    16 Witness, you would also recall that you were

    17 brought to the Kaonik camp on your way -- on your way

    18 from Nadioci. You said you were brought to a hangar

    19 building. Do you see that hangar building on the

    20 exhibit that is on the ELMO?

    21 A. I do.

    22 Q. Could you please point out that building, the

    23 hangar building? (Witness indicates).

    24 Once again, using the highlighter, could you

    25 please circle that and mark that building with the

  34. 1 letter "A"? (Witness marked photograph).

    2 Now, you said you were put into a cell with

    3 the others. How many others were put into your cell?

    4 A. Thirteen.

    5 Q. And which cell were you put into, you and the

    6 12 others?

    7 A. I do not remember the number exactly -- it

    8 was number 13 or 16, but it is the cell right next to

    9 the room where the guards were, which means when you

    10 enter the prison, to the right of the entrance.

    11 MR. MEDDEGODA: Your Honours, may I have your

    12 permission to show to the witness exhibit number 20,

    13 which has already been admitted into evidence? These

    14 are copies of that same exhibit, your Honours.

    15 (Handed).

    16 THE REGISTRAR: It is Exhibit 64.

    17 MR. MEDDEGODA: Once again, witness, could

    18 you look at Exhibit 64 and, using the pointer, try to

    19 identify the cell to which you were brought in on the

    20 5th of May? (Witness indicates on photograph).

    21 Thank you. Could you please mark -- you can

    22 see the door of that cell; is that right?

    23 A. Yes.

    24 Q. Could you please mark that door with the

    25 letter "A"? (Witness marked photograph).

  35. 1 Witness, do you recognise any other object on

    2 this photograph?

    3 A. Right next to us, this was the room where the

    4 guards were. There was a TV set in the corner, which

    5 could be seen when we had lunch, because I usually sat

    6 here on this side so I could see the TV. On a number

    7 of occasions I saw Kordic making statements -- I did

    8 not hear anything but I, you saw him making a statement

    9 dressed in a camouflage uniform. These were excerpts

    10 of TV programmes.

    11 This is the table where we had lunch. The

    12 inmates of two cells never had lunch together, it was

    13 cell by cell. When we finished eating, then the people

    14 from the next cell would be allowed to eat. On this

    15 other side was the stove which heated the whole prison,

    16 and just underneath the window is a bed where HVO

    17 members would rest and who would talk until late into

    18 the night about their accomplishments, about their

    19 killings and lootings in the village around Busovaca.

    20 Q. Could you please mark -- you identified the

    21 room in which the guards were. Could you please, using

    22 a highlighter, mark that room with the letter "B"?

    23 (Witness marked photograph).

    24 And also the table at which you had meals

    25 with the letter "C". (Witness marked photograph).

  36. 1 Thank you. Now, witness, could you please

    2 describe the size of the cell -- the cell to which you

    3 were put into?

    4 A. I do not know exactly, but I think it was

    5 about four metres by 360. I just know that 13 of us

    6 could not lie down on the kind of bed that existed, but

    7 that two of us slept on the concrete. We had blankets

    8 and we slept on those blankets on the floor.

    9 Q. And what was the kind of bed that existed

    10 inside the cell?

    11 A. It was a wooden bench, stretching from one

    12 wall to the other, and I must say that when we first

    13 came to the cell we lifted all the blankets there were

    14 in the cell and we found a knife and we called in a

    15 guard to show him the knife. This was probably planted

    16 there by a -- by the HVO.

    17 Q. Was there any heating inside the cell?

    18 A. No, just this stove, which was in the

    19 corridor.

    20 Q. Were there any electric lights inside the

    21 cell?

    22 A. Not inside the cell.

    23 Q. Now, when you were brought to Kaonik, could

    24 you describe to this court what happened immediately

    25 upon being brought into the cell?

  37. 1 A. When we were brought to the cell, the

    2 colleagues asked me, because I was in the police, for

    3 my advice, and I said to them, "I have never been a

    4 prisoner. I did imprison others". But I suggested to

    5 them that we should remove all the objects from the

    6 bed, that we shake out the blankets, and, when you are

    7 looking into the cell from the door, on the right-hand

    8 side towards the end was this knife, so we knocked on

    9 the door, the guard came, and he later brought in the

    10 commander -- the commander of the shift -- a young man,

    11 who had come, just before the conflict, from Canada.

    12 At first he shouted at us, thinking it was our knife

    13 and then we said, "But you searched us; you saw we had

    14 nothing on us," so, he took the knife. We arranged the

    15 cell a little bit. Then they brought in a tin to be

    16 used for urination in the cell.

    17 Q. What was this commander of the shift wearing

    18 at the time he came into the cell?

    19 A. A camouflage uniform. He did not have boots

    20 on his feet, because one of his legs was injured, so he

    21 was walking around in slippers.

    22 Q. When you were brought to the cell, did you

    23 have occasion to see or meet the commander of the camp?

    24 A. Yes. A couple of days later, he entered our

    25 cell, wearing a camouflage uniform, with his sleeves

  38. 1 turned up, with a pistol at his belt, and he asked,

    2 "Who is Zlotrg Edib?", and I said it was me. Then

    3 introduced himself at Zlatko Aleksovski. He said that

    4 he had spoken to my sister and brother-in-law and that

    5 they had enquired about me and he asked me how I was

    6 and whether I needed anything. I was afraid that this

    7 may be a provocation. So I said that I was fine and

    8 I did not need anything. And he went off.

    9 Q. Would you be able to recognise Mr. Aleksovski

    10 if you see him again?

    11 A. Due to the fact that I know that it is him --

    12 I could hardly recognise him otherwise, because I saw

    13 him twice in my life for 10 or 15 minutes each time,

    14 though I later did see his photograph from his former

    15 workplace, but this photograph was taken when he was

    16 much younger.

    17 Q. And you just said that you saw him twice in

    18 the 10 to 15 days that you spent in the days that you

    19 spent in the camp?

    20 A. Yes.

    21 Q. Now, you described an occasion on which he

    22 came into your cell -- was it the first occasion or the

    23 second occasion that you saw him?

    24 A. That was the first occasion. On the second

    25 occasion was when we were being released from prison.

  39. 1 We had to sign a paper, a release paper, in his office.

    2 Q. Now, witness, when you were detained in the

    3 camp, did you hear any beatings and screams and cries

    4 going on in the camp?

    5 A. Yes, at all times of day and night one could

    6 hear blunt blows and moans, but we did not see

    7 anything.

    8 Q. Did you see or hear detainees being taken out

    9 of the camp on labour detachments?

    10 A. Almost every morning, Muslims were called out

    11 and, when a Muslim is called out, then he would say the

    12 number of cell he is in, then the cells would be opened

    13 and the people would come out. When they were called

    14 out, they would be told "Strane", "Kula", "Loncari" or

    15 wherever they were supposed to go, and we could hear

    16 them leaving the prison premises, but I did not see

    17 anything.

    18 Q. Do you know whether prisoners in the camp in

    19 Kaonik were subjected to interrogation?

    20 A. Yes. From my cell, a guard came to call

    21 Alija Basic, who was director of the Sintevit factory

    22 in Vitez a plant belonging to Unis. When Alija came

    23 back, he said that Darko Kraljevic had interrogated

    24 him, together with two other members of the Vitezovi.

    25 Q. What was the guard wearing when he came into

  40. 1 the cell?

    2 A. Camouflage uniforms.

    3 Q. Did he have an insignia on his sleeves?

    4 A. They all had the insignia of the Croatian

    5 army, that is the HVO.

    6 Q. During the time you spent in custody in the

    7 Kaonik camp, witness, did you have sufficient food to

    8 eat and water to drink and water to wash yourself?

    9 A. We did have three meals a day, but it was a

    10 very poor quality. Before my arrest I weighed 96

    11 kilograms, and on the 16th of April, when I left, I had

    12 63 kilograms.

    13 The hygiene was terrible, there was just a

    14 toilet at the bottom of the prison that was used by all

    15 the prisoners, and a wash basin, so if you needed

    16 water, or if you wanted to go to the toilet, you had to

    17 knock on the door to indicate the name of the cell, and

    18 wait for the guard to come and unlock it. There was no

    19 other way you could go out.

    20 Q. So for how long, witness, were you detained

    21 in Kaonik camp?

    22 A. From the 5th of May until the 13th or 14th of

    23 May. On the 16th, we were exchanged and we were

    24 released a couple of days before that.

    25 Q. When were you released from the Kaonik --

  41. 1 when were you taken out of the Kaonik camp?

    2 A. I think it was the 14th of May.

    3 Q. And from there, where were you taken to?

    4 A. We were again taken to the cinema hall of the

    5 Radnicki University in Vitez.

    6 Q. You said you were exchanged on the 16th of

    7 May?

    8 A. Yes.

    9 Q. Do you know the circumstances under which

    10 your exchange was secured?

    11 A. I think it was the International Red Cross

    12 that mediated between the army and the HVO to arrange

    13 the exchange, because 13 or 14 of us were exchanged on

    14 this side, and a couple of Croats were exchanged,

    15 also. Anyway, the exchange was attended by a

    16 representative of the International Red Cross.

    17 Q. And, after you were exchanged, where were you

    18 taken to?

    19 A. To Zenica.

    20 MR. MEDDEGODA: I have no further questions,

    21 your Honour, in examination-in-chief.

    22 JUDGE RODRIGUES: I think that this is a

    23 good time for us to break. But I would like to take

    24 advantage of the opportunity to say something.

    25 I notice that in the public there are many young

  42. 1 students, and I should like to greet you as the hope of

    2 humanity and to wish you welcome to the International

    3 Criminal Tribunal. So we are now going to have a

    4 15-minute break.

    5 (11.52am)

    6 (A short break)

    7 (12.14pm)

    8 JUDGE RODRIGUES: Mr. Mikulicic, you have the

    9 floor.

    10 Cross-examined by MR. MIKULICIC.

    11 Q. Thank you, your Honour.

    12 Good morning, I am Goran Mikulicic. I am

    13 Defence lawyer from Zagreb. I am representing the

    14 accused in this place. I will ask several questions

    15 and would you please answer them to the best of your

    16 recollection.

    17 Mr. Zlotrg, you described for us in the

    18 introduction the events in which you took part in April

    19 and May 1993. Let me take you back to your first

    20 arrest when you were taken to the Workers' University.

    21 You said that your name was registered on that

    22 occasion?

    23 A. Yes.

    24 Q. Is that correct?

    25 A. Yes, it is.

  43. 1 Q. Who registered you?

    2 A. Members of the HVO police.

    3 Q. Do you know who the commander was who

    4 commanded these people who registered you?

    5 A. I do not know higher commanders but I do know

    6 that Anto Kovac was one of the commanding officers. He

    7 was later killed. I think he and another man were

    8 shift commanders.

    9 Q. Okay. I will focus on the events relating to

    10 the Kaonik facility, because this is relevant for these

    11 proceedings. You said that you were brought to

    12 Kaonik. Who brought you there?

    13 A. The first time or the second time?

    14 Q. The first time and then the second time as

    15 well.

    16 A. Members of the HVO police.

    17 Q. When, the first time?

    18 A. The first time was on the 25th, in the

    19 morning around 12, half past 12.

    20 Q. And the second time?

    21 A. The second time was on 5th May in the

    22 afternoon around 4 o'clock. I did not have a watch on

    23 me, so I do not know.

    24 Q. Yes, I understand. You have described for us

    25 that some kind of record was being kept at the Workers'

  44. 1 University, that there were two agendas, a red one and

    2 a blue one; who took your names down?

    3 A. Anto Kovac was the one who took our names in

    4 the red agenda and another person whose nickname was

    5 Butur did the other agenda. They were members of the

    6 HVO military police.

    7 MR. MIKULICIC: Mr. Zlotrg, I will now show you

    8 the same photograph that has been already shown to you

    9 by the usher, and which has been admitted as

    10 Prosecution Exhibit P63.

    11 I would kindly ask the usher to put the

    12 photograph on the ELMO. Thank you.

    13 I would kindly ask the technicians to focus

    14 the camera so that we can see the whole photograph on

    15 the screen -- thank you.

    16 Mr. Zlotrg, on this photograph you identified

    17 two facilities and you have marked them with two

    18 letters. I would kindly ask you to use the pointer and

    19 to circle that part of the photograph which you believe

    20 represents the Kaonik facility?

    21 A. You mean the place Kaonik or the facility

    22 where we were detained?

    23 Q. Yes, would you please circle the building in

    24 which you were detained?

    25 A. During my first time there, I was detained.

  45. 1 Q. I am not only referring to buildings but the

    2 whole area.

    3 A. We were brought in at night so I do not know

    4 exactly where it was. It used to be a military depot

    5 and it used to be premises. I could circle it for you,

    6 but it would be approximately, so before the conflict

    7 access was not allowed to these premises.

    8 Q. I understand. I do not wish you to circle

    9 something you are not sure about, but could you

    10 identify for us other facilities -- other buildings

    11 that can be seen on this photograph?

    12 A. Yes, I can.

    13 Q. Would you please do that?

    14 A. I can show you the location where the

    15 intervention squad of the Croatian Defence Council was

    16 located.

    17 Q. Yes, could you please show that to us?

    18 A. (Witness indicates on photograph). In this

    19 building here.

    20 Q. Could you mark the building the same way you

    21 have marked buildings so far but using another letter,

    22 please? (Witness marked photograph).

    23 Mr. Zlotrg, how do you know that the

    24 intervention platoon of the HVO was located in that

    25 building?

  46. 1 A. I know that, because our colleague from the

    2 cell Fuad Kaknjo spent one night there, and we had to

    3 pass by that building, which was situated 30 metres

    4 away from the entrance to the Kaonik facility.

    5 Q. I understand. Could you also identify other

    6 locations on the photograph? Do you know for which

    7 purpose they were used and what they were?

    8 A. I just know that the facility used to be a

    9 military depot, a military warehouse.

    10 Q. Mr. Zlotrg, you said that guards were wearing

    11 uniforms in Kaonik?

    12 A. Yes.

    13 Q. You said that you also met the warden and

    14 later you came to know his name, Zlatko Aleksovski?

    15 A. He introduced himself.

    16 Q. Okay, he introduced himself. How was he

    17 dressed?

    18 A. He was dressed in a camouflage uniform and he

    19 had a pistol in his belt.

    20 Q. Did you notice any insignia on his uniform?

    21 A. He was wearing a shirt and the shirt did not

    22 have any insignia and I did not see him wearing a

    23 jacket.

    24 Q. Mr. Zlotrg, you said that you saw photographs

    25 of Zlatko Aleksovski; where did you see them?

  47. 1 A. Before he became a member of the HVO, he used

    2 to work at the Zenica correction facility. He used to

    3 be a deputy -- I do not know exactly which function he

    4 had, but he knows that.

    5 Q. Could you tell us, was that prior to the

    6 events or after the events?

    7 A. After the events.

    8 Q. Did you see his photograph anywhere else?

    9 A. No, I did not.

    10 Q. To your knowledge, Mr. Zlotrg, was Zlatko

    11 Aleksovski commanding the military police or the

    12 intervention platoon?

    13 A. I do not know what kind of competencies he

    14 had, whether he was commander of the intervention

    15 platoon, but I know that he commanded -- the guards who

    16 guarded us.

    17 Q. Mr. Zlotrg, my colleague from the Prosecution

    18 asked you whether you had heard any screams, moans, or

    19 some similar noise during your time at Kaonik. I will

    20 ask you a different question. Did you see any actions

    21 which would result in such noises?

    22 A. We were locked up in the cell, and we did not

    23 have an opportunity to see anything, except for what

    24 was going on in our cell, but we could clearly hear the

    25 sounds coming from the surrounding cells.

  48. 1 Q. Mr. Zlotrg, you said that you were given food

    2 three times a day?

    3 A. Yes.

    4 Q. Did you maybe see what kind of food was given

    5 to the guards in Kaonik?

    6 A. I do not know exactly what they ate. I just

    7 know that we took meals after them.

    8 Q. Did they use the same place to have their

    9 meals?

    10 A. As far as I know, they did not.

    11 Q. How do you know that?

    12 A. I did not see them, I did not hear a noise

    13 coming from the use of cutlery -- because this was

    14 right across my cell.

    15 Q. So how do you know that they did actually

    16 take meals?

    17 A. Well, I believe that no-one would have

    18 guarded me if they had not had anything to eat.

    19 Q. So, this is merely an assumption?

    20 A. Well, in order to live, you simply have to

    21 eat.

    22 Q. Mr. Zlotrg, you obviously have some

    23 experiences as a policeman, so you have to tell me from

    24 your experience what guards were eating -- did you see

    25 that?

  49. 1 A. I did not see that, but the people who

    2 brought us food told us that the food was being

    3 prepared all together and what we had to eat was very

    4 hard pieces of meat, but the rest was simply water.

    5 Q. Mr. Zlotrg, while you were at Kaonik, did you

    6 personally see any mistreatment or beatings of

    7 prisoners?

    8 A. I personally did not see anything.

    9 Q. Thank you, thank you, that is enough.

    10 A. But, when Fuad Kaknjo was returned to the

    11 cell, we noticed he had bruises all over. How he

    12 sustained them, we do not know. Maybe he had fallen

    13 down or something.

    14 MR. MIKULICIC: Mr. Zlotrg, thank you very much

    15 for your answers. I do not have any further

    16 questions.

    17 Re-examined by MR. MEDDEGODA

    18 Q. I have a couple of questions that arose out

    19 of cross-examination.

    20 Witness, you were shown Exhibit 63,

    21 Prosecution Exhibit 63. You marked on the exhibit

    22 buildings with the letters "A" and "B", the buildings

    23 in which you were detained?

    24 A. Yes.

    25 Q. Were you, during your stay in Kaonik, taken

  50. 1 to -- taken out of those buildings to any other

    2 building?

    3 A. No, except for the first time I was there,

    4 when I was sent to dig trenches, when I was taken from

    5 this building here. (Witness indicates).

    6 Q. Were you ever taken to the building where the

    7 intervention group was located?

    8 A. I was not, but I know that Fuad Kaknjo spent

    9 the time after the interrogation in that building.

    10 MR. MEDDEGODA: Thank you, I have no further

    11 questions, your Honours.

    12 JUDGE RODRIGUES: Mr. Mikulicic, I do not

    13 think that we have it on the record that the witness

    14 has identified the building of the intervention platoon

    15 of the HVO. It has been identified with a letter "F"

    16 -- I think it has to be confirmed -- do you agree?

    17 MR. MIKULICIC: Thank you for your concern,

    18 your Honour. The Defence agrees.

    19 JUDGE RODRIGUES: Mr. Zlotrg, we do not have

    20 any further questions for you. You have completed your

    21 testimony, and we would like to thank you once again

    22 for having appeared before this Tribunal, and we wish

    23 you a safe return to your country. Thank you very

    24 much?

    25 A. Thank you.

  51. 1 (The witness withdrew)

    2 JUDGE RODRIGUES: Mr. Prosecutor, we still

    3 have a half hour before the lunch break. I should like

    4 to know whether you consider it useful for us to begin

    5 the next testimony, or should we have the lunch break

    6 now. What is your opinion, please?

    7 MR. NIEMANN: Your Honour, we are in your

    8 hands as to what you find most convenient, but we are

    9 in a position to start with the next witness now and to

    10 continue after the luncheon break.

    11 I should say, though, your Honours, that this

    12 is the last witness for today; we will have another

    13 witness for tomorrow, but we have no other witnesses

    14 for today.

    15 JUDGE RODRIGUES: Perhaps, if he is the only

    16 witness for today, we could try and make an effort and

    17 then we would not meet in the afternoon at all?

    18 MR. NIEMANN: I am not sure that we would be

    19 finished -- I do not think we would finish -- we will

    20 see how we go. We can try, your Honour.

    21 JUDGE RODRIGUES: Let us try. I do not know

    22 whether the interpreters agree to prolong the morning a

    23 little, and then we would be free for the afternoon --

    24 THE INTERPRETER: We agree.

    25 JUDGE RODRIGUES: Then we will try.

  52. 1 Could you have the witness brought in,

    2 please?

    3 (The witness entered court)

    4 Good morning, Sir. Do you hear me well?

    5 A. I hear you very well, thank you.

    6 JUDGE RODRIGUES: Please read the solemn

    7 declaration handed to you by the usher?

    8 A. I solemnly declare that I will speak the

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

    10 JUDGE RODRIGUES: You may be seated. Thank

    11 you for having come to the International Criminal

    12 Tribunal, and, first, you will be answering questions

    13 put to you by Mr. Marchesiello of the Prosecution.

    14 A. Thank you.


    16 Examined by MR. MARCHESIELLO

    17 Q. Good morning, Professor Surkovic. Could

    18 you --

    19 A. Good morning.

    20 Q. Could you please start by stating your name,

    21 age and date of birth?

    22 A. My name is Enes Surkovic. I was born on 2nd

    23 of March 1949 in Konjic. I am a Bosniak of ethnic

    24 origin. My religion is Islam, I am a member of the

    25 SDP, the Social Democratic Party and I am a graduate

  53. 1 mechanical engineer. Most of my career I spent working

    2 as a teacher in Vitez, I was a teacher for about 20

    3 years. I taught mechanical engineering in that school

    4 and I also spent some time involved in politics. For a

    5 time, I was a professional politician, and during my

    6 working lifetime, I was a manager -- a director of a

    7 secondary school, a manager of a factory in Vitez.

    8 Vitez, for me, is a very familiar town. I am very well

    9 versed in the political climate before the war. I am

    10 also familiar with the activities of the political

    11 parties during the war.

    12 I wish to declare here, with full

    13 responsibility, that before 1990, before the

    14 multi-party elections in Vitez, there were absolutely

    15 no conflicts. The Croats and Muslims lived in close

    16 relations amongst each other.

    17 As a teacher, I often went to the villages,

    18 I spoke to people there, and among the elders no-one

    19 recollected any nationalistic conflicts between Croats

    20 and Muslims in the past.

    21 Q. Thank you, Professor. Could I ask you some

    22 questions? You mentioned -- in order to make the court

    23 more aware of some of the facts you have referred to,

    24 you said you were involved -- you were a member of the

    25 SDP Party. Can you explain, briefly, what the initials

  54. 1 mean and which were the main characteristics, or are

    2 the main characteristics of this Party, please?

    3 A. I have to make a correction. In 1980, I was

    4 President of the League of Communists for the

    5 municipality of Vitez. In those days, the leaders of

    6 the present-day republics, Mr. Kirog Gligorov, the

    7 President of Macedonia, Mr. Milan Kucan, Mr. Milosevic,

    8 Mr. Franjo Tudjman, Mr. Bulatovic, all of them were

    9 members of the League of Communists. It is known only

    10 for Mr. Alija Izetbegovic, the President of Bosnia

    11 Herzegovina, was never a member of the League of

    12 Communists and he was persecuted in those days and

    13 spent some time in prison. I was President of the

    14 Party for four years in that period.

    15 Q. I am sorry to interrupt you, and I know that,

    16 as a policy-maker, you are deeply involved in that

    17 activity, and you have had a lot of experiences and

    18 facts and events that you are familiar with; but

    19 I would rather go and ask you about the facts and ask

    20 you to follow what I am going to ask you. I simply

    21 wanted you to explain to the court which were the main

    22 characteristics of the Party you were a member of and

    23 actually you were the President of that Party in Vitez.

    24 To start with, what do the initials "SDP"

    25 mean?

  55. 1 A. With the collapse of Tito's Yugoslavia, in

    2 Bosnia Herzegovina and in the other republics, a number

    3 of parties cropped up. Among them was the Social

    4 Democratic Party, a modern political Party with a

    5 European orientation, a Party advocating democracy,

    6 human rights, a market economy and, of course, a

    7 unified Bosnia Herzegovina. This political Party is

    8 open to Serbs, Croats and Muslims. It is not a single

    9 ethnic Party, but a multi-ethnic one and it is open to

    10 all people of goodwill.

    11 Q. Thank you, I think that is enough. Could you

    12 please explain and tell the court how was the political

    13 situation in Vitez after the 1990 multi-Party election

    14 -- I am concerned particularly with the seats

    15 apportionment in the local Parliament?

    16 A. The new Parliament -- the Parliament formed

    17 after the first multi-Party elections, numbered 60

    18 aldermen or deputies. In that Parliament the HDZ had

    19 23 deputies; the SDA, 16; SDS, two; and the Opposition,

    20 which consisted of the SDP, the Reformists and the

    21 Liberals, we had 19 seats.

    22 Q. In November 1991, the Croat Community of

    23 Herceg-Bosna was established. Did the situation you

    24 described of the Muslim people in Vitez change

    25 significantly thereafter, compared to the Croat

  56. 1 community situation?

    2 A. Yes, the situation changed significantly.

    3 The newly formed political Parties interpreted

    4 democracy erroneously, I would say, in that -- and

    5 especially HDZ, because the word "democratic" implies

    6 democracy and, within a short period of time, the SDP

    7 Party, the SDA Party, the trade unions -- all of them

    8 were thrown out of their premises and these were

    9 occupied by the HDZ. People who did not agree with the

    10 HDZ, and among them were my friends, members of the SDP

    11 -- Ivanic Mijo, Stipo -- they are terrorised and one

    12 night they were taken from the SDP premises to the

    13 woods.

    14 They were shot behind their heads; they were

    15 threatened if they went to SDP meetings. I claim that

    16 at that time members of the Serb people, and there were

    17 only 5.4 per cent of the population were Serbs --

    18 JUDGE RODRIGUES: I am sorry for

    19 interrupting you. Could you slow down a little bit so

    20 that the interpreters can follow you, because we would

    21 like to understand everything that you are saying.

    22 Thank you.

    23 A. Yes, I will.

    24 MR. MARCHESIELLO: Now, Professor --

    25 A. So, shall I continue -- may I?

  57. 1 Q. I would rather ask you to describe to the

    2 court, how did the Muslim community react to this new

    3 and difficult, for them, situation -- very difficult,

    4 extremely critical situation, as you described it? How

    5 did the Muslim community react? Did they organise in

    6 some way?

    7 A. You see, I pointed out a moment ago that

    8 there were no conflicts between the Muslims and Croats

    9 in Vitez in the past and the Muslims wanted to avoid

    10 conflict at all costs, and at the level of the Vitez

    11 municipality, a council was set up for the protection

    12 of the interests of the Muslims. I was not a member of

    13 that council, but my friends were -- Dr.

    14 Mujezinovic, Mr. Fuad Kaknjo and others were members of

    15 this council. Whenever an incursion occurred into a

    16 Muslim house, and there were cases of people being

    17 beaten up -- for example, Mr. Dzevad Ridzanovic, who had

    18 an MA in technology, he was beaten up in front of his

    19 wife and children, a sack was thrown over his head, he

    20 was taken out of his flat to the woods and he spent two

    21 days and two nights in custody.

    22 Mr. Fuad Salkic, an MA in electrical

    23 engineering, he was also taken. Private shops and

    24 kiosks owned by Muslims were blown up; monuments from

    25 the past; a bust of a revolutionary, Mose Pijade, a man

  58. 1 who was a fighter against fascism, who was very

    2 prominent in the Second World War, his bust was broken

    3 up and blown up, and the Muslim Council, the Council

    4 for the Protection of Muslim Interests, reacted by

    5 issuing statements, and making those statements on

    6 Croatian television in Vitez. I must admit that these

    7 statements were correctly read out on television, but

    8 nothing came of it all. There was little use -- little

    9 benefit.

    10 Q. Thank you, Professor. Let us go to your

    11 personal experience and I would be grateful if you

    12 could tell the court what, briefly -- what happened to

    13 you and your family on 16th April 1993?

    14 A. 16th April, I was in my flat at the time.

    15 I was working in the secondary school as a professor,

    16 and about 20 past 5, we were woken up by shell fire,

    17 mostly mortar fire and light infantry weapons could be

    18 heard. We went into the basement. The lights were on,

    19 however, there were no tenants there. Obviously,

    20 somebody had come there earlier on, unlocked the door

    21 and switched on the light. As we were alone, we went

    22 back to our apartment. 20 minutes or so later, I was

    23 looking through the window and I saw a flame in Stari

    24 Vitez, obviously houses were on fire.

    25 From the direction of Ahmici, one could hear

  59. 1 artillery fire, probably mortars were operating there

    2 and there was a fire that could be heard from Stari

    3 Vitez as well. I went down to the basement again with

    4 my family and, this time, there were many tenants there

    5 -- almost all of them were there, women and children,

    6 both Croats and Muslims. All of us were frightened.

    7 Both the Croatian and the Muslim women were crying,

    8 because it was obvious that we had war and that the

    9 situation was getting more and more complicated.

    10 About 6 o'clock, some young men knocked on

    11 the door wearing camouflage uniforms. A Croatian woman,

    12 a neighbour of mine, opened the door. I wanted to open

    13 it, but she said, "No, you will not open it, I will

    14 open it." We were in the basement, and these two young

    15 HVO men came to the door, and told us that the men

    16 should go and unlock their apartments.

    17 Q. Sorry, Professor, could you describe these

    18 soldiers in camouflage. Did they have something on

    19 their face -- did they wear masks or something similar?

    20 A. I cannot describe them. Let me continue.

    21 I turned towards my apartment door. When I got hold of

    22 the handle, the door was unlocked and I was surprised

    23 to see in my kitchen a man in a camouflage uniform with

    24 a black stocking over his face. You could just see his

    25 eyes, there were slots for his eyes. He was tall

  60. 1 wearing a camouflage uniform.

    2 Next to him was my older son -- these local

    3 people of Vitez covered themselves up with masks.

    4 Q. How old was your son at that time?

    5 A. My son was 15 at the time -- my older son who

    6 was there. He was a secondary school pupil. May

    7 I continue?

    8 Q. Yes?

    9 A. As the order was for the men to unlock the

    10 doors, I called my son over, because I saw that this

    11 man had an automatic rifle on him. And I must point

    12 out that, before that, this young man standing there

    13 had broken the door on the cupboard in the kitchen with

    14 his rifle, and I had a pistol in that cupboard and this

    15 was locked, because of my children, but I had a permit

    16 for that pistol.

    17 My oldest son told me later that he had asked

    18 the soldier for permission to go downstairs and get the

    19 key for the cupboard, but he would not let him, so he

    20 broke the door and this man had looked through my

    21 papers and my documents. He was obviously looking for

    22 something and I was scared for my child.

    23 So I said to Denis -- and that was my son's

    24 name -- "Go to the basement." This young man was

    25 obviously surprised, because, after all, they were not

  61. 1 sure of themselves. They were in another person's

    2 apartment, and he said, "No", the young man could not

    3 -- the child could not go downstairs, but I begged him

    4 to let him go because I was afraid he would get

    5 killed. I insisted that he go down and this masked man

    6 took his automatic rifle, he cocked it, pointing it at

    7 me and said he would kill me.

    8 I tried to remain as cool as I could, and

    9 collected. I knew that this man probably knew him,

    10 because I had worked in the secondary school in Vitez

    11 for some 20 years. So I said to him, "Listen, young

    12 man, if you are looking for weapons, if you are looking

    13 for the pistol, I have put it away. Just let the boy

    14 go downstairs and keep me here." He asked me, "where

    15 is the pistol?", and I said that it was in the

    16 washing-machine where I had hidden it.

    17 The boy moved towards the bathroom where the

    18 washing-machine was. I pointed to my son, telling him

    19 to come out. I must point out that behind me was a

    20 Croat, my neighbour, Ilija Azinovic, who was ringing

    21 his hands and who kept saying, "please go downstairs,

    22 please go to the basement", as if he felt that

    23 something terrible would happen.

    24 My son went by me and I followed him. On the

    25 staircase I was met by another young man, who was not

  62. 1 wearing a mask. He was about 180 centimetres tall, he

    2 had freckles, he was wearing an earring in one ear. He

    3 was not masked and I could recognise him if I were to

    4 see him. He passed by me. He reached my apartment.

    5 My neighbour, Ilija Azinovic, told me later, "Thank God

    6 the masked man entered your flat first. If it had been

    7 the other blond one, he would have killed you".

    8 I said, "Why would he do that? I do not believe he

    9 would have killed me." Mr. Azinovic said to me that this

    10 blond fellow, when I went down the stairs, took a rifle

    11 and pointed it at my back, he wanted to shoot, but the

    12 masked man had come out of the apartment in the

    13 meantime and he prevented him from doing that. My son

    14 and I went to the basement.

    15 Q. I have another question to put to you as to

    16 this moment. In your experience, was somebody killed

    17 during this episode in your basement -- actually

    18 killed?

    19 A. Yes.

    20 Q. Would you please tell the court?

    21 A. I can.

    22 THE INTERPRETER: Could the witness be asked

    23 to slow down, please?

    24 A. When I entered the basement we could hear

    25 rifle fire.

  63. 1 JUDGE RODRIGUES: Perhaps in your testimony,

    2 you could make pauses, because the interpreters cannot

    3 follow you, so please make a pause when you come to the

    4 end of the sentence. Do you understand the need to

    5 slow down and to make a pause at the full stop -- can

    6 you continue?

    7 A. Yes, yes, of course I understand. I can, but

    8 I think that you are probably tired and you want to get

    9 through this as quickly as possible, but I will slow

    10 down.

    11 MR. MARCHESIELLO: Professor, I would like

    12 you not to comment and not to make these kind of

    13 comments, just answer my questions, possibly, and as

    14 the President told you, try to slow down in order to

    15 help the translators to do their job. Did you

    16 understand that, please?

    17 A. Yes. I do understand, thank you.

    18 When we got to the basement, my boy and

    19 myself, we heard bursts of fire on the upper storeys of

    20 the building I lived in. My neighbour, Ms. Jasmina

    21 Omerdic, started crying. We asked her why she was

    22 crying. She said that her husband was not amongst us.

    23 We did not dare go upstairs to see what was happening.

    24 A couple of minutes later, we heard the sound

    25 of military boots on the steps. Obviously, HVO soldiers

  64. 1 were leaving our building. Shortly after that, the

    2 entrance door banged shut. I asked my neighbour,

    3 Franjic, a Croat, to come with me to see Salih or

    4 Omerdic's flat, to see whether the man was alive. The

    5 man went with me for a couple of steps, but then he

    6 moved away from me, and said that he did not have the

    7 courage to go upstairs.

    8 A good friend of mine, Ilija Azinovic,

    9 offered to come with me, and we went to Salih Omerdic's

    10 apartment. Salih was killed. His head and shoulders

    11 were on the floor. His middle area and his pelvic area

    12 and his legs were on a couch. I saw on the right-hand

    13 side of his face a wound -- obviously, that was the

    14 entry wound of the bullet. I moved closer to him.

    15 I raised his head, and, from the other side of the

    16 head, that is, in the same direction, was a larger

    17 wound.

    18 I bent down over the man and I saw another

    19 wound on his neck -- as the head was leaning over to

    20 one side, I saw that this was a blow with a knife. The

    21 muscles of the neck had been cut. This part here

    22 (indicating) had not been cut. Therefore, this was a

    23 penetrating wound -- he had been stabbed. The man did

    24 not show any signs of life.

    25 Q. Did you go back to the basement?

  65. 1 A. No. Ilija Azinovic and myself laid the man

    2 on the floor. I closed his mouth, and eyes. Then

    3 I buttoned up his collar below his neck, so that his

    4 wife, if she were to come to her apartment, would not

    5 see this wound in his neck. Then we covered him with a

    6 sheet.

    7 Another two neighbours came up then --

    8 Professor Hajrudin Zisko and Emir Priganica -- they saw

    9 this, and all of us then went back to the basement. We

    10 had to let his wife know what had happened.

    11 MR. MARCHESIELLO: Mr. Surkovic, I know how

    12 concerned you are with the facts I am examining you

    13 about and I do not want you to have the impression that

    14 we are pushing you ahead. I want you to have all the

    15 time you need -- you think necessary to tell what is

    16 relevant to the case, but even if it is important for

    17 you to say, we have to find a good measure as to this.

    18 So, do you think it will take you a long time to go

    19 ahead telling us your story from this point of view? .

    20 I am saying that, because, your Honours,

    21 I hope they will understand -- I think it is important

    22 for the witness not to have the impression that all

    23 what he has to say, and I personally will take care

    24 about the fact that everything he is saying is relevant

    25 to the case, but I think that psychologically he should

  66. 1 not be put in the situation where he is urged to

    2 deliver his declarations, so I am sorry to say that,

    3 but I am afraid that we will have to -- I cannot

    4 maintain the promise I made to the court, and I think

    5 I will take it a little longer time to go ahead with

    6 this witness, if your Honours understand.

    7 JUDGE RODRIGUES: No problem. You just

    8 promised to try.

    9 MR. MARCHESIELLO: Yes, I did.

    10 JUDGE RODRIGUES: Therefore, I think it

    11 would not be advisable to pressure the witness. It is

    12 just a question of organisation. The Trial Chamber is

    13 fully conscious of the fact that we should not exert

    14 any pressure on the witness. Therefore, I think it is

    15 better for us to have our luncheon break and then, in

    16 the afternoon, we can continue, calmly and quietly, and

    17 at ease, so we are going to have a lunch break now and

    18 we will resume work in the afternoon.

    19 (1.02pm)

    20 (The luncheon adjournment)






  67. 1 (2.30pm)

    2 JUDGE RODRIGUES: Good afternoon. Is

    3 everybody ready to proceed?

    4 MR. MARCHESIELLO: Yes, your Honour, we are.

    5 JUDGE RODRIGUES: The Prosecution has the

    6 floor. Please proceed.

    7 MR. MARCHESIELLO: Do you hear me,

    8 Mr. Surkovic?

    9 A. Yes, I can hear you very well.

    10 Q. I did not have the same impression this

    11 morning, but anyway, let me remind you that I will put

    12 the precise question on a matter of fact and I am

    13 expecting you to answer these questions. You have to

    14 know and realise that this is not in an historical or

    15 political context, or a sociological context -- it is a

    16 judicial context -- yes? So I will ask you some

    17 precise facts and please answer to them.

    18 Now, I left you in your apartment building in

    19 Zenica. Now, what I want to know and what the court

    20 wants to know is what happened after that -- where were

    21 you taken, if you were taken somewhere else?

    22 A. The apartment was not in Zenica -- I was

    23 talking about Vitez -- the apartment was in Vitez.

    24 Q. Excuse me, Vitez.

    25 A. So, at about 10 o'clock, three HVO soldiers

  68. 1 arrived. We were in the basement, and they ordered

    2 Croats, both men and women, to one side of the basement

    3 -- to go to one side of the basement and the Muslims

    4 to go to the other side of the basement. Both Croatian

    5 and Muslim women started crying, because a murder had

    6 already happened in the building and we did not know

    7 what was awaiting us.

    8 After that, an order came for the Muslims,

    9 both men and women, to take their children and go to

    10 the premises of the Workers' University.

    11 Q. And were you conducted there and by whom, if

    12 so?

    13 A. May I just add something, please? Some women

    14 fainted. HVO soldiers asked me, because they

    15 recognised me, to tell them that we were only going to

    16 the Workers' University to sign a piece of paper and

    17 that no harm would be done to anyone, so these three

    18 HVO soldiers took us to the basement of the Workers'

    19 University.

    20 Q. Which kind of situation did you find there?

    21 Were there other Muslim people gathered?

    22 A. Once we got there, there were about 20

    23 persons there -- there were women and children, and

    24 children 10 years of age. Dr. Ekrem Mahmutovic was

    25 there as well. The rest of us were all men.

  69. 1 Q. What happened then, were the women and

    2 children sent back home later on?

    3 A. New groups of people were being brought in,

    4 including women and children, who were camped there for

    5 about four hours.

    6 Q. And what happened then?

    7 A. Then women and children were released and

    8 sent back home, whereas men between the age of 16 and

    9 70 and over remained there at the camp.

    10 Q. Was it a camp or a building?

    11 A. I say it was a camp. There was no barbed

    12 wire around it. However, we were not free -- it was

    13 not a usual prison. Those were premises in the

    14 basement, but the reason I am referring to it as a

    15 "camp" is because innocent people were being detained

    16 there.

    17 Q. I understand your point of view. How long

    18 did you remain there?

    19 A. In that camp, I remained until the 3rd of May

    20 1993.

    21 Q. Which were the conditions within the Radnicki

    22 University?

    23 A. We did not have any blankets there, there

    24 were no beds. We were given a can of fish a day and a

    25 quarter of a loaf of bread. However, our families were

  70. 1 allowed to bring us some food and some blankets as

    2 well.

    3 Q. During your stay there, did you notice

    4 whether some of the prisoners were taken out of those

    5 premises, and for what reason, if so?

    6 A. Three days later, we were allowed to, whoever

    7 wanted to go, to move to the cinema hall and to the

    8 upper storey and about 10 o'clock, 11 o'clock, groups

    9 of people were being taken to dig trenches.

    10 Q. Did all of them return on those occasions, or

    11 were some of them missing?

    12 A. Since I used to work as a teacher, I knew

    13 many as young men, I remember Almir Gadjun, who used to

    14 be a student of mine, who never came back. The people

    15 who were there with him told us that he had been killed

    16 while digging trenches.

    17 Q. After how many days did you leave the cinema

    18 where you had moved, and how many of you did leave the

    19 cinema?

    20 A. On the 30th of April, representatives of the

    21 BiH army and the HVO arrived and they told us that we

    22 would be released on the 1st of May and that we would

    23 be sent home. However, this did not take place, and

    24 there were about 85, 86 people at that time at the

    25 cinema hall. A number of them, perhaps 60 of them, did

  71. 1 go home on the following day -- that is, on the 1st of

    2 May, whereas 23 of us remained at the cinema hall.

    3 Q. And when did you leave the cinema hall --

    4 those who had remained?

    5 A. On the 3rd of May, around 4 o'clock,

    6 20 minutes past 4, Zlatko Nakic arrived in the cinema

    7 hall and he called names of certain detainees. He

    8 called out seven names, seven of us, and he ordered us

    9 to take our things and to get out to the corridor.

    10 They took us to a van, and they transported us from

    11 there to the chess club.

    12 Q. Do you remember the names, or some of the

    13 names, of those who were with you on that occasion?

    14 A. I remember all of them -- Fuad Kaknjo was

    15 with us, an engineer; Bahtija Sivro; Suad Salkic, also

    16 an engineer; Edib Zlotrg, Alija Basic, and two more

    17 persons whose names I cannot remember right now.

    18 Q. So, how many of you were taken to the chess

    19 club?

    20 A. Seven of us were taken to the chess club from

    21 the cinema hall, and later on five more people from

    22 Vitez were brought to the chess club, all of them

    23 Muslims. One more man by the name of Sahman joined us

    24 later on. He had been at Manjaca, in one of the

    25 Chetnik camps and, after he was released, he came back

  72. 1 to Vitez and then he was arrested again.

    2 Q. Professor Surkovic, were you able, in those

    3 circumstances, to send a message? You say that your

    4 relatives were allowed to visit you with food; were you

    5 able to have a message to your relatives delivered --

    6 the fact that you were being brought away from the

    7 cinema?

    8 A. I suspected that something was wrong, because

    9 they had released a large number of people from the

    10 camp, and the 13 of us were transported to the chess

    11 club, so I had an inkling that something bad would

    12 happen, so I made a list of people, all 13 of us who

    13 were there at the chess club. I sent -- I gave that

    14 list to the wife of a colleague of mine, who was there

    15 with me at the camp, who happened to be passing under

    16 the window. Her last name is Karajko and her husband

    17 was there with me. He told her to bring him some food

    18 to the chess club, and on that occasion I gave her the

    19 list, and I asked her to take -- to make copies of that

    20 list and to give it to our families and to UNPROFOR

    21 and, if possible, to the command of the 325th Vitez

    22 Brigade.

    23 Q. So, your assumption is that it was known you

    24 were being taken away from the cinema and brought to

    25 the chess club?

  73. 1 A. Well, since -- at 4.30, 4.20am we were taken

    2 from the cinema hall, only seven of us from that camp,

    3 it was obvious that I could not expect anything good to

    4 happen to us, and also, in view of our previous

    5 experiences and considering the murders that had taken

    6 place in Vitez, and in view of certain provocations to

    7 my family, to my relatives; late night calls, the

    8 destruction of my property in Vitez and so on.

    9 Q. I understand you were asked not to bring your

    10 things with you -- your belongings -- is that correct?

    11 A. At the chess club, we spent two days and two

    12 nights. When they took us from the chess club to

    13 Busovaca, it is true that Mr. Marko Vidovic answered to

    14 my question whether I shall take personal belongings,

    15 he said that we would not need anything there and that

    16 we should not take anything with us.

    17 Q. When you left -- on leaving the chess club,

    18 the HVO soldiers did not give you any indication about

    19 the place you were going to be taken to?

    20 A. No, they did not say anything to us and I had

    21 the feeling that they were doing it in secret -- in

    22 secrecy. A van arrived and Marko Vidovic called us out

    23 and told us to get on the van. The driver turned on

    24 the engine and we set off.

    25 Q. So you said you did go to Busovaca, or Kaonik

  74. 1 more precisely. How long did this trip take?

    2 A. This all happened five years ago and, to the

    3 best of my recollection, I believe that we set off

    4 around 10 o'clock on the 5th of May -- that we left the

    5 premises of the chess club. Kaonik is not very far

    6 from Vitez. However, when we got there in front of the

    7 former military warehouse at Kaonik, we did not get off

    8 immediately, but we stood -- we remained sitting in the

    9 van for about an hour, an hour and 20 minutes. We did

    10 not know why we were waiting, and what they planned to

    11 do with us.

    12 Q. And what happened then?

    13 A. Then we were ordered to leave the van, to get

    14 off, and we had to walk in a single file, one by one,

    15 to the premises of the former military warehouse that

    16 had been redone in the meantime. We were searched at

    17 the entrance. We had to take out all our belongings

    18 from our pockets and raise our hands so the HVO

    19 soldiers could search us. They then took us to cell

    20 number 13.

    21 Q. Can you describe the interior of this

    22 building in which you were searched and then detained

    23 into cell number 13?

    24 A. In my estimate, it is a square building which

    25 is approximately 30 metres long. In front of the

  75. 1 building was a kind of platform -- the kind they have

    2 at warehouses from where trucks are loaded. There was

    3 a large corridor running across the middle of the

    4 building and there was also a table with chairs, where

    5 we used to take our meals. Also, in the building,

    6 inside the building, was a large stove that had been

    7 made of a barrel -- an oil stove that heated all the

    8 premises inside the building, so that was at the

    9 entrance -- at the entrance of that particular

    10 building.

    11 On the right-hand side, there was an office

    12 of the police and, on the left-hand side, there was the

    13 office of Mr. Zlatko Aleksovski.

    14 MR. MARCHESIELLO: If I am permitted, I would

    15 like to introduce as evidence one photograph.

    16 THE REGISTRAR: It is document exhibit

    17 number 65. (Handed).

    18 MR. MARCHESIELLO: Mr. Surkovic, can you look

    19 at the photograph which is on the ELMO and tell the

    20 court whether these are the premises you have been

    21 describing to us?

    22 A. Yes, this is the area I have been

    23 describing. You can see the stove here and the table

    24 at which we took our meals (indicating), both lunch and

    25 dinner. Here on the sides (indicating), you can see

  76. 1 doors. Here (indicating) was cell number 19 where

    2 prisoners were detained.

    3 Q. Can you show us and sign with a pen the

    4 office where the guards used to stay?

    5 A. Here on this photograph I cannot really

    6 recognise the office, but I know it was on the left

    7 side as you enter the building -- it was behind glass,

    8 so that those people could control movement. I do not

    9 remember very well and I cannot observe this particular

    10 detail on the photograph.

    11 Q. And can you point to cell number 13 where you

    12 have been detained?

    13 A. Cell number 13 -- I believe it was behind the

    14 stove. As you get in here to the corridor

    15 (indicating), the police were on the right-hand side

    16 and, after the police office, the office of the police,

    17 was cell number 13. So, if the entrance is here

    18 (indicating), then cell number 13 should be thereabouts

    19 (indicating). So, the first door after the police --

    20 after the office of the police.

    21 Q. Can you mark with a pen and the letter "A"

    22 the cell number -- where you did locate cell number 13?

    23 A. I believe that this is the bed that used to

    24 be here (indicating). The police must have been here

    25 and I believe that behind this area here (indicating)

  77. 1 was cell number 13. It was five years ago. I am not

    2 quite sure, but I believe it was there (indicating).

    3 Q. Will you be so kind as to draw a letter "A"

    4 near the cross you marked? (Witness marked

    5 photograph).

    6 Thank you. Do you remember something

    7 specific happening immediately after you were put into

    8 the cell? Did some sort of incident occur?

    9 A. Yes, I remember an incident that occurred

    10 then, although it was some time ago -- we entered the

    11 cell and it was normal for us to tidy up the area a

    12 little bit. There was a wooden pallet there with a

    13 mattress and some blankets on it, but it was all messy,

    14 so we wanted to clean it up a little bit. The

    15 professor who was brought there with me, Kadir Dzidic,

    16 found a big knife under the blanket.

    17 Q. And then what did you decide to do with this

    18 knife?

    19 A. We then called the shift commander, and we

    20 showed him the knife. This gentleman was very angry

    21 when he saw the knife and he started shouting at the

    22 guards, and he wanted to know how the knife had ended

    23 up there, and one of those young men was honest and he

    24 said that he had forgotten the knife there by accident

    25 and the shift commander said that he would investigate

  78. 1 the whole case and that this young man would be

    2 punished for that.

    3 Q. Professor Surkovic, during your stay in

    4 Kaonik, you spent all your time in the cell -- you,

    5 personally -- did you?

    6 A. Yes, I did, except for one day when I went to

    7 a medical examination -- I only stayed four days at

    8 cell number 13. Later on, I was transferred -- we were

    9 transferred to another cell where there was more room

    10 for sleeping, because in this other one there were 13

    11 of us and that cell was only 15 or 16 square metres

    12 large, so they wanted to give us somewhat better

    13 accommodation.

    14 Q. Thank you. And, during your stay in Kaonik,

    15 were some of you interrogated and who, if so?

    16 A. The first amongst us was taken, I think, on

    17 the third day for interrogation -- his name was Serif

    18 Causevic. He is now deceased. He was taken about

    19 6 o'clock in the afternoon. He stayed there for about

    20 four hours. When he came back from the interrogation,

    21 he was crying. We asked him did anyone beat him. He

    22 said they had not, but that the interrogation was very

    23 hard to bear. He said it was some sort of

    24 cross-examination; there were three investigators; he

    25 was extremely depressed. We thought he had been beaten

  79. 1 up, but he said -- he denied it, but he just found the

    2 interrogation difficult.

    3 Q. Where had he been taken in order to be

    4 interrogated -- did he tell you?

    5 A. He told us that they had taken him outside

    6 the building. To tell you the truth, he did say where,

    7 but I do not remember now -- I think he was taken to

    8 town, to the MUP premises, or the municipality. In any

    9 case, it was not there he was interrogated; he was

    10 taken somewhere by car.

    11 Q. Can you tell who did call him out of the cell

    12 on that occasion?

    13 A. No, I do not know.

    14 Q. And did he not tell you anything about those

    15 investigators -- were they from the police, were they

    16 HVO, from the military police -- did he give you any

    17 indication about that?

    18 A. He said that there was a highly experienced

    19 man among them, that he was a professional to all

    20 intents and purposes -- a man who must have worked in

    21 the judiciary before, who knew how to put the questions

    22 and who expected exhaustive answers. But he did not

    23 mention any names, because he did not know the people

    24 who interrogated him.

    25 Q. And who else was interrogated after that?

  80. 1 A. After that, engineer Fuad Kaknjo was taken

    2 for interrogation. He was kept there a long time. He

    3 did not come back the whole night, but I was not in his

    4 cell when he was taken away -- I was in cell number 9.

    5 But, later on, he told me that it was very hard for

    6 him, that we had a lot of problems. He said he was

    7 beaten during the interrogation and, when we left the

    8 camp, he still had some bruises on his body. After

    9 Fuad Kaknjo, engineer Bahtija Sivro went for

    10 interrogation and Basic Alija, and I do not think they

    11 took anyone else for interrogation.

    12 Q. During your stay there, were you visited by

    13 the Red Cross or by ECMM?

    14 A. Yes, yes -- there were two visits. The first

    15 was by the International Red Cross. They filmed the

    16 cells, they talked to us, they filmed us. We asked the

    17 International Red Cross to organise medical checkups

    18 for us and, also, for them to intervene and prevent us

    19 being taken to dig trenches, as we were afraid that

    20 someone might get killed there and I can confirm now

    21 that, out of our group, no-one was taken to dig

    22 trenches, and that the very next day we were taken to

    23 see a doctor for an examination, and whoever wanted to

    24 see a doctor was enabled to do so.

    25 Q. And what about the ECMM visit?

  81. 1 A. Yes, yes -- they came, too. I remember that

    2 these men in cell number 9, and there were five of us,

    3 asked me to talk to them. We presented our comments in

    4 a nice manner so that our stay in Busovaca was

    5 facilitated by these visits, by the International Red

    6 Cross and the European Monitors. We felt freer, safer,

    7 we knew people knew where we were, and we did not

    8 expect anything bad to happen to us if the world knew

    9 where we were.

    10 Q. Was the camp commander with them?

    11 A. No, no, he was not. I saw the camp commander

    12 only two or three times in my whole life. If

    13 necessary, I can explain when I saw him.

    14 Q. First of all, did you know his name?

    15 A. The first time, that is, the third day after

    16 we arrived in the camp, Mr. Aleksovski came in to cell

    17 number 13. He called out, asking for Edib Zlotrg.

    18 Zlatko introduced himself. He said he was the camp

    19 commander, Zlatko Aleksovski, and that he had come to

    20 convey to them a message from his relatives in Zenica.

    21 That was the first time.

    22 Q. Then, was there another name?

    23 A. Yes. After the European Monitors left,

    24 Zlatko came by to cell number 9 once. He talked to us

    25 for a while and he offered people cigarettes. The

  82. 1 third time was when we were about to leave to be

    2 exchanged, and I asked Mr. Aleksovski then for some of

    3 my things to be returned, which had been seized from me

    4 in cell number 9 by HVO soldiers.

    5 Q. And then when were you released?

    6 A. On the 14th of May orders came for us to be

    7 released, and for us to be exchanged. Clearly, we had

    8 to sign those orders and that was the third time I saw

    9 Mr. Aleksovski, because he told us this, and we were not

    10 released straight away, but we were taken back to

    11 Vitez.

    12 When we reached the cinema, we were told that

    13 we had to wait for half an hour for some HVO commanders

    14 to come for us, to sign some papers and that we would

    15 then be released. However, that was not what

    16 happened. We were held in the cinema for another two

    17 days and two nights, which means the 15th and the 16th,

    18 and it was only after that that we were released.

    19 Q. Did some meeting take place during your stay

    20 there, during those two days?

    21 A. Yes. One day -- I think it was the second

    22 day of our stay -- it was the 15th of May, two young

    23 HVO men entered the cinema and they called out Suad

    24 Salkic, an engineer, to come out. I asked whether

    25 anyone else should come with him and he said there was

  83. 1 no need, because these were his acquaintances and

    2 neighbours from the village of Sadovaca. However,

    3 shortly after that we heard some strange sounds in the

    4 corridor. I opened the door and I saw that these two

    5 young HVO men were beating Suad Salkic with a wooden

    6 pole.

    7 The policeman on duty ran up and we also came

    8 out of the cinema hall, so that we grabbed engineer

    9 Salkic away and the policeman on duty started yelling

    10 at these two young men who had beat Salkic. One of

    11 them had hit him with this pole at the back of the

    12 head, so that he was bleeding. He was as white as the

    13 wall; he was terrified. We took him back into the

    14 cinema hall, and that was how the incident ended.

    15 Of course, I personally later informed

    16 Mr. Santic about this, as well as Mario Cerkez, Stipo

    17 Krizanac and Boro Zozic, who came to visit us two hours

    18 later.

    19 Q. Why did they come to visit you?

    20 A. Mr. Ivica Santic, not being aware of this

    21 incident, proposed that we should not leave Vitez. He

    22 asked that we stay and that, within a period of two

    23 hours, they would return our apartment keys to us.

    24 I asked Mr. Ivica, "How safe will we be in our

    25 apartments and will we be protected adequately?"

  84. 1 Mr. Ivica answered that we would be as protected and as

    2 safe as he and that we had nothing to fear and he asked

    3 us to stay, saying that, if we left Vitez, that many

    4 other people, including both Croats and Muslims with

    5 high qualifications, would leave Vitez, following our

    6 example.

    7 I turned Mr. Suad Salkic around and he was

    8 still bleeding at the back of his head and I asked him,

    9 "Is this the kind of safety you are guaranteeing for

    10 us?" They were extremely surprised to see the man

    11 bleeding so heavily, and I explained to them then what

    12 had happened.

    13 I said that we would not stay in Vitez --

    14 under no circumstances -- and that, if they had really

    15 wanted us to stay, they would not have taken us to a

    16 camp, deprived us of our freedom, and I also said, "If

    17 you do not let our families go with us, then we will

    18 protest, too, and we will not move from here."

    19 I wish to point out that I had learned

    20 previously from people who had passed through this

    21 area, from Croats, my friends -- and I stressed that

    22 every Muslim family had at least five or six Croat

    23 friends, so there were decent honourable people -- and

    24 I learned that my family had already been moved to

    25 Zenica but not the families of my friends and that is

  85. 1 why I insisted that our families should go with us,

    2 that is, the families of the other people who were with

    3 me in the camp.

    4 Q. So, when were you exchanged?

    5 A. On the 16th of May, about 12 o'clock in the

    6 village of Poculica, the exchange took place. We were

    7 taken to Zenica with our families.

    8 MR. MARCHESIELLO: Thank you, I have no more

    9 questions.

    10 JUDGE RODRIGUES: Mr. Mikulicic, you surely

    11 have questions to put to the witness.

    12 Cross-examined by MR. MIKULICIC

    13 Q. I do have some questions, your Honour, but

    14 not too many.

    15 Good afternoon.

    16 A. Good afternoon.

    17 Q. My name is Goran Mikulicic, I am an attorney

    18 and I represent the accused in this case together with

    19 my colleague, Mr. Joka, sitting next to me. I should

    20 now like to ask you a number of questions and I would

    21 ask you kindly to answer them to the best of your

    22 recollection.

    23 Mr. Surkovic, in view of your previous life

    24 that you have described to us, you were a prominent

    25 figure in Vitez and the surroundings. What I mean is

  86. 1 that you knew many people and many people knew you; is

    2 that correct?

    3 A. Yes.

    4 Q. Similarly, during these critical events that

    5 we are discussing, that is, the first half of 1993, you

    6 had contact with some quite important people in the

    7 area; is that correct?

    8 A. One could say that.

    9 Q. Mr. Surkovic, did you ever have any contact

    10 with Mr. Zlatko Aleksovski?

    11 A. I saw Mr. Aleksovski in Busovaca three times

    12 and I knew nothing about him from before that.

    13 Q. So, you saw Mr. Aleksovski for the first time

    14 in Kaonik?

    15 A. Yes.

    16 Q. You have described to us the events, your

    17 arrival at Kaonik, and the entrance to the building

    18 where you were put up. Do you remember whether, at the

    19 entrance to the building, there was any kind of board?

    20 A. I do not recollect that.

    21 Q. Do you remember whether there were locks on

    22 the doors of the cells where you were?

    23 A. The door could only be opened outwards. We

    24 could not open the door from the inside, but, if we

    25 needed anything, we had to knock, and the guard on duty

  87. 1 would remove a kind of lid that was on the door, he

    2 would peep inside and ask us what we wanted and then he

    3 would open the door from the outside.

    4 Q. Do you remember how he opened the door?

    5 A. On the door, there was a kind of latch, a

    6 kind of lever, which was lifted (indicating) and on the

    7 door frame was another latch and that is how the door

    8 could be opened.

    9 Q. Do you remember, Mr. Surkovic, that, in

    10 addition to people of Muslim origin, there were people

    11 of other ethnic origins?

    12 A. I remember very well that one evening, about

    13 10 o'clock, a Croatian soldier was brought to cell

    14 number 9. His name was Zoran. He was a bit tipsy --

    15 he was under the influence of alcohol. He was very

    16 talkative. He had no weapons on him. He told us that

    17 he had fled from the front, that the fighting was

    18 fierce, and that he had somehow found a bottle of

    19 spirits. He had drunk it, he had been caught by the

    20 HVO police and they had brought him to cell number 9.

    21 If you need any more details, I can go into

    22 them.

    23 Q. No, that is fine, Mr. Surkovic. Mr. Surkovic,

    24 you said that during your stay in Kaonik you saw Zlatko

    25 Aleksovski on three occasions; do you remember how he

  88. 1 was dressed?

    2 A. He was dressed in a camouflage uniform, but

    3 I did not notice any ranks indicated on the uniform of

    4 Mr. Aleksovski.

    5 MR. MIKULICIC: Thank you, Mr. Surkovic. Thank

    6 you, your Honours, I have no further questions.

    7 MR. MARCHESIELLO: No further questions.

    8 JUDGE RODRIGUES: Mr. Surkovic, I have a

    9 question. At one point, you said that you asked

    10 Mr. Aleksovski for the property which had been taken

    11 away from you previously by the HVO; did I understand

    12 you well?

    13 A. Yes, you did, you understood me very well.

    14 JUDGE RODRIGUES: Did Mr. Aleksovski say

    15 anything to that?

    16 A. Mr. Aleksovski was very angry when I said that

    17 HVO soldiers had entered the cells on a number of

    18 occasions and they had indeed entered, and that, on one

    19 occasion, they had taken some of our personal

    20 belongings.

    21 JUDGE RODRIGUES: But did Mr. Aleksovski give

    22 you back your property? What was his answer to you?

    23 A. The gentleman was very angry when he learnt

    24 about this --

    25 JUDGE RODRIGUES: But why was he very angry?

  89. 1 A. I said that HVO soldiers had entered the

    2 cells on a number of occasions and they had mistreated

    3 some of the prisoners and, on top of that, they had

    4 taken some of my personal belongings. He said that

    5 this should not have happened. He appeared to be

    6 astonished, because these people who, with me in the

    7 camp, knew that my family was in Vitez, that my

    8 apartment had been destroyed, my car had been destroyed

    9 and everything, but this was something I cared about,

    10 I cherished, so I did -- I decided that I wanted to get

    11 it back.

    12 JUDGE RODRIGUES: Mr. Surkovic, you have

    13 completed your testimony here at the International

    14 Criminal Tribunal. We wish to thank you for coming,

    15 once again, and we wish you a safe journey home. Thank

    16 you?

    17 A. Thank you, your Honours.

    18 JUDGE RODRIGUES: I think that we have some

    19 other witnesses for today, Mr. Prosecutor?

    20 MR. NIEMANN: No, your Honours, there are no

    21 more witnesses for today. We have another witness for

    22 tomorrow, but not for today.

    23 JUDGE RODRIGUES: In that case, we meet

    24 again tomorrow.

    25 (The witness withdrew)

  90. 1 (3.26pm)

    2 (The hearing adjourned until 10.00 am

    3 on Thursday, 5th March 1998)