Tribunal Criminal Tribunal for the Former Yugoslavia

Page 13269

 1                          Tuesday, 8 October 2002

 2                          [Open session]

 3                          [The accused entered court]

 4                          --- Upon commencing at 2.24 p.m.

 5            JUDGE ORIE:  Madam Registrar, would you please call the case.

 6            THE REGISTRAR:  Case Number IT-98-29-T, the Prosecutor versus

 7    Stanislav Galic.

 8            JUDGE ORIE:  Thank you, Madam Registrar.

 9            Before we resume the examination-in-chief, perhaps it would be

10    wise to turn into closed session for a very short period so in order to

11    find out whether any additional information is available to the Chamber.

12    Yes, private session will do.

13                          [Private session]

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 8                          [Open session]

 9            JUDGE ORIE:  Could we turn into open session.  It is not confirmed

10    on my screen yet -- yes we are in open session again.

11            Madam Registrar, would you please escort Witness DP1 into the

12    courtroom and may I ask the technicians to take care that during the entry

13    of the witness the facial distortion will be effective.

14                          [The witness entered court]

15            JUDGE ORIE:  Please be seated.  Mr. DP1, may I remind you that you

16    are still bound by the solemn declaration you gave yesterday.  I would

17    like to apologise that you had to wait for some time, but we had to deal

18    with procedural issues, meanwhile, the examination-in-chief will be

19    continued by Ms. Pilipovic now.  Please proceed, Ms. Pilipovic.

20            MS. PILIPOVIC: [Interpretation] Thank you, Your Honour.

21                          WITNESS: WITNESS DP1

22                          [Witness answered through interpreter

23                          Examined by Ms. Pilipovic: [Continued]

24       Q.   [Interpretation] Good afternoon, Mr. DP1.

25       A.   Good afternoon.

Page 13284

 1       Q.   Today I would merely like to draw your attention to one thing.

 2    When you answered our questions, please try to make it short.  If you can,

 3    try to be concise.  I would like to go back to what you said yesterday.

 4    It was at 18.22 or 21, and you said that a large number of Serbs had

 5    stayed in Sarajevo.  Can you tell us why, in your view?

 6       A.   I can say with certainty why I stayed.

 7       Q.   Why did you stay?

 8       A.   I stayed because I was confident that people that I lived with

 9    shared all the joys and sorrows.  People I worked with were not of the

10    kind to engage in a fight.  And secondly, I sincerely believed that the

11    Yugoslav People's Army as a cohesive factor once the whole state to

12    provide sufficient guarantee that no bloody conflict would break out.  I

13    must admit that when the Yugoslav People's Army left, I understood once

14    and for all that there could be no coming to terms, that there are two

15    points which hated each other, that they wanted to fight against each

16    other and then I realised I had lost my homeland.

17       Q.   Mr. DP1, you said when you realised that the Yugoslav People's

18    Army left the territory of the city of Sarajevo, that you then realised

19    that you lost your homeland.  Why didn't you leave Sarajevo after that?

20       A.   I hope you won't hold it against me if I say that perhaps I have

21    some literary bent so I will remind you of Standou's [phoen] words, that

22    one cannot love or should not love two women at the same time.  Perhaps

23    that is a question, but it is quite sure that one cannot love two

24    homelands.  So one is left with a void.  An even if I wanted to leave, I

25    couldn't because the authorities of the day would not allow me and to do

Page 13285

 1    something on my own, it would be too risky, because I would have to go

 2    across two lines, or rather one front line where the firing never stopped.

 3       Q.   I would like you to explain to us your sentence that the

 4    authorities of the day would not let me or did not allow it.

 5       A.   Well, the authorities of the day did not allow people to leave.

 6    As far as I know it was possible until about late April, and I really

 7    wanted from the bottom of my heart to find a way for my child, for my

 8    daughter, who was -- who had barely turned 17, and I wanted her to leave

 9    the city safely.  And even manage to obtain the ticket for the last flight

10    out.  I even found a driver who would take her to the plane, but the day

11    one could hear gunfire from a distance, and there was also gunfire in the

12    city and there were barricades, checkpoints all over the place.  And the

13    man who came to drive her to the plane, he tried to tell me that there

14    were no -- that it could be done because he ha a badge of the Patriotic

15    League and badge of HOS and badge of Serb forces and that would be

16    sufficient surety, yet I did not dare send her away, and thus I lost all

17    hope that I would be able to leave Sarajevo, not only I, but everybody who

18    was on either side of the front line.

19       Q.   Witness DP1, you told us that you stopped working, I think you

20    said in August 1992.  You said, "I lost my job."  Can you tell us whether

21    that principle that people lost their jobs applied to all ethnic groups in

22    Sarajevo or were there some differences?

23       A.   Well, of course, there were differences.  The control over the

24    city was taken over by the then -- well, monoethnic authority and of

25    course it looked for people it could trust.  Crisis Staffs were set up in

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Page 13287

 1    early June, a little bit after that, or perhaps before that, I am not

 2    quite sure.  The house councils were replaced by agents, by building

 3    agents and again the criterion was their loyalty to the then-authority,

 4    and that is how it went on.  As the ruling principle was that those who

 5    happened to be on the other side of the front line were fired from their

 6    work straight away and those who did not get to work, they were put on a

 7    waiting list, and those who did go to work were also under the required

 8    labour obligation.  But I would say about 95 -- executive

 9    personnel -- Muslims -- Bosniaks, then Muslims, accounted for about 95 per

10    cent of the executive personnel.

11       Q.   So could you tell us if one of the reasons you lost your job was

12    because you were a Serb?

13       A.   Through my friends, I tried to find out why I was not selected for

14    the work obligation.  And in my company, they all agreed that they ask

15    that I be put on to the list to people who would be under work obligation,

16    but they did not get the approval of the higher body, which higher ranking

17    body it was, I do not know and I was never told.  What I do know is that

18    Serbs were completely cleansed from all the bodies which in one way or the

19    other had a part in decision making.

20       Q.   So you just told me, told us that you believe that the majority of

21    all Serbs in Sarajevo lost their jobs?

22       A.   Except those in mixed marriages.

23            MR. IERACE:  Mr. President, this is the second leading question,

24    the first being, sir would you tell us if one of the reasons you lost your

25    job was because you were a Serb.  I would be grateful if my learned

Page 13288

 1    colleague would refrain.

 2            JUDGE ORIE:  Yes, would you please refrain from leading questions

 3    unless, as we all know, the issue is not in dispute and it is merely

 4    technically leading to points that really count.  Please proceed, Ms.

 5    Pilipovic.

 6            MS. PILIPOVIC: [Interpretation] Thank you, Your Honour.

 7       Q.   Mr. DP1, you told us yesterday at 18.52 that you had seen mortars.

 8       A.   Yes.

 9       Q.   Can you tell us where and when.

10       A.   Well, I don't think that I can remember the date.  I mean, I saw a

11    mortar in the street in front of my house mounted on a truck.  If you want

12    me to, I can explain the conditions under which I saw it, namely, in my

13    house where my wife and my neighbor, I was sitting writing or reading

14    something in a different part of the apartment.  It was late afternoon and

15    they called out to me to come and see how mortar was firing shots.  I put

16    my papers together and came, but it had stopped firing, and the truck at

17    that moment switched on the engine and left.

18       Q.   And you saw that truck?

19       A.   Yes, I did.

20       Q.   Can you describe the truck?  What type, what make is it?

21       A.   You know, I was on the third floor.  I could only see from above,

22    so I really can't say.

23       Q.   Could you see in which direction the -- in which direction it

24    fired?

25       A.   Well, the way it was turned in the street it could fire frontally

Page 13289

 1    towards Trebivic, towards Grbavica, or perhaps the next building.  I

 2    can't -- I can't really say.

 3       Q.   When you say that you -- that when you look through the window of

 4    your flat you say that frontally one can fire towards Trebivic, can you

 5    explain, what do you see from your flat, specifically?  When I say "what

 6    do you see," do you see some elevations in the city of Sarajevo and which

 7    ones?

 8       A.   You can see a large part, almost all of Trebivic, and its slopes

 9    down to Mojmilo.  On the other side, I can see Kosevo hill, Ciglane

10    locality, and the area stretching towards the whole Kosevo stadium.

11       Q.   When you tell us that a part of your flat faces Trebivic, can you

12    tell us if you can see in that direction and did you see shelling?

13       A.   Yes.

14       Q.   Where could you see it from?

15       A.   I could see it partly from the balcony, although that was not

16    advisable.  I could even see it from the sixth floor with a friend of mine

17    lived, and at times we would come out to his balcony in late afternoon or

18    in the evening, we could go out to watch.  Since we survived and somehow

19    overpowered our fear, because and we stopped fearing everything as we did

20    in the beginning.

21       Q.   Can you be more precise and tell us where and when and in what

22    direction?

23       A.   There was evening fighting which looked like sci-fi or action

24    films when you use light bullets and when they are being fired towards

25    Trebivic or from Trebivic.

Page 13290

 1       Q.   And you say towards Trebivic and from Trebivic.  Where from?

 2       A.   From the city.

 3       Q.   When you say "from the city" which part of the city?  Could you

 4    determine that?

 5       A.   What I could see when I watched it, the impression, one could see

 6    the tracing bullets that it could have been from Marin Dvor towards

 7    Trebivic.  It could have been from Marin Dvor, it could have been from

 8    the railway stations it could have been from a third place.  It's

 9    difficult to say because I am not really a ballistics expert.  But these

10    bullets crossed their paths because they went towards each other.

11       Q.   And you also said that you saw other sights.  Can you tell us what

12    other sights you saw.

13       A.   Well, I saw a number of them.  I saw a strange intensive artillery

14    fire in a part which is called, I believe, Colina Kapa or its

15    neighborhood. And after all, I can't really remember the date, but I think

16    it was in early 1994 right in front of my house near the faculty of

17    stomatology, there were some small buildings where former high executives,

18    and I couldn't understand how not a single of these low buildings were hit

19    by any of these projectiles, but a huge number of them fell.  I also

20    watched, though it was a bit further away, but I could see Hrasno being

21    shelled and media said that it was Pero Kosjerica Square but I can't

22    really say.

23       Q.   When you answered my question about watching the shelling from

24    Colina Kapa, did you have any direct knowledge which army had Colina Kapa?

25       A.   At some point, and I am not sure if it was after the shelling, but

Page 13291

 1    at some point I heard on the radio and saw it on television, they were

 2    marking the successes of the Army of Bosnia-Herzegovina when they had

 3    expelled the Chetniks from Trebivic, cut off the communication

 4    Lukavica-Pale, taken Vidikovac and how oxen were being roasted in

 5    accordance with the old tradition.  That they had reached Stari Sumar

 6    which is a well-known coffee shop in Trebivic but then I heard it also

 7    denied by those on Pale, because they had the registration, Srna that is

 8    what it was called.  It was not sure, that the Serb units held on to their

 9    positions and our television showed the [indiscernible] Vidikovac and

10    other things --

11            THE INTERPRETER:  Will the witness please speak into the

12    microphone.

13            JUDGE ORIE:  Madam Registrar, could you perhaps adjust the

14    microphone so that -- Ms. Pilipovic, perhaps in order to give you some

15    guidance, I see that some ten lines were filled with an answer to your

16    question whether he had any direct knowledge which army held Colina Kapa

17    and on from the third, fourth line, it became clear to me that the answer

18    could have been perhaps "no" as well.

19            Please proceed.

20            MS. PILIPOVIC: [Interpretation] Thank you, Your Honour.

21       Q.   Witness, I told you already to make your answers -- to answer us,

22    if you know, and if you know, you can say "yes." So I will ask you again.

23            Do you know which army held Colina Kapa?

24       A.   Well, I thought I had answered.  One side said one thing, the

25    other side said a different thing.  I don't know with certainty which

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Page 13293

 1    troops were at Colina Kapa.

 2       Q.   Thank you, Witness.  Witness, you said that you heard people say

 3    how that there were mortars in carriages at the railway station and fire

 4    was opened from them.  You told us that you heard it from somebody.  Can

 5    you tell us who it was that you heard it from?

 6       A.   Well, it would take some time to remember the names.  But I think

 7    it was the story that went around.  People who boasted about the successes

 8    of their troops, and they spoke about the martial arts, about the martial

 9    skills which allowed them to score those victories.  I mean, it wasn't

10    something that individuals said here and there, it was simply the view

11    expressed by all people whom you came across.

12       Q.   Witness, you just told us that in the media it was written that

13    the BH Army was boasting of its successes, that it had taken the positions

14    of the Republika Srpska Army.  Could you tell us if you have any knowledge

15    of how often such operations took place, particularly, in this area.  You

16    told us about one.  But do you have any knowledge if there were any more

17    of such operations and do you know how many?

18       A.   I can only tell you according to what I heard in the media, what I

19    read in the media, because I was not a participant.  I know that in early

20    August, Mr. Siber who was a Deputy Commander of the BH army, publicly

21    announced that the citizens should be patient for a couple of days, and

22    that there would be more successes of the BH Army, and that the Ilidza

23    would also be liberated and that there would be a space liberated for

24    normal life.  There were such announcements that came more or less

25    regularly after some successes that were publicised as being successes of

Page 13294

 1    the BH Army.  I think it was also at that time a little later that

 2    Mr. Alija Izetbegovic said that within a month, Sarajevo would have this

 3    siege lifted and normal life would continue.

 4            JUDGE ORIE:  If it will assist you, if you put the headphones so

 5    you don't have to struggle with them.  Perhaps you can assist.  Yes.  I

 6    see you are struggling all the time.

 7            Please proceed.

 8            MS. PILIPOVIC: [Interpretation] Thank you, Your Honour.

 9       Q.   Witness, you said yesterday, 18.53, that you heard frequent

10    shelling around Kosevo.

11       A.   Yes.  There were shellings, there were frequent shellings.  I

12    always interpreted these shellings to myself as being a part of some

13    operation that was being conducted.  If there was a clash between the two

14    sides or attempt to break through the lines, each side would use what it

15    thought was efficient weapons in this conflict.

16       Q.   Witness, when I asked you, in relation to you saying that you

17    heard frequent shellings around Kosevo, could you please tell us whether

18    it was possible to determine whether you, personally, were able to

19    determine from which direction and for where -- from which directions fire

20    was coming and where to?

21       A.   I had the opportunity to hear frequently how shells were going,

22    but I have to admit that I was never able to determine by myself, alone,

23    from where these shells were coming.  I think that for an ordinary citizen

24    who is inside a room or perhaps if he is sheltering in a basement or in a

25    flat, it is extremely hard to determine where the shells were coming from.

Page 13295

 1    I was never able to determine this, although I was able to see that the

 2    hill which goes above Pionirska Dolina, Pioneer Valley - I can't remember

 3    what it's called - it used to be shelled, there were shells raining,

 4    literally in that valley.  But in the night, you could see from that hill,

 5    there were explosions coming out.

 6       Q.   Witness, you told us that you were active in an association, that

 7    you were an activist of an association.  Could you tell us, as such, did

 8    you get in to any kind of contact with the authorities, civilian or

 9    military authorities?

10       A.   Yes, very briefly, I had official negotiation with the then-mayor,

11    Kresevljakovic and there was a group of Serb patients and old people and

12    in November they were not able to leave the city.  So they were stopped

13    from leaving.  So in this discussions we tried to get them to be allowed

14    to lave because out of 360, 72 had already died.  So, he was very nice.

15    We had these talks.  And he asked some institution, director of

16    institution, who was in charge of this, who was Mr. Smajic, he was told to

17    become immediately involved in this.  And I also went to a reception at

18    Mr. Alija Izetbegovic because of Bajram.  And I did have talks after I

19    entered the humanitarian organisation.  I also had talks with other

20    administrators who insisted that other organisations should bring in as

21    much food as possible into Sarajevo.

22       Q.   When I asked you about your contacts with civilian and military

23    authorities, could you tell me what were the military authorities that you

24    were in touch with?

25       A.   Well, sometime either it was June or July, it could be sometime

Page 13296

 1    around that, three persons in uniform came to the premises of the

 2    humanitarian association, wanted an interview, and the point of the

 3    interview was the possibility of bringing in food through the -- into

 4    Sarajevo through the voluntary association, humanitarian association,

 5    because as they said, some permanent communication lines were cut off.  I

 6    believe that this was about the conflict between the Muslims and the

 7    Croats.  And there was some negotiations, but this was a very unrealistic

 8    request.  And still I asked him, what was the quantity of the food

 9    involved, and one of them answered that this was a very large quantity,

10    that it could be a very successful business deal and that it would be very

11    easy to work out because there were 35.000 armed people inside the city

12    and 12.000 policemen.

13       Q.   Mr. DP1, when you told us that you were an activist of a

14    humanitarian association, could you tell us where was the humanitarian aid

15    distributed, the humanitarian parcels, and how frequently?

16       A.   Well, the humanitarian aid in this association was being given out

17    extremely rarely, distributed extremely rarely.  It was humanitarian

18    association that was called the humanitarian association of the aggressor.

19    So nobody wanted to cooperate with us.  But this humanitarian association

20    distributed the letters which arrived through the Red Cross, and collected

21    the letters, those people who left Sarajevo, and then we passed them on.

22    And there was a large number of family parcels.  And for a year and a

23    month that I was a member of this association, I think that over 155.000

24    family parcels arrived in Sarajevo.

25       Q.   Let us go back to what you said that you were called "humanitarian

Page 13297

 1    association of the aggressor."  I just wanted to ask you, in which

 2    location were these parcels distributed?  Was there a usual place where

 3    humanitarian aids were distributed, the parcels?

 4       A.   Yes, in several locations of the city.  One of the locations was

 5    the scout's centre, and then the second one was in Novo Sarajevo.  I can't

 6    tell you the exact location.  One of them is in Stari Grad or in the Old

 7    Town in Vladicin Han.  So there were several locations for distributions

 8    and it was distributed from a centre which was near those places and that

 9    is where it was distributed.

10       Q.   When you listed these places where distribution was done could you

11    tell us for the period from the end of 1992, 1993, 1994, did it happen

12    that during the distribution of humanitarian help, humanitarian aid, there

13    was shooting that occurred, was there firing at the people who came to

14    collect the aid at these locations?  Was there ever any firing?

15       A.   Yes, once.  I think that this happened the middle or end of

16    April.  I can't tell you the exact date.  But I know it was Orthodox

17    Easter, the time of Orthodox Easter, when people were expecting

18    distribution of eggs which never arrived.  Two shells landed on the roof

19    of the scout centre.  There were no casualties, nobody died.  And I found

20    out from the Croatian Defence Council soldiers who were in this facility,

21    that they had helped 12 people who were slightly wounded because people

22    were probably, most probably wounded by shrapnel.  And I remember an

23    interesting sarcastic question asked by a Croatian soldier.  He said:

24    "Sir, do you know whether they are firing at us or at you?"  At that time

25    I understood that sarcasm as comment on the fact that there were fierce

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Page 13299

 1    conflicts between the Muslims and the Croats.

 2       Q.   Mr. DP1, until 18th of July 1991, you lived in Sarajevo, could you

 3    tell us, what was the everyday life of your family in Sarajevo?  Could you

 4    tell us about electricity, gas and water?

 5       A.   It was hard.  There were periods when there was water, when there

 6    was electricity for ordinary citizens, and there were very long periods

 7    where there weren't any.  But certain, people who had privileges as a rule

 8    had both.  Once I bitterly observed to a friend that in the evening it was

 9    easy to spot who was the new commanders, new authorities, new leaders,

10    because they were able to get electricity and there was gas.  So they were

11    able to transform that into electricity.  At one point, there was

12    electricity in the entire building, and I was the only one without.  But

13    what I want to say is that one occasion, it was early November in 1993,

14    and I spoke to Mr. Hasan Muratovic at the airport, this was with the

15    Serbian side Mr. Koljevic, who was on the Serbian side, and I realised

16    that less hatred between these two would have ensured more water and

17    electricity for Sarajevo because they did discuss the repairs that were

18    supposed to be done to the electrical equipment.

19       Q.   I believe that you said there was always gas?

20       A.   Yes, almost always.

21       Q.   Did you have any knowledge about the causes of electricity and

22    water shortage?

23       A.   I can only say with certainty what I heard, which was at this

24    discussion, these talks that the electrical equipment was that was

25    damaged, and because they went on the confrontation line and Mr. Muratovic

Page 13300

 1    and Mr. Koljevic agreed that the commanders are to be given orders that

 2    they should not fire at the workmen who come to repair.  This was

 3    official, but I heard, and not more than once that this was used as

 4    manipulation that the supply of water, supply of electricity was being

 5    manipulated with.  Because there was a general desire, general belief,

 6    general expectation, that only difficult atmosphere, difficult situation

 7    in Sarajevo would speed up an intervention from outside and it would lift

 8    the siege of Sarajevo, as they said.

 9       Q.   Witness, if I tell you that on the 3rd and 4th of December 2001, a

10    witness appeared before this Chamber who replying in relation

11    to -- relation to water and electricity, page 678 asking about the water

12    and who had the control of the water.  He replied that water supply was

13    under the control of Republika Srpska.

14            Now, could you tell us if this is an exact accurate answer to a

15    question?

16       A.   As far as I know the main two points for water supply, one was

17    Mojmilo and the other one -- the other one was sources and pumps in

18    Ilidza.  I was not there.  I don't know exactly where the line went.  But

19    if this belonged to Ilidza, then it was probably was under the control of

20    the Republika Srpska.  But and also so the pumps, even the Serbian pumps

21    couldn't work without electricity, so obviously it was all linked.

22       Q.   Could you tell us if the other one was under the -- other one was

23    in Mojmilo.  Can you tell us under whose control Mojmilo was?

24       A.   I found out after I left Sarajevo the second time because during

25    the war, I left Sarajevo four times, or I got out of Sarajevo four times,

Page 13301

 1    and then I was informed, and I saw that Mojmilo was under the control of

 2    the BH Army.

 3       Q.   Mr. DP1, you told us that you got out of Sarajevo four times.

 4    Could you tell us how easy was it for citizens of Sarajevo to leave it?

 5       A.   From the moment that the conflict broke out, no citizens in

 6    Sarajevo could leave easily.  I managed to get out because I was a

 7    humanitarian worker and I managed to get all the permissions from police,

 8    army, and so on.  The first time I left was in April 1993, and I got out.

 9    I was out for one hour in Ilidza.  That time I then slightly adjusted my

10    opinion about the conflict.  I was amazed that Ilidza was severely

11    damaged, that it was much more damaged than the part of town that I was.

12    And on the demarcation line so from Stupska Petlja,, the street which goes

13    from the main road towards Ilidza, I can't remember it exactly, this was

14    an actual wasteland.  There was nothing that could be seen.  This was all

15    destroyed.  So I got out when I was allowed, and on the agreement of the

16    other side, that is, the Serbian side.

17       Q.   Mr. DP, you told us that you left the city, and that you were in

18    Ilidza.  Could you tell us the demarcation lines that you spoke about, and

19    which were, as you say, ethnic lines, could you tell us what was the

20    percentage of the urban part of Sarajevo that was under the control of one

21    side and how much under the control of the other side?  Or perhaps you

22    could tell us according to municipalities, which part of the town was

23    under the control of one side, and which was under the control of the

24    other?

25       A.   I am not quite clear with the expression "urban part of town,"

Page 13302

 1    because urban part of town is also Ilidza, urban part of town is also

 2    Ilijas.  These were all parts of the city because they were connected with

 3    public transport, with infrastructure.  So in my opinion, all of these

 4    were urban parts of town.  But, according to what I saw when I got out,

 5    this demarcation line ran approximately, according to the lines which on

 6    both sides represented the majority population, so the demarcation lines

 7    from Grbavica, they followed the street where there was more majority Serb

 8    population.  The other side majority Muslim and so on.  Grbavica was a

 9    majority Serbian.  Stari Grad, Old Town, majority Muslim and so on.  So I

10    felt that these lines were like ethnic demarcation lines dividing the city

11    under the control of two strong nationalist groups that were in the city.

12    When I finally left Sarajevo and I left Sarajevo on several occasions,

13    when I finally left Sarajevo, I found exactly the very same demarcation

14    lines in place the first time and the last time I left.

15       Q.   Mr. DP, you told us about the discussion with civilian authorities

16    that you had when a convoy of six Serbs was supposed to leave Sarajevo.

17    Could you tell us, bearing in mind the activities that you were involved

18    in and the possibility of contacts with authorities, could you tell us

19    about the position, situation of Serbs in Sarajevo, and did this convoy

20    ever leave Sarajevo with the six Serbs?

21       A.   I think that was 9, 10, 11th in 1992.  I was involved directly.

22    At the time I did not belong to a single association, not even

23    humanitarian.  But I was interested because one of the people who were ill

24    was my grandmother.  So incredible things happened the way I felt -- the

25    way I saw them, that they, in the morning, the convoy was supposed to

Page 13303

 1    leave of 900 or 1.000 people --

 2       Q.   Witness, could you please tell us briefly whether this convoy left

 3    or not.

 4       A.   I think only three buses left.  I think the others didn't.  All

 5    the sick people didn't leave including those that were in the wheelchairs

 6    and stretchers and that was a cold November day.  Only three buses left.

 7       Q.   Witness, during my examination you told us that there were days

 8    with no electricity and no water, and there were also situations that only

 9    you in the entire building had no electricity, that is, water.  Now, could

10    you tell us, where did your family get water from?

11       A.   In different locations because occasionally there would be some

12    water, and then we would fill up canisters, and then occasionally, very

13    rarely in the beginning, there were cisterns, tanks that came.  And then

14    we went to Bistrik because there was a brewery there which had a lot of

15    water and people would wait in the line to get water.  But I never want to

16    those -- I never went to the brewery because there was this belief that

17    Caco was there, that he was without mercy, that he was arresting people,

18    so I didn't dare go.  That was one reason I didn't go.  And the second

19    reason was for a while I was injured and I had broken a rib so I was not

20    able to go to Bistrik.

21       Q.   Mr. DP, you told us at that part of Bistrik there was Caco and

22    that he was arresting people.  Could you tell us which people he was

23    arresting and why and do you have any knowledge of this?

24       A.   Well, arrests of people in the street started rather early,

25    sometime in May because of digging of trenches.  The second wave started

Page 13304












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Page 13305

 1    in June after the mobilisation was proclaimed.

 2            MR. IERACE:  Mr. President, I can see that I rise to my feet a

 3    little late.  The question asked by my learned colleague was in part:

 4    "You told us at that part of Bistrik there was Caco and that he was

 5    arresting people." When one looks at the previous answer of the witness,

 6    he in fact said "I never went to the brewery because there was this belief

 7    that Caco was there."

 8            My objection is to the question on the basis of that it doesn't

 9    accurately state the evidence, and I think that is in important in respect

10    that the question should do that, Mr. President.  In other words, that it

11    was a "belief" and not a "fact."

12            JUDGE ORIE:  Ms. Pilipovic, in the English translation it says

13    that it was "believed" that Caco was there and was arresting people.  So

14    therefore it would have been appropriate to see what is the basis of this

15    belief or assumption or what the knowledge of the witness exactly is.

16            Please proceed.

17            MS. PILIPOVIC: [Interpretation] Yes, Your Honour.  That would have

18    been my question.

19       Q.   Who did you get this information from?  So, did you see this, did

20    you hear this?  If you heard it, who did you hear it from?

21       A.   I heard it from Mr. Rade Savic which was a long time friend and

22    who spent nine months digging trenches in Trebivic and the surrounding

23    area.  And I know also before the war and also another friend of mine,

24    Radivojevic, also went to dig trenches.  This is common knowledge, that in

25    Sarajevo it was normal, it was usual for people in the first months of

Page 13306

 1    war, people who were not in the army, who do not have a work obligation,

 2    they would be just gathered in the street, rounded up, and they would be

 3    taken to dig trenches.

 4            JUDGE ORIE:  Ms. Pilipovic, looking at the clock, if you could

 5    find a suitable moment for a break, relatively soon, that would be

 6    appreciated.

 7            MS. PILIPOVIC: [Interpretation] Yes, Your Honour.  We will have a

 8    break.  I just wanted to confirm, to have it confirmed by the witness --

 9       Q.   So for these people whose names you quoted, from them you heard

10    that it was Caco, and Caco's unit, they were the ones who were arresting

11    people and taking them to dig trenches.

12       A.   Yes, yes, I heard that.  And I was the prey of such arrests.

13            MS. PILIPOVIC: [Interpretation] Your Honour, I believe that this

14    is the time for us to have a break.

15            JUDGE ORIE:  Yes.  We will adjourn until quarter past 4.00.

16                          --- Recess taken at 3.45 p.m.

17                          --- On resuming at 4.20 p.m.

18            JUDGE ORIE:  Ms. Pilipovic, please proceed.

19            MS. PILIPOVIC: [Interpretation] Thank you Your Honour.

20       Q.   Mr. DP, yesterday during the examination you identified for us a

21    number of buildings in your area where the troops were accommodated.  Can

22    you tell us if you personally saw -- during the time which you lived in

23    Sarajevo -- did you see those buildings shelled?  And please say yes or

24    no.

25       A.   Yes.

Page 13307

 1       Q.   Thank you, Witness.  You say, "yes."  Can you tell us when?

 2       A.   I can tell you about one occasion and I already mentioned it.  It

 3    was the scout's home which accommodated a Croat unit.  So shells

 4    frequently fell there.  And as you walked by, you could see marks.  And I

 5    already said that next to the faculty of stomatology of dentistry, there

 6    were -- one could see a large number of projectiles which had fallen

 7    around small buildings in a park around the between them.  I do not know

 8    whether the shells hit Skerliceva.  One hit the building next to mine.

 9    Another one hit my building or rather in my -- and that was in the

10    immediately vicinity of those buildings.  So the answer could be yes.

11       Q.   Mr. DP, when you mentioned the faculty of stomatology, can you

12  [redacted]

13  [redacted]

14  [redacted]

15  [redacted]

16  [redacted]

17  [redacted]

18  [redacted]

19  [redacted]

20  [redacted]

21  [redacted]

22  [redacted]

23  [redacted]

24            JUDGE ORIE:  Ms. Pilipovic, if I would have a map with some places

25    on it, and someone would say it is 1.000 metres, then you have a lot of

Page 13308

 1    other places that were at the distance of 1.000 metres, but the closer

 2    comes, the more identifiable it is.  You asked for the protective

 3    measures.  The Chamber granted them.  I will ask the Registrar to make a

 4    redaction on from page 33 -- no my pages are -- or I hope they are

 5    correct.  Page 33, line 8.  And would you please take care that the

 6    protective measures you sought really remain effective.

 7            MS. PILIPOVIC: [Interpretation] Yes, Your Honour.  With your

 8    leave, I would like to show the witness a map, and then would ask that we

 9    go into a closed session, and then he could mark it and if he can help us

10    by telling us which part of the city it is, so that he explains to

11    everybody what he has explained, what he has answered.

12            JUDGE ORIE:  Yes.  It is up to you to use your time as you deem it

13    good.  On the other hand, you might be aware that if it is about the

14    general geography of the city, the Chamber has become more and more

15    familiar with it already.  So if it is just about the area, the region, it

16    might be repetitious, but if it goes into more detail, please proceed.

17    Yes, we will then --

18            MS. PILIPOVIC: [Interpretation] Thank you, Your Honour.

19            JUDGE ORIE:  We will then turn into closed session so that

20    whatever is on the ELMO -- Ms. Pilipovic, if we do not use the ELMO, I

21    don't know whether the witness has to point at several locations, because

22    that can only be done through the ELMO.  If it's just a matter of

23    explaining it could be done in private session as well.  But if you think

24    the ELMO would be of any use, then we should go into closed session.

25            MS. PILIPOVIC: [Interpretation] Your Honour, we need the ELMO

Page 13309

 1    after all.  Of course, I can first ask the witness if whether he can --

 2            JUDGE ORIE:  We are in closed session now.

 3                          [Private session]

 4  [redacted]

 5  [redacted]

 6  [redacted]

 7  [redacted]

 8  [redacted]

 9  [redacted]

10                          [Closed session]

11  [redacted]

12  [redacted]

13  [redacted]

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15  [redacted]

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18  [redacted]

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Page 13310












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Page 13317

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10  [redacted]

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16  [redacted]

17  [redacted]

18  [redacted]

19  [redacted]

20  [redacted]

21                          [Open session]

22            JUDGE ORIE:  We are in open session again.  Please proceed, Ms.

23    Pilipovic.

24            MS. PILIPOVIC: [Interpretation]

25       Q.   Mr. DP, you marked the Kosevo Hospital, and I think you said that

Page 13318

 1    you visited it four times while you were in Sarajevo; is that true?

 2       A.   Three times.  Three times.

 3       Q.   Thank you, Witness.

 4            Can you tell us, on those three occasions when you went to the

 5    hospital, did you next to the hospital or in the hospital see any armed

 6    men?

 7       A.   I went there -- the first time, I went there to see Dr. Starovic,

 8    whom I had known for many years.

 9       Q.   Witness, you don't have to go into all this explanations.  Just

10    tell us if you were there and what --

11       A.   Yes.  There were quite a number of soldiers at the entrance into

12    the hospital and some of them were armed.

13       Q.   Can you tell us when was that?

14       A.   I think it was sometime in the autumn of 1992, because

15    Dr. Starovic was wounded by a sniper while he was in his yard.  He was

16    receiving their treatment and so we went to pay him a visit.

17       Q.   Witness, I would like to ask you for your protection, not to give

18    us any names, not to mention names of people.  And I am asking you about

19    the second and third time when you went there.  When was that and did you

20    see armed men there, too, on those occasions?

21       A.   I went to the orthopaedic clinic because I had some problems with

22    my arm, and there was a war commander, war director, Dr. Cibo [phoen] and

23    from the window of the surgery of the doctor that I went to see, he said

24    that there was a group of his armed escorts who were in uniform and --

25            JUDGE ORIE:  Yes, Mr. Ierace.

Page 13319

 1            MR. IERACE:  Mr. President, again it seems to be another case of

 2    the witness relating what someone else has told him was the case as we

 3    heard yesterday in relation to the Military Hospital.  I appreciate that

 4    hearsay is admissible and it is a question of weight.  But if it is

 5    entirely dependent upon what he was told by someone else, in my respectful

 6    submission, it is of no assistance to the Trial Chamber.  Thank you.

 7            JUDGE ORIE:  As I indicated yesterday, it is to some extent left

 8    to the parties to draw a line between what is useful hearsay and what is

 9    hearsay that would finally not assist the Chamber.  Ms. Pilipovic, it is

10    also a matter of how you use your time and of course, direct knowledge of

11    witnesses might be to be preferred.  So I -- the Chamber is aware that you

12    cannot always forecast what the answer of the witness will be, but please

13    keep that in mind.

14            MS. PILIPOVIC: [Interpretation] Yes, Your Honour.  Thank you.

15       Q.   Witness, when you told us that you went to the clinic for the

16    second time and you mentioned a certain commander, a doctor, did you

17    personally see at that time when you were there, did you see armed men?

18       A.   I went to see Dr. Remzo Bajrovic who was an orthopaedic surgeon,

19    and through the window it could be seen that a group of soldiers were

20    passing by.  He then told me that this was the new director of the centre

21    for orthopaedic surgery that was Dr. Cibo.

22       Q.   Mr. DP1, could you tell us this third time when you say that you

23    went, when was that?  When did you go to the hospital?

24       A.   I had some heart problems and I --

25       Q.   Would you just please be precise, when that was and did you see

Page 13320

 1    armed men, armed soldiers?

 2       A.   I did not see armed soldiers at the time because I went to see

 3    Dr. Lipa who was a -- before that, he was a health minister.

 4       Q.   Thank you, Witness.

 5       A.   You are welcome.

 6       Q.   When you went to the hospital on these occasions, did you, on the

 7    way from your house to the hospital, did you observe or rather did you see

 8    any weapons and armed men?

 9       A.   Yes, I had to go past the aforementioned locations where I

10    specified that there were soldiers, and in those locations I saw the

11    soldiers.

12       Q.   Did you see any weapons?

13       A.   No.

14       Q.   During your stay there, your stay in Sarajevo, did you see armed

15    men in movement or movement of these units?

16       A.   On several occasions, I saw large groups of soldiers for whom I

17    assumed, I presumed, according to their appearance, that they were

18    returning from the front line.

19       Q.   Mr. DP, in the building where you lived, were there troops there?

20       A.   In the building where I lived, occasionally, on two or three

21    occasions, there would be some wild unit that came in to premises that

22    belonged to a company which had just ceased to function.  I think it was a

23    company from Croatia or from Serbia.  But occasionally, a group of 30 men

24    would appear there and be there for 7 or 8 days and the story was they

25    were called a "wild unit or an irregular unit."

Page 13321

 1       Q.   Mr. DP, could you tell us if in the part of town where you lived,

 2    were there facilities that were shelled?

 3       A.   The shells were falling around the faculty of medicine and around

 4    the faculty of stomatology.  I already said that the shells were falling

 5    in this mini-locality next to the stomatology faculty.  There was also

 6    shells falling in the Skerliceva street where I --

 7       Q.   Thank you, you already said that. Do you have any knowledge about

 8    other parts of town, did you see facilities that were shelled?

 9       A.   Yes, I saw shelling of the former government of

10    Bosnia-Herzegovina, government building.  I saw shelling of facilities in

11    Marin Dvor, the so-called Unisys skyscraper, in that part of town, I

12    mostly saw those high-rise buildings were shelled and were targeted.

13       Q.   When you tell us that you saw that high-rise buildings were

14    shelled, did you have any knowledge whether in those buildings there were

15    troops in there?

16       A.   I never went to any of those buildings.  Although this is not an

17    argument, I have to say, that talks, the rumours had it, that from the top

18    of those buildings, snipers were active, although I never saw any snipers,

19    because I never went past there.

20       Q.   Mr. DP, could you tell us --

21            MR. IERACE:  I make the same objection.  But I appreciate what the

22    ruling is likely to be.

23            JUDGE ORIE:  Yes.  The question was whether the witness had any

24    knowledge and I think when the answer was given Ms. Pilipovic intended to

25    put the next question, so I can't prevent the witness to give the answers

Page 13322












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Page 13323

 1    he has in mind.  And I would not prevent him from doing so.  But perhaps,

 2    in general, Mr. DP1, and I repeat what I said yesterday to you, the most

 3    important is what you observed by yourself.  And sometimes it might be of

 4    specific importance to know what someone told you.  But, in general, I

 5    would not say for certain but in general what rumours that were there is

 6    not of much assistance for this Chamber, since we do not know the sources

 7    of these rumours.  So unless there is a specific reason to refer to that,

 8    I invite you to answer the questions of Ms. Pilipovic in such a way that

 9    we get clear information about what you experienced, what you observed,

10    and only if really necessary also what general information that was there,

11    and then preferably, with a specific source of your information.

12            Please proceed, Ms. Pilipovic.

13            MS. PILIPOVIC: [Interpretation] Thank you, Your Honour.

14       Q.   Mr. DP, could you tell us on the basis of what information did you

15    tell us, and who did you hear from that there was snipers on those

16    high-rise buildings?

17       A.   On the basis of a general opinion there was a front, there were a

18    front line, there were two parties on two opposing sides, and they were

19    trying to eliminate each other with the use of weapons.  And I can say

20    that I heard some stories, I heard stories about snipers in my own

21    building.  There were snipers, and this is not contested.  There was

22    firing all over the place.  And I am just saying that the general opinion

23    that people held is that this was the way that was used to eliminate

24    firing positions.

25       Q.   Thank you, Mr. DP.

Page 13324

 1            Mr. DP, on several occasions you mentioned that you watched

 2    television, and that you listened to the radio.  Could you perhaps tell us

 3    what was media -- what were media reports like?  Did they faithfully

 4    report about what was happening in Sarajevo?

 5       A.   I have to say that truth is the first casualty of war, and then

 6    morality.  The warring parties used the media as a type of psychological

 7    war, and really, you could not believe the media at all because they were

 8    just expressing the opinions of the parties in power.  They were

 9    instigating in people, they were spreading hatred, that is my assessment

10    of the work of the media.

11       Q.   Thank you, Witness.

12            Do you have any personal knowledge, first-hand knowledge, if you

13    do please tell us, on the basis of which information do you know if in the

14    city of Sarajevo there were workshops for manufacturing weapons?  If you

15    don't have personal knowledge, please say no.

16       A.   I don't have any personal knowledge.

17       Q.   If you heard about it, could you tell us where from, who from did

18    you hear about it?

19       A.   When shells are flying and when there is fear in corridors and in

20    the basements where we gathered, there were all sorts of stories.  And

21    naturally, there were these stories, and also stories that said that new

22    weapons were invented that would eliminate enemy overnight and so on.  But

23    of course these are just stories and I wouldn't retell them.

24       Q.   Mr. DP.  You told us yesterday in the examination-in-chief that

25    there were lots of weapons in Sarajevo.

Page 13325

 1       A.   Yes.

 2       Q.   Could you tell us, did you personally have weapons, and do you

 3    have any knowledge how Serbian population was getting the arms in

 4    Sarajevo?

 5       A.   As a former manager, I had a trophy pistol and I had quite a lot

 6    of problems to hand it over.  And I handed it over or surrendered it,

 7    thanks to a friend --

 8       Q.   Thank you, Witness.

 9            I would just like you to answer in relation to your knowledge,

10    your personal knowledge, whether you know if a party -- and I am

11    particularly -- there were several parties -- but, did the SDS arm Serbs

12    in Sarajevo?

13       A.   I am a Serb.  I am a member of the Serb nation, of the Serbian

14    people.  I was not armed.  I have -- there are seven other families who

15    are related to me of the same surname, they were in Sarajevo as well.  And

16    they were not armed.  It doesn't mean that they were not doing the arming.

17    Before the war, the weapons were timidly discussed, but when the war

18    started, then suddenly people started talking how people got weapons for

19    themselves, for their children, in order to defend Bosnia-Herzegovina.

20    And then I also drew the conclusion that wherever there is war, there is

21    always a large number of weapons smugglers.

22       Q.   Mr. DP, you as an activist of an organisation or an association

23    you said that people who knew about it called it "aggressors

24    organisation."  Could you tell us if there were Serb families in Sarajevo

25    in 1993, in that part of town where you lived in, that you say was under

Page 13326

 1    the control of the BH Army?

 2       A.   Together with the group of activists considering that we had a

 3    first, quantity of food, we decided to distribute it by getting to every

 4    Serb family.  And we had a register, we kept a register, and I believe it

 5    is accurate, in September 1993, 15.300 Serb families, out of that there

 6    were about 15 per cent of mixed families, and then there were some Serbs

 7    who were closer to the front lines.  They didn't feel like they could say

 8    that they were Serb, they refrained from that.  And then some of them --

 9    some of the Serbs didn't wish to declare themselves as Serbs.  So that

10    this conclusion could be drawn that according to this -- according to this

11    register, there were 1.6 family members.  That was the average number for

12    a number of members in Serb families in Sarajevo.

13       Q.   During your stay in Sarajevo did you have any unpleasant things

14    that happened to you?

15       A.   Yes.

16       Q.   When you say, "yes," could you perhaps tell us about these

17    unpleasant things that happened and what form did they take?

18       A.   War is a situation where reason is absent and there are no human

19    laws, but war laws.  And I always interpreted this as somebody's need to

20    identify themselves as a member of an elite and in order to do this,

21    somebody else needs to be pushed out of the way.  I am not saying to

22    eliminate, but that is the idea.  I had some encounters with the police,

23    but I am still here.

24       Q.   Mr. DP, during this trial we have heard many witnesses who told us

25    that cemeteries were shelled in Sarajevo.  While you were in Sarajevo, do

Page 13327

 1    you have any personal knowledge of this and did you ever see this?

 2       A.   Once on TV I believe that this is Partizanska Groblje, Partisan

 3    Cemetery, which is right next to the engineering faculty and because I saw

 4    that on TV, I don't know how relevant it is but this counterinformation so

 5    to speak which came from the Serbian press agency this was announced that

 6    the shell had targeted faculty of engineering which was a centre --

 7            JUDGE ORIE:  Yes.

 8            MR. IERACE:  Mr. President, the objection that I make is similar

 9    to the one I made earlier today and another one yesterday.  In this sense,

10    that I don't object to the question, I do object to the answer, both

11    yesterday and today, Mr. President, you implied that it was not possible

12    to object to an answer.  My respectful submission is that the

13    Trial Chamber is entitled to strike out part of an answer or an answer in

14    its entirety, if it is not admissible evidence.  And in this case, the

15    question -- the answer is clearly not responsive to the question.

16    Furthermore it is hearsay of, in my respectful submission, no assistance

17    to the Trial Chamber for this reason:  He is recounting what he saw on TV,

18    having only a few minutes ago, made clear his personal view that the media

19    was unreliable as a source of information.  Thank you.

20            JUDGE ORIE:  Strike out answers, of course, is mainly functioning

21    in a jury system where it should be clear for a jury what they could take

22    into account and what they could not take into account and the mere fact

23    that the witness saw something on television does not make it in itself

24    inadmissible.  But, Ms. Pilipovic, where the witness himself indicates,

25    after he has told this Chamber that the media were an instrument for the

Page 13328

 1    party that was controlling the area, perhaps after he has told us that it

 2    might not be relevant, perhaps it would have been appropriate for you to

 3    see whether it was useful spending of time.

 4            Please proceed.

 5            JUDGE NIETO-NAVIA:  Mr. Ierace, I think that the answer confirms

 6    what the witness said before, that he saw on TV something, and after that

 7    he received the counterinformation.

 8            MR. IERACE:  Your Honour, I must say I read it differently.  I

 9    read it as meaning that he has only source of information in relation to a

10    particular incident is what he saw on TV.  Although, I do note that he

11    refers to some confirmation, so I take your point, Your Honour, to that

12    extent.  But both sources are media sources presenting a particular view

13    as to what happened.

14            JUDGE NIETO-NAVIA:  That is exactly what he said before.

15            JUDGE ORIE:  Then please proceed, Ms. Pilipovic.

16            MS. PILIPOVIC: [Interpretation] Thank you, Your Honour.

17       Q.   Mr. DP, you mentioned technical faculty or was it engineering?

18       A.   I think it is faculty of engineering.

19       Q.   Do you know if there were troops quartered in the faculty of

20    engineering?

21       A.   If it is about what I saw personally, I haven't seen them, but I

22    did hear about it.

23       Q.   When you say that you heard about it, could you tell us where from

24    and when?

25       A.   I said from the media, and I really told you that I did not

Page 13329

 1    believe the media in the war.

 2       Q.   Could you tell us, when we spoke about the facilities, could you

 3    tell us whether during the war telephones operated in Sarajevo during the

 4    war?

 5       A.   In the part of Sarajevo where I lived for a while there was

 6    no -- there were no telephones that were operating because the central

 7    post office was destroyed.  But then later on some individuals who were at

 8    important positions, they had telephone connection.  It wasn't en masse,

 9    but they did have them.

10       Q.   When you say, "individuals who were in high positions or carried

11    out a higher or more important functions," could you tell us who were

12    these people and where did they work?

13       A.   I only used telephones in two locations.  This was the former

14    postal savings buildings, because I knew the director of the PTT who was

15    the same director as before the war and stayed after the war, and he

16    was -- beginning of the war.  And in my own buildings where the neighbours

17    above me, a professor and a lady who worked in the state administration,

18    they had telephones.

19       Q.   Mr. DP you told us that you communicated in the city.  What I want

20    to ask you is whether in 1992 you saw people who had had injury or were

21    killed by snipers or as a consequence of shelling in the street,

22    specifically, July, August, September October, 1992?

23       A.   Unfortunately, I saw the incident in Miskin Street.  That was at

24    the end of May.  And the [indiscernible] conflict in my opinion took place

25    somewhat later in the autumn that year.  I personally didn't find dead

Page 13330

 1    bodies, except in Vasa Miskin Street.

 2            MS. PILIPOVIC: [Interpretation] Your Honour, if I may just confer

 3    with my co-counsel.  With your leave, my co-counsel would like to ask a

 4    few questions so that we can be more efficient.

 5            JUDGE ORIE:  Yes, leave is granted.

 6            MR. PILETTA-ZANIN: [Interpretation] Thank you very much.

 7                          Examined by Mr. Piletta-Zanin:

 8       Q.   [Interpretation] Hello.  Witness, I would like to ask you some

 9    questions and I would like to ask you to answer them as briefly as

10    possible, please.  First question:  Did you hear -- I am not just saying

11    see -- did you hear that weapons were fired in the area where you lived,

12    and I am talking about heavy weapons?

13       A.   Apart from the incident that I have already described, I

14    couldn't -- I wouldn't be able to locate this, and I wouldn't be able

15    to --

16       Q.   Witness, I am not asking you to locate it, but only if you heard

17    it; yes or no?

18       A.   Yes.

19       Q.   Very well.

20            Did you hear it often, very often, rarely, relatively often?

21       A.   Well, quite often.

22       Q.   Thank you very much.

23            Witness, now I would like us to go back to the question of

24    distribution of humanitarian aid.  You told us about this distribution,

25    and what I would like to know whether in your neighborhood, this

Page 13331

 1    distribution of aid took place often, rarely, quite often, quite rarely,

 2    and so on?

 3       A.   Humanitarian aid that was distributed by the UNHCR was regular, it

 4    was insufficient, however, it was distributed equally to every citizen.

 5       Q.   I am going to interrupt you.  When you say "regularly" what was

 6    the rhythm?  What was the frequently?  Was it once a fortnight?  Once a

 7    month?

 8       A.   According to the rule, it was once a month, but it was quite often

 9    late.

10       Q.   Very well.

11            Witness, do you know if, on top of this distribution, were there

12    specific distributions of water and where, also of bread -- or of bread?

13       A.   I know that there were other humanitarian organisations that used

14    specific channels, specific criteria.  They had privileged criteria and

15    privileged channels to distribute humanitarian aid and this did not

16    encompass the whole population.  Bread was not distributed or rather it

17    was distributed in certain locations for money.  So it was sold, bought

18    and sold for coupons.  And these were certain locations where one was

19    supposed to go and wait and then approximately one would get 250 grams per

20    day when there was bread.

21       Q.   Very well.  Now in relation to these places, can you tell us where

22    they were, those points, the points which everybody knew?

23       A.   Well, more or less, yes.

24       Q.   And if these were places which everybody knew, then I think people

25    waited, what, inside or outside, in the street?

Page 13332

 1            MR. IERACE:  I object, Mr. President.  I stand to be corrected,

 2    but I don't see where the witness said that the places of distribution

 3    were places which everybody knew.

 4            MR. PILETTA-ZANIN: [Interpretation] He has just answered.  The

 5    witness has just said:  "More or less, yes," I think that is what he said.

 6            MR. IERACE:  And the question was:  "Now in relation to these

 7    places, can you tell us where they were, those points, the points which

 8    everybody knew?"  And given that it is examination-in-chief, that is a

 9    leading question which does not appear to reflect the earlier evidence of

10    the witness.  It amounts to putting words in the witness's mount, which is

11    the reason for my objection, Mr. President.

12                          [Trial Chamber confers]

13            JUDGE ORIE:  The objection is denied although, Mr. Piletta-Zanin,

14    it might be wise that if the witness said "more or less," that in your

15    next question you will refer to his precise answer.  But I may also remind

16    the parties that if no one would know where to get the bread, would that

17    make any sense?  I mean, apart from the legal and procedural aspects

18    involved in it, I wonder whether there would be one place in the world

19    where no one would know where to get the bread.  Please proceed.

20            MR. PILETTA-ZANIN: [Interpretation] Yes, you are right, but I was

21    about to -- thank you very much, Mr. President.

22       Q.   These places, Witness, where people went were they some indicated

23    queues or perhaps people didn't have the time to wait?

24       A.   You -- one waited and yes, there were queues.

25       Q.   Thank you very much.  Since there were queues since you tell us in

Page 13333

 1    your answer and I would prefer a yes or no, do you know of any example of

 2    one of those queues that everyone knew about and that was shelled, that

 3    you had seen.

 4       A.   Only when I mentioned Vasa Miskin Crni Street.

 5       Q.   Perhaps we shall come back to this incident later on.  But you

 6    personally, apart from that incident, are you aware of any other incidents

 7    yes or no?

 8       A.   No.

 9       Q.   Thank you.

10            Witness, you spoke a while ago about the engineering faculty.  Do

11    you know if it worked during the war?

12       A.   I don't know.

13       Q.   When you say that it is that you don't know or that it did not

14    work?

15       A.   I said I do not know.  That was my answer.  I did not know.

16       Q.   No, your answer was no, that is what came out.  Thank you very

17    much.

18            Witness, now I would like to ask you something about possible

19    marketplaces in your area.  Were there green markets there?  I believe you

20    mentioned a while ago that you talked about in the area that you lived,

21    were there any marketplaces?

22       A.   Well not quite near me.  At a certain distance, yes.

23       Q.   At that area, was it an open area; yes or no?

24       A.   Open.

25       Q.   Thank you.

Page 13334

 1            Do you know if this marketplace, to your knowledge, was ever the

 2    target of mortar attacks?

 3       A.   I heard about it, but I did not see it.

 4       Q.   Did you hear about other attacks on other markets or perhaps the

 5    area where you lived, resided and lived?

 6       A.   Well, I am referring to them.  I told you about those places.  I

 7    told you that I heard -- that I heard -- that I had heard about those

 8    markets.

 9       Q.   But which markets are you referring to?  Could you -- are we

10    talking about something else outside your neighborhood?  What do you have

11    in mind?

12       A.   I mean, the Markale market, and the market at Alipasino Polje.

13    The media reported that it had been hit by shells and of course showed

14    those sites on television.

15       Q.   Witness, I would like to make something quite clear:  The question

16    that I asked you a moment ago, namely, whether the market in your

17    neighborhood was ever shelled, and you said "yes."  But did you mean that

18    market or perhaps some other market?

19       A.   As far as I can remember I said that in my neighborhood, strictly

20    speaking, there was -- there were no markets, that they were at a certain

21    distance.  I used to go to three different markets.  I went to Markale and

22    Kosevsko brdo, Kosevo hill there at the latter place, there were no

23    shellings there.  That I heard and saw on television the shells had hit

24    the Markale market.

25       Q.   Right, Witness, do I understand you then correctly, if I

Page 13335

 1    understand your testimony, admitting the fact that the market in the area

 2    where you lived, to your knowledge was never shelled; is that it?

 3       A.   That's right.

 4       Q.   Thank you.

 5            MR. IERACE:  I object.

 6            JUDGE ORIE:  Mr. Ierace.

 7            MR. IERACE:  If I had correctly read the transcript and heard the

 8    interpretation, the witness has --

 9            THE INTERPRETER:  Microphone, please.

10            JUDGE ORIE:  Use the microphone.

11            MR. IERACE:  As I understand the witness's evidence he has made

12    clear repeatedly that there was not a market in his immediate area.  Again

13    the question seems to be incorrectly putting the evidence to the witness.

14            JUDGE ORIE:  Yes, the objection is sustained.

15            MR. PILETTA-ZANIN: [Interpretation] Very well.

16       Q.   Witness, apart from the market that you spoke to me about, that is

17    the Markale and the incident that you mentioned, were there, to your

18    knowledge, other cases, are there cases when markets were targeted?

19       A.   Apart from what I already said and those two markets which I

20    mentioned, I did not hear of any others.

21       Q.   Thank you.

22            Witness, I now go back to bread queues, bread lines, that is,

23    queues of people waiting for bread.  To your knowledge, were there other

24    places where people also had to queue in the area that you knew, for

25    instance, to queue for water or whatever other need?

Page 13336

 1       A.   Except water and bread, I am not aware -- at least I did not have

 2    to queue anywhere else.  Needless to say, there were queues in front of

 3    humanitarian organisations.

 4       Q.   To your knowledge -- and now I am not talking about markets, I am

 5    talking about queues -- are you aware of water queues that were targeted

 6    in your area, neighborhood?

 7       A.   In my area, that did not happen.  But I did hear that once a shell

 8    fell --

 9       Q.   No, no no.  I am only asking about your direct knowledge, Witness.

10    So that we avoid any difficulty.

11       A.   In my area, in my neighborhood where we had water from time to

12    time, but at times we had to queue for it and a shell never fell on those

13    water queues.

14       Q.   Thank you very much.

15            Is there a mosque or mosques in the area in which you live?

16       A.   Well at a distance of some 300 metres in different directions,

17    there were two mosques.

18       Q.   Were they destroyed or targeted with a view to destroying them?

19       A.   No, while I was there.

20       Q.   The minarets, were they in place during the war?

21            MR. IERACE:  I object, Mr. President, on the basis of relevance as

22    this has come up in the last few weeks, the accused has not been charged

23    in relation to targeting places of worship or other buildings, and

24    therefore, this question and this line of questioning simply lacks

25    relevance.

Page 13337

 1            JUDGE ORIE:  Mr. Piletta-Zanin, yes.

 2            MR. PILETTA-ZANIN: [Interpretation] I don't think so, Mr.

 3    President.  I think if there was a campaign, really, a campaign whose

 4    purpose was to cleanse, then I do not see why -- I do not see why -- I

 5    mean, this is the war logic.  Why should one avoid the symbol which is

 6    most painful, which are most representative of a particular group.  The

 7    Defence is out to prove that these symbols were always protected and that

 8    is the best proof that there was no such campaign.

 9                          [Trial Chamber confers]

10            JUDGE ORIE:  The objection is denied.  The circumstances as the

11    Defence intends to demonstrate at this moment might be of some relevance

12    for the - for both the - whether the shelling was at random or not or

13    whether there was a campaign.  It could shed some light on that, so the

14    objection is denied.

15            Please proceed, Mr. Piletta-Zanin.  I say "please proceed" but it

16    is time for a break as well.  So I don't know whether this would be a --

17            MR. PILETTA-ZANIN: [Interpretation] Yes, I think it would be great

18    and we should need only a few minutes after the break.

19            JUDGE ORIE:  Yes.

20            MR. IERACE:  Mr. President --

21            JUDGE ORIE:  Yes.

22            MR. PILETTA-ZANIN: [Interpretation] If there are no more

23    objections.

24            MR. IERACE:  Mr. President, there is something I would seek to

25    raise at some appropriate time --

Page 13338

 1            JUDGE ORIE:  Yes.

 2            MR. IERACE:  In relation to, I suppose it could be called a

 3    housekeeping matter at a time convenient to the court but preferably

 4    today.

 5            JUDGE ORIE:  Yes, is it of such urgence or that it could wait

 6    until just a couple of minutes just before we adjourn or a couple of

 7    minutes before 7.00.

 8            MR. IERACE:  That could be fine, Mr. President, and I think I

 9    could telegraph my intentions by reminding you of some guidelines that the

10    Prosecution needs reasonably urgently.

11            JUDGE ORIE:  Yes, I am not sure whether I am give you after answer

12    to that.  Mr. Piletta-Zanin, you said you needed only a couple of minutes.

13    Is that -- without any objections, you added to that, unnecessarily.  If

14    that would be five minutes, I would like to continue so that the

15    cross-examination could start after the break.

16            MR. PILETTA-ZANIN: [Interpretation] It will be more than five

17    minutes, Mr. President.

18            JUDGE ORIE:  We will then have a break until five minutes to 6.00.

19                          --- Recess taken at 5.35 p.m.

20                          --- On resuming at 5.59 p.m.

21            JUDGE ORIE:  Mr. Piletta-Zanin, please proceed.

22            MR. PILETTA-ZANIN: [Interpretation] Thank you, Mr. President.

23       Q.   Witness, these water queues that you spoke to us about, we would

24    like to know if the distribution of water happened frequently or not, was

25    it on a daily basis or not?  What can you tell us about it?

Page 13339

 1       A.   Well water was not distributed practically.  Everybody had to go

 2    and look for water for himself, on those occasions when there was no water

 3    at all.

 4       Q.   Very well.  And where did you find yours and were there perhaps

 5    some points where you had access to water?

 6       A.   Well, such points were in Pionirska Dolina and there was next one

 7    next to the brewery and at times near some houses --

 8       Q.   No, I am going to interrupt you. Don't give us too many details,

 9    please.  Simply tell us if you were aware of such-and-such locations?

10       A.   Yes, one could hear it from one's neighbours.

11       Q.   Thank you very much.

12            And to your knowledge, Witness, did you ever see such places

13    shelled in your neighborhood?

14       A.   No.

15       Q.   Thank you.

16            Witness, I am now moving to another subject.  You spoke to us

17    about a "wild unit," remember?

18       A.   I do.

19       Q.   Thank you.

20            To begin with, were there some other similar units, units that

21    could be compared to that particular unit, whose members you could meet

22    personally in that part of the city?

23       A.   Yes.

24       Q.   Were there many such units, one, several?

25       A.   Towards the end of April and in early May, there were a number of

Page 13340

 1    such units.

 2       Q.   Thank you.

 3            Witness, those men, how strong were they were these groups, 10?

 4    30?  Less?

 5            MR. IERACE:  Mr. President, perhaps my friend could ask what year

 6    with the answer was "towards the end of April, early May," I assume that

 7    is 1992, but perhaps that can be clarified.

 8            JUDGE ORIE:  Please clarify this.

 9            MR. PILETTA-ZANIN: [Interpretation] Yes, I shall be happy to do

10    so.

11       Q.   Witness, are we talking about 1992, 1993 or what?  Which year are

12    we talking about?

13       A.   1992.

14       Q.   Thank you.

15            So I will go back to my question.  How strong were those groups,

16    approximately?

17       A.   Those who were in these building now and 10, were at times 10 men

18    strong, at times 20, at times 5.  I couldn't really.

19       Q.   Thank you, and were those men armed?

20       A.   Yes.

21       Q.   Could you tell us what kind of weapons did you see, for instance,

22    were they?  I am saying for instance, were they small arms or something

23    that you could wear in your belt or rifles, automatic rifles, machine-guns

24    or I don't know?

25       A.   As a rule, those were light weapons.  I didn't see any long

Page 13341

 1    barrels.

 2       Q.   For a technical reason, when you say, "light weapons," Witness, do

 3    you include -- are you talking about those weapons which you carry over

 4    your shoulder, that is, rifles, or do you mean just small arms?

 5       A.   Well, they at times had pistols and Hecklers, and they had knives

 6    and automatic ones, too.

 7       Q.   Thank you very much.

 8            Witness, I would like to move on to another line of questioning,

 9    namely, to the trenches.  Did you see in your neighborhoods or when you

10    went further out, did you see any trenches?

11            MR. PILETTA-ZANIN: [Interpretation] Now, this question is leading

12    on purpose, Mr. President, but I believe that we agree that there were

13    trenches.

14            JUDGE ORIE:  I think the existence of trenches is not in dispute.

15            MR. PILETTA-ZANIN: [Interpretation]

16       Q.   Witness, in your neighborhood, did you see them?

17       A.   No.  No, not in the area where I lived.

18       Q.   Did you see them outside that area?

19       A.   I did, yes, when I left -- when I went out of the city.

20       Q.   Witness, did you see people working at those trenches?

21       A.   I used to see people working at those trenches.

22       Q.   Witness, could you tell us, what do you know, who were those

23    people?  Were they military or were they civilians, to your knowledge, for

24    instance?

25       A.   They were civilians.

Page 13342

 1       Q.   Witness, could you tell us a little bit more, that is, according

 2    to you, were they -- could it be a construction company that had sent its

 3    workers or was it perhaps some other system at work?

 4       A.   They were just rank and file citizens who were rounded up in

 5    streets or summoned directly.

 6       Q.   Witness, you say that they were rounded up in the streets.  Who

 7    did that?  Who rounded them up in the streets?

 8       A.   In the area which I covered when going to work, those areas or

 9    parts of them would quite often be blocked and the people had to show

10    their IDs, their papers.  And it was the basis on which they selected

11    people who would have to go and dig trenches.  I was intercepted three

12    times -- I was stopped on three occasions by women and told not to go into

13    the streets that had been blocked, so as not to find myself in that

14    situation.

15       Q.   Witness, I don't quite understand what you are saying.  Is it your

16    capacity to dig something that you can read from your identity card or

17    why, for instance, this request to show your papers?

18       A.   Well, they were checking your ethnic origin.

19       Q.   And what were the consequences of this?  What is the conclusion

20    that can be drawn from it?

21       A.   Well, since the Army of Bosnia-Herzegovina was basically made of

22    Muslims, then the trench diggers ought to have been Serbs, by and large.

23       Q.   If I understand your testimony well, you are telling us that the

24    authorities were collecting -- were making the screening of civilians so

25    as to when they were Serbs they would send them to the front lines, is

Page 13343

 1    that what you are trying to tell us?

 2       A.   Yes.

 3       Q.   Very well.  And would there be fighting when people were sent like

 4    that to work on the front lines; yes or no?

 5       A.   Yes.  And the fighting would erupt all of a sudden, unexpectedly.

 6       Q.   Witness how did the authorities react if somebody was stopped, but

 7    then said "I don't want to go and dig trenches," to your knowledge, what

 8    was their reaction?

 9       A.   I don't think that could happen.

10       Q.   Why not?

11       A.   Well, you would simply be apprehended, put in a van or a truck and

12    taken to the place where you were supposed to dig trenches.

13       Q.   Would you be able to describe to us a kind of campaign intended to

14    provide labour which would -- who would be forced to go to the front line?

15       A.   Well it looked like forced labour, and I guess it was.

16       Q.   Witness, does -- did it seem to you structured, organised, I mean,

17    either from the point of view of -- by administration or by the military.

18       A.   In the area where I used to go through --

19            JUDGE ORIE:  Mr. Ierace.

20            MR. IERACE:  That is the third leading question that my learned

21    colleague has put to the witness.  The previous two put to the witness

22    where he had not previously said it, that the trenches were on the front

23    line.  So these are not technical leading questions.  I respectfully

24    submit to you that the Defence should not ask leading questions on such

25    critical issues in chief.  Thank you.

Page 13344

 1            JUDGE ORIE:  Mr. Piletta-Zanin, it is my recollection that the

 2    witness testified that he saw trenches when he left the city.  That is as

 3    far as the location is concerned.

 4            MR. PILETTA-ZANIN: [Interpretation] That is quite true, I confirm

 5    that.

 6            JUDGE ORIE:  But did he say it was at the front lines?

 7            MR. PILETTA-ZANIN: [Interpretation] I don't think that he said so,

 8    but we can clarify it.  However, I am going to ask him whether it was

 9    under fire or under shells and he said "yes."  But I will rephrase my

10    question.

11       Q.   Witness, these trenches, did they -- did they follow the front

12    line, that is, were they at the confrontation line between the two camps?

13            MR. IERACE:  Mr. President, that also is a leading question.

14            MR. PILETTA-ZANIN: [Interpretation] Right.

15       Q.   Where -- all right.  Let me put it this way:  Where were those

16    trenches?

17            MR. IERACE:  Mr. President, I think the question by itself is

18    without any relevance.  The question should be placed in a context, that

19    is, which trenches, and perhaps an appropriate starting point of the

20    trenches that this witness is forced to dig, where were those trenches?

21            JUDGE ORIE:  It is -- let's keep it as factual as possible,

22    Mr. Piletta-Zanin.  Let's not ask where trenches were in Sarajevo, but

23    let's -- could you please try to put your questions in such a way that we

24    get the information from the witness which comes from his own experience

25    and his own observation.

Page 13345

 1            Please proceed.

 2            MR. PILETTA-ZANIN: [Interpretation]

 3       Q.   Witness, these trenches that we are talking about, could you --

 4    could you locate them?  Could you place them so that we can see?  Could

 5    you somehow look at them in space so that we would know where they were?

 6            MR. IERACE:  Mr. President, that question also does not given an

 7    appropriate context.  The trenches that we are talking about, what

 8    trenches, in what context?  Trenches that this witness dug, that he saw

 9    other people that he knew to be Serb civilians digging or what?

10            MR. PILETTA-ZANIN: [Interpretation] Mr. President, I can ask a

11    question which can be very very long and I think it is much better if I

12    asked him -- if request ask it in three stages, in three steps.

13            JUDGE ORIE:  Yes.  I asked you, Mr. Piletta-Zanin, to be as

14    factual as possible in your questioning, so that we could, first of all,

15    get the answers concerning facts known to the witness.  So would you

16    please be very precise in asking for facts rather than general.  Perhaps,

17    first ask whether he saw trenches.  He answered that question already.

18    But when he saw then, whether he had to dig them, whether he knew of

19    anyone else.

20            Please proceed.

21            MR. PILETTA-ZANIN: [Interpretation]

22       Q.   Witness, can you tell the Chamber at what time did you see

23    trenches, what type of them, in relation to the work performed by

24    civilians there or at them?

25       A.   I saw trenches.  I already said when I went out of Sarajevo

Page 13346

 1    travelling in the cabin of a truck I could see trenches in two places.

 2    One as you come out of Stupska Petlja and then on another occasion as

 3    coming down from Trebevic, I could see on one side there were trenches.  I

 4    mentioned those two names, and I won't mention them again.  But one of

 5    them worked in the early days at the Jewish cemetery, that is where the

 6    confrontation line.  And another friend dug at Trebevic and at the foot

 7    hill --

 8            THE INTERPRETER:  Would the witness please repeat the other place

 9    name.

10       Q.   [Previous translation continues]... repetez les deux dernier noms

11    de lieus que vous avez indiquez.  Je crois que vous avez dit, Cimetiere

12    Juif et l'autre?  Pour raison de traduction.

13       A.   The line along Trebevic, and a second at Poljine and that is what

14    these people told me.

15       Q.   Right, thank you, Witness.

16            Now, in relation to those men to those people that you just

17    mentioned did -- or this man, did he go to those places of his own will;

18    yes or no?

19       A.   No.  One of them was a very sick man.

20       Q.   Was it one of those people who were just rounded up in the street

21    indiscriminately?

22       A.   Well, that could be true of one of them.  As for the other one,

23    well, they came to his home and summoned him to go and dig trenches.

24       Q.   Thank you very much.

25            Witness, you said that if this task was not accepted by people,

Page 13347

 1    then these people would be taken somewhere in a lorry.  Is this what your

 2    testimony is?

 3       A.   Yes.  Yes.

 4       Q.   And if you were taken somewhere in a lorry towards which direction

 5    was it?  For instance, was it a prison?  I am not saying anything, I am

 6    not implying anything, but why would one be taken in a lorry?

 7            MR. IERACE:  Yes, Mr. President, the question still does not

 8    follow the proper form.  Essentially it is an invitation to speculate.  It

 9    is not a specific request for information which is within the witness's

10    knowledge.

11            MR. PILETTA-ZANIN: [Interpretation] May I respond?

12            JUDGE ORIE:  Yes, you may, Mr. Piletta-Zanin.

13            MR. PILETTA-ZANIN: [Interpretation] I think, Mr. President, that

14    the witness said that if you didn't accept to go, then you were still

15    taken in a lorry.  So what I am to know, what I am interested in, is

16    whether the witness knows what would happen, or what would have happened

17    after someone was taken in a lorry.  And that is this type of question

18    that I would like to ask.

19            JUDGE ORIE:  If you in fact, Mr. Piletta-Zanin, you should ask the

20    witness whether he ever observed such a lorry, and in what direction it

21    drove.

22            MR. PILETTA-ZANIN: [Interpretation] Yes, with pleasure.

23            JUDGE ORIE:  I further say that the question where you second

24    sentence was "I am not implying anything," you were leading in an

25    unacceptable way.  Please proceed.

Page 13348

 1            MR. IERACE:  Mr. President, I should also add now that I have had

 2    an opportunity to check, that according to my search of LiveNote.  The

 3    witness has not referred to a lorry at all.  I think the witness said they

 4    were taken anyway, which does not lend itself to the interpretation of

 5    Mr. Piletta-Zanin that they were taken somewhere different.

 6            JUDGE ORIE:  Whether it was a lorry or not, it is my recollection,

 7    true or not, and I am also looking to my colleagues that there was some

 8    means of transportation the witness was referring to.  But I can check

 9    that, and looking in the LiveNote for the word lorry might make you miss a

10    similar form of transportation.

11            Please proceed.

12            MR. PILETTA-ZANIN: [Interpretation]

13       Q.   Witness, specifically, did you know of situations where people

14    would have refused to go and dig?

15       A.   I know of one case.

16       Q.   Could you, therefore, tell us what happened in this case.

17       A.   He spent a night in Trebevic.  He found some people that he knew

18    up there and those people pulled some strings who knew some people who

19    were high-ranking, and he managed to get back home.

20       Q.   So this was a person who was perhaps sick or something else?

21            MR. IERACE:  I object.

22            JUDGE ORIE:  Yes, Mr. Ierace.

23            MR. IERACE:  Mr. President, the witness has not said that this

24    person was sick or something else.  The question, yet again offends the

25    rules of examination-in-chief.

Page 13349

 1            JUDGE ORIE:  Yes.  Mr. Piletta-Zanin, it is my recollection that

 2    the witness testified that one of the two persons he knew about was sick

 3    or something like that.  So you should first verify whether this was one

 4    of the persons and whether it was the sick person or the person that he

 5    did not call to be sick.

 6            MR. PILETTA-ZANIN: [Interpretation]

 7       Q.   Witness, you spoke of these two cases, and in one of these cases a

 8    person was sick; is that correct?

 9       A.   Yes.

10       Q.   Thank you.

11            The person that you just spoke of earlier, was it this sick person

12    that you were talking about?

13       A.   This is a third person who was not sick.

14       Q.   Very well.

15            Which one was not sick?

16       A.   Those two out of whom one was sick kept on digging trenches, and I

17    told you that one who had refused to dig trenches, he was put on a lorry,

18    he was taken to Mount Trebevic.  He spent the night there, among the

19    soldiers there.  He either found an acquaintance or an acquaintance of an

20    acquaintance and there was a quick intervention of some influential people

21    from Sarajevo, and he was returned to Trebevic to his employment.  At the

22    moment he is a high-ranking official in the Federation of

23    Bosnia-Herzegovina.

24       Q.   Witness, when you say that he spent the night in Mount Trebevic,

25    what do you mean by that?  Is there something specific that you have in

Page 13350

 1    mind?  For us, it is an area, I believe.

 2       A.   Well apart from the trenches, there was certainly, there was the

 3    troops, there were shelters for the army, huts.  I presume that is where

 4    he could have spent the night.  It is an acquaintance of mine.

 5       Q.   Very well.

 6            Do you know -- I am going to rephrase my question.  Let us imagine

 7    that during the period that we know about, the period of the war, somebody

 8    does something which is contrary to the law, something that is illegal,

 9    and this person in your area, in your neighborhood, would have been

10    a -- who would have been in charge of police in your area, in your

11    neighborhood, do you know that?

12       A.   As far as my personal experience goes, all of the communications,

13    although it was not in relation to illegal actions, this was done by

14    members of the police or the measures were undertaken by the members of

15    the police.

16       Q.   Witness, you said, and I am going to try to quote you in relation

17    to the transcript, but in relation to my personal experience or as far as

18    my personal experience goes, what are you saying about that?  Are you

19    talking about a personal experience, something that you have experienced

20    yourself?

21       A.   Yes.  Yes.

22       Q.   Could you tell us what was this personal experience that you had?

23       A.   There are a few but my first experience with the police in terms

24    of being detained, that was in October 1992 when members of police force

25    came for me to hand me over to the Military Police in Viktor Bubanj, and I

Page 13351

 1    was charged, I was accused of having betrayed, having committed the act of

 2    treason because I changed the place of residence and therefore avoided

 3    receiving the call up papers for the regular Army of Bosnia-Herzegovina

 4    and, therefore, I put at risk the independent sovereignty and so on of the

 5    state.  Of course I was at the address which I hadn't changed for 10 years

 6    and still I found myself in the prison in Viktor Bubanj.  And thanks to

 7    the police who brought me there, I stayed only one day, because they tried

 8    to find a military judge because I was found on the actual scene, I had

 9    all the documents, and the military judge ruled that I had not committed

10    the -- what I had been charged with.

11       Q.   Witness, you said that this happened on one occasion, and I

12    believe that you said in your language that this was the first time, but I

13    am not able to follow everything on the transcript.  But was it the only

14    time, the one time that you were confronted to this type of situations?

15       A.   Well, I can tell you about it, but reluctantly so.

16       Q.   Witness, why are you hesitating to answer?

17       A.   There was several pointless summons, detentions, interrogations,

18    accusations.  I truly believed that if there had only been one tiny detail

19    that was true in all these accusations, I certainly would not have been

20    sitting here today as a witness.

21       Q.   Witness, perhaps I can assist you in a sense that I can see you

22    becoming emotional.  Were you arrested on several occasions by this police

23    force or Military Police force or whatever police we are talking about.

24            MR. IERACE:  I object on the grounds of leading, Mr. President.

25            MR. PILETTA-ZANIN: [Interpretation] Mr. President, I know, I am

Page 13352

 1    aware that this is a leading question.  I thought that this would not be

 2    objected to because I can see the emotion of the witness.  I will remember

 3    that.  I will rephrase the question.

 4            MR. IERACE:  Mr. President, one would have thought that a

 5    prerequisite to not expecting an objection would be to have referred to

 6    this evidence, whatever it is, in the description of the evidence which is

 7    anticipated from the witness, and I don't recollect anything of this

 8    nature.  Thank you.

 9            MR. PILETTA-ZANIN: [Interpretation]

10       Q.   Witness, you spoke once that you were arrested.  Could you please,

11    in the interest of justice, could you please tell us more about it, if

12    there are -- if there is more to say about the subject.

13       A.   Well, at one point I was detained, accused of, so to speak, that I

14    was accused of participating in ethnic cleansing.  Because, as an activist

15    of Dobrocinstvo, I was helping people to leave with the approval and the

16    order, and then they would leave and then they wouldn't come back.  Now,

17    the second time it was a more serious accusation.  I was accused of

18    participating with some people in an act of creating a kind of enemy

19    centre out of this humanitarian association that I was calling people to

20    establish some kind of sabotage, subversive group, which was supposed to

21    cause an incident or even bloodshed in Sarajevo, so that Serb crimes would

22    then be diverted so that the attention would be diverted from the Serb

23    crimes and I was then taken for interrogation.  And at the end when there

24    was nothing else left, I was even accused, I was even charged with, there

25    was proceedings that was initiated against me, I was charged that with as

Page 13353

 1    a member of the humanitarian organisation, I have committed the misuse,

 2    abuse of my position that a company that was doing us a favour by

 3    giving -- lending us lorries because the humanitarian association

 4    Benefactor did not have its own lorries, so they had to be borrowed and

 5    they had to be paid for.  And I claim before this Chamber that -- I claim

 6    that not one parcel or one kilo, kilogram, of food was distributed without

 7    the approval and the permission of the then-financial police.

 8            However, I was detained and I was interrogated.

 9       Q.   Thank you very much.  This will be my --

10            MR. PILETTA-ZANIN: [Interpretation] Mr. President, this will be my

11    very last question

12            JUDGE ORIE:  I heard you saying in French that this was your very

13    last question.  You said before the break a few minutes.  Please proceed.

14            MR. PILETTA-ZANIN: [Interpretation] Thank you very much.

15       Q.   Witness, you said that not a single parcel went out of the way,

16    that every single parcel was delivered, and we don't doubt it, but the

17    distribution of aids that you were involved with, what was it like?  Was

18    it equitable, was it selective, destined to only some categories of the

19    population?  What can you tell us about this, please?

20       A.   When we are talking about family parcels, they arrived at the

21    address of all citizens, regardless of their ethic or religious belonging.

22    They normally came from Yugoslavia.  Of course, the most important number

23    came to Serb addresses, but there was a high percentage of Croats or

24    Muslims who had friends or relatives in Yugoslavia.  And you know that

25    there are many people who have relations in Belgrade and Muslims in

Page 13354

 1    Belgrade and Muslims in Sandzak and in Sarajevo.  So this is as for the

 2    family parcels that went to the addresses and this was checked by the

 3    police which is natural.  And because there were some central points where

 4    these parcels arrived and these policemen were, and we had excellent

 5    cooperation with them I have to say, we were aware of the situation we

 6    were in and we had no problems with that.  And I have already told the

 7    Chamber we had little humanitarian aid except for two occasions.  Once one

 8    humanitarian association -- the only association that we had a completely

 9    equitable relationship or relation to attitude to all the ethnic groups

10    which was called Baltimor [phoen] a Catholic association.  On one occasion

11    they gave us 25 pounds of sugar.  Because there was no regular supply, we

12    wanted to have a global distribution to the population.  So we distributed

13    this according to the list that we had at points, and this was distributed

14    to Serb families.

15       Q.   Thank you very much, Witness.

16            MR. PILETTA-ZANIN: [Interpretation] No further questions.

17            JUDGE ORIE:  Mr. DP1, this concludes the examination-in-chief

18    where the transcript, by mistake says that you were cross-examined by Mr.

19    Piletta-Zanin, but you will now be examined by the Prosecution.  Mr.

20    Ierace, is the Prosecution ready to cross-examine the witness?

21            MR. IERACE:  Yes, Mr. President.

22            JUDGE ORIE: And may I indicate, that since you asked for some

23    time, that you would stop at anything between 10 and 8 minutes to 7.00,

24    because it might take a bit more time and we might even have to go in

25    closed session for the guidance you are seeking.  Please proceed.

Page 13355

 1            MR. IERACE:  Thank you, Mr. President.  Mr. President, the witness

 2    was shown a map which I don't think at this stage has an exhibit number.

 3            THE REGISTRAR:  Exhibit D1755 under seal.

 4            MR. IERACE:  Mr. President, I ask the witness be shown the map and

 5    it may be appropriate for the questions to be dealt with in closed

 6    session.  It shouldn't take more than a few minutes.

 7            JUDGE ORIE:  We then turn into closed session.

 8                          [Closed session]

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Page 13356













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21                          --- Whereupon the hearing adjourned at

22                          7.04 p.m., to be reconvened on Wednesday,

23                          the 9th day of October, 2002, at 2.15 p.m.