1 Monday, 19 July 2010
2 [Open session]
3 [The accused entered court]
4 [The witness takes the stand]
5 --- Upon commencing at 1.33 p.m.
6 JUDGE KWON: Good afternoon to everybody.
7 Judge Baird cannot be with us during the first session, due to
8 his official engagement in another Chamber. I believe he will join us
9 from the second session. So we'll be sitting pursuant to Rule 15 bis
10 during this first session.
11 Ms. Sutherland, I was informed that you have something to raise
12 before we begin today.
13 MS. SUTHERLAND: Yes, Your Honour.
14 On Friday, Mr. Karadzic, during cross-examination, took the
15 witness -- or put a proposition of another witness to Dr. Mandilovic, and
16 I have looked through that particular witness's prior testimonies and a
17 number of documents and wasn't able to find the proposition that
18 Mr. Karadzic was putting to this witness.
19 I would ask, in future, to be given a page number of the source
20 of the assertion being put so that we can quickly check that. I didn't
21 have the transcript of that other witness with me in the courtroom on
22 Friday, and checked it subsequently. And as I said, if we could have a
23 page reference number, that would be very helpful. And as I said, I also
24 was not able to find that assertion or that proposition that was put to
25 the witness in any of the witness's testimony that I was able to check.
1 JUDGE KWON: Thank you, Ms. Sutherland.
2 I believe Mr. Karadzic received that notice already, so I would
3 like him to bear that in mind in the future cross-examination.
4 Very well. Please continue, Mr. Karadzic.
5 WITNESS: MILAN MANDILOVIC [Resumed]
6 [The witness answered through interpreter]
7 THE ACCUSED: [Interpretation] Thank you.
8 I am sorry. I just need to have a look at this and see what this
9 relates to.
10 Good afternoon to all.
11 Cross-examination by Mr. Karadzic: [Continued]
12 MR. KARADZIC: [Interpretation]
13 Q. Good afternoon, Dr. Mandilovic.
14 A. Good afternoon.
15 Q. I hope that you understand my need to spell things out as
16 precisely as possible and to establish what is a rumour and what is
17 uncontested knowledge.
18 Let me ask you, by the way: Did you talk to anyone about this
19 over the weekend?
20 A. No.
21 Q. Telephone with the old country?
22 A. No.
23 Q. Very well. Did you have a scholarship from the military, or did
24 you get a job with the military after you graduated?
25 A. I did not receive a scholarship during my schooling from the
2 Q. Thank you. On the first page of your statement, you said -- that
3 is, your statement dated the 11th of January (as interpreted), 2000, that
4 the JNA was a professional military organisation that was well organised,
5 and so on and so forth.
6 A. I do agree with that.
7 Q. Do you agree that that the soldiers were conscripts rather than
9 A. Soldiers were recruited, they were conscripts, but the officers
10 were professionals.
11 Q. Thank you. On page 2 of that statement, you said that it was
12 difficult to make a decision, and that, in fact, your departure from the
13 unit was desertion. Do you continue to believe that?
14 A. No, that is not my position. This was an informal conversation
15 that was later used in my statement. That was stated hypothetically. I
16 have been saying all the time that it was the former JNA.
17 Q. Would you agree with me if I were to tell you that the Yugoslav
18 People's Army changed its composition in the following way: Officers who
19 were Slovenes and Croats, and later on the others, simply left it?
20 A. They left it because the states of Slovenia, Croatia, Macedonia
21 Bosnia-Herzegovina, seceded from Yugoslavia
22 Q. Do you agree that many of these officers left the army before
23 these countries attained independence?
24 A. That is possible, but I do not have any knowledge to that effect.
25 Q. On page 2 of that statement, you say:
1 "Hypothetically speaking, it would be possible that this may have
2 been execution on the spot. However, I must add that I am not aware of
3 any specific examples, so this was my opinion, and it is based on my
4 experience from the JNA."
5 THE INTERPRETER: Interpreter's note: We do not have the
7 MR. KARADZIC: [Interpretation]
8 Q. You're talking about the VRS?
9 A. No, we're talking about the JNA. We talked about the
10 establishment of the Yugoslav People's Army, not the former Yugoslav
11 Army, rather, the Yugoslav People's Army, when Yugoslavia was a
12 comprehensive state. We were talking about the Rules of Service. We
13 were speaking hypothetically about the forms of murder. We were talking
14 about high treason, and we said that capital punishment did exist for
15 that. That is what I meant.
16 Q. Are you talking about regular situations, or are you talking
17 about emergencies, or are you talking about court-martials, as they were
19 A. The discussion had to do with a regular situation in the Yugoslav
20 People's Army.
21 THE ACCUSED: [Interpretation] Thank you.
22 JUDGE KWON: Just to be clear, Dr. Mandilovic: When you referred
23 to the former Yugoslav Army, you referred to the VJ, and Yugoslav
24 People's Army, to JNA?
25 THE WITNESS: [Interpretation] I mean the Yugoslav People's Army,
1 the JNA. As the state disintegrated and as the republics acquired
2 independence, it became the former JNA, the former Yugoslav People's
3 Republic, practically from 1991 onwards.
4 JUDGE KWON: Thank you.
5 MS. SUTHERLAND: Excuse me, Your Honour.
6 I don't know if Mr. Karadzic said "11th of January, 2000," but
7 the statement is actually dated the 11th of February, 2000. That's at
8 page 3, line 2.
9 THE ACCUSED: [Interpretation] I may have said "February." Thank
10 you all the same.
11 MR. KARADZIC: [Interpretation]
12 Q. So what was it that you meant? From 1991, when were the
13 republics actually recognised?
14 A. They were recognised when they were recognised by the United
16 Q. But that's January 1992; isn't that right?
17 A. I thought that you asked me about Slovenia and Croatia
18 Q. Slovenia
19 A. I don't know exactly when they were recognised, but I know for
20 sure that it was 1991.
21 Q. Thank you. We will have to go back to this question of patriotic
22 forces. The hospital was surrounded by patriotic forces, and an
23 agreement was reached that equipment would be left behind. Let us see
24 how much you know about this.
25 What is it that you call patriotic forces, and what were the
1 forces that exist in Sarajevo
2 A. Patriotic forces are the Territorial Defence, the regular police
3 force, and the reserve police force.
4 Q. In the Muslim part of Sarajevo
5 A. In the part of Sarajevo
6 Army of Bosnia-Herzegovina.
7 Q. The Serbs from Grbavica, Vraca, Lukavica and so on, they weren't
8 patriots; right?
9 A. Of course they were. I'm not denying that.
10 JUDGE KWON: Ms. Sutherland, you said his statement was taken on
11 February 11th, 2010
12 MS. SUTHERLAND: No, Your Honour. I said "11th of February,
13 2000." It was a prior statement of the witness that Mr. Karadzic was
14 putting to him.
15 JUDGE KWON: Not the amalgamated statement?
16 MS. SUTHERLAND: That's correct.
17 JUDGE KWON: Yes, I was confused about that.
18 Let's move on, Mr. Karadzic.
19 Thank you, Ms. Sutherland.
20 MR. KARADZIC: [Interpretation] Thank you.
21 Q. Dr. Mandilovic, did you know that in addition to the
22 Territorial Defence -- or, rather, do you agree that the
23 Territorial Defence, according to federal law, was subordinated to the
25 A. According to federal law, yes. But don't forget that
1 Bosnia-Herzegovina was proclaimed an independent state at the time that
2 we are discussing now.
3 Q. Thank you. Well, none of us will ever forget that. Did you know
4 when the Patriotic League was formed, and the Green Berets? Do you know
5 that the decision was reached on the 31st of March, 1991, and that in
6 April 1991 the Patriotic League was established, which, up until
7 January/February 1992, grew to a force of, say, 120.000 soldiers?
8 A. I'm not aware of these figures, Mr. Karadzic. I was not a member
9 of the Patriotic League, I was not a member of any political party.
10 Q. I wasn't, either, but I know. I know that it was a force to
11 reckon with, and --
12 JUDGE KWON: Mr. Karadzic, if you wish to give evidence, you can
13 do so. But at this time, just put your questions.
14 MR. KARADZIC: [Interpretation]
15 Q. Mr. Mandilovic, is this a convincing answer? You say, No, I
16 don't know, I wasn't a member. Is it only members that know?
17 A. You are asking me about 1991. 1991 was not a war year, and I was
18 not really involved in any of that. I just did my job.
19 Q. Thank you. On page 3 - I think it's page 3 or 4 of your
20 statement -- it's page 4 --
21 THE INTERPRETER: Interpreter's note: We do not have the
23 MR. KARADZIC: [Interpretation]
24 Q. You say that the State Hospital
25 weren't any military positions, there weren't any personnel -- military
1 personnel within the hospital compound:
2 "We were simply there to treat people. In spite of that, the
3 hospital was intentionally targeted by mortar fire."
4 First of all, tell me, was there a detachment or a battalion
5 belonging to the Medical Corps there?
6 A. Are you talking about the hospital after the 10th of May, 1992?
7 It is not very clear, what this pertains to.
8 Q. Mr. Mandilovic, in your view, when was it that the Serbs
9 intentionally shelled the Military Hospital
10 A. The shelling of the former Military Hospital
11 10th of May, 1992, when the personnel of the former JNA started
12 withdrawing from the hospital.
13 THE INTERPRETER: Interpreter's note: We did not hear the
14 question. It is too fast.
15 JUDGE KWON: Yes, Mr. Tieger.
16 MR. TIEGER: I'm sorry, Your Honour. The interpreters were
17 quicker to note the problem with the quick -- the sequence of questions
18 and answers, some of which are occurring while the interpretation is
19 still taking place of the previous responses.
20 JUDGE KWON: That was your point. Thank you, Mr. Tieger.
21 As you can note from this transcript, the interpreters couldn't
22 follow your question and answer because you overlapped and you spoke too
23 fast. So if both of you slow down and put a pause between the question
24 and answers.
25 So could you repeat the previous question and answer,
1 Mr. Karadzic and Mr. Mandilovic?
2 THE ACCUSED: [Interpretation] I do apologise to all participants
3 in these proceedings, the interpreters in particular. But all of this
4 rushes you to the fact that I haven't got enough time for this
5 re-examination or cross-examination.
6 MR. KARADZIC: [Interpretation]
7 Q. Doctor, did you say that after the 10th of May, there was no
8 medical battalion in the Military Hospital
9 A. In the Military Hospital
10 never was any military battalion.
11 THE ACCUSED: [Interpretation] 1D2111, could I have that document,
13 MR. KARADZIC: [Interpretation]
14 Q. Doctor, could I ask you to read these 19 points?
15 A. "The Command -- the Command of the Corps, Military Unit," such
16 and such a number. Do I need to read all of this out? This is a list of
17 the temporary locations of the units of the 1st Corps, and then they are
18 listed here: The Mountain Brigade, the 2nd Mountain Brigade --
19 Q. Just a moment, please. The first paragraph, can we read that:
20 "On the basis of a need that was expressed and frequent requests
21 coming from the unit, we hereby send you a review of the temporary
22 locations of the units from the composition of the 1st Corps.
23 "The Command Corps," number 1.
24 "2. 1st Mountain Brigade, Sarajevo.
25 "The 2nd Mountain Brigade --"
1 JUDGE KWON: Just a second, Dr. Mandilovic.
2 Yes, Ms. Sutherland. Microphone, please.
3 MS. SUTHERLAND: Sorry. Could the document be scrolled up so
4 that we could see the date in the top of the document, please.
5 JUDGE KWON: Thank you.
6 MR. KARADZIC: [Interpretation]
7 Q. Doctor, could you read this slower?
8 A. Yes:
9 "The 1st Motorised Brigade, Danijela Ozme, Sarajevo
10 Motorised Brigade, Dzemala Bijedica, Sarajevo
11 Dobrinja; 9th Motorised Brigade, Trampina, Sarajevo. 101st --"
12 JUDGE KWON: I don't think the witness needs to read out all the
13 document. What is your point, Mr. Karadzic? You said point 19. What
14 was your question? We can read it later on.
15 THE ACCUSED: [Interpretation] There is no translation, and I
16 wanted this to be heard in the courtroom, what forces were involved here
17 in April 1993. This is the organic composition of the 1st Corps, and
18 nothing seems to be known about that here. Later on, they grew to the
19 level of three divisions, out of which the 12th Division remained in
21 In many proceedings and trials here, Sarajevo was considered a
22 harmless, helpless --
23 MR. KARADZIC: [Interpretation]
24 Q. Could you read number 17?
25 JUDGE MORRISON: Mr. Karadzic, we can see the substance of the
1 document, as to the amount of brigades that there are, and you can deal
2 with it in your evidence. So for other documents like this, simply put
3 the question to the witness, and you can be assured that the meaning will
4 be clear to the Tribunal.
5 MR. KARADZIC: [Interpretation] Thank you.
6 Q. Doctor, could you read item 17?
7 A. "Medical Battalion, Military Post 5751, Military Hospital
9 Q. Thank you, Doctor. You lived in Sarajevo for a long time, just
10 like me. Do you know where these streets are?
11 A. Yes, I know most of them.
12 Q. Is it correct that Danijela Ozme is right in the very center,
13 right opposite the Presidency building?
14 A. Yes.
15 Q. Is it correct that Vase Miskina is in the very center, it
16 continues along Tito Street?
17 A. Yes --
18 Q. Is it correct that Trampina is close to the grand park in the
19 center of town as well?
20 A. Yes.
21 Q. Do you agree that Nemanjina is also in the center of town, but
22 it's a bit towards the slopes?
23 A. Yes.
24 Q. Again, Danijel a Ozme, the Military Hospital, and the Marsal Tito
25 Barracks. All of this except for Dobrinja is in the center of town;
2 A. Yes.
3 Q. And if I tell you that Asim Dzambasovic signed this document,
4 Dzambasovic, who is chief of staff of the 1st Corps, would you accept
6 A. Yes, I accept it.
7 THE ACCUSED: [Interpretation] Thank you. Can it be admitted?
8 THE WITNESS: [Interpretation] But I have an observation.
9 MR. KARADZIC: [Interpretation]
10 Q. Go ahead.
11 A. The Medical Battalion was never part of the Military Hospital
12 We have to be very clear about this. The former Military Hospital
13 is, the State Hospital
14 very positive and strenuous about that.
15 Q. Yes, but it says this is part of the corps, not part of the
16 hospital. Was it deployed within the infrastructure of the
17 Military Hospital
18 A. Not way. It was outside the Military Hospital.
19 Q. Within the compound of the Military Hospital
20 A. Within the compound of the Military Hospital
21 from it.
22 Q. How far?
23 A. Three hundred metres.
24 Q. Well, you said it was 300 metres to the River Miljacka?
25 A. Yes, but you forget that it spreads in the east-west -- along the
1 east-west line. It is very narrow along the north-south line, but it's a
2 very broad area along the east-west line.
3 JUDGE KWON: We'll mark it for identification, pending
5 THE REGISTRAR: As MFI
6 JUDGE KWON: Thank you.
7 MR. KARADZIC: [Interpretation]
8 Q. On this page, you said that despite that, the hospital was
9 deliberately targeted by mortars. How do you know that?
10 A. Well, simply, the rest of 1992 and all of 1993, the city of
12 indiscriminately in the immediate area of the Military Hospital
13 shelling went on for 10, 12 hours non-stop, and we could clearly hear the
14 detonations of the incoming projectiles and their falling very close to
16 You must know that a shell of any artillery piece falls within
17 the narrow core of the city, on concrete or on asphalt, and you cannot
18 mistake that sound for anything else. And the projectile, itself,
19 disintegrates into a huge number of shrapnel. There is no dilemma about
21 Q. Thank you. Which outgoing fire did you mention? Which outgoing
22 fire did you hear?
23 JUDGE KWON: Before you answer, Dr. Mandilovic.
24 Yes, Ms. Sutherland. Microphone, please.
25 MS. SUTHERLAND: Mr. Karadzic said, page 13, line 1:
1 "On this page, you said that despite that the hospital was
2 deliberately targeted by mortars."
3 Which page is Mr. Karadzic referring to?
4 THE ACCUSED: [Interpretation] I'm talking about page 4 of this
5 statement, dated the 11th of February, 2000, and I do not mind at all if
6 the doctor needs some breathing space to give an answer to this question.
7 But, please, it is his statement, page 4 of that statement.
8 MS. SUTHERLAND: Your Honour, that wasn't my reason for standing
9 up. The document -- the reference before had been to the amalgamated
10 witness statement. Now he's going back to the February 2000 statement.
11 So that was why I raised, because I couldn't see it on that page of that
12 amalgamated witness statement or on the page of the transcript.
13 JUDGE KWON: Thank you.
14 Dr. Mandilovic, if you remember the question, yes, please, go
16 THE WITNESS: [Interpretation] Thank you, Mr. President.
17 I did not hear any outgoing fire.
18 MR. KARADZIC: [Interpretation]
19 Q. Doctor, a moment ago you said that you heard outgoing and
20 incoming fire?
21 A. No, no. Your question was whether I heard mortar fire or other
22 kinds of artillery fire that was coming from the positions of the Army of
23 Bosnia-Herzegovina and going towards the forces of the Bosnian Serbs.
24 That's what you meant, and I did not hear any such fire.
25 Q. Let us try to refresh your memory now.
1 I read this out to you, and I said, In spite of that, the
2 hospital was intentionally targeted by mortar fire. I assumed that after
3 the 10th of May, you are ascribing that to the Serbs, and my question to
4 you was: How come you knew? And you said that you had heard outgoing
5 fire and incoming fire, and you described what was falling around you,
6 and so on. There was outgoing fire, and I'm going to show you what kind
7 of outgoing fire that was. But I would be interested in hearing what it
8 was that you heard.
9 A. Two days ago, when I discussed this problem with you, I said that
10 the positions of the Bosnian Serbs were very nearby, close to the centre
11 of Sarajevo
12 that artillery positions were relatively nearby. So when I say "outgoing
13 fire," I'm talking about the initial firing of shells or projectiles.
14 And after a while, we would hear them fall in a particular part of town,
15 and that created a great deal of noise. That's what I said, and that's
16 what I'm repeating again.
17 Q. Are you trying to say that you heard outgoing and incoming fire,
18 and that both were Serbian fires, as it were?
19 A. No. "Outgoing" is not a good term. That is initial fire created
20 by detonation due to a projectile that was fired from an artillery piece.
21 However, since there wasn't a classical front-line in Sarajevo, the
22 distances were very short. So down there in town, in hospital, we heard
23 the moment when artillery pieces fired from the hills and when these
24 projectiles hit the city. That's what I'm talking about.
25 Q. Thank you. What hill are you talking about?
1 A. The entire southern part of the town of Sarajevo.
2 Q. Are you talking about the slopes of Trebevic? That's right,
3 isn't it?
4 A. Yes. As a rule, yes.
5 Q. How far is the Jewish cemetery, as the crow flies, from the
6 Military Hospital
7 A. I don't know. I've said this on a number of occasions.
8 Six hundred or six hundred and fifty metres as the crow flies, perhaps.
9 It's difficult for me to estimate.
10 Q. Thank you. What sort of heavy artillery pieces did the Serbs
11 have at the Jewish cemetery?
12 A. I don't know. I didn't visit the Serbian positions, so I don't
14 Q. We'll have to go back to that subject when we receive some
15 documents that we are waiting for.
16 But you said, sir, that stress contributed to the fact that a lot
17 of errors were made. On the same page:
18 "Human nature is such that errors are made, but when providing a
19 diagnosis or curing patients in the course of an artillery shelling, more
20 mistakes are made."
21 And so on and so forth.
22 Can you mention some of these mistakes?
23 A. No. That's the translation that you have just read out. It's
24 not in the spirit of our language. That's why it seems a little clumsy
25 when you read it out. In our own language, it's different.
1 What I want to say is that there was a lot of stress of all those
2 who -- for all those who worked in the hospital. They were under a lot
3 of psychological pressure. That concerned them and their families as
4 well. That is what is at stake. The problem is that in such an
5 uncertain situation -- well, such an uncertain situation went on for
6 several months, not just for a day or two, and this can exhaust someone
8 In addition, I have to point out that there was also a lack of
9 energy, a lack of heating. This also contributed to stress. I said that
10 the temperature in the hospital was equivalent to the outside temperature
11 on numerous occasions. You know that the climate is a continental
12 climate in Sarajevo
13 the operation room or in the hospital wards. When this goes on for a
14 lengthy period of time, then it's quite natural that your psychological
15 equilibrium isn't what it usually is. As a psychologist, you're well
16 aware of the fact. Another factor is the lack of food; a significant
17 lack of food, not an absolute lack of food.
18 Q. We'll get to that, Doctor. But I am interested in whether these
19 mistakes that you have mentioned had certain medical consequences, and if
20 so, of what kind?
21 A. I didn't notice any significant mistakes that would have affected
22 the health of the patients that were in our care.
23 Q. Thank you.
24 A. If I could just return to the matter. I do remember that
25 statement, and I think that part of the statement also relates to the
1 significant influx of wounded. On such occasions, it's possible for
2 certain mistakes to be committed, given the significant influx of wounded
3 and the various types of wounds involved. Then mistakes are quite
4 possible. However, we did our best to avoid committing mistakes, to
5 reduce the mistakes made to a minimum.
6 Q. Thank you. Did you provide this statement in English or in
7 Bosnian, as they say, originally?
8 A. In the Bosnian language, but it was then translated into English
9 and then back into our own language.
10 Q. Thank you. On page 5, you said that you couldn't say that the
11 hospital was deliberately targeted by snipers, but you said that the
12 hospital was hit on numerous occasions by fire from light weapons.
13 Doctor, could you tell us the following: Where were the closest Serbian
14 positions from which it was possible to see clearly the Military Hospital
15 without any buildings hindering one's sight?
16 A. The positions -- the Serbian positions from which you can see the
17 hospital is the entire Trebevic area, especially the western slopes of
18 Trebevic. The Jewish cemetery, Grbavica, and Vraca are concerned.
19 Q. Thank you. And tell me the following: Was it possible to fire
20 on the Military Hospital
22 A. Yes, that was absolutely possible. Certain parts of the hospital
23 could be fired on, and especially the more elevated parts.
24 Q. And, Major - I address you as Major now - what is the range for
25 rifle fire?
1 A. Mr. Karadzic, this is at the end of the 20th century. The
2 weapons were sophisticated. Snipers had a range of over 1.000 metres,
3 without a doubt.
4 Q. Are you saying 12.7 or 7.92?
5 A. I'm not a military specialist, Dr. Karadzic, but you know what I
6 mean. The range is quite sufficient.
7 Q. Thank you. We will have a look at that once we have received the
9 You mentioned the lack of water, and you said that the water
10 supplies were sometimes interrupted, but:
11 "Since water was essential for the hospital, we had to improvise
12 so that we always had water available. When there was no water, we would
13 bring it in by lorries to the hospital. They would be kept in special
14 reservoirs. In spite of all the difficulties, we always managed to have
15 available water."
16 Could the water of Miljacka be used for the hospital?
17 A. Mr. Karadzic, we were in the hospital, and we had water in the
18 hospital for the basic needs. Where water was brought in from, I don't
19 know, but its quality was controlled, it was disinfected, it was
20 sterilised. That's certain. Our management took good care of the water
21 supply and the energy supply. I wasn't directly concerned.
22 Q. Since you know Miljacka, you must know whether the water could
23 be put to good use.
24 A. Mr. Karadzic, we didn't have any cases of poisoning as a result
25 of the use of water, so where the water was actually brought in from, I
1 really do not know.
2 Q. But could anything have been brought in from Miljacka? You and
3 I are familiar with Miljacka. Could the water from Miljacka have been
5 A. If you're thinking of the river that passes through the town of
7 really been necessary to sterilise the water.
8 Q. Thank you. Do you agree at the time, in the part of Sarajevo
9 under Muslim control, there were about 300.000 individuals?
10 A. I believe that's the correct figure.
11 Q. Do you agree that 50.000 to 60.000 individuals, out of those
12 300.000, were Serbs?
13 A. In which part of Sarajevo
14 Q. Throughout Sarajevo
15 Serbs and 24.000 Yugoslavs -- there were at least 15.000 Yugoslavs, so
16 there were 180.000 Serbs, 175.000 Serbs in all of Sarajevo, but in the
17 part that remained under Muslim control, there were 50.000 to 60.000
18 Serbs at the time; correct?
19 A. It's possible.
20 Q. Would you agree that the daily consumption of water
21 per individual in such -- or, rather, in normal conditions, is between
22 600 and 800 litres, but in such conditions, 100 to 120 or 180 litres
23 daily would be the daily consumption of water?
24 A. I don't know about that information, Mr. Karadzic. But as a
25 member of the State Hospital
1 was very little water and that it had to be used with care. I really
2 don't know where you have that information from.
3 Q. We went to the same university, we graduated from the same
4 university. For an individual to function normally, such an individual
5 needs between 600 to 800 litres of water a day. But given the conditions
6 in Sarajevo
7 A. We can't talk about normal conditions. You have to reduce that
8 amount quite significantly.
9 Q. Doctor, the water that did arrive, where did it arrive from?
10 A. I don't know.
11 JUDGE KWON: Just for confirmation, Dr. Mandilovic, could you
12 give the number of the individuals that were in the part of the Sarajevo
13 under the Muslim control? Did you say 3.000 or 300.000?
14 MS. SUTHERLAND: Your Honour, it was actually Mr. Karadzic that
15 said the figure of 300.000, and I think the witness said, That's about
16 correct, or words to that effect.
17 JUDGE KWON: So 300.000. Thank you. It was Dr. Karadzic who
18 said that.
19 Let's move on.
20 THE ACCUSED: [Interpretation] Yes, 300.000, if I have understood
21 this correctly, and the witness said that perhaps 50.000 to 60.000 of
22 them were Serbs. That's the information that international institutions
24 MR. KARADZIC: [Interpretation]
25 Q. Doctor, where did the water come from? Which sources were under
1 the control of the Muslim government?
2 MS. SUTHERLAND: He's asked that question three times and it's
3 been answered already.
4 JUDGE KWON: Yes. Let's move on, Mr. Karadzic.
5 MR. KARADZIC: [Interpretation]
6 Q. Do you, Doctor, reject the possibility that Muslim authorities
7 sabotaged the possibility of repairing the water supply system and making
8 water available?
9 A. I don't believe that the forces of the federal part of Sarajevo
10 were involved in any acts of sabotage. It wasn't in the interest of the
11 population that lived there.
12 Q. Was it in the interest of certain criminals to sell water? And
13 if water was readily available, then the price of water would fall
14 because they wouldn't be able to sell it?
15 A. I have to admit that I didn't notice anyone selling water.
16 That's quite interesting. Food would be sold, but I never noticed water
17 being sold.
18 Q. Did you notice that the price of food will also vary, and when
19 there wasn't a sufficient amount of food, the prices would be very high?
20 A. Yes, there were such situations.
21 Q. Thank you. Doctor, do you reject the possibility that the Muslim
22 authorities asked Hungary
23 pressure -- or, rather, said that the Serbs weren't providing any gas?
24 A. I can't say anything about that information. This was something
25 that occurred at an international, inter-state level, so I really didn't
1 have the opportunity of finding anything out about that.
2 Q. And if I were to tell you that the authorities in Sarajevo
3 to a large extent, responsible for the lack of water and gas, and we'll
4 demonstrate this here, we have information pertaining to that subject, if
5 I said that, what would you say? Would you be angry with the Serbs or
6 with them?
7 A. I wouldn't believe them.
8 JUDGE KWON: No probative value for us, questions which would
9 require speculation on the part of the witness, Mr. Karadzic.
10 THE ACCUSED: [Interpretation] Your Honour, you'll see that it
11 does have such value when we show certain documents. But the witness
12 isn't aware of many things. I don't object to that, but I object to the
13 fact that he says that Serbs did certain things, whereas he has no
14 knowledge about the matter.
15 MR. KARADZIC: [Interpretation]
16 Q. Sir, Doctor, did you say that there was a lack of medical
17 supplies, of medicine, of anaesthetics, of oxygen, et cetera?
18 A. Yes, that's what I said, and that was the case.
19 Q. Have you heard about the death of 12 babies in Banja Luka because
20 no one made it possible for oxygen to be delivered for the incubators?
21 A. No, I haven't heard about that. But I don't understand why that
22 happened in Banja Luka. Banja Luka wasn't surrounded, and you can't
23 compare the situation in Banja Luka to the situation in Sarajevo.
24 MR. TIEGER: Your Honour.
25 JUDGE KWON: Yes, Mr. Tieger.
1 MR. TIEGER: I think the objection is obvious by way of
2 relevance, and it is astonishing that the accused continues to complain
3 about the amount of time he has for cross-examination when he ventures
4 into areas such as this and into the kinds of arguments that he's been
5 advancing during the course of this afternoon.
6 JUDGE KWON: I quite agree with you, Mr. Tieger.
7 Mr. Karadzic, come to your question that is relevant to the
8 evidence of this witness.
9 THE ACCUSED: [Interpretation] Thank you.
10 I think I have good reason to test the credibility of the
11 witness -- or, rather, to test whether the witness is well-informed. I
12 don't mean to say that he is deliberately stating certain things that are
13 detrimental, not only to me but to the Serb people as well, but I have
14 the right to prove that the witness lacks certain knowledge.
15 JUDGE KWON: Just put your question, Mr. Karadzic.
16 THE ACCUSED: [Interpretation] Since this has not yet been entered
17 into the e-court system, could we have this part here? Could it be
18 placed on the ELMO, please?
19 MR. KARADZIC: [Interpretation]
20 Q. Doctor, reading a map shouldn't present a problem.
21 A. It depends on the map. We'll see.
22 JUDGE KWON: I take it you received the map, Ms. Sutherland.
23 MS. SUTHERLAND: If this is the same one that was in an e-mail at
24 2.13 p.m.
25 JUDGE KWON: Is that different from the map which appears on
1 page 8 of the Sarajevo
2 THE ACCUSED: [Interpretation] Yes, I think we have this. No,
3 it's different, different. This is a map of the Muslim commander.
4 [In English] Could you lift it a little bit.
5 MS. SUTHERLAND: I believe it is, Your Honour, it is different.
6 THE ACCUSED: Okay, I believe --
7 MR. KARADZIC: [Interpretation]
8 Q. Doctor, can you find your way here, and can you tell us where the
9 Military Hospital
10 A. Let's try.
11 [In English] May I? Yes, thank you.
12 JUDGE KWON: No, you should point to the actual map in order for
13 us to follow. It's not in the e-court system.
14 Just a second. Do you have another copy -- do you like the
15 witness to mark the map?
16 THE ACCUSED: Maybe we have this in electronic form. Let's see.
17 Maybe it is in --
18 JUDGE KWON: Very well.
19 Then proceed to mark it, if you are able to locate it. The
20 question is whether you can recognise the place for Military Hospital
21 THE WITNESS: [Marks]
22 MR. KARADZIC: [Interpretation]
23 Q. I agree with you. Can you place "VB" or "GB "there, whatever you
25 JUDGE KWON: Or "MH," whatever. Yes.
1 THE WITNESS: [Interpretation] "SH" for "State Hospital
2 MR. KARADZIC: [Interpretation]
3 Q. Very well. Can you find the Jewish cemetery now?
4 JUDGE KWON: If you can use the red one. Yes, please.
5 THE WITNESS: [Marks]
6 MR. KARADZIC: [Interpretation]
7 Q. Isn't it a bit to the left, to the south? Can't you see the
8 markings? No, no, that's the cemetery.
9 JUDGE KWON: Yes, Mr. Tieger.
10 MR. TIEGER: Your Honour, we've been through a variation of this
11 before, so I think we need to be careful about who's marking the map.
12 The witness --
13 JUDGE KWON: I think the doctor will mark it only when he agrees
14 with it.
15 Dr. Mandilovic, did you follow me? So you agree with that
17 THE WITNESS: [Interpretation] [Marks] Roughly, that would be it.
18 MR. KARADZIC: [Interpretation]
19 Q. Dr. Mandilovic, do you agree --
20 JUDGE KWON: Just a second.
21 JUDGE MORRISON: Mr. Tieger, I mean, I presume these locations
22 are fixed objects within the city. They're not going to be in dispute,
23 are they?
24 MR. TIEGER: I'm less concerned about the prospect of reaching
25 agreement on where fixed locations are as I am about locations, the
1 boundaries of which -- or the particular locations of which at the time
2 of the examination may not be so clear to either the parties or the
3 witness, in particular, and then having been -- having reluctantly agreed
4 to place a location in a particular area, questions are posed on that
5 basis as if it was a fixed and agreed area. So it's not that, in the
6 abstract, that consensus can't be reached, but the use of a location as
7 precise, when it was placed there by a witness who's only approximating
8 and doing so on the basis of guidance by the accused.
9 JUDGE MORRISON: Well, I don't see the difficulties, for
10 instance, with a potentially mobile front-line of either party in the
11 dispute. But when we talk about a hospital or a cemetery, in my
12 experience, they don't move very far.
13 MR. TIEGER: No, I agree, Your Honour, although if we are -- then
14 we have to be cautious later, when markings are made in this fashion,
15 that some effort is made to arrive at a consensus understanding of where
16 that location might actually be and what the ambit of the area
17 encompassed by that location may be, to the extent it's relevant.
18 JUDGE KWON: Very well. Let's move on.
19 MS. SUTHERLAND: Sorry, Your Honour. If I may.
20 If this map, which is on ELMO, is the same map as what was
21 e-mailed by the Defence at 2.13 or whatever this afternoon, then it's in
22 e-court, 65 ter number 11786. And I note the map is from March 1995 to
23 1996, May 1996.
24 MR. TIEGER: And, Your Honour, if I may follow up on His Honour
25 Judge Morrison's question.
1 I would also say in response, Your Honour, then it seems to me if
2 the precise locations are really the point of such an exercise, and we
3 could arrive at them in advance, save the Court a lot of time, and be
4 confident that we actually had them identified, one has to wonder about
5 the reason for continually engaging in this kind of a cartographic
6 exercise in court when the witness is repeatedly evidencing reluctance to
7 do so, discomfort with doing so, and uncertainty in doing so.
8 JUDGE MORRISON: Mr. Tieger, that's exactly why I raised the
10 I mean, Dr. Karadzic, presumably, when we're talking about fixed
11 objects like hospitals, cemeteries, other notable buildings, this is a
12 matter where an agreed -- all of those could be put on an agreed plan
13 with the Prosecution, could they not?
14 MR. TIEGER: I'll let the accused respond. I had some additional
15 information, but let me -- the Court put a question. I won't get in the
17 THE ACCUSED: [Interpretation] Can we agree out of court on the
18 weapons around the Military Hospital
19 agree on the distances, either, say, between the Jewish cemetery and the
21 So let us identify this map. This is the working map of the
22 chief, Rizvo Pleh signed it. Now, I would like the central zone to be
23 zoomed in.
24 Have a bit of faith in my lawyerly skills. I know exactly what
25 I'm trying to say and what I'm trying to show, and we cannot settle that
1 out of court.
2 JUDGE KWON: Let's move on, Mr. Tieger. Do you have any further
4 MR. TIEGER: Only to note that the matters that Dr. Karadzic just
5 raised are distinct from the precise locations that we were talking
6 about. And I would also note that approximately 10 days ago, we
7 provided, in response to a request by the Court, a map with such
8 locations, and hoped that we would be able to arrive at some kind of
9 resolution, so we're still awaiting a response from the Defence.
10 JUDGE KWON: Let's move on.
11 Let's zoom in this e-court -- map in the e-court so that we can
12 identify the relevant portions. No, if you can zoom in in the actual
13 size, 100 per cent, we can find it. Zoom further. Again.
14 THE ACCUSED: [Interpretation] A bit to the east. And now a bit
15 further down. No, the other way around.
16 JUDGE KWON: Going up. Yes. Further, further.
17 MR. KARADZIC: [Interpretation] Thank you.
18 Q. Doctor, could we ask you to mark the Military Hospital
19 Jewish cemetery?
20 MS. SUTHERLAND: Your Honour, if I may, we have a bit of a
21 clearer copy, and it's a blow-up of one part of this big map that I've
22 just taken you to, and it's 65 ter number 07048J.
23 THE ACCUSED: [Interpretation] If it's not the very same map, the
24 work map of the chief of staff, it's of no use to us.
25 MS. SUTHERLAND: It is the same map.
1 JUDGE KWON: Shall we try it?
2 THE ACCUSED: [Interpretation] Thank you.
3 Could you zoom out a bit, and could we see the eastern part. Now
4 we just see a part, so we need to zoom out a bit. If you can't do better
5 than that, then we can't see the Military Hospital
6 Q. Is this the Jewish cemetery, Doctor, and do you see that the
7 Muslims are on one side and that the Serbs are on the other side of that
9 Maybe we'd better go back to the previous map, because we cannot
10 see the Military Hospital
11 A. Exactly. You cannot see the State Hospital
12 lower it down a bit.
13 JUDGE KWON: Or we can zoom out once again.
14 MS. SUTHERLAND: Your Honour, unfortunately, the map finishes
15 here where it was actually on the screen, so it doesn't go high enough
16 for the State/Military Hospital on this inset.
17 JUDGE KWON: Then why don't we carry on with the actual map,
18 which is on the ELMO. Yes, let's proceed with the --
19 [Trial Chamber and Registrar confer]
20 JUDGE KWON: And then we can scan that map and up-load in the
22 We proceed with the actual map.
23 MR. KARADZIC: [Interpretation]
24 Q. Doctor, while we're waiting, can I ask you whether you know where
25 Avde Jabucice Street?
1 A. Yes, I know.
2 Q. Do you know where Livade is in that street?
3 A. I don't know what Livade is in that street.
4 Q. It's that area where there are no buildings, where nothing had
5 been built yet.
6 A. I know roughly.
7 Q. Do you know where Crni Vrh is?
8 A. I do.
9 Q. Please have a look at this now. There's the Jewish cemetery,
10 there's the Military Hospital
11 at Crni Vrh? Actually, is that Crni Vrh above the Military Hospital
12 where we see this marking here?
13 A. I really cannot see any marking or figure. I don't know what
14 you're saying, Mr. Karadzic.
15 Q. You're a major. Isn't this a marking for a howitzer or a cannon?
16 A. I'm sorry, but I really see no such thing.
17 Q. Do you see this thing that looks like a syringe? Could you
18 please put a circle around Crni Vrh, that area?
19 A. Here it is. [Marks]
20 Q. That's that neighbourhood, Doctor, but I don't want to correct
21 you. Do you see where it says "Gorica" up here?
22 A. No, but Crni Vrh and Gorica is practically one and the same
24 Q. I'm not talking about that built-up area. I'm talking about the
25 area about two centimetres away. Doesn't it say "Gorica" there?
1 A. I see that.
2 Q. Can you put a circle around Crni Vrh, and can you tell me what
3 that marking is at Crni Vrh?
4 A. That is a marking denoting an artillery piece. [Marks]
5 Q. Could you please put a circle around that. Is that a Serbian gun
6 or cannon, Major?
7 A. No, it's not a Serbian cannon, but I have no idea what cannon
8 you're talking about. It is certainly not a Serbian cannon, because that
9 part of town was not under the control of the Bosnian Serbs. Now, where
10 this map came from and who made this map, I really have no idea.
11 Q. We'll deal with that later. Do you see this, the "105th Mountain
13 A. Yes, I see that.
14 Q. What is that marking there?
15 A. The "105th Mountain Brigade," and that's a tank there.
16 Q. Can you please put a circle around that?
17 A. [Marks]
18 Q. Could you place the letter T there or simply write "Tank"?
19 A. [Marks]
20 Q. Is that a Serb tank, Doctor?
21 A. I have no idea whether there is a tank there. I have never seen
22 it there. This is just what you're suggesting.
23 Q. But what does this military mark denote?
24 A. That is the military mark that we are talking about, but I cannot
25 confirm for you something that I had never seen.
1 Q. Do you see another mark, semicircular, to the north-west of this
2 one that we talked about just now?
3 A. Yes. [Indicating]
4 Q. What does it mean?
5 A. I think it's a symbol for mortars.
6 Q. Thank you. Could you circle that, please?
7 A. [Marks]
8 Q. And could you mark "MB" by that place, please?
9 A. [Marks].
10 Q. Now, could we go back to Gorica. Would you agree that
11 immediately below this cannon, there are several streets that are called
12 Avde Jabucice, they are sort of meandering streets of a kind?
13 A. Yes, that is a very steep and narrow street.
14 Q. Could you please mark that with the letters "AJ"?
15 A. [Marks]
16 Q. It's between the Military Hospital
17 And could you mark the cannon position with a T or an H? It's obviously
18 a howitzer.
19 A. You know what it is; I don't. [Marks]
20 Q. But there's no doubt that that is a symbol for a cannon, for an
21 artillery piece?
22 A. Yes, but I don't know who put it there.
23 Q. Thank you. Could you please date this and sign it.
24 A. [Marks]
25 THE ACCUSED: [Interpretation] And could we have the whole map
1 again so that we can see what the distance is between the
2 Military Hospital
3 MR. KARADZIC: [Interpretation]
4 Q. Doctor, we have the scale of the map down below. I would say
5 that this is about a thousand metres, one kilometre. You have the scale
6 in the lower part of the map, and you can check the scale, you can check
7 the distance.
8 A. No, that distance is incorrect. It's a far shorter distance, as
9 the crow flies.
10 Q. Have a look. Can you open up the map and have a look at the
12 A. I don't need the scale, Mr. Karadzic. I can see the Jewish
13 cemetery every day, and I can see details there. I can't see any details
14 from a distance of one kilometre.
15 Q. Can we scroll down and see whether you agree that this is
16 Debelo Brdo?
17 A. I don't know where Debelo Brdo is.
18 Q. Very well. Please date it, sign it. We will then scan it and
19 file it.
20 A. [Marks] I've never seen this map before, though, because this map
21 is practically a map that I've just been shown, so I can't confirm that
22 it's an authentic -- an adequate map.
23 Q. I don't believe that you are responsible for the map. But you're
24 a major, and the map demonstrates the artillery positions, where the
25 artillery positions are above the hospital?
1 A. If I sign the map, it means that I accept the map and I accept
2 the fact that the ABiH was deployed in this manner, and this is not my
3 opinion; therefore, I cannot sign it.
4 Q. Can you see whose map it is?
5 JUDGE KWON: No, it is not for the witness --
6 THE WITNESS: [Interpretation] Regardless of whose map it is --
7 JUDGE KWON: We understood your position, Dr. Mandilovic, rest
8 assured. So did you sign it?
9 THE WITNESS: [Interpretation] I haven't signed it, Your Honour.
10 JUDGE KWON: You recognised the place for the Military Hospital
11 and also you confirmed the location of the Jewish cemetery, and you just
12 recognised the marking or the markings which would mean the artillery, or
13 separate from the issue of whether that artillery actually existed at the
14 time. So with that caveat, we'll admit that document. So if you are
15 happy with that, so you can sign it.
16 THE WITNESS: That's correct, Your Honour. With those
17 reservations, yes, I will sign the map, because I'm not saying that those
18 artillery positions were really there at the time. But as far as the
19 positions of the hospital are concerned, the Jewish cemetery position,
20 and the position of the street, well, naturally, there's no doubt about
21 those positions.
22 JUDGE KWON: Thank you. We understood that.
23 THE WITNESS: [Marks]
24 THE REGISTRAR: Your Honours, that will be Exhibit D497.
25 JUDGE KWON: Ms. Sutherland, did you have something to raise?
1 MS. SUTHERLAND: No, Your Honour. I was simply going to make the
2 point that Mr. Karadzic is again making comments when he shouldn't be,
3 and, secondly, that as the witness just said, he was directed to those
4 markings by Mr. Karadzic and then circled them himself, but he is only
5 sure about the Military Hospital
6 street that he mentioned.
7 JUDGE KWON: And in some cases, he understood what those markings
8 meant, so that's the furthest frame of the witness's evidence.
9 Mr. Tieger.
10 MR. TIEGER: If I may, Your Honours, I'd make one further point.
11 I understand that's -- that the date of the map was 1995. I
12 would think that when such documents are being presented to a witness, it
13 would be helpful to indicate to the witness the relevant date.
14 JUDGE KWON: We'll bear that in mind in analysing the evidence.
15 MR. KARADZIC: [Interpretation]
16 Q. Doctor, can you have a look to the south of Jewish cemetery. You
17 can see that it says "Debelo Brdo" there. Can you see that?
18 A. No, I can't see that on the screen.
19 Q. It's in the e-court system, not on the ELMO. It's in e-court.
20 A. No, I don't have it.
21 THE ACCUSED: [Interpretation] It looks like it's the ELMO -- no,
22 it isn't. It's in the e-court system.
23 Could you assist us, perhaps? Could you assist Dr. Mandilovic
24 and provide him with the map or make it possible for him to see the map
25 that we have on the screen.
1 MR. KARADZIC: [Interpretation]
2 Q. Can you see it now?
3 A. No, I can't see anything.
4 Q. Do you have the same map on the screen, the one that we were
5 looking at just a minute ago?
6 We have it in e-court system. It could be marked and signed.
7 I'm talking about the previous map. All we have to do is switch the
8 e-court system on.
9 Have you got that now, Doctor?
10 A. Just a minute, please.
11 I can see the Jewish cemetery, but I can't see the
12 Military Hospital
13 Q. No, I'm referring to Debelo Brdo, not the Military Hospital
14 A. I can see it.
15 Q. Can you circle that? It says "Debelo Brdo" there. Can you just
16 circle it?
17 A. [Marks]
18 Q. Could we have the date and your initials, please.
19 A. [Marks]
20 THE ACCUSED: [Interpretation] Thank you.
21 Could this document be admitted into evidence?
22 JUDGE KWON: Actually, I don't see the point, Mr. Karadzic. You
23 are simply wasting your time. We can read "Debelo Brdo" in this map.
24 Why do we need the witness to mark this "Debelo Brdo" at all?
25 THE ACCUSED: [Interpretation] Your Honour, Debelo Brdo was taken
1 over by the Muslim Army, and the Muslim artillery was positioned there.
2 It faces the Military Hospital
3 than from the Jewish cemetery. There are no buildings that hinder one's
4 sight. We'll get to that.
5 JUDGE KWON: You can adduce evidence from another witness who can
6 testify to that effect, but asking this witness, Dr. Mandilovic, to mark
7 the location of Debelo Brdo in this map, which you can do easily without
8 the assistance of this witness, is simply a waste of your time.
9 THE ACCUSED: [Interpretation] The doctor said that what came from
10 the hill, from Trebevic, were, in fact, Serbian shells. This is
11 something we have to clarify. Were Serbian shells fired from there or
12 not? This entire slope was in the control -- under the control of the
13 Muslims. The doctor isn't aware of the fact. I don't object to that,
14 but he can't claim that they are Serbian shells. That's what I object
16 Will it be admitted or not? I'll get to my question now.
17 JUDGE KWON: Yes, Mr. Tieger.
18 MR. TIEGER: I'll just add one more point to the point the Court
19 was making, and that is: The first question that Mr. Karadzic asked
20 about Debelo Brdo:
21 "Can we scroll down and see whether you agree that this is
22 Debelo Brdo?"
23 And the answer was:
24 "I don't know where Debelo Brdo is."
25 So not only are we engaging in the unnecessary exercise of
1 marking and circling an area on a map that says Debelo Brdo, which
2 clearly anybody can do, but we're doing it with someone who has
3 previously indicated that he can't be of assistance in that regard, and I
4 don't think we should encourage this kind of practice by admitting this
6 JUDGE KWON: I don't think the witness said that he didn't know
7 where Debelo Brdo is. But, Dr. Karadzic, we can admit the unmarked one,
8 but I don't see any point of admitting this marked version of this map.
9 There's no point.
10 So we can admit the unmarked version, and I take it there should
11 be no objection from the Prosecution. So if you are minded to tender
12 this unmarked version, we'll admit it.
13 THE ACCUSED: [Interpretation] I would like to tender it. I'm
14 convinced that the Chamber has the opportunity to see the deployment of
15 forces around Debelo Brdo and the Jewish cemetery, and it's the first
16 time you have had such an opportunity. So I suggest that this document
17 be admitted.
18 JUDGE KWON: This clean version will be admitted.
19 THE REGISTRAR: As Exhibit D498, Your Honours.
20 THE ACCUSED: [Interpretation] Can we see 1D2109 on the screen,
22 MR. KARADZIC: [Interpretation]
23 Q. Sir, Doctor, do you know that the Supreme Command Staff wanted
24 the Sarajevo Military Hospital
25 again -- or, rather, to a hospital for the Army of the Republic of Bosnia
1 and Herzegovina
2 A. No, I'm not familiar with the details. Perhaps such request was
3 made, but it was never put into effect.
4 Q. Could you please have a look at that document.
5 A. I am looking at it now.
6 Q. Can you see it says "The Military Hospital, Special Institute,"
7 and so on and so forth? Do you know that such attempts were made -- such
8 requests were made by the ABiH?
9 A. Perhaps, but I'm not familiar with the details. And this was
10 never put into effect. That's what's most important.
11 THE ACCUSED: [Interpretation] Could we have a look at the
12 following page?
13 JUDGE KWON: But before we move on, can you see the first page?
14 Dr. Mandilovic, can you recognise what document is -- this is
16 THE WITNESS: [Interpretation] I've never seen this document
17 before, but I can see what it's about. It's a request. I saw the
18 signature a minute ago. It's a request from the chief of staff of the
19 ABiH, and it says that for the needs of the Armed Forces of the ABiH a
20 medical centre should be established and organised, and in their opinion
21 the former military hospital was the most appropriate hospital for
22 providing the wounded and officers with care; because of its experience.
23 I can see a stamp, I can see a signature here, so that's probably an
24 authentic document, but, again, I'll repeat what I have already said:
25 This was never put into effect.
1 JUDGE KWON: Thank you.
2 MR. KARADZIC: [Interpretation]
3 Q. Could you tell us, Doctor, what this means, "The French
4 Hospital," because -- was it called the French Hospital
6 A. Yes. After the 10th of May, after it had been taken over, after
7 the former Military Hospital
8 Bosnia and Herzegovina, 10 days after that event, as I have already said,
9 a new name was given to it. "The State Hospital" is what it was called,
10 and this was certified as the correct name. But at one point in time,
11 I think it's when President Mitterrand visited Sarajevo - I remember this
12 very clearly, he visited the hospital - at that point in time there was
13 an idea according to which the civilian hospital could be under the
14 auspices of the French -- or, rather, the name "The French Hospital"
15 could be used, but that didn't happen.
16 THE ACCUSED: [Interpretation] Could we have a look at the last
17 page so that we can see the commander, Sefer Halilovic, actually sent
18 this document.
19 MR. KARADZIC: [Interpretation]
20 Q. Is that correct, that's "Sefer Halilovic" there, and we have the
21 stamp of the Main Staff?
22 A. Yes. I said a minute ago that it's an authentic document. I've
23 never seen it before. I wasn't in such a position to have access to such
24 a document, but there were rumours according to which such a
25 transformation might occur. But as I have already said, this was never
1 put into effect.
2 THE ACCUSED: [Interpretation] Thank you.
3 Could this document be admitted into evidence?
4 JUDGE KWON: We'll mark it for identification.
5 THE REGISTRAR: As MFI
6 MR. KARADZIC: [Interpretation]
7 Q. Doctor, would you agree there were conflicts in 1992 between the
8 Territorial Defence of Bosnia and Herzegovina and between the Croatian
9 Defence Council, the HVO, and that there were wounded and dead?
10 A. In 1992, as far as I can remember - a lot of time has passed
11 since then - I think that at that time there were no clashes between the
12 ABiH and the HVO. Naturally, we're speaking about the year 1992.
13 Q. And were there any armed conflicts between them at a later date?
14 A. Yes, I think there were certain disagreements and
15 misunderstandings later on. I think there were certain low-level
16 conflicts as well, but this was somewhat later.
17 THE ACCUSED: [Interpretation] Could we see 1D2110, please.
18 MR. KARADZIC: [Interpretation]
19 Q. While waiting for the document: Doctor, how were these victims
20 described, the victims of the internal conflicts?
21 A. I don't know. We were surrounded for a long time in Sarajevo
22 We had no contact with those who were wounded or who were ill outside the
23 boundaries of the town of Sarajevo
25 Q. Thank you. Can you read out what you can see here, what has been
2 Can we have a look at the bottom part of the document.
3 Could you please read it out?
4 A. "We also have information according to which, in the evening
5 hours on the 27th of December [Realtime transcript read in error
6 "September"], 1992, a conflict broke out between members of the so-called
7 BiH TO and the HVO. There was a conflict in the area between the tobacco
8 factory, the School of Economics
9 for five hours."
10 I've already provided my answer, and I stand by that answer. If
11 there were any clashes, I'm not aware of them, but one should point out
12 that the conflicts that did break out could have been conflicts between
13 certain unofficial bodies, between certain military formations that were
14 out of control, so I really couldn't go into the details and comment on
16 Q. What would these informal groups be? You mean military groups
17 that are out of control. Which ones?
18 A. Well, you know, in the first stages of the war in the town of
20 informal groups were established. That wasn't just a characteristic for
21 the ABiH. That was a characteristic of all the armies that were involved
22 in the war in the Balkans. So there were groups led by certain
23 criminals. At certain points in time, they wanted to take advantage of
24 the situation. But these were low-level conflicts, and they didn't have
25 a significant influence on the situation in Sarajevo and on the
1 relationships that prevailed in Sarajevo
2 THE ACCUSED: [Interpretation] Thank you.
3 Could this be admitted into evidence, please?
4 JUDGE KWON: We'll deal with it after the break. We need to rise
5 right now.
6 The first break will be for 35 minutes. We'll resume at 3.35.
7 --- Recess taken at 3.02 p.m.
8 --- On resuming at 3.38 p.m.
9 JUDGE KWON: Yes, Ms. Sutherland.
10 MS. SUTHERLAND: Your Honour, it's just a matter for the
12 On page 42, line 12, the witness's -- the witness was asked to
13 read out the last paragraph on this document that's on the screen, and it
14 says in the transcript "27th of September, 1992." I don't know if that's
15 what the witness actually said or whether he said "December," which is
16 the correct date, 27th of December.
17 JUDGE KWON: Yes, the document reads "27th of December."
18 Is it correct, Dr. Mandilovic?
19 THE WITNESS: [Interpretation] Correct.
20 JUDGE KWON: When I said that we would deal with the admission of
21 this document after the recess, I was wondering about the relevance of
22 this document. But you do not object to the admission of this document,
23 separate from the issue of translation, Ms. Sutherland?
24 MS. SUTHERLAND: Yes, Your Honour. The witness hasn't been able
25 to speak to anything in this document, and according to your guide-lines,
1 then, it's my position that it shouldn't be admitted.
2 JUDGE KWON: And I was also wondering how it is related to the
3 evidence of this witness which was given in-chief.
4 THE ACCUSED: [Interpretation] I'm sorry, I've been waiting for
5 the interpretation.
6 Well, this is what this is about: The fighting between the HVO
7 and the Territorial Defence of Bosnia and Herzegovina was taking place in
8 the vicinity of that hospital. Obviously, the wounded would be admitted
9 to that hospital, and if there are fatalities, that would be the same
10 thing. So that's the French Hospital
11 JUDGE KWON: Instead of making submissions, you can put your
12 question to the witness.
13 THE ACCUSED: [Interpretation] Well, I had put a question to him.
14 MR. KARADZIC: [Interpretation]
15 Q. Doctor, did your hospital bear the name of "French Hospital
16 a while, and is it referred to as the place where there was fighting
17 between the HVO and the Territorial Defence of the BH?
18 A. We did bear the name of the French Hospital
19 correct, but I did explain a few moments ago that in this triangle that
20 you were talking about, the hospital, the economic school, and the
21 factory of tobacco, there was no conflict. You know full well that the
22 HVO is in the system of defence of Bosnia-Herzegovina and it was located
23 at Stup, and that is very far away from the French Hospital
24 Hospital. Therefore, I cannot accept this document of
25 Mr. Predrag Ceranic. I have read it, but I do not stand by what it says.
1 This is just an approximate version, as it were.
2 JUDGE KWON: Mr. Karadzic, while the witness testified to the
3 so-called low-level conflicts, but the witness didn't have any idea about
4 this document, so we'll not admit this.
5 MR. KARADZIC: [Interpretation] Thank you.
6 Q. Doctor, let's just see this: Do you know where Trscanska Street
8 A. I do.
9 Q. Is it true that it goes from Titova towards Silvije Kranjcevica,
10 or, rather, the street where the Military Hospital
11 A. A bit further away from the Military Hospital.
12 Q. How far away?
13 A. A couple of hundred metres.
14 Q. A couple of hundred metres. Is it between the Military Hospital
15 and the Unis skyscrapers?
16 A. I think the answer is yes.
17 Q. Do you know where Alpina is?
18 A. No.
19 Q. So you don't know where Alpina is in Trscanska Street?
20 A. I don't know.
21 Q. And if I tell you that in Trscanska Street, in the Alpina
22 building, there was the Command of the 2nd Battalion of the 243rd Light
23 Croatian Brigade, of the HVO, that is, do you rule out that possibility
24 or do you allow for that possibility?
25 A. I allow for that possibility, but it wasn't a typical location
1 for the HVO forces.
2 Q. However, Doctor, Stup is a Croatian neighbourhood, but
3 Kralj Tvrtko, Marin Dvor [Realtime transcript read in error "Mali
4 Zvornik"], is that a predominantly Croatian neighbourhood as well?
5 A. I don't know whether it's predominant, but there certainly are
6 Croats living there like in the other parts of Sarajevo for that matter.
7 Q. Marin Dvor, not "Mali Zvornik," as the transcript says. Marin
8 Dvor. I'm sorry I'm in such a rush, but the point is that I don't have
9 enough time.
10 Doctor, do you allow for the possibility or do you rule out the
11 possibility that at Livade, in Avde Jabucice Street, mortars were taken
12 out of garages, then they were used from time to time, and then they were
13 taken back to garages, and that's what went on throughout the war, and
14 that that was the outgoing fire that you could have heard?
15 A. This is the first time I hear of this, from you, here and now. I
16 never saw that, personally, and I never heard anyone talk about that.
17 Q. Do you allow for the possibility or do you rule out the
18 possibility that in front of the Military Hospital
19 time to time, a cannon, used to operate against Serb positions?
20 A. I absolutely rule out that possibility. You know the
21 configuration of the Military Hospital
22 the very centre of town. You know full well that it is practically
23 inserted between two streets, and anyone who knows anything about
24 artillery and artillery pieces would have to rule that possibility out.
25 Q. Thank you. We are going to bring those documents later.
1 Tell me, Doctor, do you know that mortars also fired from the
2 compound of the Kosevo Hospital
3 as well?
4 A. This is the first I hear of it.
5 Q. Thank you. Let us be very specific. I'm not accusing you of
6 doing anything on purpose. However, when you say that some shells had
7 come from Serb positions, do you have any proof of that or are you
8 inferring that on the basis of the fact that there were Serb positions on
9 the southern slopes, the slopes of Trebevic?
10 A. I've already spoken about that. The entire area of the hospital
11 and of Marin Dvor was shelled from Trebevic. And since Serb forces were
12 at Trebevic, it was obvious that the fire came from there.
13 THE ACCUSED: [Interpretation] Thank you.
14 I would like to recommend the testimony of Mr. Mandilovic to the
15 participants here, dated the 17th of January, 2007, in the case against
16 General Milosevic. 558 [as interpreted] is the page number, the 17th of
17 January, 2007.
18 MR. KARADZIC: [Interpretation]
19 Q. So you told us that you don't know where Debelo Brdo is, and also
20 that Serb positions were at Trebevic, and that the shells that fell from
21 Trebevic on the city were Serb shells. Let me read out to you now what
22 happened on this page. I have to do this in English.
23 The lawyer asked you the following -- it was Mr. Tapuskovic:
24 [In English] "I just received the answer, and since the witness
25 doesn't know, I wasn't assisting so much --"
1 JUDGE KWON: Just a second.
2 Yes, Ms. Sutherland.
3 MS. SUTHERLAND: Your Honour, page 558 is page 2 of his
4 evidence-in-chief, so if I could be taken to the correct page, please.
5 THE ACCUSED: [Interpretation] I said "588." I hope, at least,
6 that I said "588."
7 JUDGE KWON: Can he carry on, Ms. Sutherland?
8 MS. SUTHERLAND: Yes, Your Honour.
9 MR. KARADZIC: [Interpretation]
10 Q. [In English] "I didn't insist on whether the Muslim forces were
11 there. This is going to be proven in some other testimonies. I am only
12 asking you whether Debelo Brdo -- the elevation of Debelo Brdo, and in
13 the way he showed us, indicates that the Jewish cemetery was very close
14 to the bottom of Debelo Brdo. Yes or no?"
15 [Interpretation] And this is what you said:
16 [In English] "Below Debelo Brdo, but I don't know who held
17 Debelo Brdo."
18 And so at that time, you didn't know where Debelo Brdo was?
19 A. No, I never knew where Debelo Brdo was. I know the term, but I
20 don't know where it is. During the discussion and during the
21 cross-examination, it was my understanding that Debelo Brdo was above the
22 Jewish cemetery. And then I said, Well, yes, possible.
23 Q. Thank you. I'd like to draw page 604 to your attention, the 18th
24 of January, 2007. I'm going to read it out to you now. Did you state
25 your views on Colina Kapa during that trial as well?
1 A. No. I know of Mala and Velika, Colina Kapa, but I don't know
2 where they are. They are somewhere in the eastern part of Sarajevo
3 I don't know where. Somewhere below Trebevic.
4 Q. This is what it says here. The question was on page 604:
5 [In English] "Thank you very much. You spoke about this
6 yesterday, and I don't want to dwell on that, but let me ask you: The
7 two points, Colina Kapa and Debelo Brdo, they are the two dominant points
8 and, of course, the hills of Trebevic?"
9 [Interpretation] This was your answer:
10 [In English] "What do you mean when you say 'the dominant
12 "Q. Well, these are two hills, too. One is almost a thousand
13 metres high and the other is maybe 800. I can't remember the exact
14 heights. Would those be the hills that dominated the hospital?"
15 And you said: "Yes, yes."
16 [Interpretation] Do you allow for the possibility or do you know,
17 in fact, who was at those hills -- on those hills?
18 A. First of all, I have to make a certain correction; not in terms
19 of what I said, but in terms of how it's been interpreted.
20 Colina Kapa is pretty far away from the hospital, quite far away.
21 It's at the periphery of town. These hills are not as high as you say.
22 These are small hills, in relation to Trebevic, and -- and they do not
23 have any great tactical importance, and they are of no strategic
24 importance whatsoever.
25 Q. So you do know what their strategic and tactical importance is;
2 A. No, I don't, but one fact is for sure. Wherever the BH Army was,
3 the army of the Bosnian Serbs was always above them. So the low hills
4 that you refer to are absolutely unimportant, from a strategic point of
6 Q. Are you trying to say that Colina Kapa is at a lower altitude,
7 lower than 800 metres?
8 A. I don't know. You can find that on a map. First of all, you
9 have to look at the altitude of Sarajevo
10 Colina Kapa. We should not confuse the two.
11 Q. Thank you. We are going to show that, if we're given an
12 opportunity, perhaps even during the course of your own testimony.
13 Very well. What was the defence function of your hospital during
14 the war?
15 A. The State Hospital
16 institution that is in a state of war. Namely, we took care of the
17 wounded and the sick.
18 Q. The Army of Bosnia-Herzegovina did not take care of it at all, as
19 if it were its own, and they did not feel that they had any right to do
21 A. Absolutely not. The State Hospital
22 had its own management, and, unfortunately, throughout the war it had to
23 fend for itself.
24 THE ACCUSED: [Interpretation] 1D2108, please, could we have that
1 MR. KARADZIC: [Interpretation]
2 Q. Could you please read the text below, just the first sentence
3 that says: "I also ask you ..."? Actually, can you identify this? Is
4 this a document of the Ministry of National Defence, the Staff of the
5 Territorial Defence?
6 A. Yes.
7 Q. And who's it sent to, addressed to?
8 A. The PTT Service of the town of Sarajevo.
9 Q. Thank you. They're asking for some numbers here; right?
10 A. Yes, I see that.
11 Q. Can you please have a look at the sentence underneath the
12 figures, the numbers?
13 A. "We also kindly request that you look into the possibility of
14 assigning five new PTT numbers for the needs of the former
15 Military Hospital
16 Q. Was this signed by Sefer Halilovic?
17 A. Yes.
18 THE ACCUSED: [Interpretation] Thank you.
19 Can this be admitted?
20 MR. KARADZIC: [Interpretation]
21 Q. Doctor, this seems to me like care about the Military Hospital
22 and also claiming the military as one's own, asking for additional
23 telephone numbers, et cetera.
24 A. This is not any kind of particular care, Mr. Karadzic. This is
25 mere necessity.
1 After the destruction that came from you, or, rather, your
2 forces, in terms of PTT facilities in the town of Sarajevo, there was
3 chaos in the town of Sarajevo
4 communicate. Since the town of Sarajevo
5 subjected to the military command, including PTT. It is only natural
6 that the Military Hospital
7 the State Hospital
8 command to ask for approval. You know that in war, there is only a
9 military command and that it's only the military that has jurisdiction.
10 Q. Are you trying to say that there was military administration in
11 the town of Sarajevo
12 A. No, no, far be it from the truth. I'm just saying that certain
13 functions were under the military. For example, the assigning of
14 telephone numbers for normal communication in such an important health
15 institution does not mean that this institution is under the control of
16 the military. I've already said that, and I stand by that. You don't
17 have a single relevant document stating that the State Hospital
18 the military throughout the war. This is just normal assistance in a
19 very difficult situation.
20 Q. Doctor, why didn't your director, your general manager, ask for
21 this? Why was it the commander of the staff?
22 A. Our manager must have asked, but he addressed the chief of staff
23 to make sure that they get this PTT line through him. As I said, this
24 was of vital importance, PTT, et cetera, and it has to be under the
25 military in a state of war.
1 Q. Very well. So he asked the commander of the Main Staff to obtain
2 this for him. He asked him -- he made this request, since it was sent to
3 his superior; isn't that right?
4 A. I don't agree with that. Mr. Sefer Halilovic was never our
5 director's superior, never.
6 Q. Very well. Let me ask you something else.
7 Do you know anything about Markale I, about the incident, the
8 tragedy, however you want to call it? It was February 1994?
9 A. Yes, the 5th of February, 1994. There was a large-scale massacre
10 that occurred on that occasion. I remember it. I wasn't on duty at the
11 time, but according to the information I was provided with -- in the late
12 afternoon, I arrived in the hospital. Much medical care had already been
13 provided. It really was a large-scale massacre. There were many
14 wounded, and many people were killed.
15 Q. Thank you. Did you ask Ms. Sutherland not ask you about
16 Markale I, but only about Markale II?
17 A. I didn't ask anyone for anything. I haven't done so in the past,
18 and I'm not doing so now.
19 THE ACCUSED: [Interpretation] Thank you.
20 JUDGE KWON: In the meantime, we'll admit the previous document
21 as MFI
22 MR. KARADZIC: [Interpretation] Thank you.
23 Q. In your supplemental information sheet, the first item on the
24 first page says the following:
25 [In English] "People would be terrified and lapse into
1 depression, and eventually could become indifferent and, apparently,
2 fatalistic. This is a progression and indicative of psychological
3 exhaustion. After a while, we seem to adapt to the fear."
4 JUDGE KWON: Yes, Ms. Sutherland.
5 MS. SUTHERLAND: Could I have the date of the supplementary
6 information sheet?
7 THE ACCUSED: This is supplemental, date 2nd of October 19 -- 2001.
8 MR. KARADZIC: [Interpretation]
9 Q. And at the top, it says the "22nd of November, 2001,"
10 supplemental information sheet.
11 Doctor, what is this called, in scientific terms? How does one
12 arrive at such a conclusion?
13 A. Mr. Karadzic, I have already said that. That's what I stated. I
14 stand by what I stated there. According to my information, I have my
15 knowledge from the sphere of psychology, psychiatry. Well, I said what I
16 knew, and I didn't go into the details, but I do stand by what I stated.
17 Q. Is that a precise scientific fact or is this your impression?
18 A. It's my impression. It's not an exact science. I wasn't
19 involved in the science. There are people who were involved in that
20 science. But this was my personal impression, as a person who,
21 nevertheless, does have a certain amount of medical experience and
23 Q. Thank you. On the following page, you say:
24 "I haven't noticed symptoms in those close around me ..."
25 [In English] "... in people at large. Particularly, you see this
1 in traffic, the impatience, nervousness, agitation. They break traffic
2 rules and have alteration," probably, "[indiscernible] symptomatic of
3 stress, PTSD effect."
4 [Interpretation] Was a scientific study made which is the basis
5 for what you claimed?
6 A. Dr. Karadzic, there were many scientific studies that were
7 carried out in the war that continued from 1992 to 1995. Many such
8 studies were made that, in particular, concerned the victims of the war.
9 Q. Which studies are you referring to here?
10 A. I'm not basing my opinion on studies here. I was asked what my
11 personal opinion was about the matter, so this statement isn't based on a
12 scientific study of any kind.
13 Q. Thank you. The next item says:
14 [In English] " ... military doctors before. I did not know
15 anything about how the VRS operated. They had come from JNA and had the
16 same command staff, so it is logical that they worked in the way of the
17 old JNA. I do not include paramilitaries in this. I never had contact
18 with any of them."
19 [Interpretation] Do you know where Muslim officers came from,
20 ABiH officers, Sefer Halilovic, Nadalic [phoen], Hajrulahovic, and so on
21 and so forth? Which army did they come from?
22 A. The officers, whose names you have mentioned, came from the JNA,
23 that's what it says here, but there were officers in the ABiH who didn't
24 have a military pedigree, who had come from other areas.
25 Q. Thank you. Have you heard of Caco, Juka Prazina, Celo -- a
1 certain Celo, and have you heard of their brigades and of the terror that
2 they spread against the Serbs in Sarajevo?
3 A. Yes, I have heard of the names that you have mentioned. They
4 come from the town of Sarajevo
5 to the Sarajevo
6 formations present amongst all the armies that were established. They
7 had certain disagreements, they had certain problems. And during one
8 period of time in the course of the war, the ABiH really strove to unite
9 all those units and to place them under their control.
10 Q. Are you familiar with an army in the Balkans, or anywhere in the
11 world, where criminals, such as Juka Prazina, became a general and a
12 member of the supreme command?
13 A. Juka Prazina was never a general in the ABiH. He moved over from
14 the ABiH to the HVO for certain reasons that I can't comment on. I'm not
15 familiar with all those situations. And there, he was promoted to the
16 rank of general.
17 Q. Thank you. Have you heard of Kazani, the place Kazani, which is
18 where Serbs and Jews were killed, and does this remind you of the Second
19 World War at all?
20 A. I heard of Kazani only after the end of the war, after 1995. It
21 was mentioned in the press, in the media, certain investigations were
22 launched, but I know nothing else about that. As to the outcome of the
23 investigation, I'm not familiar with it.
24 Q. How was this described to you? What did you hear about it after
25 the war?
1 A. All I knew was what I learned from the media, electronic media or
2 the printed media.
3 Q. What did you learn about the event?
4 A. Kazani was a place where certain Serbs were killed. That was the
5 crux of the matter. That's a bit approximative. Definite conclusions
6 were never reached with regard to the numbers concerned or the
7 time-period, because a thorough investigation was never launched into
8 that, as far as I know.
9 JUDGE KWON: Yes, Ms. Sutherland.
10 MS. SUTHERLAND: Your Honour, I'm just wondering where the
11 relevance of this [indiscernible] to the charges in the indictment.
12 JUDGE KWON: I quite agree.
13 I don't understand, Mr. Karadzic, how come you can complain about
14 the shortage of time, asking these questions to the witness.
15 THE ACCUSED: [Interpretation] Your Honour, if this witness says
16 the Serbs were targeting the hospital from Trebevic, they were doing that
17 deliberately, and if he doesn't know who was on Trebevic, if he says it
18 was terrible to live in Sarajevo
19 responsible for this. If he says that the inhabitants of Sarajevo
20 suffered, well, I know, but let's see why. This cannot be ascribed to
21 the Serbs.
22 Could we please see 1D2103.
23 With all due respect for the witness, his statements have been
24 made in a fairly cavalier manner. He's been expressing his impressions.
25 He hasn't provided us with information about the conditions in Sarajevo
1 for the Serbs, and these are the terrors that have to be described.
2 JUDGE KWON: Just ask your question.
3 MR. KARADZIC: [Interpretation] This is item -- this is from
4 "Srna," 8th of May, 1992. It's a report from "Srna." Could we now see
5 page 4 in this article, please.
6 Q. As someone born in Novi Sad
7 read the Cyrillic script without any problems. It says:
8 "This is a dramatic appeal from the doctors who work in the
9 Military Hospital
10 It was sent on the 7th of May, 1992, to the Service for Informing
11 the Crisis Staff. It says -- well, could you read out what it says here?
12 A. It says:
13 "Gentlemen, please prevent -- gentlemen, use all your forces to
14 prevent the lies that are being spread with regard to this institution.
15 There are no hostages here. No one has been isolated here. Only those
16 who don't want to hand this institution over to the TO of the BH have
17 remained here. I'm afraid that the authorities might be responsible for
18 this house falling. We have some forces for our defence, but for five
19 days now we haven't received any bread or milk. What have you done? We
20 have been left here, and we are being targeted by mortars and snipers
21 every day. You can't be heard. You are not doing anything. If you lose
22 this house, you've lost half of Sarajevo
23 JUDGE KWON: Just a second.
24 I think we have an English translation for this. No? Thank you.
25 Please carry on, Dr. Mandilovic.
1 THE WITNESS: [Interpretation] "You can't be heard. You are not
2 doing anything. If this house is lost, you will have lost half of
4 alive. Colonel Dusko Kovacevic is with us. Gentlemen, do something as
5 soon as possible."
6 MR. KARADZIC: [Interpretation]
7 Q. Did you know Colonel Kovacevic?
8 A. No, no.
9 Q. Did you know that at the time you were absent there, do you know
10 that they opened fire on the Military Hospital
11 targeted the hospital, and they weren't provided with bread and milk for
12 five days? Did you know that?
13 A. I can't answer the question. I wasn't there.
14 Q. When you arrived there, did you ask about the situation when you
15 were absent?
16 A. No. When I arrived there, there was no one present.
17 Q. None of those who complained; is that right?
18 A. That's right, no one was there.
19 Q. Very well. Did you notice the damage inflicted by the bullets or
20 the mortars? Did you notice it on the 10th or the 12th, when you arrived
22 A. When I arrived in the hospital, I didn't notice anything. I've
23 already said that. I didn't notice any significant or extensive damage,
24 not on the asphalt, or on the facade, on the walls, or on windows.
25 Q. Did you know -- did you notice minor damage?
1 A. I really couldn't say. Eighteen years have passed since then. I
2 can't remember. At the time, it wasn't important.
3 Q. Those people who were crying out for help think that that was
4 important. Do you know who was shooting, until the 7th or the 10th of
5 May, who was shooting at the Military Hospital
6 A. I don't know. I really don't know.
7 Q. Do you rule out the possibility that it was the Serbs?
8 JUDGE KWON: Mr. Karadzic, I think you exhausted your topics --
9 I think you covered this topic at the beginning of your
10 cross-examination. Move on to another topic, please.
11 THE ACCUSED: [Interpretation] Thank you.
12 Can this document be admitted?
13 JUDGE KWON: Ms. Sutherland?
14 MS. SUTHERLAND: Pursuant to your guide-lines, Your Honour, I
15 would -- it's our position that it shouldn't be admitted.
16 [Trial Chamber confers]
17 JUDGE KWON: Mr. Tieger.
18 MR. TIEGER: I just want to be a bit cautious, Your Honour.
19 Since we have engaged with discussions about the Defence with this, and
20 we have had some discussions in court and Chambers about this, I'm not
21 suggesting that every time a witness can't speak to the document or a
22 document is presented to him to amplify some aspect of a
23 cross-examination, it's not admissible. But in this case, in light of
24 the fact that we have a time-period preceding the period about which the
25 witness can use, and we have -- the document tendered is "Srna," which is
1 the Serbian press agency, promulgated for particular reasons, I think we
2 have a particular reason for caution here. So I don't want to suggest
3 that we are re-introducing a more stringent form of admissibility, but
4 I think the caution, as Ms. Sutherland expressed, with respect to these
5 kinds of documents, is appropriate.
6 I'm looking at Judge Lattanzi. She's -- I don't know if she has
7 any questions about it, but I think "Srna" has a -- is a matter of a
8 different kind of concern than normally official documents, the type
9 we've been looking at coming from -- that are produced contemporaneous;
10 for example, communications within particular bodies and so on.
11 THE ACCUSED: [Interpretation] May I say something before --
12 JUDGE KWON: Yes.
13 THE ACCUSED: [Interpretation] Please, "Srna" is a state news
14 agency. It does not invent things. It doesn't provide comments. I
15 don't rely on their comments. I rely on them conveying other documents.
16 This is an appeal from the Military Hospital
17 Military Hospital
18 Agency. It is totally unacceptable to disqualify a news agency in this
19 way, as far as news are concerned, not comments.
20 [Trial Chamber confers]
21 JUDGE KWON: The Chamber is of the view that we do not need to
22 set up a new rule depending upon the content of the document. But simple
23 or consistent application of our guide-line is that the witness didn't
24 confirm anything about this, he gave his testimony about the content of
25 this event, so we will not admit this.
1 MR. KARADZIC: [Interpretation] Thank you.
2 Q. Doctor, now I'd like us to have a look at something. Actually,
3 I'd like us to discuss medical documents, the medical documents that you
4 provided. Is this everything that this hospital did, and, if so, in
5 which period?
6 A. I don't know which documents you're referring to.
7 Q. I mean the documents that are attached as medical documentation
8 from this hospital that is often called the General Hospital of Sarajevo,
9 and then the Military Hospital
10 General Hospital of Sarajevo the same thing as the Military Hospital
11 rather, the State Hospital
12 A. The State Hospital
13 Q. And what is this General Hospital of Sarajevo?
14 A. That's a new term. That's a new term. Presently, that is the
15 name it bears, the Hospital of Dr. Abdulah Nakas.
16 Q. When did it become the General Hospital
17 A. It's been about five or six years now.
18 THE ACCUSED: [Interpretation] 65 ter 09595, but I believe that it
19 has a P number now.
20 MS. SUTHERLAND: Your Honour, just while we're waiting for the
21 exhibit number to come up: Mr. Karadzic put to the witness "medical
22 documents that you provided." It's clear from the witness's statement
23 that he didn't provide them. He was shown certain documents by the OTP,
24 and he commented on certain documents.
25 JUDGE KWON: Thank you.
1 THE REGISTRAR: Your Honours, this document has been admitted as
2 Exhibit P1235.
3 MR. KARADZIC: [Interpretation]
4 Q. Does it say here that it's the General Hospital of Sarajevo, and
5 is the date the 9th of September, 1993?
6 A. That's what's written there. But in 1993, it was the
7 State Hospital
8 Q. Five years ago, it became the General Hospital?
9 A. I cannot really say for sure. I am not sure about the actual
10 dates, but in 1993 it was the State Hospital
11 Q. Well, look, let's try to find our way somehow. It was the OTP,
12 then, that showed this to you?
13 A. I haven't seen this document. This is a document. It has a
14 stamp, it's got everything, but -- ah, no, no, no, no, no. Dr. Karadzic,
15 Dr. Karadzic, this is what this game is about: This is a copy of the
16 findings of 1993. It was copied out. Often, for the purposes of various
17 commissions, excerpts were requested from medical documentation, and it
18 says up here "Copy." That is to say, this was copied from the original
20 Q. I see. And where are the original findings?
21 A. If the patient had the original findings, he wouldn't have asked
22 for this. He probably needs to exercise some rights in connection with
23 this. Obviously, the patient had been wounded, and he's probably asking
24 for some kind of rights, exercised on the basis of a disability or
25 whatever. So he simply wanted the original findings to be copied many
1 years later.
2 THE ACCUSED: [Interpretation] Excellencies, by your leave, I
3 really have to be a lot more careful with these associated documents.
4 Dr. Mandilovic never saw this document before, and we admitted it into
6 THE WITNESS: [Interpretation] Dr. Karadzic, the document is
7 perfectly valid. However, you tried to confuse me with the name of the
8 hospital. It is absolutely valid, the document. You speak our language,
9 don't you? And it says up here "Prepis Naliza" [phoen], that is to say,
10 "Findings copied out for" such and such a person, and so on. And there's
11 the date as well. Do you understand?
12 MR. KARADZIC: [Interpretation]
13 Q. Well, all right, Doctor. But why did we not receive a photocopy
14 of the original findings? Why did we just get this copy that was written
15 out a couple of days ago?
16 A. Well, you could not, because the lady obviously lost the original
17 findings somewhere during the course of the war, and that is why she was
18 asking for the original document -- for the original findings to be
19 copied out. However, since we have excellent documents, we found her
20 name, we found her diagnosis, and we simply wrote this out and said that
21 she was wounded, and what the diagnosis was, and so on and so forth.
22 It's hard for me to say now.
23 THE ACCUSED: [Interpretation] Excellencies, I think that such
24 documents should not be admitted through this witness; rather, these
25 documents should be admitted through the person who actually copied them
1 out, who wrote them out. Are these findings going to remain in evidence
2 or will you have them withdrawn?
3 JUDGE KWON: Mr. Karadzic, Dr. Mandilovic confirmed the way and
4 as to how it is issued by the hospital, and he confirmed the
5 authenticity. There's no reason not to admit this. And he confirmed in
6 his statement that the -- in para 117 and 118, he confirmed the
7 authenticity of these documents. On that basis, we admitted this
8 document, and there's no reason for us to revisit the issue.
9 Please carry on, Mr. Karadzic.
10 THE ACCUSED: [Interpretation] Can we have another page of this
11 same document? If Dr. Mandilovic is familiar with this document, then
12 let's have a look at it. The next page -- or, rather, 2, 3 -- page 3.
13 MR. KARADZIC: [Interpretation]
14 Q. Doctor, why was that needed? Because over here, you can see on
15 the first page the actual patient history. So why was that copy needed
16 when there is a patient history, without a stamp, in all fairness, but
17 something is written here?
18 A. This document that I have on my screen now is perfectly valid,
19 just like those findings. Now, why did the lady need the document, why
20 did she need to have the findings copied out, I don't know. But both
21 documents are absolutely valid.
22 THE ACCUSED: [Interpretation] Page 7, could we have that now.
23 MR. KARADZIC: [Interpretation]
24 Q. Now, this is somebody else, some person called Meliha in this
25 document, then Admir.
1 A. I just have the case history signed by Dr. Ranko Vuletic. I
2 don't have the first page, so I don't know the name and surname of the
3 patient. I see that it's a valid document because it was signed by a
4 doctor who I know personally.
5 Q. And this child was injured by whose bullet? Who was it that
6 wounded this child?
7 A. It doesn't say in the case history. It just says what the date
8 was, that the child was brought to the ward after having been injured by
9 a projectile and was immediately re-animated, and then the actual surgery
10 performed is explained in greater detail.
11 THE ACCUSED: [Interpretation] Thank you.
12 65 ter 09615 now, please.
13 THE REGISTRAR: Your Honours, for the record, this has been
14 admitted as Exhibit P1237.
15 THE WITNESS: [Interpretation] Yes.
16 MR. KARADZIC: [Interpretation]
17 Q. What is this wound; can you tell us?
18 A. It's an explosive wound in the right foot.
19 Q. And the person was released after two days; right?
20 A. Probably.
21 Q. Does it say here: "Discharged on the 7th of February, 1994
23 A. I don't know. It is barely legible, the original that I see
24 here. I just see the name and surname. I see it says "civilian," and I
25 see that this person was born in 1973. I see the address, Humska Street
1 27. I have the diagnosis, and I see what was done; that the wound was
3 Q. And underneath?
4 A. It says: "Discharged on the 7th of February, 1994
5 Q. Thank you. So she was released on the 7th of February, 1994
6 A. Yes, that's what is written here.
7 Q. "Vulnus," as it is written here; is that right?
8 A. Why are you asking?
9 Q. Because there are several findings with the very same word.
10 A. But, of course, we didn't have 100 doctors, Mr. Karadzic. Our
11 doctors were there in surgery and at the Emergency Ward. It's one and
12 the same doctor who wrote up all these documents, yes.
13 THE ACCUSED: [Interpretation] Could we have the next page.
14 MR. KARADZIC: [Interpretation]
15 Q. "Vulnus," is that the same handwriting?
16 A. Of course, it's got to be the same doctor, no dilemma about that,
17 the very same handwriting.
18 Q. I see. And this person was released two days later as well?
19 A. Yes, yes, that's the way we had to operate. We didn't have
20 enough room. We would treat patients, and when there was no danger of
21 further complications, we discharged patients, and then they were asked
22 to come back for check-ups.
23 This is an explosive wound of the right arm; that is to say, that
24 the patient is perfectly mobile and we were in no position to keep that
25 patient in hospital any longer.
1 THE ACCUSED: [Interpretation] Could we have the next page. Thank
3 MR. KARADZIC: [Interpretation]
4 Q. This is also the 5th of February, Sefik Kukavica, civilian?
5 A. Yes.
6 Q. How did the doctor come to this information, that this person was
7 a civilian?
8 A. Well, that's very simple. Mr. Sefik came to the Surgery Ward on
9 the 5th of February, and he showed documents showing who he was.
10 Q. Thank you. So it's the same handwriting; right?
11 A. Yes. Dr. Karadzic, you worked in medical institutions. For
12 heaven's sake, you can see it's the same date, and you can see that it is
13 one single doctor who was working throughout that day at the Surgery
14 Ward. It's different patients, but of course it's the same handwriting.
15 It's the same day in surgery. Of course, it's the same man; of course,
16 it's the same handwriting.
17 Q. And they all waited for him to see them?
18 A. Who else could see them? I apologise. These are not urgent
19 cases. These are people who come for a check-up and to have their wounds
20 dressed. These are not people whose lives are in danger.
21 Q. Doctor, this is the 5th of February, so this is an exit/entry
22 wound, we see, in the abdomen; explosive, hemi-thorax, all right, limbs,
23 arm, leg. But look at all of this. They are all waiting in the waiting
24 room to be received by that doctor. He's receiving them one by one, and
25 he's dealing with them. It says "PHO."
1 Can we have the next -- no, no, no, this is it. The next one,
2 actually. That's it. Now the next one. Next one, please.
3 "Vulnus sclopetarium"; right? What is this? "Slatizan [phoen]
4 history." "Surgical treatment of wound."
5 Can we have the next one?
6 This is an exit/entry wound, is it not?
7 A. Yes, it is, of the gluteal area, right area. An anti-tetanus
8 serum was administered, and the individual was hospitalised. Apologies.
9 Q. And the person was discharged on the 8th of February; is that
11 A. Yes.
12 Q. So these are all patients following the explosion at Markale, and
13 a doctor would line them up, take them in one by one, discharge them, or
14 hospitalise them. So how does this all seem to you, as a doctor?
15 A. Well, it's very well. You have to know that serious cases were
16 being operated in surgeries at this very moment and that there was a
17 doctor there to receive less-serious patients. We used to have a triage
18 conducted, prioritising patients for treatment. So if we are talking
19 about this period, you are, in fact, bringing confusion into this whole
20 matter. We have serious cases being treated in the theatre; whereas,
21 less-serious cases were being treated in this ward. Most of the surgeons
22 were being engaged in operations at this very moment, whereas there was
23 just one surgeon, with the assistance of a nurse, who treated these
24 less-serious cases.
25 Q. Doctor, have you reviewed all the material shown to you by the
2 A. Well, it was very voluminous. I don't know if I've seen
3 everything, but I've seen a large part of it, and I stand by what I say.
4 THE ACCUSED: [Interpretation] Let's look at 09616, a 65 ter
5 document which probably has a P number.
6 THE REGISTRAR: Your Honour, this has been admitted as
7 Exhibit P1238.
8 THE ACCUSED: [Interpretation] We don't need to have the document
9 in English. Could we have the entire document up.
10 MR. KARADZIC: [Interpretation]
11 Q. Who added this in handwriting, "Shell"?
12 A. Where?
13 Q. In the third column.
14 A. Can you give me a name? I don't see a "shell" written anywhere.
15 Ah, now I see it, yes.
16 Q. It's evidently a different handwriting and a different pen. Who
17 made these additional annotations?
18 A. I don't know. This is a different institution. It's a document
19 from the Clinical Centre, and obviously somebody else made these
20 additional annotations. However, from the description of the wounds, one
21 can see that these were most probably -- this was most probably shrapnel,
22 because we have "explosive wound," "explosive wound," "explosive wound."
23 In other words, we had explosive wounds which were typical for shells.
24 THE INTERPRETER: Can Mr. Karadzic please repeat his question.
25 THE WITNESS: [No interpretation]
1 JUDGE KWON: Just a second, Dr. Mandilovic.
2 Could you repeat your question, Mr. Karadzic. The interpreters
3 couldn't hear that.
4 MR. KARADZIC: [Interpretation]
5 Q. Does the letter K stand for "Kuca," meaning "in-house" or
7 A. Yes, it's possible. This is the Clinical Centre after all, but
8 it is possible. We have reception or hospitalisation with the first and
9 the second cases as well; whereas, next to the case of Mira Stanisic, we
10 have "K" there, so maybe meaning that she was actually discharged, sent
11 home. Of course, there were less-serious wounds. Not all these cases
12 were necessarily hospitalised.
13 THE ACCUSED: [Interpretation] Can we turn to the next page.
14 Another one, please.
15 MR. KARADZIC: [Interpretation]
16 Q. Here, it says two were discharged home?
17 A. And the other two died.
18 Q. Yes. How was it possible that a shell caused a vulnus
19 sclopetarium, an entry/exit wound? We saw it in the Military Hospital
20 We have it here. How can we have an entry/exit wound as a result of a
21 shell impact?
22 A. Well, I don't recall there being such wounds. They were, for the
23 most part, explosive wounds. And down here, if you look at the second
24 patient from the top, we have combustion or, in other words, it's a burn.
25 In the document we looked at earlier on, there was a sclopetarium wound,
1 but it's really difficult to tell.
2 Q. But it wasn't just one case. I'll find many more, as many as you
4 A. There was constant fire, not just shelling. There was small-arms
5 fire, there was sniper fire. It's difficult to tell.
6 Q. Hodzic -- no, 974 or page 7 --
7 JUDGE KWON: Can you identify the patient in the English page in
8 which the exit and -- entry and exit wounds appear?
9 THE ACCUSED: [Interpretation] There, Patient 870, for instance.
10 We have it here in the Serbian version, and it says clearly "Vulnus
11 sclopetarium," "Regionis vateris femori sinistri." It says
12 "sclopetarium," and it is added in handwriting "shell."
13 THE WITNESS: [Interpretation] Well, it's possible. Why not?
14 What does "sclopetarium" stand for? It means that it's an entry/exit
15 wound. It's possible.
16 MR. KARADZIC: [Interpretation]
17 Q. Yes. Doctor, entry/exit wound?
18 A. Precisely. The shrapnel got in and got out and did not make
19 extensive damage. It is quite possible. It need not always be an
20 explosive wound. It can be a sclopetarium wound.
21 Q. And need there be laceration, Doctor? How can shrapnel pass
22 through tissue without lacerating it?
23 A. Shrapnel can be of different sizes. There are shrapnel -- there
24 is shrapnel that can be smaller than a bullet, and, of course, they can
25 get fragmented into thousands of pieces.
1 Q. On page 879, the next page, again we have the entry/exit wound?
2 A. Right.
3 Q. 885, "Vulnus sclopetarium"?
4 A. Yes, "Entry/exit wound." And that's as clear as day. I don't
5 see why you should highlight it so. These are entry/exit wounds from
7 Q. 879, again "Vulnus trans-sclopetarium"?
8 A. Well, these were probably lucky people.
9 Q. I didn't hear you.
10 A. Well, the ones -- the individuals you're referring to were
11 evidently lucky.
12 Q. To be hit by a bullet; right?
13 A. No, to have had the projectile go in and out.
14 Q. Come on, Doctor. You, yourself, don't believe what you're
15 saying. How is it possible that you would have so many cases of vulnus
16 sclopetarium as a result of a shell? Be a doctor and tell us.
17 A. Well, I've already said what I've experienced, myself, and I
18 stand by what I said. But I cannot stand behind every diagnosis made and
19 every doctor's findings.
20 Q. Page 5, can we look at Person number 863. "Vulnus sclopetarium."
21 861, "Vulnus sclopetarium."
22 A. Well, fine. This was minor damage. Shrapnel got in and went
23 out. The diagnosis is quite clear. I don't see why you're belabouring
24 the point.
25 Q. 858, 859, 860, it only says "Shell"?
1 A. Yes.
2 Q. Let's move along. Let's look at page 1. "Vulnus sclopetarium,
3 regionis vateris femori sinistri." We will not be mentioning the name.
4 It says "Page 1." I'm not looking at the collective findings,
5 but individual findings, so it's one page ahead.
6 A. What are you referring to?
7 Q. A page before the one we're seeing right now.
8 JUDGE KWON: Yes, Ms. --
9 MS. SUTHERLAND: Your Honour, if Mr. Karadzic doesn't want the
10 witness's name to be spoken, perhaps we can go into private session or
11 the document can be taken off the broadcast.
12 JUDGE KWON: I'm not sure whether this has already been
13 broadcast, but --
14 THE ACCUSED: [Interpretation] I don't have any particular wish to
15 mention the names. We simply don't need them. Perhaps we need not
16 broadcast beyond the courtroom what we have on our screens.
17 MR. KARADZIC: [Interpretation]
18 Q. At page 42, again we have the Military Hospital, again "Vulnus
20 A. If you don't want us to mention names --
21 JUDGE KWON: Just a second. But it was not tendered
22 confidentially. It was admitted publicly. Just out of --
23 MS. SUTHERLAND: I have no problem, Your Honour. I wonder why
24 Dr. Karadzic said that, and I thought there might be a reason for it.
25 JUDGE KWON: It just -- I think it was out of an abundance of
1 caution, but it is a public document. But let's carry on.
2 THE ACCUSED: [Interpretation] Excellent. No problem. Can we go
3 back, then, to the very beginning of the document.
4 THE WITNESS: [Interpretation] We can only read out numbers. We
5 don't need to mention first and last names.
6 MR. KARADZIC: [Interpretation]
7 Q. Yes. These numbers, 09 -- yes, these numbers, we can read them
9 65 ter 09959 -- 09595. It's been admitted already. It says
10 "Vulnus sclopetarium, abdominis, hospitalisation."
11 A. The diagnosis is more than clear, Mr. Karadzic.
12 Q. The first one we looked at.
13 A. "Vulnus trans sclopetarium abdominis" is very clear. It means
14 that the shrapnel entered the abdomen and left the body.
15 Q. Very well. This is not important anymore.
16 THE ACCUSED: [Interpretation] There are some documents here from
17 the Military Hospital
18 should have allowed for documents originating from other hospitals to be
19 admitted through this witness.
20 JUDGE KWON: I don't understand what you're saying.
21 THE ACCUSED: [Interpretation] If documents originating from his
22 hospital were admitted through this witness, I wonder perhaps -- should
23 we have also introduced documents looking from some other hospital? I
24 don't know which hospital this comes from.
25 MR. KARADZIC: [Interpretation]
1 Q. It says "Military Post," doctor, does it not, up here?
2 A. Where? Can you direct me to the spot you're looking at?
3 Q. Well, the longest column, "Findings," "Opinions" -- no, and now
4 it says, the first column. It says: "Names," "Military post," and
5 "place." Describe -- or, rather, write the personal identification
6 number -- can you see that, above the names, themselves? It says
7 "Military Post" there, does it not?
8 A. Yes, "Military Post, "Place," and "Address," and, of course, all
9 the other details concerning patients.
10 Q. Who does this document belong to?
11 A. This is a medical document. It's a universal medical document.
12 It doesn't say who it belongs to, but it's standard. This is something
13 that we referred to during the earlier sessions, that we needed to have
14 the patient's particulars; name, last name, address. We had to know
15 whether the person was a civilian, what his occupation was, if he was a
16 serviceman, what the details were, et cetera.
17 Q. And which hospital is this, Doctor?
18 A. I think it's the State Hospital
19 Q. And that's the document there?
20 A. Well, you see the protocol is the same. If you don't have a
21 signature, if you don't have a stamp, you won't know who it belongs to,
22 because the templates -- the forms are always the same. But I believe
23 that this belonged to the State Hospital
24 Q. Very well. Can we, based on the wounds described herein, draw
25 conclusions as to who inflicted them?
1 A. We cannot. A wound is a wound. We can approximately tell
2 whether the wound was the result of a shell shrapnel or anything else,
3 but we can't establish that. This would be beyond my powers and beyond
4 my role.
5 Q. A general question, Doctor: How many post-mortems can a doctor
6 carry out during the course of a single day? Forensic or pathology, they
7 are very similar, aren't they?
8 A. Yes, they are very similar; I agree. It depends on the doctor,
9 it depends on his knowledge, on his skill, on his motives. It's very
10 hard to say. He can carry out post-mortems all night.
11 Q. So if he works all day, how many can he carry out?
12 A. Say, 10 to 15, no doubt about that.
13 THE ACCUSED: [Interpretation] Thank you.
14 I don't know how much time I have left, Your Excellencies, so I'm
15 cutting things short.
16 JUDGE KWON: I'm advised that you will have about an additional
17 15 minutes, but I'm of the impression that you can conclude in 5 minutes.
18 THE ACCUSED: [Interpretation] Well, then I have to deal with
19 fewer documents.
21 MR. KARADZIC: [Interpretation]
22 Q. Doctor, did you know Vesna Pagon?
23 A. No.
24 THE ACCUSED: [Interpretation] Can we have that document, please?
25 JUDGE KWON: Could you give the number again?
1 THE ACCUSED: [Interpretation] 1D2120.
2 I don't know whether we have a translation, but it bears an OTP
3 number -- an ERN number, rather.
4 MR. KARADZIC: [Interpretation]
5 Q. Doctor, can you have a look at this. Do you agree that this is
6 Vesna Pagon, and it says that she has a Master's Degree in Pharmacology
7 and that she worked in the pharmacy of the former Military Hospital
9 A. Yes, that's what it says here, but I don't know the lady.
10 Q. All right. Let's see what this lady doctor says. I shall
11 interpret it, and you check on what I'm saying.
12 So this is an interview at the State Security Service, at the
13 Department of Novo Sarajevo. The date is the 8th of October, 1994
14 lady says that she crossed over to the Serb territory through
15 Kabil Amra, through the Commission for the Exchange of Civilians,
16 and she was -- that person was Deputy of Amor Masovic. And then
17 she says that the situation in the Military Hospital
18 there are too few people working there, and doctors who are not
19 professional enough are in different positions in the hospital. She
20 gave, as a good example, Dr. Nakas, Abdulah, who protects Serb personnel
21 who still work there. He is an eminent doctor, but he doesn't have
22 support because he's not a member of the SDA. She says that Nakas is
23 still in touch with doctors of Serb ethnicity, his former colleagues, who
24 are now in Serb territory. As for his brother, Nakas, Bakir, she says
25 that as opposed to Abdulah, he's turned into a major fundamentalist, on
1 account of which he clashes frequently with his brother. As for ethnic
2 Serbs who still work at the hospital, Vesna says that there are only
3 about 30 of them left and they all want to leave Sarajevo and to cross
4 over into Serb territory. Ethnic Muslim doctors are trying to prevent
5 that in every conceivable way, and if somebody leaves all of a sudden,
6 they say that it will not be a good thing, it causes panic in the
7 hospital. They say it's not good if all the Serbs leave, because they
8 are quite professional and they do their job professionally.
9 Do you know who it was that left?
10 A. I don't know exactly now, but perhaps I can give a comment in
11 respect of what you quoted just now.
12 This is what I can say: I express my great dissatisfaction in
13 relation to this document. I don't know what to call it. It absolutely
14 does not correspond to the truth.
15 Dr. Abdulah Nakas was a doctor, first and foremost, who helped
16 everyone, irrespectively. Dr. Bakir Nakas was the manager of the
17 hospital throughout and, as I said earlier on, he has enormous merit, in
18 terms of keeping the hospital going. I did not notice anything extremely
19 nationalist about any of these doctors.
20 However, in respect of this pharmacist, I have to say the
21 following: The first three surgeons at the State Hospital
22 left the JNA - one was a Montenegrin, another one was a Serb, and one was
23 a Muslim, too - the chief of the group of Internal Medicine in our
24 hospital was a Slovak, so this was really a multi-ethnic group of people
25 and multi-religious as well. This was our main characteristic that we
1 preserved throughout the war. That is why I think that we survived as
2 such, and we were always guided by the idea of anti-fascism.
3 As for these qualifications that I read here, I categorically
4 renounce them and they do not correspond to the truth.
5 Q. If you were guided by the idea of anti-fascism, are you talking
6 about the Second World War or this war?
7 A. This war, Dr. Karadzic.
8 Q. Who was a fascist, Doctor? Who was it that you fought against?
9 A. We fought against aggression, against a terrible aggression that
10 went on for 44 months incessantly, without interruption. That's what I'm
11 talking about.
12 Q. Who carried out an aggression against who?
13 A. Well, if you're shelling an area all the time, and if people
14 cannot leave that territory, it is well known who it is that is carrying
15 out this aggression. You don't have to be terribly clever to realise who
16 it is. After all, you can ask all the many foreign observers who were
17 there; professional monitors in UNPROFOR, then the European monitors.
18 Then you should ask the media who were present in Sarajevo. I think they
19 know that full well, and I think that they presented it very well, too.
20 Q. Doctor, would you accept the formulation of the Security Council
21 of the United Nations with regard to this particular topic?
22 A. You would have to give me an actual quotation so that I would
23 know whether to accept that or not.
24 Q. Is there anyone competent there? You spoke of international
25 factors. Is there anyone who has greater competence than the Security
1 Council of the UN, and the Security Council said that this was a tragic
2 conflict, not an aggression?
3 A. I, as an individual, cannot accept that as a conflict, because a
4 conflict has -- goes on over a definite period of time, not over 44
6 Q. Conflicts can go on for 30 years and 100 years. There are wars
7 that went on for a hundred years.
8 A. Well, wars, yes.
9 JUDGE KWON: Yes, Mr. Tieger.
10 MR. TIEGER: I don't know how long the Court wants to encourage
11 this particular debate to continue.
12 JUDGE KWON: It ended, I think. Are you --
13 THE ACCUSED: [Interpretation] Well, debate. The doctor says
14 something that cannot remain unchallenged. He says something that is
15 new. He gives his opinion as if he were an expert here, and I have to
16 put it to him that the United Nations, that he referred to, termed the
17 conflict in a different way.
18 MR. KARADZIC: [Interpretation].
19 Q. So, all right, Doctor. Do you know how many doctors from
21 A. I don't have that exact figure, but a considerable number.
22 Q. You mentioned at one point that you had heard that
23 Professor Najdanovic got killed. Was he your professor too?
24 A. Yes, yes, he was.
25 Q. Do you know that Professor Najdanovic was stabbed, beaten up, and
1 thrown into a garbage container?
2 A. I had never heard of that before I heard it from you just now.
3 Q. Did you ever mention that he was a member of the SDS?
4 A. I think he was, yes. He was quite active in 1991, when the
5 multi-party system was developing in Bosnia-Herzegovina. I think he was
6 one of the SDS
7 Q. Do you know that he was a federal MP in the Federal Parliament of
10 A. I didn't know about the federal level, but I think he was an MP
11 at republican level.
12 Q. When you say, I heard that he got killed, but he was a member of
13 the SDS
14 doctor, a wonderful man, married to a Jewish lady, now that we're on the
15 subject, is that reason enough for him to be killed and to be thrown into
16 a garbage dump, a container?
17 MS. SUTHERLAND: Excuse me.
18 JUDGE KWON: Just a second.
19 MS. SUTHERLAND: Your Honour --
20 JUDGE KWON: I will hear from you first, Ms. Sutherland.
21 MS. SUTHERLAND: Your Honour, that wasn't what the witness said.
22 And if Mr. Karadzic is going to put something the witness said to him, he
23 needs to -- he needs to say exactly what the witness said.
24 In the supplementary information sheet that was provided to
25 Mr. Karadzic, of the 14th of July, 2010, the witness -- it states that:
1 he stated -- when asked about Professor Dr. Najdanovic, Dr. Mirko Sosic,
2 and Marko Vukovic, he stated that they all worked at the Sarajevo
3 University Clinical Centre and were members of the SDS. The witness
4 stated that he heard that Professor Dr. Najdanovic died but did not know
5 the circumstances of his death.
6 He didn't say what Mr. Karadzic just put to him, that he died and
7 he was a member of the SDS
8 JUDGE KWON: Mr. Karadzic, how much longer do you have? Conclude
9 in three minutes.
10 THE ACCUSED: [Interpretation] Three minutes, I'll conclude in
11 three minutes.
12 MR. KARADZIC: [Interpretation]
13 Q. All right, Doctor. Why did you find it necessary to say that
14 they were members of the SDS
15 and in relation to the death of Dr. Najdanovic?
16 A. Mr. Karadzic, that has nothing to do with their flight from
18 political parties that were being established after the disintegration of
20 Q. How was it that you found out that Sosic and Vukovic were members
21 of the SDS
22 A. I did not say that they were members of the SDS. As a matter of
23 fact, I said that I thought that Najdanovic was a member of the SDS.
24 Sosic and Vukovic worked at the centre and perhaps they were members
25 of the SDS
1 THE ACCUSED: [Interpretation] Can you admit this statement?
2 MR. KARADZIC: [Interpretation]
3 Q. And in the meantime, Doctor, with the permission of the
4 Trial Chamber, I'm going to remind you of an anecdote, as they say: That
5 all Jews and all cyclists are going to be arrested, and people say, why
6 cyclists? See, so nobody asks, why Jews.
7 So you're doing the same thing with the SDS, since you said
8 members -- that they were members of the SDS.
9 A. I have nothing to do with the SDS. I have nothing to do with
10 Professor Najdanovic. I really cannot give you proper answers to that
12 JUDGE KWON: According to our consistent guide-line, we'll not
13 admit this previous statement of Vesna Pagon, which the witness did not
14 confirm any content of the document. It's a third party's document.
15 We'll not admit that.
16 Yes, Ms. Sutherland, did you have something else?
17 MS. SUTHERLAND: I was just going to say that Dr. Karadzic should
18 refrain from making those sorts of comments.
19 JUDGE KWON: I take it you are concluded.
20 THE ACCUSED: [Interpretation] Yes.
21 JUDGE KWON: Do you have any redirect examination,
22 Ms. Sutherland?
23 MS. SUTHERLAND: Yes, Your Honour.
24 JUDGE KWON: How much longer?
25 MS. SUTHERLAND: Five minutes, but I think --
1 JUDGE KWON: I'm not quite sure whether we can continue. We
2 started almost at 20 to. I think we can go on about five minutes. If
3 you're confident in concluding in five minutes, I think we can go on.
4 [Trial Chamber confers]
5 JUDGE KWON: Yes, Ms. Sutherland.
6 Re-examination by Ms. Sutherland:
7 Q. Dr. Mandilovic, Mr. Karadzic put to you, on page 69, starting at
8 line 24 -- he asked you, had you reviewed all of the material shown to
9 you by the Prosecution. And your answer was:
10 "Well, it was very voluminous. I don't know if I've seen
11 everything but I've seen a large part of it, and I stand by what I said."
12 Just to be clear, if we can go to your amalgamated witness
13 statement, which is Exhibit P1217.
14 First of all, were you talking about the documentation, as a
15 whole, the medical records the Prosecution holds or, in particular, the
16 documents that you were particularly shown by the Prosecution?
17 A. I'll tell you very briefly.
18 All the medical documents that you showed me and that the OTP
19 presented to me, I confirmed them and I stand by them. As for the
20 document that appeared here, I'm not sure it was from the OTP or from the
21 Defence. That's why there was a bit of a dilemma. But I did not
22 challenge or contest the validity of the documents at any point. All of
23 the documents were perfectly valid, perfectly proper, with stamps, with
24 the names of physicians, and diagnoses. That is why there was a bit of
25 insecurity on my part. If all of these documents come from the OTP, I
1 reviewed all of them and I stand by them.
2 MS. SUTHERLAND: Thank you, Dr. Mandilovic. I have no further
4 JUDGE KWON: Dr. Mandilovic, that concludes your evidence. Thank
5 you for coming to the Tribunal to give it. Now you are free to go.
6 THE WITNESS: [Interpretation] Thank you, Mr. President.
7 JUDGE KWON: Thank you.
8 [The witness withdrew]
9 JUDGE KWON: Yes, Ms. Sutherland.
10 MS. SUTHERLAND: Your Honour, just one matter --
11 JUDGE KWON: Microphone, please.
12 MS. SUTHERLAND: Sorry.
13 At the beginning of today's session, I took Your Honour to -- I
14 mentioned that Mr. Karadzic had referred to a previous witness's
15 testimony, and I just wanted to take to you that page. And that was
16 page 5351, and it started at line 5.
17 And may I be excused, Your Honour, because we need to make way
18 for Ms. Uertz-Retzlaff, who is taking the next witness.
19 JUDGE KWON: Taking advantage of about two or three minutes, I
20 I'm minded to give a ruling in relation to the motion filed by
21 Mr. Karadzic on 16 July 2010
22 incidents from the testimony of Ekrem Suljevic, who is due to testify
23 later this week.
24 The Chamber has considered the submissions made in that motion,
25 as well as in the Prosecution's response thereto filed on 19th July 2010,
1 to determine whether it should exclude parts of Mr. Suljevic's testimony
2 that go to shelling incidents in Sarajevo in the period relevant to the
3 indictment, but which are not specifically listed in Schedule G to the
5 The accused has noted that the Chamber's decision on the fifth
6 Prosecution motion for judicial notice of adjudicated facts, which
7 declined judicial notice of a number of facts relating to such
8 unscheduled incidents and argues that a similar approach should be taken
9 to the evidence of Mr. Suljevic. However, decisions on the relevance of
10 certain evidence to these proceedings are made on the basis of
11 considerations that are not coterminous with those that apply when
12 deciding to take judicial notice of adjudicated facts.
13 Moreover, as noted by the Prosecution, the Trial Chamber has
14 previously permitted evidence to be led concerning incidents and events
15 in Sarajevo
16 indictment, on the basis that such evidence may go to establishing the
17 necessary general requirements for crimes against humanity or to the
18 elements of some of the underlying offences.
19 The Chamber emphasised that detailed evidence going to specific
20 incidents which are not listed in the indictment or its schedules is
21 unhelpful, as the Chamber would not ultimately be making beyond
22 reasonable doubt findings as to the responsibility of the accused for
23 such specific incidents. Having reviewed the proposed Rule 92 ter
24 statements of Ekrem Suljevic in this light, the Chamber does not consider
25 it necessary or appropriate to exclude parts thereof at this stage.
1 However, it advises the Prosecution to be rigorous in its selection of
2 those exhibits to tender through Mr. Suljevic and to avoid those that
3 provide great amounts of detail about incidents which are not listed in
4 Schedule G of the indictment.
5 With this warning, the Chamber hereby denies the accused's motion
6 to exclude evidence of unscheduled shelling incidents.
7 We'll now rise and we'll have a break for 25 minutes. We'll
8 resume at quarter to 6.00.
9 --- Recess taken at 5.18 p.m.
10 [The witness entered court]
11 --- On resuming at 5.47 p.m.
12 JUDGE KWON: Good afternoon again to all.
13 Welcome to the Tribunal, General Abdel-Razek.
14 If you could take the solemn declaration.
15 THE WITNESS: [Interpretation] I solemnly declare that I will tell
16 the truth, the whole truth, and nothing but the truth. May God be my
18 WITNESS: HUSSEIN ABDEL-RAZEK
19 [The witness answered through interpreter]
20 JUDGE KWON: Please make yourself comfortable, General.
21 Welcome back, Madam Uertz-Retzlaff. It's your witness.
22 MS. UERTZ-RETZLAFF: Good afternoon, Your Honours.
23 Examination by Ms. Uertz-Retzlaff:
24 Q. Good afternoon, sir. Please state your full name.
25 A. Retired Major General Hussein Ali Abdel-Razek.
1 Q. General, you provided statements to the Office of the Prosecutor
2 and also testified here at the Tribunal in the Galic case in 2002; is
3 that correct?
4 A. Yes, correct.
5 Q. Today, we are only concerned with your statement of 16 July 2002
6 and the corrections that you made to that statement at that time.
7 General, have you had opportunity to review this particular
8 statement when you came to the Tribunal this time?
9 A. Yes, I've had that opportunity.
10 Q. Would you say that the statement of 16 July 2002 accurately
11 reflects the evidence you've provided to the Office of the Prosecutor?
12 A. Yes.
13 Q. General, would you provide that same evidence to the Court if
14 questioned on the same matters here today?
15 A. Yes.
16 MS. UERTZ-RETZLAFF: Your Honour, I would like to tender the
17 statement of 16 July 2002
18 Rule 92 ter.
19 JUDGE KWON: Yes, it is admitted.
20 THE REGISTRAR: As Exhibit P1258, Your Honours.
21 MS. UERTZ-RETZLAFF: With the Court's permission, I would now
22 read a short summary of the witness's evidence, as admitted.
23 General Abdel-Razek was commander of Sector Sarajevo of UNPROFOR
24 from 21st August 1992
25 civilian leaders of the warring factions, including the accused, as well
1 as military officials, including Stanislav Galic, the commander of the
3 General Abdel-Razek regularly received reports from UN Military
4 Observers about the constant shelling of the city by Serb forces and of
5 sniping perpetrated against civilians. In addition, the witness himself
6 made observations of random shelling and specific targeting of civilians.
7 General Abdel-Razek and other UN officials frequently protested
8 to Bosnian Serb officials the sniping and shelling attacks; in
9 particular, attacks against the main hospital, the bus station, the
10 market-place, and water lines. UNPROFOR also made written complaints to
11 General Mladic and the accused.
12 Generals Galic and Mladic, as well as Karadzic, Plavsic,
13 Krajisnik, and Koljevic regularly denied that the Bosnian Serbs were
14 responsible for the shelling or sniping. They claimed that the Bosnian
15 government forces shelled their own people to gain support from the
16 international community or that the VRS was only responding in
18 With respect to complaints about sniping against civilians at the
19 airport, in particular, General Galic said that the VRS would continue
20 this practice in order to stop all movements in that area.
21 General Abdel-Razek observed a functioning chain of command
22 within the Sarajevo Romanija Corps, headed by General Galic, who reported
23 to General Mladic. SRK
24 appeared to be professional, well-trained, and equipped.
25 In a meeting requested by the accused after the
1 London Conference, the accused spoke to the witness about future borders
2 and said that Muslims were to be removed from Serb territories and Serbs
3 from Muslim territories. On another occasion, the accused told
4 General Abdel-Razek that the Serbs could not live together with the
5 Muslims any longer. The accused referred to historical events and said
6 that they would not allow this to happen again and that they may not
7 again have such a chance.
8 Krajisnik, Plavsic and Generals Mladic and Gvero were present on
9 that occasion and shared Karadzic's views. The witness also attended a
10 meeting with Krajisnik, Koljevic, and Plavsic, where Krajisnik expressed
11 similar views on the issue of ethnic cleansing.
12 In a meeting on 2nd October 1992
13 General Abdel-Razek raised the issue of the expulsion of 300 Muslims from
14 Grbavica and the removal and detention of three Muslim drivers from a UN
15 convoy. Typical of Bosnian Serb leadership responses to such protests,
16 Plavsic promised to look into these matters, but nothing ever resulted.
17 Your Honour, this concludes the summary, and I will now ask some
18 additional questions and also put some documents to the general.
19 Q. General, you described your training and career in the
20 Egyptian Army from 1964 onwards in your statement. Did your training and
21 career include the use of artillery and combined arms and tactics?
22 A. Yes. I have undergone all basic training in tactics, military
23 tactics, and I am certified as battalion or regiment commander, and I
24 have graduated from the Staff College
25 of qualification. I have participated in military manoeuvres within the
1 Egyptian Army or in combined manoeuvres with other armed forces of other
2 nations. For a while, I was in charge of the combined armed manoeuvres
3 with foreign forces. I was involved in three wars with the Egyptian Army
4 in Middle Eastern conflicts.
5 Q. Did you have experience in peacekeeping activities before coming
6 to Sarajevo
7 A. Yes. Before joining my post in Sarajevo, I was part of the
8 Military Observation Force in Angola
9 monitor the agreement between UNITA movement and the Angolan government
10 before being asked by the Secretary-General of the UN to lead the United
11 Nations forces in Sarajevo
12 Q. Now, in relation to the UNPROFOR mission, can you tell the Court
13 what your main sources of information were and whether they were
15 A. Yes. I asked the -- asked the assistant secretary-general,
16 Mr. Marrack Goulding, when he personally asked me moved to Sarajevo, I
17 asked Mr. Goulding to provide me with some of the information that
18 related to the situation in the former Yugoslavia, especially in the
19 Sarajevo Sector, and he faxed me from New York, to Angola
20 documents that outlined the most recent developments and the situation on
21 the ground in Sarajevo
22 suspension of flights, especially relief flights, to Sarajevo -- into
24 asked me to join -- or to go to Zagreb
25 General Nambiar, who was in command of the forces in Yugoslavia. I also
1 had the opportunity to meet with the ambassador of Serbia to Angola
2 I was able to obtain sufficient information to allow me to start my
3 mission in the country.
4 Q. And during your time in Sarajevo
6 A. According to the procedures of work within the United Nations,
7 there are military observers based in various sectors where the situation
8 was conflictual, and those military observers operated under the
9 supervision of a commander, and this commander of the observer force
10 would communicate with me on the latest developments that occurred in the
11 various sectors.
12 Q. General, you described in your statement your meetings with the
13 military commanders; in particular, General Galic. And you also
14 mentioned that Ms. Plavsic took part in such meeting. Why did she
15 attend, and what was her role during the meetings?
16 A. I'm personally not aware why she was present, that is,
17 Ms. Plavsic. When I used to ask for meetings with General Galic,
18 Ms. Plavsic attended these meetings. And when the meetings took place in
19 several occasions, she used to lead the other side in the interventions.
20 Q. From your observations during the meetings you had with the
21 Bosnian Serb political and military leaders, and from the information you
22 received, did the civilian and the military personnel pursue the same
24 A. Yes, I can say that with certainty. And as I said, when
25 Ms. Plavsic attended, she was leading the other side, an intervention,
1 and she was the main speaker -- the main interlocutor on the other side.
2 And we, the military personnel, only contributed every now and then to
3 issues relating to the military situation, but she led all the
4 interventions from the other side.
5 MS. UERTZ-RETZLAFF: I would ask that Exhibit 10670 be brought up
6 on the screen, please.
7 And as it is coming up: It is a fax from Mr. Goulding to the
8 UNPROFOR Commander Nambiar, in Zagreb
9 London Conference and the agreement achieved.
10 We have here the cover letter. And the next page, please.
11 Q. General, did you have the opportunity to study this document when
12 you came to The Hague
13 A. No, I did not have the opportunity to see this document before my
14 arrival, but I was made aware of its presence by General Nambiar when he
15 received me upon assuming my responsibility. He met with all the sector
16 chiefs, including myself, and he informed me that during the
17 London Conference there was agreement reached with the Serbian side, and
18 the Serbian side had expressed the desire to reach a -- conclude an
19 agreement with the United Nations, and that the United Nations take
20 responsibility of the collection of heavy weapons. But I have not seen
21 that document before my arrival in The Hague this time.
22 Q. And were you aware of what Dr. Karadzic and Dr. Koljevic had
23 agreed upon, as it is stated here in that main paragraph in the document,
24 that is, heavy weapons to be grouped around the four towns, weaponry
25 grouped -- the Bosnian Serb would expect the Bosnian government to take
1 reciprocal action, and so on and so forth? Were you made aware of this?
2 A. In fact, I felt there was optimism within the UN -- within UN
3 circles when Dr. Karadzic declared, following the -- or in the wake of
4 the London Conference, that these heavy weapons would be handed over, and
5 I believe that was on the 11th of the month. And there was indications
6 that we need to get ourselves into a state of readiness to oversee -- to
7 observe the hand-over of these weapons.
8 MS. UERTZ-RETZLAFF: Your Honour, I would request the admission
9 of this exhibit into evidence.
10 JUDGE KWON: Yes.
11 THE REGISTRAR: Your Honours, that will be Exhibit P1259.
12 MS. UERTZ-RETZLAFF: I would ask that Exhibit 65 ter 10622,
13 page 1, be brought up onto the screen, please, in both languages.
14 And as it is coming up: It is a letter from the Sarajevo
15 Romanija Corps Command of 30 August, 1992
16 providing a report about the London Conference on 26 and 27 of August,
18 Q. General, in your talks with the Prosecution personnel the last
19 two days, did you have an opportunity to read this document?
20 A. Yes.
21 Q. It says here, on the first page -- it says here, in the second
23 "... you are obliged to acquaint all members of the units under
24 your command with its content, and especially to pay close attention to
25 the consistent implementation of the recommended measures in the units
1 and commands at the end of the report."
2 General, given your experience as a military commander, are
3 troops pre-briefed in the way described here in this document about
4 agreements made by political bodies? Is that a regular procedure or not?
5 A. In some countries, there is such a policy where military
6 instructions have this political element incorporated into it to make
7 commanders aware of what led to that decision. I would say that there is
8 a possibility such instructions are given, that is to say, political
9 instructions to military commanders, if the situation is very complex or
10 very precarious.
11 MS. UERTZ-RETZLAFF: Can we have the last page, please, in both
13 Q. General, you see here that Assistant Commander General Gvero is
14 signing this report. Did you meet this commander in your talks?
15 A. I would only meet with General Gvero in the presence of
16 General Mladic in the course of the meetings of the joint military
17 committee, whereby senior military commanders from the three sides would
18 meet in the airport under the facilitation or the co-ordination of
19 General Morillon. So that's the only time where I met General Gvero.
20 Q. And in paragraph 8 on that same page, a bit higher up, it says:
21 "Ensure that all measures which the Serbian republic's delegation
22 pledged to carry out or that arise from the conference documents are
23 consistently implemented."
24 General, did you see this order being implemented on the ground?
25 A. In fact, no, and that's why I raised this issue with
1 Mr. Karadzic. And he explained to me, when I met him in Pale, that that
2 was not the case, but he made it clear to me that was not what he
3 intended to say or what he said was misinterpreted, and that the United
4 Nations would only oversee the process, and that the UN would not be
5 involved in handling weapons physically. He said that 11 points --
6 collection points were designated, and that designation of the 11 points
7 would allow the UN to see what's happened in these 11 points. In fact,
8 this did not materialise, and a lot of the issues that we were hoping or
9 would like to have happen did not take -- did not materialise.
10 MS. UERTZ-RETZLAFF: Your Honour, I request the admission of this
12 JUDGE KWON: Yes.
13 THE REGISTRAR: Your Honour, that will be Exhibit P1260.
14 MS. UERTZ-RETZLAFF: Can we now have Exhibit 65 ter 10671 be
15 brought up.
16 And as it is coming up: It is a code cable of General Nambiar to
17 Mr. Goulding of 14 September 1992, and a report attached regarding a
18 meeting with Dr. Karadzic and Colonel Siber.
19 Can we have the -- that's the cover letter. Can we have the next
20 page, please.
21 Q. General, is this a report that you made?
22 A. Yes, I recall that this report existed.
23 Q. Is the report a correct reflection of the meeting that you had
24 with Dr. Karadzic?
25 A. The meeting was shrouded in optimism, to start with, and I felt
1 that we were going to proceed with the collection of weapons. However, I
2 noticed that the Serbian side was determined to retain these weapons, and
3 I remember that they mentioned a reason for that. They said that the
4 Muslim side outnumbered them, and that's why they needed to have the
5 heavy weapons to counter-balance that numerical superiority. And I
6 remember Mr. Karadzic was full of optimism, himself, and he was talking
7 about steps of showing hope of improving the situation. He was talking
8 about providing oxygen cylinders for the hospital. So that's what we
9 were all hoping to achieve after the process.
10 Q. Under B, it refers to Dr. Karadzic's opinion not to have the
11 Egyptian troops involved in the monitoring. Why was that? Did he give
12 you an explanation why?
13 A. This opinion was not expressed to me directly or openly, but I
14 believe he expressed that opinion to General Nambiar.
15 Q. And why was that? Do you know why he had some reservations?
16 A. My understanding from him at a later stage, that had to do with
17 the security situation. He gave the impression that his own people in
18 certain instances would not accept Egyptian troops because of their
19 faith, because of their leanings, and he thought that they would be --
20 they would not be safe being present on Serb territory.
21 MS. UERTZ-RETZLAFF: I would now -- Your Honour, I request the
22 admission of this document.
23 JUDGE KWON: Yes.
24 THE REGISTRAR: Your Honours, Exhibit P1261.
25 MS. UERTZ-RETZLAFF: I would now like to ask Exhibit P1004 be
1 brought up, the first page in both languages.
2 And as this is being brought up: It is an order from the
3 commander of the Sarajevo Romanija Corps, dated 5th September 1992,
4 related to the preparation for a meeting with the political leadership on
5 6 September.
6 Q. General, did you have an opportunity to review this document when
7 you came here in the last two days?
8 A. Yes, I did.
9 MS. UERTZ-RETZLAFF: The second page, please, in the English.
10 The B/C/S is correct as it is now.
11 Q. It refers here to where the meeting is supposed to take place.
12 It says here "Rajska Valley
13 that is --
14 A. Yes, and we did meet once before in this position with
15 Ms. Plavsic and the Serbian delegation.
16 MS. UERTZ-RETZLAFF: Your Honour, this document was admitted in
17 the decision on Prosecution submission on the relevancy of certain
18 documents relating to the testimony of Richard Philipps, dated 9 July
19 2010, a source document. I request the admission of this exhibit into
20 evidence now for all purposes.
21 JUDGE KWON: Thank you for your notice. It well-noted.
22 MS. UERTZ-RETZLAFF: Thank you.
23 JUDGE KWON: And it will be admitted as you indicated.
24 MS. UERTZ-RETZLAFF: Thank you, Your Honour.
25 I would ask that Exhibit P2006 be brought up onto the screen, and
1 the first page in both languages, please. 1006. Did I say something
2 differently? I'm sorry, 1006. I misspoke.
3 And as this is being brought up: It is a document from the
4 commander of the Sarajevo Romanija Corps, dated 12 September 1992, to the
5 corps's rear command post, and it relates to the 6 September meeting and
6 task list.
7 Q. General, did you also review this document while -- during the
8 last two days here in The Hague
9 A. Yes, we did.
10 Q. In paragraph 3 - that's at the bottom in both languages - it
12 "Ensure absolute agreement and unity with the civilian
13 authorities and MUP forces at all levels. Eliminate the creation of any
14 paramilitary units or para-political groups, and eliminate any squabbles
15 because we have the same goal."
16 General, did you observe such co-operation as is requested here
17 on the ground?
18 A. Yes. There were serious attempts that I noted within the
19 Romanija Corps, and they were trying to put control on the paramilitary
20 forces in the region because some of these forces were creating many
21 problems, because they did not enjoy the same level of discipline that
22 military -- regular military forces demonstrate. Some of them acted in
23 light of their own emotions. And, of course, such instructions should be
24 given in order to provide for unity and for lack of discipline or
25 disobedience against orders issued by the commanders.
1 MS. UERTZ-RETZLAFF: And can we have the next page, please, in
2 both languages.
3 Q. And in paragraph 9, it says here:
4 "Study all the requests made by the Sarajevo Romanija Corps
5 commander and the civilian authorities, and do everything possible to act
6 on them ..."
7 General, as a military officer with experience in combat, do you
8 have any comment on the fact that the rear command post is requested to
9 respond to requests of the civilian authorities? Is there something --
10 is that special?
11 A. According to my experience, I can say this was a civil war that
12 took place in residential areas, and I expect that such instructions can
13 be given to military commanders to co-operate more closely with civilian
14 authorities in order to impose control and discipline on different parts
15 of the country. And I can accept that such instructions be given in such
16 a manner.
17 Q. And further on --
18 MS. UERTZ-RETZLAFF: The next page, please, the next page, in the
19 English as well.
20 Q. And here, if we look at paragraph 16, it says here -- it refers
21 here to the Ministry of Interior and the
22 Intelligence/Security Administration, and that they should make a plan.
23 General, do you -- did you see co-operation between the military
24 forces and the police on the ground?
25 A. I cannot say this with certainty because I was not directly
1 involved in the field. However, in some locations I saw a degree of
2 co-operation. And if we take Ilidza, we found, in certain command posts,
3 many military and civilian personnel using the same rationale and acting
4 in accordance with the guide-lines of the leadership. But in other
5 places, we found matters to be completely different and each party did as
6 it willed. Therefore, I cannot say this was specifically the case,
7 because I was not everywhere. I can only speak of those locations that I
8 visited. And I based my impression on what I saw. In some cases, they
9 were in compliance with what we call discipline, and in other places,
10 they were not.
11 Q. And in paragraph 18, it refers here to the behaviour towards the
12 UNPROFOR and journalists. Was that reflected on the ground, this polite
13 and correct behaviour towards UNPROFOR?
14 A. In fact, from the Serbian side and from the other parties, we
15 were met with respect and warm hospitality and good arrangements for our
16 meetings. But as I said earlier, the problem was always in the field,
17 when we went to the field. Many of what -- of the arrangements we put in
18 place and what we agreed on were not strictly adhered to in the field.
19 On the contrary, we found that there was a degree of non-discipline by
20 certain soldiers, certain individuals in the field.
21 MS. UERTZ-RETZLAFF: Your Honour, this is another of the Philipps
22 documents, and I would now like to tender it for all purposes.
23 JUDGE KWON: [Indiscernible]
24 MS. UERTZ-RETZLAFF: I would now ask for Exhibit 65 ter 09083 be
25 brought up on the screen.
1 And as it is coming up: It is an order of Commander Galic to the
2 Sarajevo Romanija Corps, dated 16 November 1992, to all units.
3 Q. And in the first paragraph, it refers to a call from
4 Professor Koljevic, requesting assistance from the SRK in manpower for
5 the Herzegovina
6 we see that the Ilidza Brigade and other units are requested to make
7 fighters available.
8 Did General, did you see this document as well in the last two
10 A. Yes.
11 Q. And as you have mentioned that you met Mr. Koljevic several
12 times, to your knowledge, was he in a position to make requests to the
13 Bosnian Serb Army?
14 A. In fact, I do not know what exactly is the competence of the
15 senior or lower commanders in these forces, but I often discussed with
16 them matters related to civilian affairs. Therefore, this document is
17 very strange for me, to have a command to General Galic in this manner.
18 I believe these matters are up to them, and these were not matters I was
19 involved with. There may be a delegation from the senior command to
20 Mr. Koljevic to present such orders.
21 MS. UERTZ-RETZLAFF: Your Honour, I request the admittance of
22 this document.
23 MR. ROBINSON: Excuse me, Mr. President.
24 I think this one goes outside of your guide-lines, in the sense
25 that the witness really couldn't speak to this.
1 MS. UERTZ-RETZLAFF: Let me then ask a few more questions.
2 Q. Professor Koljevic, which role did he have, to your knowledge?
3 A. Usually, Mr. Koljevic accompanied Mr. Karadzic, and I thought
4 that he always addressed supreme political issues and was not involved in
5 tactical matters and in military matters. And what I find strange in
6 this document is that it is related to a military command, and I would
7 ask: Where is General Mladic, who is the professional person of
8 competence? For the Serbian corps, they should be getting their orders
9 from General Mladic. Therefore, I did not know what exactly were the
10 mandates given to them. This is some matter related to the Serbian side
11 that I was not aware of.
12 Q. An order given by a political leader in this way and responded
13 to, would that be outside the regular chain of command?
14 A. I would say somebody has drafted this report in this military
15 language. Perhaps Mr. Koljevic gave a general -- a broad guide-line, but
16 then military leaders drafted it and he just signed his name. So I do
17 not know how this reached Galic. Was it delivered to him by telephone or
18 in the form of a letter, I do not know exactly. But I would imagine,
19 from the text of these orders, this is a simple military order. It does
20 not require a very high military professionalism. It is just a request
21 for support from this sector to a certain quarter. It does not go into
22 many technical details related to military issues.
23 MS. UERTZ-RETZLAFF: Your Honour, I still request the admittance
24 of this document as evidence. And it relates, in fact, to the evidence
25 of this witness, who has stated here so far of the close co-operation
1 between the military and the political leadership, and, therefore,
2 I think it falls within the guide-lines of this Court.
3 MR. ROBINSON: Mr. President, we do maintain our objection, and,
4 in principle, there's nothing objectionable about the document, itself.
5 And with the proper witness or under other more relaxed guide-lines, the
6 document could be admitted. But if this kind of standard that's being
7 applied to the Defence documents, I think if it's going to be applied
8 equally, this is not a witness who could speak to this. And, in general,
9 civilian and -- any document -- military document which mentions contact
10 with a civilian official is considered to be -- can be admitted under the
11 same kind of argument that Ms. Uertz-Retzlaff has made.
12 JUDGE KWON: Mr. Tieger, did you have something to say?
13 MR. TIEGER: Yes, Your Honour.
14 JUDGE KWON: [Overlapping speakers]
15 MR. TIGER: I was going to say that Mr. Robinson was not here for
16 the entirety of the testimony of Mr. Mandic, during which a battery of
17 documents were presented and admitted with -- well, military documents,
18 in particular, by -- during the course of an examination of a witness
19 who, at various times, purported to have very little information about
20 the military chain of command. I raise that because contrary to
21 Mr. Robinson's suggestion that there's some lack of equality here,
22 documents have been coming in because of some form of contextualisation.
23 I believe this witness has provided more than ample contextualisation in
24 that context. And I believe if Mr. Robinson would take the opportunity
25 to review the entirety of the documentation that was admitted during the
1 course of that examination, he would see that there is no imbalance here,
2 but that this document would properly come in under the same approach
3 that was used previously.
4 JUDGE KWON: What is also important is the consistent application
5 of the guide-line. While the witness testified to the close relation
6 between the civilian authority and the military leaders, he was not aware
7 of this incident, and then he cannot assist the Chamber in relation to
8 this document.
9 Certainly, this document can be a subject of further Bar table
10 motion later on, but as I indicated, to apply the guide-line consistently
11 we'll not admit this at this time.
12 Let's move on.
13 MS. UERTZ-RETZLAFF: General --
14 THE ACCUSED: [Interpretation] May I just say a word, by your
16 JUDGE KWON: I gave our ruling. In relation to this one?
17 THE ACCUSED: [Interpretation] The problem is in the translation.
18 Had it said "appeal" instead of "call," the meaning would have been
19 completely different as for this document. "Appeal," "appeal" is the
20 word that should have been used.
21 JUDGE KWON: Thank you.
22 Let's move on, Ms. Uertz-Retzlaff.
23 MS. UERTZ-RETZLAFF: Yes. Thank you, Your Honour.
24 Q. General, you described throughout your statement meeting with
25 Dr. Karadzic and other members of the Bosnian Serb leadership. During
1 such meetings, what role would Dr. Karadzic have?
2 A. Dr. Karadzic represented the head of the Bosnian Serbs or the
3 head of the party, and he was at the top of the decisions related to the
4 Bosnian Serbs. And, therefore, I always was concerned to meet with the
5 relevant parties to be able to arrive with them at agreements that would
6 facilitate the work of the United Nations, and, through them, to have the
7 decisions reached that would affect those working in the field so that
8 they will co-operate with us in the Sarajevo Sector. He represented the
9 leader of the Bosnian Serbs.
10 Q. And, General, you also mentioned meetings with both Mr. Karadzic
11 and General Mladic in attendance. In such meetings when they were both
12 together, what role would Dr. Karadzic have in such meetings?
13 A. As I said, I would attend these meetings carrying with me a
14 number of points to discuss with them in order to arrive at decisions
15 related to the operations of the United Nations. In some cases, I would
16 take with me certain claims that were reported to me, claims from the
17 other parties, to raise in this meeting and to hear the response. And I
18 would act the role of a mediator, I would play this role, although it
19 wasn't one of my core competences, yet I did this voluntarily in order to
20 help facilitate operations of the United Nations. I tried to build a
21 degree of confidence with the parties in order to be successful in our
22 work in the Sarajevo Sector. Therefore, he was always the spokesperson,
23 and he had his assistants mentioned earlier by me. Some of them would
24 sometimes give some comment, and this is normal. However, the head of a
25 delegation usually consults with his assistants before responding to
1 certain points. Thank you.
2 Q. And did you have opportunity to observe General Galic among his
3 troops? And if so, how would they behave towards him?
4 A. I would notice him at his command centre. I would not go to the
5 field. I would meet him at his headquarters in Lukavica. I know that
6 there matters were run professionally towards command headquarters, and
7 there were officers there who were co-operating with them, and I would
8 describe relations as professional. However, I did not have the
9 opportunity to see him among his soldiers, among the front-lines, or
10 other such places in the field.
11 Q. And did you have an opportunity to observe General Mladic with
12 other generals and his subordinate commanders?
13 A. Yes. Mr. Mladic would come to meetings of the joint military
14 group, surrounded by his assistants, and I would note his strength and
15 control. You can see him as a -- and as a military man, I can judge such
16 matters. I felt him to be a strong man among his assistants.
17 Q. Thank you. Now, a few questions on the Sarajevo shelling.
18 And I would ask that Exhibit 65 ter 10816 be brought up.
19 And as it is coming up: We have here a note for Mr. Thornberry,
20 dated 8 October 1992
21 Do you know who made this note?
22 A. If this is related to Mr. Thornberry, I believe the person
23 concerned is the Civilian Affairs adviser in the sector command. It
24 could be Mr. Adnan Abdel-Razek, perhaps, and there is always a confusion
25 or misunderstanding between our names because we have the same family
1 name. Mr. Adnan Abdel-Razek was an adviser for the sector commander for
2 civilian affairs and within the liaison with Mr. Thornberry. He should
3 send him the report, but he would present the report to me before sending
4 it. Mr. Thornberry would collect his report from the different advisers
5 on civilian affairs, and then it would go to Mr. Nambiar.
6 Q. It says here -- in paragraph 1, it says:
7 "The general mood of Sarajevo
8 that I have seen since last April. The lack of water and electricity,
9 together with the continuing shelling of civilian targets, have pushed
10 people to their edge of tolerance and caused a high degree of despair and
11 aggressiveness. People are lining up to leave the city."
12 General, is that an accurate description of the situation of the
13 people in Sarajevo
14 A. Taking the date into account, I would say, yes, definitely; not
15 only the population, but also the United Nations. Everyone was in
16 despair, for the city was besieged and there was shelling and sniping and
17 roadblocks and killing, and everybody was in this mood. And I found
18 these feelings to be normal, in light of the situation.
19 MS. UERTZ-RETZLAFF: Your Honour, I request the admission of this
21 JUDGE KWON: Yes.
22 MR. ROBINSON: Yes, Mr. President.
23 JUDGE KWON: Just a second.
24 Yes, Mr. Robinson.
25 MR. ROBINSON: We don't object to the admission of the document,
1 but I think it ought to be clarified whether this witness is the author,
2 because since he refers to "last April," and then this witness had only
3 arrived in August, I think it's the other Abdel-Razek who was the author
4 of the document, and that ought to be clarified; although, we don't have
5 any objections since he confirmed part of the document.
6 JUDGE KWON: Did he not clarify that issue?
7 MS. UERTZ-RETZLAFF: I think he said --
8 JUDGE KWON: Yes, he said there was confusion.
9 MR. ROBINSON: Yes, he said there had been confusion among the
10 two of them, but I didn't know that he was specifically directing that to
11 this particular document.
12 MS. UERTZ-RETZLAFF: Yes. The witness actually said that he
13 thinks it was Adnan Abdel-Razek.
14 MR. ROBINSON: Very well.
15 MS. UERTZ-RETZLAFF: I would now ask to show a very brief
16 video-clip, and it is 65 ter --
17 JUDGE KWON: Yes. It is noted in page 108 from line 8. This
18 will be admitted as P --
19 THE REGISTRAR: As Exhibit P1262, Your Honours.
20 JUDGE KWON: Yes.
21 MS. UERTZ-RETZLAFF: A short video, 65 ter 45025 and is -- please
22 be played, it's just a minute duration. And, General, I would like you
23 to look at who you see in that video and whether you know where this
24 is -- what is happening there.
25 Yes, please.
1 [Video-clip played]
2 MS. UERTZ-RETZLAFF: But where's the voice?
3 JUDGE KWON: Are we supposed to hear something?
4 MS. UERTZ-RETZLAFF: Yes, we are supposed to hear Mr. Owen say
5 something in English. Can it be louder?
6 JUDGE KWON: Or shall we try again?
7 MS. UERTZ-RETZLAFF: Yes. I don't -- at least I heard him speak.
8 THE INTERPRETER: Interpreters note that we don't have the
9 transcript of this videotape.
10 MS. UERTZ-RETZLAFF: The interpreter just said that they have the
11 transcript --
12 JUDGE KWON: They don't.
13 MS. UERTZ-RETZLAFF: Oh, they don't. Sorry, I misheard.
14 Okay, then we can't have that.
15 Q. But what you saw here, do you recall what event it is, when you
16 look at the people?
17 A. Yes. I, myself, co-ordinated this meeting upon the headquarters
18 in Zagreb
19 Mr. Karadzic and his aides. I, myself, accompanied them to that meeting,
20 as you can see from the tape. I remember well that was Mr. Owen,
21 accompanied with General Morillon, and I was, myself, representing the
22 United Nations. And from the other side, I remember Mr. Karadzic was
23 there, General Mladic was also present, and Mr. Koljevic, if I remember
24 well, was also present.
25 This visit came as a result of the intensification of shelling
1 and the complication and the exacerbation of the security situation,
2 which culminated in the shelling on the hospital. Mr. Owen visited the
3 hospital and spent some time there and talked to the doctors, and he was
4 briefed by them on the problems faced at the hospital. And he carried
5 from them a message to Mr. Karadzic, and that was the speech that we
6 could not hear.
7 Q. In that speech, did Owen address -- Lord Owen address the
8 shelling and --
9 A. He mentioned that he visited the hospital and he was affected by
10 the situation there, he was touched by the situation, but he was not
11 there to express any opposition as to what happened. He was diplomatic
12 in his words, but he wanted to say that something wrong happened in the
13 situation there which culminated in the shelling of the hospital. We
14 were all affected by the situation. I, myself, visited the hospital, and
15 I saw for myself that the situation was so bad. Mr. Owen also raised a
16 number of other topics, too.
17 MS. UERTZ-RETZLAFF: Your Honour, I think we have to try a bit
18 later, whether we can hear it, because I really want to tender it. But,
19 of course, that's not possible right now.
20 Can we please have Exhibit 65 ter 11350 brought up.
21 And it is an UNPROFOR report from sector commander to the force
22 commander in Zagreb
23 Q. Is that your report about a flour mill damaged?
24 A. I think, yes, there was a lack -- penury of supplies, and I do
25 remember that date very well. And I think there was an appeal for help
1 from the Bosnian side, because they were facing a dire situation because
2 of the penury in food supplies in the city of Sarajevo.
3 MS. UERTZ-RETZLAFF: So I request the admission of this exhibit.
4 JUDGE KWON: Yes.
5 THE REGISTRAR: Your Honour, that will be admitted as
6 Exhibit P1263.
7 MS. UERTZ-RETZLAFF: I would now also try another video. I can
8 only hope this time it works. It's 65 ter 45015.
9 [Video-clip played]
10 MS. UERTZ-RETZLAFF: No, it's -- at least there is a transcript
11 running. Can we start again?
12 [Video-clip played]
13 MS. UERTZ-RETZLAFF: I would like to have played the section
14 00:09:52 to 00:11:25, and we would have to read what is actually here.
15 Your Honours, I just hear we have to come back to this as well
16 tomorrow because there is a wrong clip being used.
17 JUDGE KWON: Very well, thank you.
18 MS. UERTZ-RETZLAFF: Thank you. I'm sorry.
19 I would ask that Exhibit 65 ter 09922 be brought up.
20 And as it is coming up: It is a very urgent order of
21 Commander Galic to all RSK units of 10 October 1992, and -- well, that's
23 MR. ROBINSON: It should be 09122.
24 MS. UERTZ-RETZLAFF: 09122. Oh, yeah, I misspoke. Thank you.
25 Yes, that's the correct one.
1 It is a very, very urgent order, as it says on top,
2 Commander Galic to all RSK units of 10 October 1992 to stop firing on the
3 city of Sarajevo
4 paragraph 2 -- there, it says that for using the heavy artillery,
5 permission from the corps commander or his deputy is needed.
6 Q. General, did you have an opportunity to review this document
7 within the last two days?
8 A. Yes.
9 Q. And if you recall, what was happening on the 10th of October in
11 A. I think that was in the aftermath of the intensive bombing and
12 shelling of Sarajevo
13 civilians. I did raise this question in many of the meetings I held with
14 the other side. I think in October, that October, I noticed that there
15 was intensive shelling at different areas in Sarajevo. I did raise this
17 I think that was an order which was political in nature. I don't
18 think that General Galic issued that order as a result of my protest
19 against it, but I think he received orders from his higher commands.
20 This could have been a result of a protest by Mr. Karadzic, thanks to the
21 letters that I carried, that such an order was issued. As I see and you
22 see, this order called for some kind of a cease-fire, and that in case of
23 need, any forces can resort to the weapons at their disposal.
24 MS. UERTZ-RETZLAFF: Your Honour, I would like to tender this
1 JUDGE KWON: Yes.
2 MS. UERTZ-RETZLAFF:
3 Q. In your statement, you referred also to this --
4 JUDGE KWON: That was admitted as Exhibit P1264.
5 MS. UERTZ-RETZLAFF: Thank you.
6 Q. In your statement, you also referred to Bosnian Serb sniper
7 activities. And from the information you had and from your own
8 observations, were these sniping activities random, or systematic, or
10 A. I did not really understand the question. What I understood is,
11 from a professional standpoint, I think no -- not everyone who carries a
12 gun is a sniper. I think the snipers are chosen among highly-qualified
13 personnel and according to a plan devised by the command, the higher
14 command. Not everyone who carries a gun can be considered a sniper. So
15 the presence of snipers is decided upon a military plan that has been
16 adopted and agreed upon by the military commander.
17 MS. UERTZ-RETZLAFF: Your Honour, I would ask that Exhibit P1010
18 be brought up onto the screen, and it is another of Mr. Philipps'
20 JUDGE KWON: It's a source document?
21 MS. UERTZ-RETZLAFF: Yes, a source document. It is an order of
22 the Deputy Commander Marcetic of the Sarajevo Romanija Corps, of
23 4 November 1992
24 Q. Do you know this Colonel Marcetic?
25 Can we see the signature a bit --
1 MS. UERTZ-RETZLAFF: Can you go a bit further down? Oh, I think
2 in -- yes.
3 Q. That's in the -- in the B/C/S version, you see "Dragan Marcetic."
4 Do you know this colonel?
5 A. Yes, yes, yes. He used to work with General Galic, and he used
6 to attend some of the talks that we held there.
7 Q. And did you have an opportunity to study this document within the
8 last two days? And if so, what is it? For a military man, what is it?
9 A. Please give me some time to look at this document to know what it
10 is. I have seen a number of documents on snipers.
11 As you said, I think that goes along with what I said in the
12 past. I think deploying snipers takes place in accordance with a plan
13 devised by the higher command, and I think this document goes in the same
14 sense that I have already explained.
15 MS. UERTZ-RETZLAFF: Your Honour, I would now like to have this
16 document admitted for all purposes.
17 JUDGE KWON: Yes.
18 MS. UERTZ-RETZLAFF: And --
19 JUDGE KWON: I note the time, Madam Uertz-Retzlaff.
20 MS. UERTZ-RETZLAFF: Yes.
21 JUDGE KWON: How much longer would you be?
22 MS. UERTZ-RETZLAFF: Your Honour, except for the two videos, I
23 have to more documents or -- yeah, two more documents.
24 JUDGE KWON: Then we'll do it tomorrow.
25 MS. UERTZ-RETZLAFF: Thank you, Your Honour.
1 JUDGE KWON: So, General, we'll adjourn for today. We'll resume
2 tomorrow at 9.00.
3 THE WITNESS: Thank you.
4 [The witness stands down]
5 --- Whereupon the hearing adjourned at 7.00 p.m.
6 to be reconvened on Tuesday, the 20th day of July,
7 2010, at 9.00 a.m.