Tribunal Criminal Tribunal for the Former Yugoslavia

Page 21033

 1                           Wednesday, 9 November 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

 5                           --- Upon commencing at 8.32 a.m.

 6             JUDGE KWON:  Good morning, everyone.  I was advised that,

 7     Mr. Robinson, you had something to raise.

 8             MR. ROBINSON:  Yes, Mr. President.  I just would like to put on

 9     the record our objection to the testimony of war correspondent witnesses

10     absent of valid waiver of the privilege.  You've already heard this issue

11     before and decided it but since this witness falls into that category, I

12     just wanted to place on the record our objection.  Thank you.

13             JUDGE KWON:  I'm not quite sure you need to put that on record

14     every time.  It is a given, so to speak.  It is understanding that you

15     have a continuing objection, but the Chamber has ruled upon it.  So if

16     really necessary, I would rather recommend you put in writing instead of

17     taking up courtroom time, Mr. Robinson.

18             MR. ROBINSON:  Very well.  We'll do that.  Thank you.

19             JUDGE KWON:  Thank you for your indulgence.

20             If the witness could take the solemn declaration, please.

21             THE WITNESS:  I solemnly declare that I will speak the truth, the

22     whole truth, and nothing but the truth.

23             JUDGE KWON:  Thank you.  Please make yourself comfortable.

24                           WITNESS:  EDWARD VULLIAMY

25             JUDGE KWON:  It is you, Ms. Sutherland?

Page 21034

 1             MS. SUTHERLAND:  Yes, Your Honour.  Good morning, Your Honours.

 2                           Examination by Ms. Sutherland:

 3        Q.   Please state your full name.

 4        A.   Edward Sebastian Vulliamy.

 5        Q.   Mr. Vulliamy, as we discussed, part of your evidence in this case

 6     is going to be submitted in writing so we first need to deal with the

 7     formalities in relation to that submission.  You testified in the Stakic

 8     case between the 16th and 18th of September, 2002; is that right?

 9        A.   Yes, I did.

10        Q.   You've subsequently had an opportunity to review the transcript

11     of that testimony?

12        A.   Yes.

13        Q.   Can you confirm that that transcript accurately reflects your

14     testimony at the time?

15        A.   Yes.

16             THE INTERPRETER:  Kindly pause between questions and answers for

17     the sake of interpretation.  Thank you.

18             MS. SUTHERLAND:  My apologies to the interpreters.

19        Q.   If you were asked today about the matters that you testified too

20     in the Stakic case, would you provide the same information to the

21     Trial Chamber?

22        A.   Yes.

23             MS. SUTHERLAND:  Your Honour, I tender the transcript

24     65 ter 22504.

25             JUDGE KWON:  That will be admitted.

Page 21035

 1             THE REGISTRAR:  As Exhibit P3777, Your Honours.

 2             MS. SUTHERLAND:  And Your Honours leave, I'll read a summary of

 3     the witness's written evidence.

 4             In 1992, the witness was a journalist for the London based

 5     "Guardian" newspaper.  During the relevant time period he covered the

 6     conflict in the former Yugoslavia.  In early August, 1992, the witness

 7     was among the first group of journalists to visit the Omarska camp.  This

 8     is Schedule C 20.2 and the Trnopolje camp Schedule C 20.4 which are

 9     located in the Prijedor municipality.  The witness testified that the

10     access to these detention facilities, as well as the Kula prison which he

11     visited, was authorised by Radovan Karadzic.

12             On the 3rd of August, 1992, the journalists met Radovan Karadzic

13     in Pale where they were promised access to Omarska camp.  That day, the

14     journalists were taken to visit Kula prison.  This is Schedule 18.2.

15             En route from Pale to Banja Luka, the witness observed extensive

16     damage to the town of Brcko which was deserted and damaged with

17     shell-fire and mortar fire.

18             On the 5th of August, 1992, the journalists were escorted by

19     Major Milutinovic to Prijedor.  The witness saw extensive damage to the

20     houses in Kozarac.  Major Milutinovic explained that 40.000 Muslims

21     "decided to leave the area."

22             The journalists attended a meeting with Serb officials in

23     Prijedor and were then taken to the Omarska camp.  The journalists

24     observed some of the detainees when they were brought to the canteen for

25     food.  The witness describes the condition of some of the detainees as

Page 21036

 1     shocking.  The journalists began to interview a number of the detainees.

 2     The witness describes that when the group of journalists tried to access

 3     the prisoners' sleeping quarters, they were told that although

 4     Radovan Karadzic had authorised a visit to the camp this authorisation

 5     had certain limitations.

 6             The journalists were subsequently taken to the Trnopolje camp.

 7     The witness described in detail the barbed wire fence and behind it a

 8     crowded group of men, many of who were in serious state of decay and

 9     skeletal.  The witness testified to the conditions in the detention

10     facilities and the treatment of the non-Serb detainees in these

11     facilities.

12             After visiting the Trnopolje camp, the journalists left for

13     Belgrade.  On the 7th of August, 1992, the witness's article on the

14     visits to the camps was published.  The witness also described a

15     conversation he had with Nikola Koljevic in Belgrade after news of the

16     detention facilities had been published.

17             Within days of visiting the camps in Prijedor municipality, the

18     witness visited a HOS-run camp with Serb detainees.

19             The witness further described how later, around mid-August, he

20     managed to join a large convoy of non-Serb inhabitants from the

21     Sanski Most municipality who had been forcibly removed from their homes

22     and were being transferred to Travnik.  During the transfer, he witnessed

23     mistreatment, beatings, and the looting of property.

24             In March 1996, the witness interviewed Milomir Stakic and

25     Milan Kovacevic in Prijedor and testified to his observations during

Page 21037

 1     these interviews.  That completes a summary of the witness's written

 2     evidence, Your Honour.

 3        Q.   Mr. Vulliamy, I now have a number questions for you.  When and

 4     where were you born?

 5        A.   I was born in London in 1954, August the 1st.

 6        Q.   What academic qualifications do you have?

 7        A.   High school, after that I got a scholarship to Oxford University

 8     and degree in Valencia in Italy.

 9        Q.   I have a limited number of questions related to the Stakic

10     testimony which is now in evidence.  At transcript pages 7900 to 7903,

11     you briefly summarised your professional work experience after you

12     finished your studies, so I won't trouble you to repeat it here.  I wish

13     to focus first on how you came to visit the camps in Prijedor.

14             You stated at transcript page 7904 that the "Guardian" newspaper

15     which you were working for at the time published an article written by a

16     colleague O'Kane about reports on the Omarska camp.  Did Mr. Karadzic

17     respond to the allegations contained in O'Kane's article?

18        A.   Yes, Dr. Karadzic was in London for a conference sponsored, I

19     think, by the European Union when the allegations were published, and, if

20     you like, invited/challenged us the journalists involved at the

21     "Guardian" and at ITN that he was -- who's guest he was and the programme

22     to come and see for themselves or words to that effect.

23        Q.   Did he also respond directly to the "Guardian"?

24        A.   Yes, he did.  He wrote a letter which was published on, I think,

25     the 30th of July saying that there were no camps holding civilians and

Page 21038

 1     that the allegations in the "Guardian" were wholly untrue.

 2        Q.   If I can refer you to 65 ter 00413, please.  Do you recognise the

 3     document that's on the screen?

 4        A.   That's a printout of the contents of the letter.  I should say,

 5     perhaps, that I didn't see it on publication.  I was on my way to or in

 6     Belgrade by then, but I know the text, yes.

 7             MS. SUTHERLAND:  Your Honour, I tender at that document.

 8             JUDGE KWON:  Yes.

 9             THE REGISTRAR:  Exhibit P3778, Your Honours.

10             MS. SUTHERLAND:

11        Q.   You state at transcript page 7905 that upon your arrival in

12     Belgrade you spoke with Serb and Bosnian Serb officials and that

13     Nikola Koljevic was the main host.  Can you briefly tell the Chamber what

14     was discussed with him?

15        A.   Yes.  We were met by Professor Koljevic who was, as I understand

16     it, Dr. Karadzic's deputy president of the Bosnian Serb Republic,

17     declared republic, and other Serbian officials, and we talked about what

18     we wanted to talk about, our programme, to get to Omarska and Trnopolje

19     as quickly as possible.  They wanted to talk about other things,

20     including, and this was of interest, camps in which Serbs were being held

21     prisoner as well on the other side.  And we were invited to visit other

22     facilities at which Muslims were being held and I went to one of them.

23     We were -- and I -- we were getting impatient.  We thought we were being

24     held up.

25        Q.   At transcript page 7908, you gave evidence that you were greeted

Page 21039

 1     by Dr. Karadzic upon your arrival in Pale from Belgrade via the federal

 2     army helicopter.  I'd like to play some footage now.  This is

 3     65 ter number 40583A.

 4                           [Video-clip played]

 5             "Penny Marshall:  Good morning.  Thank you very much indeed for

 6     bringing us down.

 7             "Karadzic:  Thank you for coming here

 8             "Penny Marshall:  I'm Penny Marshall.

 9             "Karadzic:  Nice to meet you.  We have to make some plan for your

10     journey around Bosnia and Herzegovina.  We would like you to see

11     concentration campuses for Serbian civilians held by Muslim forces in the

12     valley of Sarajevo.  We'll point for you a few points.  Prison then in

13     Tarcin 6 c 20 kilometres from Sarajevo in Silos more than 300 Serbs kept

14     in terrible conditions, all civilians.  You will see our [indiscernible],

15     and then you will say what you want to see all around Bosnia-Herzegovina

16     and we'll make a plan for you to be safe.  What we are concerned about is

17     that Muslim may try to kill some of you in order to blame us.  That's

18     very usual.  They do that.  Just do some atrocities with foreigners, you

19     know, in order to blame Serbs.  They kill their own people in the streets

20     and then they put blame on the Serbs.  So we have to make it absolutely

21     secure for you.  Then we would like to show you Mr. Panic's way

22     [indiscernible] that will probably be tomorrow about noon, in the

23     afternoon.  In Bijeljina, we have arrested 72 independent Serbs who have

24     been disobedient to police or to other.  In this area we have been -- we

25     are arrested all of them and they're going to be [indiscernible], and

Page 21040

 1     then you could proceed to Bosanska Krajina, Banja Luka, if the corridor

 2     is safe.  I think it is safe right now.

 3             "Penny Marshall:  Is that by car or helicopter?

 4             "Karadzic:  I think by car is much better because they could

 5     shoot you by helicopter.  So they can reach 150 -- 1.500 metres.  They

 6     could reach you and kill you.  So we have a corridor and I think it's

 7     safe still, and we'll get you to Omarska.  There you'll join our police

 8     and they'll get you to Omarska.  You wanted to see Omarska and what else?

 9             "Penny Marshall:  Trnopolje.

10             "Karadzic:  Trnopolje, I will ask ...

11             "Penny Marshall:  And Prijedor.

12             "Karadzic:  Yeah, that's all in the area.  I will ask what's in

13     Trnopolje.  In Trnopolje is a kind of a place for stay for people who

14     have no place to stay.  This is -- they are not kept by -- by guards.

15     They just have to eat something and they wait to be displaced somewhere,

16     because their villages have been burnt down.  They're Serbs and Muslims

17     over there too.

18             "Penny Marshall:  Who controls Tarcin?  I mean, how can you get

19     us into Tarcin because Tarcin is controlled by Muslims, isn't it?

20             "Karadzic:  Yes, that's by Muslims.  We can't --"

21             MS. SUTHERLAND:  Stop the tape there.

22        Q.   Mr. Vulliamy, I think we just heard you asking Dr. Karadzic that

23     question there.

24        A.   Yes.

25        Q.   What is the gist of the remainder of the conversation that you

Page 21041

 1     had with Mr. Karadzic?

 2        A.   The conversation carried on over lunch and it covered both those

 3     issues that we -- we -- it developed both those issues we were talking

 4     about.  On the film, the camps that we were intend to see and those that

 5     Dr. Karadzic wanted to us see on the other side and we had a general

 6     conversation over lunch too, which involved discussion of other -- other

 7     things so including literature and stuff, but that was the -- those were

 8     the parameters of the conversation, more or less.  And people came and

 9     went.

10        Q.   At transcript page 7910, you state that you left Pale and went by

11     road to Banja Luka via Bijeljina and Brcko and you had a military escort.

12     Was Koljevic part of the convoy?

13        A.   Yes.  Your Honours, I apologise for the sniffling and the

14     coughing.  It's just how it is.  Yes, Professor Koljevic had been --

15     joined us in Pale, again having been in Belgrade, and he was, I suppose,

16     our main host along the road.  Although not travelling with us in the

17     same vehicle, he popped up for lunch at Bijeljina on the way the place

18     that Dr. Karadzic mentioned in the film where the disobedient Serbs were

19     to be disciplined.  We didn't do any more on that, and then he took us as

20     far as Banja Luka where we arrived on the night of the 4th of August.

21        Q.   At transcript page 7911, you state that the following morning

22     which I think you indicated was the 5th of August, you travelled from

23     Banja Luka to Prijedor escorted by Major Milutinovic and met there a

24     number of persons in the municipal civic centre.  If I can just show you

25     a very short piece of video footage.  This is Exhibit P3542.  And if we

Page 21042

 1     can play from 00:22.

 2                           [Video-clip played]

 3             "Omarska, Trnopolje."

 4             MS. SUTHERLAND:  00:35.

 5             JUDGE KWON:  Microphone.

 6             MS. SUTHERLAND:

 7        Q.   Mr. Vulliamy, do you recognise the people in this shot?

 8        A.   Yes, I -- I did.  It's not with me now again.  Sorry.  Yes.  So

 9     here we are.  We've gone down the chain of command, as it were, Karadzic,

10     Koljevic, Milutinovic, and here we are in Prijedor.  And on the left is

11     Milomir Stakic, who was introduced to us as the president of the

12     municipality and Crisis Staff, and next to him second along from the left

13     looking at the screen is Milan Kovacevic, who was introduced to us as

14     Dr. Stakic's deputy of the municipality, the opstina and of the

15     Crisis Committee.  We go into keep deep shadow here.  I think that's

16     Colonel Arsic there in the middle of the five, introduced to us as the

17     military commander in the region.  Next to him, that's the last man along

18     to the right, is Simo Drljaca, introduced to us as the chief of police in

19     Prijedor.  All of those four members of the Crisis Staff.  And on the end

20     in the pink is Mrs. Balaban whose title we didn't know but she was

21     translating for -- for them at the meeting that was to follow and when we

22     went into the camps -- camp, sorry, in Omarska.

23        Q.   At transcript pages 7913 to 7935, it deals with the meeting --

24     with the meeting that you had with the people that you've just

25     identified.  You said at the conclusion of the meeting that you went

Page 21043

 1     outside and waited there for about 20 minutes or so, and you were then

 2     taken to the Omarska camp.  Did any other journalists join you?

 3        A.   Yes, the meeting went on for quite some time, after which --

 4     during which they wanted us to go to other places, Manjaca, which we

 5     didn't want to go to because it had been visited by the Red Cross.  And

 6     we were then told to go and wait outside, and we did, and talked to some

 7     women lining up at the police station worried about the whereabouts of

 8     their menfolk, and another journalist from the "Times" and a colleague

 9     from "Liberation" of France came along and wanted to join our convoy to

10     my annoyance, professionally speaking, if you appreciate that I didn't

11     want people breezing in on this and they tried to join in, yes.

12        Q.   But were told they couldn't?

13        A.   Yes, the matter was adjudicated by Simo Drljaca that they

14     couldn't and the reason given was they weren't part of Dr. Karadzic's

15     party.  They weren't going at his invitation and on his authority.

16        Q.   At transcript pages 7939 to 7948, you describe your visit in the

17     camp and mention being present in the canteen when detainees came in for

18     food.  Did you interview anyone in the canteen or overhear any interviews

19     being conducted?

20        A.   Well, yes.  The -- I've testified in the -- in the transcripts

21     that have been submitted about what it was like to see those men and be

22     there, so I won't take your time with that.  But, yes, we endeavoured,

23     and perhaps to go back on to something that was said earlier in the

24     introductory remarks, we didn't interview several people.  They were too

25     scared to be interviewed.  Things were done with -- well, the looks of

Page 21044

 1     terror in eyes and things, but, yes, we did interview -- one man only

 2     felt -- was emboldened to speak, who I've seen since, and he told us that

 3     he -- to summarise it:  I do not want to tell any lies but I cannot tell

 4     the truth.  So the -- as it were, in quotations, the interviews you

 5     referred to earlier, there was only one, and really -- and -- but did I

 6     speak to another man.  I asked what -- how he got a wound on the side of

 7     his face.  He said he had fallen over.  I met him since.  He had not

 8     fallen over.  The wound was otherwise inflicted.

 9        Q.   If we could play a short clip from 65 ter number 40168.  And this

10     is starting at 12.19 through to 12.54?

11                           [Video-clip played]

12              "Penny Marshall [voiceover]:  This is all we saw of the

13     prisoners and of Omarska itself.  They never spoke.  The only voices

14     those of the guards ordering them to eat faster and leave.  How are you

15     treated, what are the conditions, I asked?

16              "Unknown person:  I don't want to tell lies.  I can't speak the

17     truth.  Thank you for coming."

18             MS. SUTHERLAND:

19        Q.   And -- and that's your colleague Penny Marshall there in the pink

20     shirt?

21        A.   Yes, that's Penny Marshall in the pink asking the questions.

22     Actually, I was in shot just on the left sitting at the end of that

23     table, yeah.

24        Q.   I now wish to focus on the discussion when you and Penny Marshall

25     and the other reporter, Ian Williams, were trying to get to see the

Page 21045

 1     hangar buildings.

 2             JUDGE KWON:  Before that, the video we just saw, was it marked as

 3     40168B as one of the associate exhibits?

 4             MS. SUTHERLAND:  No, it's -- that will be C.  That will be

 5     40168C.  It's a new clip, Your Honour.

 6             JUDGE KWON:  So are you tendering that, C?

 7             MS. SUTHERLAND:  Yes, Your Honour.

 8             JUDGE KWON:  That will be admitted.

 9             THE REGISTRAR:  Exhibit P3779, Your Honours.

10             MS. SUTHERLAND:

11        Q.   From transcript page 7948 to 7953, a video-tape is played.  In

12     the transcript, it has speaker, speaker, speaker, and what's being said,

13     but it's not clear who's doing the -- the talking.  And, in fact, at

14     transcript page 7952, what is written in the trial transcript is not a

15     full conversation which is actually contained in the English translation

16     which is -- which is attached to 65 ter number 40437, Your Honours.  If

17     he would could play a short video-clip.  And this is 65 ter number 40437,

18     starting at 00:44.

19                           [Video-clip played]

20             MS. SUTHERLAND:  If you could just pause there.

21        Q.   Could you identify the two people who are in that shot, and

22     that's at :49.

23        A.   Yes.  We're trying to get into the hangar at this point, having

24     seen the canteen earlier.  This is Colonel Milutinovic on the left and on

25     the right Simo Drljaca, the chief of police, Your Honours.

Page 21046

 1             MS. SUTHERLAND:  If we could keep playing.

 2                           [Video-clip played]

 3             "They could prove --"

 4             MS. SUTHERLAND:

 5        Q.   If could you stop there.  If you could identify the three people.

 6        A.   The man at the moment talking, gesticulating is called Misa.  He

 7     was from Belgrade, ITN's interpreter and driver.  That's Penny Marshall

 8     nearest us.  And hidden from view at the moment but there is Ian

 9     Williams, who is a reporter also from ITN.

10        Q.   And that's at :52.  Mr. Zeljko Meakic, he's not in this footage

11     but -- but are you able to distinguish him from the others from what he

12     may have been wearing?

13        A.   Yes.  I mean, he was there throughout as well as these other two.

14     He was wearing a beret and I -- comes in and out of the footage at

15     various points.  He's come in and out of the day at various points.  He

16     had been introduced to us as the commander of Omarska itself, if you

17     like, the end of the line down this chain of command.

18             MS. SUTHERLAND:  If we could keep playing the footage, please.

19                           [Video-clip played]

20             "Guilty or not guilty --"

21             MS. SUTHERLAND:  Actually, if you could stop.  If we go to 2:53,

22     please.

23                           [Video-clip played]

24              "I'm sorry.

25              "You must get some orders.  Your wishes are --

Page 21047

 1             MS. SUTHERLAND:  If we could stop there.  If we could rewind that

 2     tape because this -- and if I could ask the interpreters, please, to

 3     interpret what Mrs. Balaban says to Simo Drljaca and what Drljaca

 4     responds, please.  And if we could take it back to 3:01.

 5                           [Video-clip played]

 6             THE INTERPRETER:  Interpreter's note:  We do not have the

 7     time-code in the transcript.

 8             MS. SUTHERLAND:  I'm sorry.  It's at the top of page 4, and it

 9     starts "Red Cross representative" which is how Mrs. Balaban is described

10     in the actual transcript.  And then "guard 2" is how Simo Drljaca has

11     been identified in the -- in the transcript at the top of page 4 of the

12     English.  Do you have that?

13             THE INTERPRETER:  Yes, thank you.

14             MS. SUTHERLAND:  If you could go back to 3:01, please.

15                           [Video-clip played]

16             THE INTERPRETER:  "[Voiceover] "Red Cross representative:  I

17     explained that our protocol allows us to show only certain things and we

18     cannot contravene this, that is, we need to follow orders.

19              "Guard 2:  We cannot.  Yes.  There are -- and they have all the

20     necessary medical care here, so ... yes they can.

21             "Red Cross representative:  You must know we have some orders.

22     Your wishes are ... yes, and your reason is one and our is the other."

23             MS. SUTHERLAND:  Thank you.  And if we can now continue playing

24     the tape.

25                           [Video-clip played]

Page 21048

 1              "Penny Marshal:  Show us where they live.

 2              "Red Cross woman:  Oh, well.

 3              "Male reporter:  Why are you not fulfilling Dr. Karadzic's

 4     promise to us?

 5              "Red Cross representative:  He promised us something else and

 6     said you can do this and this and that and not that.  If they say this is

 7     a protocol of your stay here that will be all.  I'm sorry, that will be

 8     all.

 9              "Male reporter:  So he told you, so he told you not to give us

10     access to the majority of this camp?

11              "Red Cross representative:  I'm just translating.  I'm just

12     trying to do my best.  You have now the chance to go to Trnopolje.

13             "Guard:  Are we going to Trnopolje?"

14             MS. SUTHERLAND:  Thank you.  If we could stop the tape now.

15        Q.   Now, shortly after that you then left for the Trnopolje camp and

16     the video footage of that camp was played at transcript page 7953 to

17     7959.  Was ITN the only TV crew at Trnopolje camp.

18        A.   Yeah.  Yes.  We were bundled out of Omarska.  I mean, the two

19     guards took the safety catches off their guns and things had got very

20     menacing.  Sorry.  Yes, we went to Trnopolje.  No, ITN were not the only

21     crew there.  There had been with us since Pale a crew from the Bosnian

22     Serb television.  It was unclear for the moment whether they were making

23     their own film about the camps or making a film about us then -- ITN

24     making a film about the camps, and there was also another camera which

25     appeared being operated by a man in military fatigues, and actually the

Page 21049

 1     Bosnian Serb TV had military fatigues as well but there was a fourth

 2     camera as well which I now know to be that of an intelligence operative

 3     of some kind.

 4        Q.   Mr. Vulliamy, I'm sorry, I just want to go back to the footage

 5     that's on the screen stopping at 4:03.  If I can just play it through to

 6     4:11.  I'm sorry.

 7                           [Video-clip played]

 8              "Red Cross representative:  Yes, some security reasons are

 9     present here.  If you --"

10             MS. SUTHERLAND:  If we could just stop it there.

11        Q.   Do you see Mr. Meakic in that shot?

12        A.   Yes, that's Zeljko Meakic on the left in the beret.

13        Q.   Thank you.  Now I want to show you another short video and this

14     is from Exhibit P03697.  And if we could play that exhibit, please.

15                           [Video-clip played]

16             THE INTERPRETER:  "[Voiceover] We would like to live here.  We

17     would not like to leave our homes.  Could you convey that message?  The

18     government --

19             "Q.  Government?  There are many governments now."

20             MS. SUTHERLAND:

21        Q.   Do you recognise yourself in that footage?

22        A.   Yes.  I'm at the end there taking notes through the fence.  Yes,

23     that's me, and that, I think -- sorry, do you want me to identify other

24     people or not?

25        Q.   Yes, yes.

Page 21050

 1        A.   Yes.  I think the man talking on the microphone at the beginning

 2     is the reporter, I think, from the Bosnian Serb television, and that's

 3     Penny Marshall there in the pink again, and that's the two of us taking

 4     notes through the fence, interviewing the prisoners in the compound.

 5        Q.   I want to show you another short video and this is from

 6     65 ter 40168 and this will be part D.  If the footage can run from 14:11?

 7             THE INTERPRETER:  Interpreter's note:  Could we please have a

 8     page reference.  Thank you.

 9             MS. SUTHERLAND:  There won't be any need for the transcript.

10                           [Video-clip played]

11              "They promised to show us the second camp Trnopolje where 2.000

12     refugees are living.  We were not prepared for what we saw and heard

13     there."

14             MS. SUTHERLAND:  If we could stop that there and that's at 14:26.

15        Q.   Do you recognise anyone in this shot?

16        A.   Yes.  I recognise Fikret Alic shaking Penny Marshall's hand

17     through the wire and others I know by sight but not by name.

18        Q.   But did you interview Fikret Alic that day?

19        A.   Yes, I did.

20        Q.   And what did he tell you?

21        A.   He told us that this group -- he told me that this group had

22     arrived, this group in the compound that we can see had arrived at

23     Trnopolje that morning from another camp, the name of which was new to

24     me, Keraterm, and he and others talked about a terrible night in Keraterm

25     when something like between 130 and 150 people were killed in one night.

Page 21051

 1     This young man Fikret Alic said that he had been tasked to be part of the

 2     dispatch loading the bodies up onto the -- with bulldozers onto trucks

 3     but that he had broken down and not been able to -- in his place taken by

 4     an older prisoner.  And there was a conversation with some of the other

 5     men about their arrival from these -- mostly from Keraterm, but I

 6     understood some had come from Omarska as well that very day.

 7        Q.   Could we then play from 17:25 to 17:32, please.

 8                           [Video-clip played]

 9              "No one we spoke to knew why they had been brought here, whether

10     they were prisoners, refugees, or what lay in store for them."

11             MS. SUTHERLAND:

12        Q.   Mr. Vulliamy, you see the barbed wire and other types of wire.

13     Was this how it was?

14        A.   Yes, they were in a compound, and it was a guarded compound, as

15     we can see, and they'd come from these other camps that morning.  And it

16     was for us, really, to try and ascertain why, which I, in part, did that

17     day.  It was very chaotic in Trnopolje and was able to establish

18     definitely later, a few days later, when, as you said in your summary, we

19     went over the mountains in the convoy of deportees because these people

20     were here for enforced deportation, and we accompanied them to illustrate

21     that.

22        Q.   You stated at transcript page 7959 that you went into the medical

23     centre and met with Dr. Idriz Merdzanic.  Who else was with you?

24        A.   In the -- well, it's called the medical centre.  They had to

25     scavenge for their medicines.  None were provided, although the Red Cross

Page 21052

 1     was there.  In the medical centre was Idriz Merdzanic, and another

 2     assistant of his -- or a colleague, I should say, of his, Azra Blazevic,

 3     who was a vet, using her medical abilities as best she could help.  And,

 4     well, the ITN crew was there.  I was by the door while Dr. Merdzanic was

 5     interviewed.  And patients coming in and out.  Other orderlies in there

 6     too.

 7             MS. SUTHERLAND:  If we could show a short clip.

 8     65 ter number 40168 and start it at 6:53 and stop at 7:40, 7:44.

 9                           [Video-clip played]

10              "... the camp.  The pictures show severe injuries, apparently as

11     a result of beatings.  In the makeshift medical centre, there were cases

12     of scabies, malnutrition and diarrhoea.  Local doctors said they were

13     chronically short of medicines and drugs.  Among them was a Muslim

14     doctor.  We asked him whether there had been any cases of beatings.

15             "Yes.

16             "Many?"

17             MS. SUTHERLAND:

18        Q.   And you were there while that was being filmed?

19        A.   Yes, I'm just standing in the doorway.

20             MS. SUTHERLAND:  Your Honour, I tender those portions of -- and I

21     think Mr. Reid has ...

22             JUDGE KWON:  Both of them are under D?

23             MS. SUTHERLAND:  No.  Mr. Reid would rather they were

24     individual -- be given individual alphabetical numbers at the end of each

25     of the separate clips.  So ...

Page 21053

 1             JUDGE KWON:  So the footage of Mr. Fikret Alic was 40168D will be

 2     admitted as Exhibit P3780, is this correct?

 3             MS. SUTHERLAND:  Yes.

 4             JUDGE KWON:  And the footage of makeshift -- so-called makeshift

 5     medical centre will be --

 6             MS. SUTHERLAND:  Sorry, there's one in between that.

 7             JUDGE KWON:  Oh, yes.

 8             MS. SUTHERLAND:  The barbed wire.

 9             JUDGE KWON:  Very well.  That will be admitted as Exhibit P3781.

10             MS. SUTHERLAND:  Yes.

11             JUDGE KWON:  And the last one admitted as Exhibit 3782.

12             MS. SUTHERLAND:  Thank you, Your Honour.

13        Q.   So, Mr. Vulliamy, from Trnopolje did you return immediately to

14     Belgrade?

15        A.   Yes.  We decided to return because I think -- I think the plan

16     had been for us to remain in Banja Luka, but the ITN translator/driver,

17     Misa, whom I pointed out, inferred that we were not safe.  Things had

18     gotten quite acrimonious between us and our hosts by then and we elected

19     to get back to Belgrade as soon as possible and, well, to communicate

20     with our offices, really, because we needed to know what to do with the

21     material we had and so we went back to Belgrade that night.  This was the

22     time before any kind of mobile communications [indiscernible].

23        Q.   And at transcript page 7977 to 7979, you mention having English

24     tea with Professor Koljevic and that he made a rather barbed joke at the

25     expense of the media in the world?

Page 21054

 1        A.   Yes, it was a valid one too.  Professor Koljevic was a professor

 2     of English and an Anglophile and he invited me to tea at the Hyatt Hotel,

 3     and his joke was, sort of, that it took us -- it took us so long to find

 4     these camps.  He joked that they were so near Venice, and he had a joke

 5     at my and our collective expense that all we cared about was the siege of

 6     sophisticated Sarajevo and how long it had taken us to find these camps

 7     and I -- I thought, in a rather dark way, he had a point, to be honest.

 8        Q.   I want to show you another short video.  This is the final video

 9     I will show you.

10             MS. SUTHERLAND:  It's 65 ter number 40154 and this is from point

11     57:29.

12                           [Video-clip played]

13              "Anchorman:  Dr. Karadzic, the Serb president of Yugoslavia, Mr.

14     Panic has said that he's ordering you to shut camps like Omarska and

15     Trnopolje within 30 days.  Can you do that?

16              "Karadzic:  I can do that even within two days if Muslim side

17     accept our proposal of exchange of war prisoners on the type 'all to

18     all.'  We have offered many times to Muslim side that kind of thing and

19     they didn't accept.

20              "Anchorman:  So what you're saying is it's most unlikely that

21     his will happen?

22              "Karadzic:  No.  If they don't accept, we will quit those

23     prisoners, prisons; these are really not camps, these are prisons, but

24     anyway we'll treat them, we'll release all of those people, no matter

25     they are war prisoners, no matter they are going to attack us again

Page 21055

 1              "Anchorman:  Now, you know the outcry that there has been

 2     following ITN's reports.  We couldn't see all of the camp in Omarska.

 3     You say the people there in the camps running them are undisciplined.

 4     Therefore, would you agree now to go back to that particular camp with

 5     our reporter Penny Marshall so that we can see everything there with you

 6     guiding us round?

 7              "Karadzic:  Yes, absolutely.  Would I like to join you there,

 8     because I would see what people are disobedient and who is responsible

 9     for so much -- so few food that people get.  I know that all people don't

10     have enough food but still prisoners would have at least two meals a day.

11              "Anchorman:  So that is a promise from you.  You are ready to go

12     with our reporter straight away to that --

13              "Karadzic:  Absolutely, that's my duty.  That's our duty to make

14     people suffer as less as we can do.

15              "Anchorman:  And so the challenge is taken up.  You will go with

16     us - what - within the next 24 hours?

17              "Karadzic:  Twenty-four hours.  It may happen also within 24

18     hours.

19              "Anchorman:  Well, we would like to hear you say very clearly,

20     Dr. Karadzic, that you will go within 24 hours.

21              "Karadzic:  You can go within 24 hours, and I hope I could -- I

22     could make it for myself within 24 hours because we have big Muslim

23     offensive in city of Sarajevo.  Very, very heavy fights today going on.

24              "Anchorman:  Very well.  The suspicion must be that where our

25     cameras are not allowed to go, and perhaps in other places, that terrible

Page 21056

 1     things are happening.  There's talk of allegations that have been made of

 2     beatings, executions or whatever.  Are you sure, yourself, that these

 3     things are not happening in camps run by Serbs, Bosnian Serbs?

 4              "Karadzic:  We have 13 prisons and the prison of Omarska is the

 5     worst one.  And we wanted these journalists to see the worst one not to

 6     see the best one in order to help people and in order to show all the

 7     faces of this terrible civil war which was caused by premature

 8     recognition of Bosnia and Herzegovina for what is very responsible

 9     European Community.  We are ready to open any corner of this country, any

10     prison of this country to Red Cross.  It was invited by me this morning

11     and to any journalist and to any international commission.

12             "Anchorman:  Dr. Karadzic in Belgrade, thank you very much

13     indeed"

14             MS. SUTHERLAND:  Thank you and that stops at 1:00:46.

15        Q.   Mr. Vulliamy, you've reviewed this footage since you've been in

16     The Hague.  Have you seen it before?

17        A.   No, I hadn't.

18        Q.   Are you able to place a date on with when it was broadcast?

19        A.   It's obviously an immediate reaction to -- to the outcry that

20     followed ITN's initial report.  I was, by then, on my way to the other

21     side to see where the Serbian prisoners was -- were being held as charged

22     by Dr. Karadzic.  So it would be either August the 7th or the 8th that

23     would be corroborated.

24        Q.   Mr. Karadzic made a number of comments.  He said that Omarska was

25     the worst camp.  Is this how he described it to you when you had met him

Page 21057

 1     in Pale a few days earlier?

 2        A.   No, it wasn't at all how he described Omarska and -- but as it

 3     turned out following my subsequent inquiries, he was right, I think.  It

 4     was terrible.

 5        Q.   And when you say subsequent to your inquiries, what are you

 6     referring to then?

 7        A.   Well --

 8        Q.   Besides the visit I'm talking about?

 9        A.   Yes, I don't know how much of this is in interest to the Court,

10     but I've been working on this on and off or the past two decades.  That

11     was 19 years ago, and I have met many of the former inmates since Omarska

12     and Trnopolje.  I've think I've interviewed -- I should -- well, if not

13     hundreds scores of them, and, yes, I think Dr. Karadzic's assessment is

14     probably right that of the camps that were being - where he calls them

15     prisons, I call them camps -- being held by the Bosnian Serbs, Omarska

16     was -- was the worst, it seems, from the things that were happening in

17     there that I've been able to decipher and hear from the survivors,

18     otherwise -- but that's hearsay.  I'm at your disposal on that.  And --

19     and certainly his remarks in that film did seem to confirm the impression

20     given when we met him in Pale, as you're asking me, that he had

21     authority.  I mean, he says:  Well never mind 30 days, I can close them

22     within two.  And that was certainly the impression we had in Pale that we

23     were going there on his authority.

24        Q.   And you're aware of journalists who visited the camp again?

25        A.   I can't testify to that.  I know that a great media circus

Page 21058

 1     descended on the camps, especially Trnopolje, because I've seen lots of

 2     footage on that on August the 7th, 8th, 9th-ish I wouldn't know, because

 3     however it may sound now, I took Dr. Karadzic's remarks seriously when we

 4     were talking in Pale, and by the -- on the day of August the 8th, I think

 5     it was, early in the morning or late on the 7th, I was heading round to

 6     the -- you can't cross lines.  I was driving through Hungary to go over

 7     to the other side to make inspections and to endeavour to get into camps

 8     where Serbian prisoners were being held which I did, so I wasn't actually

 9     there when the media circus descended on -- on Trnopolje and Omarska, but

10     certainly there were a large number of them went back, I mean, the sort

11     of -- by which time, as I understand from the films, the places had been

12     changed quite a bit, and I've certainly done a lot of interviews with

13     survivors of Omarska about how that place was part emptied out and part

14     cleaned up in readiness for these visits, as was Trnopolje.

15        Q.   If -- and then finally, you interviewed Dr. Kovacevic in 1996

16     along with Dr. Stakic, and this is in your Stakic transcripts.

17             MS. SUTHERLAND:  If I could have 65 ter number 19691.

18             JUDGE KWON:  Before that, I'm minded to tender that video-clip.

19             MS. SUTHERLAND:  Oh, yes, Your Honour.

20             JUDGE KWON:  That's the ITN interview with Mr. Karadzic.

21             MS. SUTHERLAND:  Yes.  That will be 4 -- that's 65 ter number

22     40154C.

23             JUDGE KWON:  That will be admitted.

24             THE REGISTRAR:  As Exhibit P3783, Your Honours.

25             JUDGE KWON:  And, Ms. Sutherland, I remember that you showed us

Page 21059

 1     the original video-clip that -- in which Mr. Karadzic gave some general

 2     introduction to the journalist.

 3             MS. SUTHERLAND:  Yes, Your Honour.

 4             JUDGE KWON:  Which was 40583A --

 5             MS. SUTHERLAND:  Yes, Your Honour.

 6             JUDGE KWON:  -- which hasn't been admitted, will now be.

 7             MS. SUTHERLAND:  Thank you.

 8             THE REGISTRAR:  That's Exhibit P3784, Your Honours.

 9             MS. SUTHERLAND:  And then Mr. Reid advises me that there were two

10     other clips played from 65 ter number 40437.

11             JUDGE KWON:  Mm-hmm.  40437, yes.  That will be admitted as well.

12             THE REGISTRAR:  Exhibit 3785, Your Honours.

13             MS. SUTHERLAND:  Thank you, Your Honour.

14        Q.   And finally, Mr. Vulliamy, can you recognise this document that's

15     coming up on the screen, please?

16        A.   Yes, that's a typewritten transcript of the conversation with

17     Dr. Kovacevic in 1996.  I went back with a colleague from "The New York

18     Times" to see him and Dr. Stakic and Dr. -- and Professor Koljevic and we

19     endeavoured to see Simo Drljaca, who refused to see us.

20        Q.   And that's dealt with in your Stakic transcript?

21        A.   Yes that's --

22        Q.   [Overlapping speakers]

23        A.   -- exhibited that we've [indiscernible]

24             MS. SUTHERLAND:  Your Honour, I tender these notes.

25             JUDGE KWON:  Yes.

Page 21060

 1             THE REGISTRAR:  Exhibit P3786, Your Honours.

 2             MS. SUTHERLAND:  And thank you, Mr. Vulliamy.  I have no further

 3     questions, Your Honour.

 4             JUDGE KWON:  Shall we deal with the remaining associate exhibits,

 5     Ms. Sutherland.

 6             MS. SUTHERLAND:  Yes.

 7             JUDGE KWON:  You are tendering 65 ter number 19683 and 19684.  I

 8     think there are some confusion in uploading the -- in e-court.  Should we

 9     upload 19683 first.  It's 65 ter number 19683.  It says it's allegedly a

10     copy of relevant parts of the book "Seasons in Hell."

11             MS. SUTHERLAND:  Your Honours, pages 8 and 9 and pages --

12             JUDGE KWON:  But we'll see.  What I think what is uploaded is

13     different.  I think this is a duplicate of --

14             MS. SUTHERLAND:  [Overlapping speakers]

15             JUDGE KWON:  -- 65 ter number 19685.

16             MS. SUTHERLAND:  Yes, Your Honour, you're correct.

17             JUDGE KWON:  Can we upload 19684 then?  This is the copy of

18     "Seasons in Hell."

19             MS. SUTHERLAND:  Yes, Your Honour, and that is at 19683 and it's

20     also at 19708.  19708 is excerpts of chapter 5 of the book written by

21     Mr. Vulliamy, and the excerpts that were tendered in Stakic were pages 98

22     to 107.  And, in fact, at 19683, that includes pages 100 to 101 so

23     they're actually included in 19708.  So we would simply need to tender

24     pages 8 and 9 and then pages 98 to 107, and I will ensure that those are

25     uploaded into e-court.

Page 21061

 1             JUDGE KWON:  In one number or in two separate numbers?

 2             MS. SUTHERLAND:  Your Honour, I'm just wondering in order to make

 3     sense of the Stakic transcript ...

 4             JUDGE KWON:  Very well.  Into --

 5             MS. SUTHERLAND:  [Overlapping speakers]

 6             JUDGE KWON:  -- two separate numbers.

 7             MS. SUTHERLAND:  We were to keep them separately.

 8             JUDGE KWON:  And there are in relation to notes taken by the

 9     witnesses during the interviews of Dr. Kovacevic and Dr. Stakic, you

10     already tendered 19691, but both of them have several 65 ter numbers.

11             MS. SUTHERLAND:  Your Honour, it's -- what has a lot of 65 ter

12     numbers, and this is on page 4 of the 92 ter notification filed on the

13     2nd of November, are the actual shorthand notes that Mr. Vulliamy read

14     into the record and Judge Schomburg required that they were read page by

15     page by page, and so unfortunately then they were given this one, one,

16     two, three, four, five -- eight different 65 ter number in our case.  In

17     fact, they could be given one for each of those shorthand notes, for

18     Dr. Kovacevic interview and Dr. Stakic interview, and then of course, we

19     have the -- also the typewritten version which the Stakic typewritten

20     notes were an associated exhibited, and I just tendered this morning the

21     typewritten notes of Kovacevic meeting.

22             JUDGE KWON:  We will admit them in one document per -- for -- per

23     interviewees.

24             MS. SUTHERLAND:  Yes.

25             JUDGE KWON:  One further questions you tendered 40168C until F,

Page 21062

 1     but I'm not sure the 40618B has been uploaded into e-court.

 2             MS. SUTHERLAND:  I'm sorry, Your Honour, can you repeat that

 3     number again.

 4             JUDGE KWON:  40168B.

 5             MS. SUTHERLAND:  Yes.

 6             JUDGE KWON:  No, it's not in the e-court.  Could you release it?

 7             MS. SUTHERLAND:  Yes.  Mr. Reid will release it.

 8             JUDGE KWON:  And I'm not sure whether it's 65 ter number 40438

 9     has been also uploaded in the e-court.  So while you will see to it,

10     that, I'm asking Mr. Robinson whether Defence has any objection.

11             MR. ROBINSON:  No, Mr. President.

12             JUDGE KWON:  Very well.  Then subject to those -- or the

13     supplementation, those will be admitted into evidence.

14             MS. SUTHERLAND:  Thank you very much, Your Honour.

15             JUDGE KWON:  And will be given numbers in due course.

16             MS. SUTHERLAND:  Thank you.

17             JUDGE KWON:  Well, Mr. Vulliamy your evidence in lieu of

18     examination-in-chief has been admitted in written form and now you will

19     be further asked by Mr. Karadzic in his cross-examination.

20             THE WITNESS:  Thank you, sir.

21             JUDGE KWON:  Yes, Mr. Karadzic.

22             THE ACCUSED: [Interpretation] Good morning, Your Excellencies.

23     Good morning to all.

24                           Cross-examination by Mr. Karadzic:

25        Q.   [Interpretation] Good morning, Mr. Vulliamy.

Page 21063

 1        A.   Good morning, Dr. Karadzic.  Dobro jutro.

 2        Q.   Dobro jutro.  Thank you.  Good morning.  I would like to us to

 3     take advantage of the fact that you wrote this book, so let us briefly go

 4     through the book.  Let us look at some parts of your book.

 5             THE ACCUSED: [Interpretation] So could we please have this in

 6     e-court.  04807, 1D04807, 1D.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   Now, page 4.  So this is the cover of your book, isn't it?  I

 9     wanted to ask you about this dedication.  This book of yours, is it

10     dedicated to the victims of Bosnia-Herzegovina, and can you tell us which

11     one of these is a Serb?

12        A.   Am I reading off -- is this an accurate translation on my screen?

13     I'm hearing nothing.

14             JUDGE KWON:  Could you check.

15             THE WITNESS:  Doesn't matter because I can read it.  The answer

16     is none, sir.  I can hear anything, but I can read it.

17             JUDGE KWON:  No, you should hear that.

18             THE WITNESS:  I can hear myself, but I couldn't hear

19     Dr. Karadzic.

20             JUDGE KWON:  Mr. Karadzic, could you repeat your question, just

21     in case.

22             MR. KARADZIC: [Interpretation]

23        Q.   Well, this was my question:  Since you dedicated this book to the

24     victims in Bosnia-Herzegovina, I was interested in hearing which one of

25     these was a Serb?

Page 21064

 1        A.   These are individual dedicatees.  None of them is Serbian.  I

 2     wasn't able to work on the Serbian side during the first year of the war

 3     covered by this book because I wasn't given permission after we went over

 4     on the convoy.

 5        Q.   Thank you.  Can we have a look at page 7 in e-court.  The next

 6     one.  The next one.  I would like to draw your attention to the shadowed

 7     part.  What you say there is that you will be accused of being

 8     pro-Muslim, whatever that means.  Could you please take a look at that.

 9        A.   Yes, I can see it.  Thank you.

10        Q.   Do you really think that's the way it was?  Do you really think

11     that you managed to maintain your objectivity?  Do you really think that

12     these accusations are unfounded?

13        A.   Yes, I'm grateful to you for raising this.  The word I should

14     have used there is neutral, that we remain neutral over the most

15     appalling racialist violence.  I have been ask by this before, and I

16     think it's in the transcripts that Your Honours have.  Objectivity -- and

17     I can see it a mistaken word here.  I should have said we remain neutral.

18     Where something is fact specific, I remain objective.  I mean, if you go

19     into a house and you see six bodies, it's not 12 because they're Muslim

20     or 3 because they're Serbs or whatever it's -- it's six.  What I am

21     saying here, and I stand by it, is that I make -- I do not attempt to try

22     and be neutral.  I'm not neutral between the camp guards and the

23     prisoners, between the raped women and the rapists, and I don't -- I

24     can't in all honesty sit here in court and say that I am or want to be

25     or -- or -- can be neutral over this kind of violence and when I had --

Page 21065

 1     this book is about the first year of the war, and it takes us from the --

 2     the camps, the discovery of the camps, the corralling and enforced

 3     deportation over the mountains, and the second part is to do with, if you

 4     like, a different part of the war involving the Bosnian Croats, and I do

 5     not claim to be neutral over the sort of violence I was witnessing.

 6        Q.   Thank you.  I'm interested in this particular wording, racialist

 7     violence.  Do you think that we had quarreled there on the basis of

 8     racial differences?  Do you know that Serbs believe that Muslims are also

 9     Serbs who converted to Islam and that is what Lord Owen thinks as well?

10        A.   I heard the Muslims of Bosnia-Herzegovina or Bosniaks, or

11     whatever we were going to call them, often referred to as Balija, which

12     equates as, sort of, filthy Gypsy, but the -- who converted to who to

13     what religion or what Lord Owen things is really of -- well, it's for

14     Your Honours to ask Lord Owen, I suppose, but what I -- the reason I used

15     the word "racialist" was because it seemed to me pretty clear, very

16     clear, that the -- in the camps the inmates were either Bosnian Muslims

17     or Croats and that the guards and the people running them were Bosnian

18     Serbs, and in the latter part of the book which perhaps doesn't concern

19     you so much but did me, it was very much the heraldry and insignia of

20     Croatia or of Herzegovina, I should say, perhaps that was being used in

21     this violence.

22             Certainly the iconography in the name which this appalling

23     violence was taking place was very much Serbian, and I do concede that

24     there was violence on the other side as well in the name of the Muslim

25     side, but I think that if you -- where I come from, if one self-defined

Page 21066

 1     ethnicity seeks to obliterate or to clear the territory of all members of

 2     another ethnicity and to obliterate any memory of them, that is

 3     racialism.

 4        Q.   Thank you.  We'll get to that.  I wanted to ask you whether you

 5     know that George Kenney does not belong to this group.  He is a harsh

 6     critic of his own government and the West because of their partiality,

 7     vis-a-vis the Muslim who is abused that?

 8        A.   Yes, I met George Kenney during the writing of this book and I'm

 9     aware that he changed -- he changed his position on things.  I haven't

10     spoken to him since.

11        Q.   Thank you.  Can we have the next page now.  Page 12, could we

12     have that in e-court.  Seven in e-court.  I apologise.

13             On the right-hand side, could you please take a look at where it

14     says "Bosnia-Herzegovina" and then "Greater Serbia."  So you proceeded

15     from the celebration of the 600th anniversary of the battle of Kosovo.

16     Do you really think that that's the way it was, that there were only --

17     that there were almost 2 million drunkards there and that this was a

18     problematic speech made by President Milosevic.  The Western politicians

19     at the time considered him to be moderate.  You refer to that event as

20     the beginning of all of these developments.

21        A.   I think most of the coverage -- I wasn't there.  Most of the

22     coverage sees that speech as being an important rallying cry.  As regards

23     the alcohol there seems to be little doubt about that, unless I'm to be

24     corrected.  And I think that was in -- in all the written accounts I've

25     read of the -- the rise of President Milosevic, that was seen as a -- as

Page 21067

 1     a -- as a moment whereby he connected very much to -- to the people and

 2     began this change of the language of Marxism of which his party had

 3     hitherto been an adherent to a more nationalistic and more aggressively

 4     nationalistic politics, and that he -- I won't say used, but that this

 5     was -- this particular speech at this moment was in all the writing

 6     I've -- I've read.  And, by all means, call the historians themselves

 7     that there was a converge on the opinion that this was an important

 8     moment.

 9        Q.   Thank you.  However, did you notice that at the time, not

10     historians later, but at the time Western analysts and politicians

11     consider this to be a moderate speech?  Also, statesmen from all the

12     Yugoslav Republics were present there.  They sat in the first row.

13        A.   I have no doubt they were all there.  Yugoslavia was still

14     Yugoslavia then, and no doubt many Western -- people in the West did

15     think Milosevic was moderate.  Some of them still do.  What ensued and

16     from this speech and his Presidency I -- I -- I don't regard as moderate.

17     For what it's worth.

18        Q.   Thank you.  So do we agree that this bit about drunkards, alcohol

19     in general, that that's a bit of an exaggeration?

20        A.   I haven't read a -- as it were, a sort of a -- a piece of

21     reportage about the rally that then include reference to people having a

22     few drinks.  I'm not saying it's such a bad thing.  It's just what

23     apparently happened.

24        Q.   Thank you.  Can we have pages 66 and 67 in the book, but it's

25     page 8 in e-court.  The previous one, actually, please.  Yes, that's it.

Page 21068

 1             Could you please take a look at the right-hand side where you

 2     speak about Mr. Izetbegovic.  This is what you say and I'm going to read

 3     it out in English:

 4             [In English] [As read] "Izetbegovic was determined to keep

 5     Bosnia-Herzegovina as a unitary multi-ethnically republic.  The secretary

 6     sectarian exclusively Muslim SDA was hardly the way to achieve it.  And

 7     Izetbegovic put a second blot on his -- his [indiscernible] soon after

 8     becoming president of the republic.  In March 1991, the Portuguese

 9     presidency hosted a meeting of EC leaders in Lisbon to discuss dividing

10     Bosnia-Herzegovina into regions in which the three ethnic groups would

11     enjoy spheres of influence.  It was partitioned with a sugar coating and

12     enthusiastically agreed to by Tudjman and Milosevic.  Izetbegovic, with a

13     shortsightedness that has baffled his people ever since, opened the door

14     to the thin end of ...," [Interpretation] could we have the next page,

15     [In English] "... the wedge and backed the idea.  Two days later he was

16     forced to eat crow, apparently realising his blunder and with

17     characteristic naivety withdrawing his acceptance of the EC's Greek rift.

18     Despite his Muslim nationalism, Izetbegovic was -- has argued from the

19     outset that Bosnia cannot be ethnically partitioned because it is

20     impossible without ethnic cleansing.  Our ethnic map is intermingled like

21     a Jackson Pollock painting.  There are no ethnically pure regions."

22             [Interpretation] So you were fully aware of what the solution

23     was.  However you thought that Izetbegovic made a mistake because he

24     accepted the reorganisation of Bosnia.  Do you agree that that was not a

25     partition or division but this was decentralisation according to regions?

Page 21069

 1        A.   Sorry.  I didn't quite understand your question.  Did the Lisbon

 2     discourse -- was decentralisation but not partition.

 3        Q.   Do you agree that according to the Lisbon agreement Bosnia would

 4     remain a single country with external borders and inside there would be

 5     three regions that would be rather autonomous?

 6        A.   Yes.  I think that was the idea of -- of what they were trying to

 7     do at Lisbon was to -- was to have a -- rather than the two entities or

 8     statelets that we now have, they were going to try to divide Bosnia in --

 9     in -- into some kind of ethnic canton system, and in that passage I'm

10     trying to really, I suppose, deal with -- with then

11     President Izetbegovic's meandering around this.  I don't know how much

12     the Court wants to listen to a discussion about Izetbegovic, but he -- he

13     changed his mind quite a lot on whether he wanted cantons, partition, a

14     unitary state.  But to that Lisbon agreement I referred to was, yes, sir,

15     it was -- was to do with a cantonisation along ethnic grounds.  We agree

16     on that.

17        Q.   Thank you.  Do you know why Mr. Izetbegovic gave up on this

18     agreement that had already been accepted?

19        A.   I -- I -- I can't -- I don't -- I sort of -- I don't try to

20     mind-read President Izetbegovic either in retrospect or at the time, but

21     I certainly noted that he -- that he was ready to accept things that he

22     then went on to reject.

23        Q.   Thank you.  I meant that you had heard or read about him being

24     persuaded by a diplomat to reject this and ask for more.  However you

25     haven't heard about that.  We're going to abandon that particular topic.

Page 21070

 1             When you testified in other cases, did you observe that after the

 2     secession of Bosnia-Herzegovina, the difference between the Serbs and the

 3     Croats was considerably smaller than the difference between the Serbs and

 4     the Muslims or the Croats and the Muslims respectively, in terms of their

 5     political views concerning the future of Bosnia-Herzegovina?

 6        A.   Excuse me.  I'm just going to examine your question carefully,

 7     sir.  The differences between the Serbs and the Croats -- yes.  I

 8     understood and understand that discussions were had as regarding the

 9     partition of Bosnia between Serbian -- a Serbian sphere of influence and

10     a Croatian sphere of influence with a Muslim bit, if you like, and that

11     conversations were had between, as I understand it, President Milosevic

12     and President Tudjman of Croatia with regard to that.  So I suppose you

13     could say that the influence -- the difference between the Serbs and the

14     Croats was smaller inasmuch as neither of them wanted to be part of a

15     country or necessarily part of a country called Bosnia-Herzegovina as

16     long as it was dominated by Muslims.

17        Q.   Thank you.  However, I did not mean Presidents Milosevic and

18     Tudjman.  I meant myself and Boban, or rather, Boban and myself.  You

19     noted that there were lesser differences there.  Not in terms of the

20     details where things would be, but in terms of what Bosnia would be like

21     as a whole in the future.  The Bosnian Croats and the Bosnian Serbs, if I

22     can call them that conditionally, were in favour of a decentralised

23     Bosnia consisting of three entities, whereas the Muslim side wanted to

24     have a unitary Bosnia.

25        A.   Yes.  I -- the term "Muslim side," I think one could say that a

Page 21071

 1     very considerable number of people who are called Muslims and many people

 2     of -- many Croats and many Serbs saw themselves as wanting to be -- to

 3     live in Bosnia.  Political movements representing considerable numbers of

 4     Serbs, yours and Croats, Mr. Boban's, wanted not to live in a -- in a

 5     united country and wanted to demonstrate their demands and to show their

 6     affiliations to respectively Belgrade and Zagreb.  What concerns me in

 7     the book, really, because this isn't a political book, is what was then

 8     done by, shall we say, the nationalist interests of the Bosnian Serbs and

 9     the nationalist interests of the Bosnian Croats to establish and carve

10     out the territories that they did not want to be governed from Sarajevo.

11     I mean, there's a jump between the policy to mass murder, and it's up --

12     it's up to the Court how much we want to go into the politics, but I do

13     concede that you led a movement that did not want to be governed from

14     Sarajevo and that Mr. Boban led a movement that did not want to be

15     governed from Sarajevo.  Obviously.

16        Q.   Now let me ask you this:  Do you agree that Bosnia and

17     Herzegovina had a Christian majority, taking into account both us Serbs

18     and Bosnian Croats together and that Christian majority was in favour of

19     a decentralised tripartite Bosnia, whereas the Muslim minority was in

20     favour of a unitary Bosnia?

21             JUDGE KWON:  Mr. Karadzic, I'm struggling to understand the

22     relevance of these lines of questions.  We are due to take a break soon.

23     After the break, I would like you to concentrate on his -- his evidence

24     in chief.

25             THE ACCUSED: [Interpretation] Your Excellency, I accept your

Page 21072

 1     suggestions, as usual, but this witness had written a book, and from it I

 2     saw what his understanding of our crisis was.  That is his vantage point,

 3     and that is very important for the second part of my examination when I'm

 4     going to shed light on things that the Defence does not agree about.

 5             JUDGE KWON:  And that's why we allowed you to proceed.  We'll

 6     take a break for half an hour now and resume at 10.30.

 7                           --- Recess taken at 9.58 a.m.

 8                           --- On resuming at 10.33 a.m.

 9             JUDGE KWON:  Yes, Mr. Karadzic.

10             THE ACCUSED: [Interpretation] Thank you.

11             MR. KARADZIC: [Interpretation]

12        Q.   Let's finish with the book, according to the Trial Chamber's

13     guidance.  Let's look at page 11 in e-court, please.  Can the left-hand

14     side be displayed.

15             You're talking about the embargo, about the difficulties

16     experienced by the Muslim side with regard to the purchasing of weapons,

17     and then at the bottom of the page you say that you were aware of a

18     perverse smuggling route along which guns paid for by the Muslims using

19     money from Turkey and the Arab countries would arrive at the Croatian

20     port of Rijeka.  And then can we look at the top of the right-hand side

21     page.  And then you describe how the Croats would take a half cut; is

22     that correct?

23        A.   As I understood it from a number of sources, Bosnian government

24     military, HVO Croatian military, and international intelligence, this was

25     the deal that pertained to some of the arms shipments.  I can't speak for

Page 21073

 1     all of them.  That as the front and central Bosnian, at least, became

 2     progressively cut off, they would get a quarter of the weapons that would

 3     arrive in Rijeka, or indeed later by plane, and that there would be a

 4     sort of commission, if you like, of 50 per cent to the HV and another

 5     25 per cent for the HVO.

 6        Q.   Thank you.  Let's go back to the left half of the same page.  You

 7     say here that the parliament at Pale rejected Vance-Owen's plan.

 8     UN Secretary of State Warren Christopher replied that the lifting of the

 9     embargo [In English] Simply leveled the killing field.

10             [Interpretation] Do you remember that I, myself, accepted the

11     Vance-Owen Plan but that the parliament actually rejected it?

12        A.   Yes, I do remember that, sir.  And I remember you accepting a

13     number of plans, and -- as well and there were innumerable treaties, all

14     of which ended up in nothing.

15        Q.   You, therefore, know that I accepted the

16     Carrington-Cutileiro Plan, the Vance-Owen Plan, the Owen-Stoltenberg

17     Plan, that I did not accept the Contact Group plan, but I accepted the

18     Dayton Accord.  There was just one plan that I did not accept; isn't that

19     correct?

20        A.   I -- from memory, I -- I can't remember which plans you did or

21     didn't accept, but I do remember you accepting the Vance-Owen Plan, and

22     of course the Dayton agreement.  I mean, if you'll pardon the sort of

23     implied exhaustion and cynicism of this on the ground the Vance-Owen Plan

24     came and went and it didn't really amount to much.  I mean, there were

25     negotiations going on two days before the Srebrenica massacre, I mean --

Page 21074

 1     but, yes, you accept the Vance-Owen Plan, and I'll leave it to the

 2     experts to -- to regard to the others.  From memory, here and now, I

 3     can't actually remember which ones you didn't accepted, but you did --

 4     there were endless plans, treaties, none of which amounted to very much

 5     on the ground.  The killing carried on.

 6        Q.   Thank you.  To finish with the book, I would like to ask you

 7     this:  I'm a little bit confused by the part of your CV and the

 8     bibliography where you refer to only two books, "Agriculture of

 9     Bosnia-Herzegovina" by Mustafa Imamovic and "Bosnia and Bosniaks" by

10     Rusmir Mahmutcehajic.  These are the only two books that you refer to in

11     the bibliography of your book.  Those are local sources.

12     Rusmir Mahmutcehajic was a politician at the time.  Was that enough for

13     you to understand the Bosnian knot?

14        A.   The Bosnia knot.  I'm looking at "History of the Yugoslav

15     Peoples" by Fred Singleton here.  There were, of course, books about

16     Yugoslavia and Tito and the South Slav region going right through the

17     ages which I have read.  I think mine and a book by Misha Glenny were the

18     only ones on the wall that had appeared, along the post 1992 period, that

19     had -- that had been written up until this point.  This book was written,

20     Your Honours, when, for the most part, during the summer of 1993 with

21     everything in full flow and published a few months later.  There weren't

22     many, if any, books about what was going on around me at the time.

23        Q.   Thank you.  Let's skip the part that refers to Croatia.  You were

24     in Croatia, and you saw for yourself there what was the nature and the

25     cruelty of the civil war that was raging there, and then in the Stakic

Page 21075

 1     case, on the 14th of July, on pages 735, 736, you testified that you had

 2     seen the fear of Serbs in Croatia, that you had spoken to them about that

 3     and that you had experienced and seen what they had experienced in the

 4     country, in the making that was Croatia at the time; right?

 5        A.   Yes.  I'd covered that -- that war in 1991, and I had covered

 6     both the Croatians' aspirations to fight a war of independence and the --

 7     the fears of the Serbian populations in being part of that Croatia, the

 8     independent Croatia.  There was an element of -- and I think I've put it

 9     similarly in -- in the past.  A element of at least agreement over what

10     was being fought over albeit from completely different sides in that war.

11     There were -- there was an aspiration for independence by the Croats and

12     a willingness to fight for it, and there were fears among the Serbs and a

13     willingness to -- to fight that independence.

14             MS. SUTHERLAND:  Your Honour.

15             THE WITNESS:  And I reported suffering on both sides and violence

16     by both sides.

17             JUDGE KWON:  Yes, Ms. Sutherland.

18             MS. SUTHERLAND:  Your Honour, I'm sorry to interrupt, but just on

19     page 41, line 17, there's reference to "then you testified in the Stakic

20     case, on the 14th of July, on pages 735 and 736."  Unfortunately, the

21     Kovacevic case and the Stakic case have the same case number, and so if

22     we're talking about July, we're talking about 1998 in the Kovacevic case,

23     and in -- the Stakic case was in September 2002.  So it was simply to

24     make the record clear.

25             JUDGE KWON:  Thank you, Ms. Sutherland.

Page 21076

 1             THE ACCUSED: [Interpretation] I apologise, and I would like to

 2     thank you on behalf of the Defence.  We will try to deal with that as

 3     best as we can.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   In the Prlic et al. case, which is 1D04800 on the transcript

 6     page 1726, you confirmed that you were more than aware that the JNA had

 7     attacked Croatia.  Wouldn't you say that was all one country and that the

 8     JNA was duty-bound by the constitution to preserve the territorial

 9     integrity of Yugoslavia?

10        A.   Croatian independence -- forgive me if I don't have the dates in

11     my head exactly.  It's -- it's, I think, difficult to talk about exactly

12     when Yugoslavia can be said to have ceased to exist and exactly when

13     Croatia came to exist.  Certainly the perceptions were different from

14     Belgrade and from Zagreb.

15             Certainly the Yugoslav Army with Yugoslavia insignia on the tanks

16     outside and Serbian insignia on the walls inside the barracks was

17     attacking and -- the Croatian town of Vukovar fairly ferociously, and

18     similarly the embryonic Croatian Army which called itself various things

19     at various points was attacking the JNA, and at what point it -- it

20     became Croatia and ceased to be Yugoslavia is a matter for -- for

21     examination beyond my -- my recollections of the exact dates of

22     declarations and -- and conflict in my head now, but I -- at some point

23     along the line Croatia declares independence and it becomes a war between

24     Serbia and Croatia.  But at the beginning, yes, indeed, it was the JNA,

25     Yugoslav National Army in combat with Croatian secessionists.

Page 21077

 1        Q.   Thank you.

 2             THE ACCUSED: [Interpretation] I would like to tender that book

 3     pages that we have displayed into evidence.  They are number 1D04807.

 4     The Defence may be of assistance to the Registry with regard to the page

 5     numbers.

 6             JUDGE KWON:  Shall we add it to the Prosecution exhibit or admit

 7     it separately?

 8             THE ACCUSED: [Interpretation] I don't mind.

 9             JUDGE KWON:  Do you have any observations, Ms. Sutherland?

10             MS. SUTHERLAND:  No, Your Honour.  Well, only to say that

11     Mr. Karadzic was citing certain pages in e-court, page 7 or page 12 or

12     whatever, and it may be easier when you're reviewing the record to have

13     it as a Defence exhibit.

14             JUDGE KWON:  Very well.  Let's follow that submission.  We'll

15     admit it as Defence exhibit.

16             THE REGISTRAR:  That will be Exhibit D1897, Your Honours.

17             THE ACCUSED: [Interpretation] Thank you.

18             MR. KARADZIC: [Interpretation]

19        Q.   And now I would like to move on to London.  During the

20     London Conference, I contested some allegations about camps and then I

21     invited British journalists, whoever wanted to go there, to come and that

22     entire Republika Srpska will be open to them to see whatever they wanted

23     to see.  Do you remember?  I was not provoked into doing that.  I was the

24     one who invited British journalists to come and see for themselves what

25     was going on.

Page 21078

 1        A.   No, I agree.  I don't see -- I don't see that you were --

 2     provoked isn't the word I would use.  Challenged perhaps by the

 3     allegations that had been published in the "Guardian" and in an American

 4     paper called "Newsday," and your response was, and I summarise, not your

 5     words, but the sense of it were, "Well, come and see for yourselves on my

 6     authority."  And you contested that the -- the allegations of brutality

 7     in the camps.

 8        Q.   Thank you.  And now I would like to call up 1D4821 in e-court.  I

 9     believe that you will be able to help us and tell us whether this is your

10     first report about your visit to Prijedor.

11        A.   That's it, sir, yes.

12        Q.   This was before the media circus, as you call it, that fell upon

13     Bosnia.  At this particular point in time, there was still no media

14     circus; right?

15        A.   Yes, sir, that's right.  Perhaps Your Honours might like to note

16     it says the "Toronto Star" at the top.  It's a reprint.  I believe the

17     date is the same, I don't know.  Sorry.  Yes, that's before the media

18     circus.

19        Q.   Thank you.  Can we look at the first paragraph in the report.

20     For example, the framed part.  Here you state with full responsibility

21     that you had been informed that the Omarska camp was an investigation

22     centre operated by the Bosnian-Serbian police for Muslim captives near

23     Prijedor in Northern Bosnia; right?

24        A.   Yes.  Excuse me.

25        Q.   I'm not going to read everything else.  Everybody can do it for

Page 21079

 1     themselves.

 2             You say that there was a meal in five minutes.  "They first

 3     wanted to eat and then talk to me."

 4             Can we go to the following page.  Again, the first frame where

 5     you say that Omarska was a mine and that the Bosnian government referred

 6     to it as one of the 57 concentration camps.  And then you say that the

 7     unexpected access was as part of an invitation by the Bosnian Serb

 8     president, Radovan Karadzic, to inspect whatever we wanted to see.

 9             One of your interlocutors said that he was a member of the

10     Defence forces but he was not captured in combat.  He tried to get to

11     Trnopolje, which was a transit civilian camp, but the army caught him on

12     the way.  Is that what the person told you?

13        A.   Yes.

14        Q.   Thank you.  Was your impression then that fighting in Prijedor

15     had started on the 22nd of May and that it had lasted for six weeks and

16     that was the length of the war in Bosnia.  There was no war in Prijedor,

17     and that between the 21st of May and the 2nd of June there was a lot of

18     fighting going on and that this particular person speaks about those

19     fights; right?

20        A.   My knowledge of what had happened in the area prior to August the

21     5th when we arrived was that there had been what I would -- or what was

22     being described as some sort of takeover or even a coup of the town at

23     the end of April.  Yes, there had been some sporadic resistance to the --

24     the new order, if you like, and there had been, variously, demands for

25     villages to hand over weapons.  Some had, some hadn't.  But from the --

Page 21080

 1     and I must not talk with hindsight because I've been working on this for

 2     many, many years.  We saw on the way to the camp signs of -- of -- of

 3     very heavy destruction, particularly around Kozarac, which we skirted

 4     along the main road.  The vast majority of houses burned out and their --

 5     the inhabitants gone.

 6             There had obviously been some exchanges.  This man speaking had

 7     been a member of some sort of defence.  The surrenders had been, as I

 8     understand it, pretty quick.  They had been overpowered very swiftly with

 9     an overwhelming force.  That's how I understood it.

10             I did not think there was any sign of fighting in the area at

11     this time, any -- if there had been any resistance, it had been totally

12     subjugated.

13             There was a mock battle on the way to the camp.  You, when we met

14     in Pale, sir, did talk about fears for our own safety and -- and attempts

15     to kill us by the Muslims that -- would then be blamed on you in the film

16     we saw.  There was a rather sort of ridiculous prank whereby our convoy

17     was "attacked," but actually it turned out to be by our own hosts by way

18     of a sort of prank, but there was no fighting when we visited.

19             I had some experience of warfare by then and could tell that

20     these shots were going over our heads and the return fire was going high

21     into the air.  It was a silly thing to try and make us afraid and to put

22     us off.  There was no fighting.

23        Q.   Thank you.  Let us just limit ourselves to what you know exactly,

24     what you learned and saw at the time.  Let me mind you just briefly.  On

25     page 3 you told us that you had passed through Brcko and that there was a

Page 21081

 1     lot of damage in Brcko.  Do you know who controlled Brcko at the time?

 2     Let me help you.  Do you agree that you had passed through the Serbian

 3     territory and that the Brcko that you saw was the Serbian part of Brcko?

 4        A.   As I understood it, because we were in Serb -- Bosnian Serb

 5     vehicles, the part of Brcko we passed through was in the hands of the

 6     Bosnian Serbs, and there were large areas of the town shelled, bombed,

 7     burnt out, and deserted, which I inferred would be where the Muslims had

 8     lived.

 9        Q.   But why didn't you ask who -- who was it who had shelled Brcko,

10     which was in Serbian hands?  Do you think that it was the Serbs

11     themselves who shelled Brcko?

12        A.   There wasn't -- there wasn't any -- we were in our own vehicle at

13     that point, and Professor Koljevic was in another vehicle.  I understood

14     it -- I understood at the time that -- well, there obviously had been

15     fighting in Brcko and whoever had lived in those houses didn't live there

16     any more, and so the town was under the control of the Bosnian Serb side.

17        Q.   Thank you.  It is my thesis that all that time you could only be

18     passing through the Serbian territory and that everything that you saw

19     and that was destroyed was destroyed by the opposition side who shelled

20     us.  Do you -- do you agree that you passed through the corridor west of

21     Brcko which at place was only a couple of hundred metres wide?

22        A.   I didn't know exactly how wide it was, but I knew there was a

23     corridor, yes, that connected Bijeljina, Brcko, and Serbia proper to the

24     Banja Luka region, and that we passed through it, and that it was narrow.

25        Q.   If I tell you that there was not a single day without fire being

Page 21082

 1     opened on the corridor, would you then accept that our fear for you was

 2     justified?  Not a singe day -- there are reports to that effect.  There

 3     was not a single day that passed without fire being opened on the

 4     corridor?

 5        A.   Well, I was obviously grateful for your concern for our safety,

 6     and we were lucky to get one of the days when there wasn't fighting,

 7     thankfully.  The first shots we heard was when there was this prank I

 8     discussed earlier.

 9        Q.   Well, I'm contesting precisely that.  Do you know that in

10     Prijedor and around it until late 1994 there were guerrilla Muslim groups

11     that lived in the woods in dugouts and that from time to time they would

12     go out and kill soldiers and villagers?  While you were there, there were

13     a lot of them, and there were a certain number of them until the end of

14     1994.

15        A.   To my knowledge at the time, there had been exchanges of fire but

16     that the -- any resistance had been subjugated.  Colonel Milutinovic did

17     explain to us when we asked him about all the bombed and burnt out houses

18     that 40.000 Muslims had left the area and implied that they had done so

19     of their own accord.

20             There were still some people living in intact houses, which was

21     slightly bizarre to behold, I have to say, and it was explained that

22     these were the Serbs that had remained.

23        Q.   Let us conclude with this page.  Here Sabahudin told you about

24     the investigating measures, that there were -- that were applied and that

25     he told you the truth; is that correct?

Page 21083

 1        A.   Yes.  He'd been investigated and -- and he hadn't been beaten.

 2        Q.   Thank you.  Could we go to the bottom of the page, please.  Here

 3     you report that Omarska is an investigation centre for men suspected of

 4     taking part in the Muslim irregular army.  You say that they were rounded

 5     up there to be screened in order to determine whether they were fighters

 6     or civilians.  We can see here that you observed the 80 inmates and that

 7     you saw no signs of beatings.

 8             I asked you the same thing during -- when we discussed the

 9     interview.  Could you have -- sorry.  Let's go to something else.

10             A moment ago, you said they were attacked by Serb forces.  If I

11     told you that Prijedor was attacked by Muslim forces, what would you say?

12     If I told you that it wasn't the Serbs who attacked Prijedor but that

13     they were, rather, defending the town -- the town centre and managed to

14     do so.

15        A.   I saw very little sign of shelling in the centre of Prijedor.

16     None, in fact, that I can recall.  Or put it this way:  To contrast the

17     damage of Kozarac with the centre of Prijedor, we're talking about two

18     completely different landscapes.  The centre of Prijedor, I recall, as

19     being more or less intact as I think the films show, and I certainly

20     recall them being intact.

21        Q.   Thank you.  Could we go to the next page, please.  In the

22     meantime, I wish to ask you the following:  Did you know that the

23     Green Berets on the 30th of May managed to reach the very town centre?

24     They launched a surprise attack reaching the town centre and that they

25     were only defeated after two or three days.

Page 21084

 1        A.   No, I didn't know that the Green Berets had fought this battle,

 2     nor did I see any signs of the battle in the centre of the town or any of

 3     the parts that we visited in Prijedor.  There was a little damage around

 4     but very -- I mean, compared to the surroundings, nothing really.

 5        Q.   Thank you.  I'm afraid that on page 15, line 21; we have

 6     something missing in the transcript.  Ms. Balaban then said, "I am only

 7     interpreting," when she explained her position to the journalists.  Could

 8     this be verified by Registry or whoever's in charge of LiveNote.

 9             Let's look at this, please.  Here you say that you could observe

10     that Omarska and Trnopolje were run by civilian authorities and that you

11     were told that no one was proud of it.  In the boxed part, it says:

12              [In English] "Though this may be true of Omarska, it is

13     generally untrue since a camp we visited on the outskirts of Sarajevo has

14     been established solely for the purpose of swapping Muslim captives for

15     Serbs."

16             [Interpretation] Which prison did you see exactly which served

17     that purpose?

18        A.   This is the Kula prisons on -- on the outskirts as I said of

19     Sarajevo which we visited on the same day that, Your Honours, we met with

20     Dr. Karadzic.  And it -- well, I think I've described it and describe it

21     as a sad place.  There's nothing particularly to -- to complain about, to

22     write about.

23             If I could, sorry, just make something to the record of my own.

24     Apologise.  Dr. Karadzic has said that I described Omarska as an

25     investigation centre.  The record doesn't show that that is in inverted

Page 21085

 1     commas.  That is very much their term during interminable briefings we

 2     were given upstairs.  I'm not calling it an investigation centre, I'm

 3     putting that in quotation marks, that's what they called it.  And the

 4     record, as written -- Dr. Karadzic quotes from the article correctly, but

 5     it's in inverted commas which indicates that that is what they were

 6     calling it.  I'm sorry, just to make sure it's accurate.

 7        Q.   Thank you.  Did you know, were you told that Kula had been a

 8     prison for a while for misdemeanor detainees and it remained being a

 9     prison throughout the war?

10        A.   We were told that it was a prison we were told that the people in

11     there at the time of our visit were there awaiting exchange, and that is

12     actually, I think, what most of those men said themselves, that they

13     hoped to be exchanged.

14        Q.   Did you see anyone at Kula who was not fit for military service?

15        A.   I would think that -- and this is my recollection at a distance.

16     I put that in the article to give some sense of balance and to put

17     Omarska in context of -- I didn't want to write much more about Kula.  I

18     would think, thinking back, that some of them were probably a little old

19     to fight very effectively.  Others were of fighting age, yes.

20        Q.   Thank you.  Did you know that Mr. Izetbegovic, as of the 4th of

21     April and up until your visit, on a number of occasions ordered a general

22     mobilisation of all those who were fit for military service, and did you

23     know that there was basically a hundred per cent response by Muslims to

24     that call?

25        A.   I didn't know the exact date of any conscription order, but I'm

Page 21086

 1     sure that may be right.  My experience in Sarajevo, which doesn't begin

 2     until a year after these events would indicate to me that there wasn't a

 3     100 per cent response, but they did -- they did organise an army in the

 4     months that followed.  And with regard to an earlier conversation we had

 5     about the political situation, that army included large numbers of -- of

 6     Serbs and Croats in what is called the Muslim side.  I don't know what

 7     the take-up on the conscription was.

 8        Q.   Thank you.  Could we go to the next page, please.

 9             In the boxed part you say that there was no visible evidence of

10     serious violence, let alone systematic extermination.  Then you say that

11     the Red Cross Yugoslav doctor stated that he had visited the location and

12     that the detainees were in a good state save for a few cases of

13     diarrhoea.  Then you move on top Trnopolje; correct?

14        A.   Yes.  But the paragraph that says there's no visible evidence of

15     serious violence means that we were seeing the people who were selected

16     to come into the canteen, one of which did a minor wound to his face,

17     actually, but we did not see any -- any very serious violence.  But the

18     point I'm making here and the bit that you have kindly boxed is that we

19     were trying to get into the -- into the -- into the hangar, the shed,

20     where -- well, I mustn't speak with hindsight, but where we had

21     suspicions that appalling things were taking place.  Hindsight has shown

22     that they were, and what I'm trying to say in that paragraph that you

23     have marked is that it was worth breaking your promise to stop us seeing

24     them that day, and -- sorry.  And now that I know what I know, what this

25     Tribunal knows, I can see why, because what was happening in there was

Page 21087

 1     absolutely appalling and had been for three months.  That's -- and then

 2     we go to Trnopolje.  Yes, sorry.

 3        Q.   How do you know what took place inside, and how do you know that

 4     the detainees to be shown to you were cherry picked?  Let's not discuss

 5     your assessment.  Do you know it for a fact?

 6        A.   Well, I don't know how long Your Honours want to listen to what

 7     is my work over the years listening to other people.  So I've heard from,

 8     as I said, scores of people who were in Omarska, that there was

 9     widespread and systematic killing and many of them lost family there in

10     appalling circumstances.

11             It's not for me to give the whole history of the camp unless you

12     want it from me in terms of this -- these testimonies that I've taken

13     over these years, but the Tribunal's own record over the years would, I

14     think, suffice in the cases that I've testified in including Tadic,

15     Stakic, and Kovacevic to give some idea of what was happening in that

16     hangar and other buildings in the Omarska camp.  I can elaborate on the

17     interviews I've done, if you wish, but to summarise, I think we can say

18     that your judgement that this was the worst prison is correct and that

19     the most atrocious things were happening in there.

20        Q.   I apologise.  I'm just trying to ascertain something.  What are

21     the sources of your information?  Are you relying completely on what has

22     taken place before this Tribunal and your conversations with the Muslims

23     and those who during the civil war fought the side that was in charge of

24     the prison; correct?

25        A.   My sources would be survivors of the camp, yes, some of whom

Page 21088

 1     testified to this Tribunal, many of whom have testified to this Tribunal

 2     on oath; international assessments that have been made; those bereaved by

 3     the hundreds of -- some of the hundreds of people who were bereaved by

 4     the murders in the camp.  And in a way Dr. Kovacevic's remorse was a

 5     guide although the details are provided.  But, yes, the main survivors

 6     over the years whose terrible experience that has been corroborated by a

 7     vast wealth of evidence here on oath at this Tribunal to mass murder,

 8     torture, beating, and rape.

 9             Sorry, I didn't answer an element in your question.  With regard

10     to the selection, I have heard from a number of survivors that on August

11     the 4th, while we are on our way, large numbers of prisoners were taken

12     out onto the Pista, as it's called, the tarmac area between the hangar

13     and the canteen where these altercations in the film are taking place and

14     a group selected for, as it were, presentation in the canteen, what was

15     to be the following day, and that I've heard it from large numbers of

16     people that they were judged to be those that were in better condition.

17        Q.   Mr. Vulliamy, do you know that people were taken out to the pista

18     daily to get some fresh air, not only when you arrived.  It happened

19     every day, and anyone who was not being interrogated at that moment was

20     taken out to the pista to get some fresh air.

21             JUDGE MORRISON:  Dr. Karadzic, that's not so much a question as

22     an assertion.  And it seems -- I only speak for myself, of course, but it

23     seems to me that this is a topic that one could go on and on about

24     ad infinitum without it really relating to the essence of this witness's

25     testimony.  You may agree with that.

Page 21089

 1             THE ACCUSED: [Interpretation] I do, Your Excellency.  It is a

 2     fact, however, that the witness said the detainees were taken out to the

 3     pista for their sake and that only 80 of them who were in better

 4     condition were chosen.  I simply wished to remind the witness that the

 5     taking out of prisoners in that way to the pista happened daily, not only

 6     on that occasion.

 7             In any case, let's move on.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   You go on in your book -- could we go down to the bottom of the

10     page.  You say that a group arrived from Keraterm.  Did you try and

11     verify whether 200 people were indeed killed at Keraterm and all those

12     perhaps in a single day and many more at Omarska?  But you also say he

13     has seen no bodies himself, but other people told him.

14        A.   It was -- it was hard to try and verify on that day whether this

15     alleged massacre had taken place in Keraterm, but -- and with hindsight,

16     I know that now that particular day it's not 200.  It's about 150.  But

17     that has been the subject of a -- of a trial at this Tribunal since, and

18     I was happy to --

19        Q.   [Overlapping speakers]

20        A.   I was convinced enough to quote this boy at the time that -- that

21     he says 200 were killed at Keraterm and many more at Omarska, and I did

22     quote him, and I think hindsight will show and the proceedings of this

23     Tribunal have shown that although he got the number wrong at Keraterm,

24     the -- the massacre did take place and many more were certainly killed at

25     Omarska.  He's telling the truth, essentially.

Page 21090

 1        Q.   However, he was not at Omarska.  He was in Keraterm, and he

 2     didn't see any bodies there either; is that correct?

 3        A.   He was among the group that had come from Keraterm and Omarska

 4     that morning that we saw in the picture.  On the day, yes, he is -- I am

 5     quoting someone who is quoting maybe people he knew who had arrived from

 6     Omarska that day, but knowing what I know now, I'm happy to have reported

 7     that -- that he said many more people had been killed at Omarska.

 8     Whether he means many more than 200, I don't know, but many more than 200

 9     were killed at Omarska, so he's telling the truth.

10        Q.   If I told you, Mr. Vulliamy, that none of it is true and that all

11     those who said anything about killings saw a single killing of a person

12     who was mentally disturbed, would you believe me or would you believe

13     them?  And why do you choose their stories, although you say that the boy

14     didn't see any bodies but someone else did, and he was never at Omarska?

15     It seems you choose to believe things which are to the detriment of the

16     Serbs quite easily, lightly.

17        A.   I don't choose to believe things that are detrimental to one side

18     or the other.  I don't believe that only one person was killed in Omarska

19     and Keraterm put together, and I do believe this -- what this boy says

20     when he talked about -- although, as I said, the number on that day is

21     not 200, so far as I know, that I do believe that -- that very many more

22     than one single mentally disturbed person was killed in the combination

23     of Omarska and Trnopolje -- sorry, Omarska and Keraterm.  So with

24     respect, I have to say that if you tell me it's only one, I don't believe

25     you, sir.  Nothing personal.  I just heard differently from so many

Page 21091

 1     places and sources and people, including people testifying on oath at

 2     this Tribunal, whose testimony has been upheld in a number of cases.

 3             And the detriment to the Serbs is irrelevant.  That's not how I

 4     measure these things.

 5        Q.   With all due respect, it would be irrelevant if it were true.

 6     However, I told you that they all saw a single killing.  They all

 7     discussed killings but saw only one.

 8             JUDGE MORRISON:  Dr. Karadzic, you're making an assertion as to

 9     matters which are evidential.  This is not a proper question in

10     cross-examination.  You've made the point that you don't accept the

11     witness's findings.  It's not going to be improved by argument, and in

12     terms of the time limitations, it's certainly my view, I don't know if

13     it's the view of my colleagues, that you ought to move on.

14             THE ACCUSED: [Interpretation] I agree.  I was imprecise.  I was

15     addressing what the witness said when he stated that I claim that there

16     was only one killing, but it was actually what the people were saying and

17     saw.  It is my position that they all discussed it but no one saw more

18     than one killing.  You also --

19             JUDGE KWON:  Mr. Karadzic, please move on.

20             MR. KARADZIC: [Interpretation]

21        Q.   Briefly only.  You believed that Trnopolje could not be termed a

22     concentration camp.

23             THE ACCUSED: [Interpretation] Could we turn on to the next page?

24             JUDGE KWON:  Was that a question?

25             THE ACCUSED: [Interpretation] Well, I wanted to show something

Page 21092

 1     else about Trnopolje.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   You believed that Trnopolje was not a concentration camp and that

 4     some people arrived there voluntarily as they were fleeing combat which

 5     took place in the vicinity of their villages; correct?

 6        A.   Sorry, yes and no.  The usage of the term "concentration camp" I

 7     can discuss now separately as the -- as Your Honours wish.  As regards

 8     fleeing combat which took place in the vicinity, no.  Trnopolje was a

 9     complicated place.  Some people had been corralled there from their

10     villages.  Others had gone there, as you said in your interview with us,

11     because their villages had been burned down.

12             JUDGE KWON:  As to the term "concentration camp," I thought

13     Mr. Karadzic was citing your article on the previous page.  Did you say

14     that?

15             THE WITNESS:  Yeah --

16             JUDGE KWON:  On the previous page.  Yes.

17             MR. KARADZIC: [Interpretation]

18        Q.   Yes, just below the last box.

19        A.   Yes.

20        Q.   Yes, you spotted that correctly.  Thank you.  Could we go back to

21     the next page then.

22             We see here that you state very professionally that there was no

23     compulsion and that the conditions were simply that of being hot and that

24     there was some stench.  There seems to be a person there saying that he

25     was a fighter and that they put them in front themselves.  He was so

Page 21093

 1     terrified and fled to the Serbian side of the village.  He was still in

 2     fear and felt safer in Trnopolje.

 3             Then just below you say that he arrived from Rizvanovici after

 4     the fighting.  He also says that the Muslim side initiated the fighting

 5     and that the police arrived and took the people away in order to -- to

 6     cleanse the village and to do the fighting.

 7             Mr. Vulliamy, you noted quite professionally the sentences which

 8     corroborate in full the position of this Defence; is that correct?  Is

 9     this what the people told you?  You didn't just make it up, did you?

10        A.   No.  I'm -- here's -- here's a boy who gets caught, and there is

11     shooting from the Muslim side.  The -- the -- the militias -- the Serbian

12     militia's arrived to clear the village of Muslims and he's -- appears to

13     have been caught in the crossfire.  He's safer behind the lines of the

14     advancing Serbs and he ends up in Trnopolje.

15             I think, Your Honours, I came across -- I came across that day

16     and have come across so many different reasons why people were in

17     Trnopolje, and this term "concentration camp" is -- is -- it's a

18     definition we can go into if you want.  I don't dispute what Dr. Karadzic

19     says.  He is a boy who is caught in crossfire and has -- want -- and is

20     better off there than in his village which has been cleared of his

21     people, and there has been shooting to achieve that.  And I'm not

22     disputing that there was not -- I'm sorry.  I'm not disputing that there

23     was not shooting from the Muslim side, sir.

24        Q.   Thank you.  You were free to discuss things with them without the

25     presence of guards; correct?  And you could walk around at Trnopolje?

Page 21094

 1        A.   In some places, yes; in others, no.  In the compound that we saw

 2     behind the fence, the people from Omarska and Keraterm, no.  The

 3     conversations in the medical centre, if it can be called that, I don't

 4     want the Bench to think this was some sort of clinic.  It was the room

 5     where these two people were doing their desperate best.  We were

 6     supervised as the interview with Mr. Merdzanic makes clear.  And in other

 7     points, yes, you are correct, I was able to walk around on my own and

 8     with somebody who I found who spoke English.

 9             JUDGE BAIRD:  Mr. Vulliamy.

10             JUDGE KWON:  Sir, Judge Baird.

11             JUDGE BAIRD:  Is it possible for you to give us, as briefly as

12     possible, some idea as to what you deemed a camp, concentration camp?

13             THE WITNESS:  Yeah.  Thank you.  If I could just explain.  The

14     day that my story was published, August the 7th, 1992, I did this sort of

15     fairly absurd number of some 50 something radio interviews, television

16     interviews, and time after time invocations were made of the Holocaust,

17     and Auschwitz and Birkenau.  This is in itself a long subject that I

18     won't trouble you with now, but I felt that at the time, and I think

19     there were, and I have consulted authorities at Holocaust museum and so

20     on, to try and find the language, and there were echos as authorised by

21     them -- echos.  Yes.  But this is down the line.  At the time, I felt

22     that this invocation of the shoah was unhelpful, to be honest.  We --  I

23     was trying to talk about what we had seen, what we had found, what we

24     feared we had not found, if you like, that headlines like "Belsen 1992"

25     didn't really help.  So I was disinclined to call, certainly, Trnopolje a

Page 21095

 1     concentration camp.

 2             This is all happening within a short space of time and fairly

 3     frantically.  I have decided, as I say, after consultation with people in

 4     the Holocaust museum and survivors, to use the term but actually with --

 5     very much with reference to its proper definition which comes from the

 6     Boer War in South Africa, and the more I've researched it, I think it's

 7     as fair to say that Trnopolje was camp, exactly that, where thousands of

 8     civilians were concentrated prior to enforced deportation of -- on the

 9     convoys of the kind that I accompanied across Mount Vlasic.  So it's a

10     discourse in itself, but that's the conclusion I've come to after the

11     best consultations I can muster.

12             JUDGE BAIRD:  Thank you very much indeed.

13             THE WITNESS:  Thank you.

14             THE ACCUSED: [Interpretation] Thank you.  Can we have the next

15     page, please.

16             MR. KARADZIC: [Interpretation]

17        Q.   The entire page is truly of interest and good, too.  Could we

18     please have a look at this.  You saw that were Muslim villages that were

19     intact, peasants calmly working.  Every house was marked by a white flag,

20     a piece of sheet, and that was their guarantee against Omarska or

21     Trnopolje.  And then Colonel Milutinovic explained to you that they had

22     accepted Republika Srpska and then they were left alone; isn't that

23     right?

24        A.   Yes, that's what he told us and, unfortunately, I believed him,

25     because I now know that the sheets meant that you had agreed to leave.

Page 21096

 1     But at the time that's what he told me, and I believed him.

 2        Q.   Says who?  Who told you that?  Who told you that that meant that

 3     they were supposed to leave, when the Muslims themselves say clearly that

 4     they had been told whoever doesn't want to fight can put this marking on

 5     their house so that we should not have any fear of that house, that we

 6     should not fire at that house.  Who said that to you?

 7        A.   The people who hung the sheets.

 8        Q.   Mr. Vulliamy, we did agree during our interview that in a civil

 9     war like that the two sides tried to blacken each other, as it were.  In

10     your view, how many Muslim were is killed in this war?  You are relying

11     on what the media said and what was in the public domain.  How many

12     Muslims were victims in this war?

13        A.   I don't have the figures to hand, but there is a report by two

14     investigators who -- who -- who gave a paper to a conference in Berlin,

15     and they -- what they did was they sort of combined the work of ICRC,

16     International Commission for Missing Persons, both the commissions of the

17     various entities, and they come up with I think -- and I need to confirm

18     this in the break, if Your Honours will allow me, but it's something like

19     I think it's -- I think it's 58.000 or so.  That's the figure I know from

20     memory.  There are an enormous number of estimates.  This is by two

21     Polish experts.  I can get the -- the names and the numbers, but as I

22     recall, it's something like 58- or 59.000 Muslims killed.

23        Q.   Thank you.  Have you heard the figure of 250- to 300.000, which

24     figured prominently throughout the war as the number of Muslims only that

25     had fallen victim?  Have you heard of this figure of 80.000 raped women?

Page 21097

 1        A.   I have heard the figure of 300.000 dead in the war which, as you

 2     say, is correctly prominent throughout the war.  I now know that to be

 3     incorrect.  It doesn't stand up forensically.  Eighty thousand rapes --

 4     raped women seems high.  I have heard a figure of tens of thousands of

 5     women raped.  Lower than 80, as I recall.

 6        Q.   Thank you.

 7             THE ACCUSED: [Interpretation] Can this document be admitted?

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Do you know that out of these 55 or 6 or 7.000 Muslims a number

10     were killed as fighters?

11        A.   Yes.  I think on all -- on all three sides you have both military

12     and civilian killed.

13        Q.   Thank you.  Do you know that about 35.000 Serbs lost their lives?

14        A.   That's not the figure in this report that -- that I -- that I'm

15     quoting, and I don't know where that comes from.  I -- I'm afraid I just

16     haven't got these figures off the top of my head, but it's 20-something

17     thousand Serbs.  I think it's 21.000 in that report I'm citing.

18             JUDGE KWON:  This article will be admitted as Exhibit D1898.

19             MR. KARADZIC: [Interpretation]

20        Q.   Do you agree that both you and Ms. Marshall and her

21     associate - actually, they stated that - realised only in Budapest when

22     they saw their footage from Trnopolje on TV, they realised that that was

23     a big story, as it were, when they saw that President Bush, Sr.,

24     interfered with his comment?

25        A.   I can't speak for Ms. Markale or Mr. Williams when they got to

Page 21098

 1     Budapest, but I think I am -- a big story.  Important, I'd rather say.

 2     We talked about this yesterday.  I think I realised that as soon as I

 3     walked into the canteen in Omarska and saw those men.

 4        Q.   Thank you.  1D4825.  Could we have a look at that.  We should

 5     disregard what it says in Serbian.  These are my notes.  This is some

 6     conversation, or maybe it was a talk show, or maybe it was live.  These

 7     are yours words and the words of Ms. Marshall.

 8             Actually, do you know when you stated this?

 9        A.   I don't remember exactly which interview.  I'm just reading it.

10        Q.   The next page.  Could we have that, please?  On the top here you

11     say that you returned yet again, and further down we see that you

12     returned to Omarska.  Can we have a look further down where you say --

13     actually, President Bush spoke about this, and you say that you were on

14     the phone all day, and you even say down here:

15              [In English] [As read] "These people were all skin and bone,

16     really gaunt and -- in terrible -- these men were emaciated grotesquely,

17     undernourished and thin, bony, gaunt, wiry ...," and so on.

18             [Interpretation] How come this is not contained in your first

19     report?  How come it's there when it became a big story?

20        A.   Can we get the first report back up again, because I think I do

21     talk about states of decay and emaciation.

22        Q.   We don't have enough time.  The participants have this before

23     them, and I can give you a copy, but we just don't have time.

24             JUDGE KWON:  We upload Exhibit D1898.

25             MS. SUTHERLAND:  Your Honour, in fact that's -- Mr. Vulliamy's

Page 21099

 1     article is an associated exhibit, so it would be having a Prosecution

 2     exhibit number.

 3             JUDGE KWON:  Yes.  It's 1D4821 is already admitted as associate

 4     exhibit, is that what you say?

 5             MS. SUTHERLAND:  It should have an exhibit number shortly,

 6     Your Honour.

 7             JUDGE KWON:  Very well.

 8             THE WITNESS:  As regards -- sorry, to answer your question, as

 9     regards this silly remark about number 1 for -- I mean, it was a crazy

10     day.  I'm not someone who likes to, you know, bob up on the media all the

11     time on other people's progress.

12             JUDGE KWON:  Let us show the witness.

13             THE WITNESS:  "Young man, emaciated, sunken-eyed, attacking

14     watery bean stew like a famished dog" -- it's a bit over -- I mean, it's

15     what it is.  "Spindly hands shaking."  It is what it is.  Yeah, I dont

16     see any great discrepancy between that description and what I said, you

17     know -- yet another of these interviews.  I can't remember exactly which

18     one it was.  President Bush was -- it was completely irrelevant to what I

19     was trying to say.

20             JUDGE KWON:  And third paragraph.

21             THE WITNESS:  "Internees, horribly thin, raw-boned, some with

22     almost cadaverous, with skin-like parchment folded around their arms,

23     faces, lantern-jawed, eyes haunt by the empty stare of the prisoner,"

24     et cetera.  So I think, in reply to your question, I would say that I

25     had -- while I was writing that, talking to nobody on August the 6th, for

Page 21100

 1     publication on the 7th, when I presume that interview was recorded is one

 2     of very many.  I think I probably got the gist, from what I saw, of what

 3     condition these men were in rather than taking any cue from the President

 4     of the United States.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   Thank you.  Can we go back to the previous document now, 1D4825.

 7     Could we have the last page.

 8             Are you talking about how hungry the public was for stories about

 9     Belsen and things like that?

10        A.   Your Honours, could I just read what he -- the text.

11             Yes.  This is a reference to what I was trying to explain to the

12     Bench in -- in one of Your Honour's queries about this -- this automatic

13     parallel that was being made between what we had found and the Holocaust,

14     which I considered to be unuseful at the time and certainly in need of --

15     of careful refinement before we started jumping into all of this.

16        Q.   Thank you.

17             THE ACCUSED: [Interpretation] Can this be admitted?

18             JUDGE KWON:  Yes.

19             THE REGISTRAR:  Exhibit D1899, Your Honours.

20             MR. KARADZIC: [Interpretation]

21        Q.   When you were in Prijedor, all the local leaders were ready to

22     see you and talk to you; right?

23        A.   Yes.  They made it clear that they didn't -- that it was

24     reluctant.  Mr. Kovacevic said, "I'm against this visit," even though you

25     are welcome or something to that effect, but they agreed to see us, yes.

Page 21101

 1        Q.   Thank you.  During that group meeting, did you get an impression

 2     as to who was in charge and who issued orders to who?

 3        A.   Dr. Stakic was introduced as the -- sorry, I didn't know he was

 4     doctor then.  Milomir Stakic was introduced as the president; Kovacevic,

 5     the vice-president.  Kovacevic did most of the talking.

 6        Q.   Thank you.  Also they informed you about the problems that the

 7     authorities had about the misdeeds that had been committed against the

 8     Serbs; right?  You spoke about that what you testified in Stakic, 1998,

 9     15th of July, pages 787 and 778; right?

10             JUDGE KWON:  Again, Kovacevic, I take it, Ms. Sutherland.

11             MS. SUTHERLAND:  Yes, Your Honour.

12             THE WITNESS:  I've described the meeting in both -- both those

13     trials, yes.

14             MR. KARADZIC: [Interpretation]

15        Q.   Thank you.  They informed you about Hambarine there.  They

16     informed you about the torturing of children, and Kovacevic told you that

17     he, as a child, had been a prisoner at the Jasenovac camp; right?

18        A.   Yes, they did talk about fighting in Hambarine, and they showed

19     us a video about what they called a jihad in the area, and certainly

20     Kovacevic, to my recollection, said that he had been born in Jasenovac,

21     which when I went to revisit him he said that he had been taken there as

22     a child, but he had certainly been in that appalling place, so he said,

23     and I believed him, and still do.

24        Q.   Thank you.  You said in your testimony in Kovacevic, on page 795,

25     I'll read it in English:

Page 21102

 1              [In English] "On their way to Omarska, they were attacked and

 2     they were told that it was ..."  [Interpretation] Actually you described

 3     that.  You said that you were attacked and you were told that it was the

 4     Mujahedin, and you said that all this had been rigged and you repeated

 5     that today as well.  How come you were sure of that and what would that

 6     mean to us?

 7        A.   What convinced me was, first of all, how the shots were going

 8     over our heads high, and anyone who was trying to shoot at us clearly not

 9     very good.  The return of fire was also high, and then when it sort of --

10     when we said this is ridiculous let's carry on, and it's -- it stopped so

11     suddenly and we carried on, it didn't feel like a -- a proper ambush from

12     the experience that I had of the war in Croatia and previously in Iraq.

13        Q.   And it never crossed your mind that they were firing at one

14     another and that they were not targeting you?

15        A.   If they were, they were rotten shots.  Sorry, I don't mean to be

16     facetious.  It might have done for a moment, but not after a while.  I --

17     I thought it was a prank then, and I still do.

18        Q.   So whatever the Serbs say, that will be your view; isn't that

19     right, Mr. Vulliamy?  During the interview, I informed you that the Serbs

20     consider you to be highly partial, most partial; isn't that right?

21        A.   Well, if so, that's unfortunate.  I am, as I tried to explain

22     in -- when we were talking about neutrality, I am highly partial about

23     extreme violence.  I'm not highly partial about any particular race of

24     people or -- or -- or ethnicity or whatever.  In fact, I'm highly partial

25     against racialism.  So I'm not anti-Serb.  I'm anti-what was done.  In

Page 21103

 1     name, sometimes, of Serbia, tragically, which was opposed by very large

 2     number of Serbs at the time and since.  And if Their Honours want to hear

 3     about my social acquaintances with Serbs, I'm very welcome to supply it.

 4     I don't want to sound like some of my best friends are but my colleague

 5     with whom I worked during the year of the war described in the book is a

 6     Serb and I knew many Serbs during the war and still know many now, so

 7     I'll leave my answer at that.

 8        Q.   Thank you.  You mentioned today that as far as Trnopolje was

 9     concerned, it was a camp for deportees.  During the interview, we

10     established that you did know that people could leave and get food;

11     right?  During the interview, you said that some could and others

12     couldn't.  This is what I'm putting to you now as well:  People who had

13     their own vegetable gardens could go and get food, and probably the

14     people who did not have their own gardens did not go to get food because

15     there was no other way of getting food.

16             What was it that you knew?

17        A.   What -- the -- who could and couldn't leave Trnopolje seems to be

18     quite capricious.  Obviously if you were from Prijedor, which is a long

19     way away, you wouldn't be going home, and some people were forcibly

20     brought there.  Others went of their own accord, and we've established

21     that.

22             I don't know exactly who was able to leave and who wasn't.  I

23     know that it had to be negotiated.  I've spoken to people at the medical

24     centre.  They were able to get people who were abandoned in their houses,

25     infirm or whatever, and were brought to Trnopolje.  Others were corralled

Page 21104

 1     on buses, as is well established by this Tribunal, were taken there

 2     en masse.  So -- and this is why it's -- the definition has been an

 3     issue, and I decided to call it a concentration camp on the basis of the

 4     South Africa dictionary definition.  But your point about who was and

 5     wasn't allowed to leave to get food and who was or wasn't allowed to so

 6     under guard is whimsical.  I don't exactly understand what the rules were

 7     if there were any hard and fast rules.  I'd just like to, if I may, if

 8     Your Honours will allow me to get back to this point about this serious

 9     allegation of extreme partiality, it is in the record, but I proceeded

10     immediately after all this to go and look at -- investigate camps with

11     Serbian prisoners and I think I'm the only person who actually uncovered

12     them.  Sorry, I'm retrogressing there, but I do take this sort of

13     allegation of anti-Serbian sentiment extremely seriously and I'd like to

14     go on to -- if I'm asked about that visit to the camp, which I may not

15     be, I'd just like to put it on record that I -- I made it my business to

16     do exactly that.  In fact, it was a camp that Mr. Karadzic on the film

17     that we saw, it's one of those that he wanted to go and see, and I made

18     it my business to do so in the interests of impartiality, and partiality

19     over the practise of putting people into camps.  So it was Serbian

20     prisoners in the other one.  Sorry, I'm replying to the previous

21     question.  I apologise.

22        Q.   Thank you --

23             JUDGE MORRISON:  I'm not smiling at you.  I am smiling with you.

24     I anticipate I would be doing much the same thing.

25             For this reason, as you know, Dr. Karadzic, it's been said in

Page 21105

 1     open court many times and I say it again, it isn't the Serbian people who

 2     are indicted in this case nor the Serbian state.  It's you, and you need

 3     to concentrate on that reality.

 4             THE ACCUSED: [Interpretation] Thank you, Excellency.  However, as

 5     things stand, I have been indicted as the civilian head of state and of

 6     the army for everything that every crook did on the ground.  I am trying

 7     to prove that this had nothing to do with the system whatsoever.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   However, today you said, Mr. Witness, that they were brought

10     after raids, but look at page 3 of this report of yours.  This boy from

11     Rizvanovic is telling you nicely.  When the fighting started, the Serbs

12     rallied the civilians and took them away so that they could continue the

13     fighting.  Do you know that in accordance with our law civilians have to

14     be evacuated from a combat zone?

15        A.   Yes, and the civilians were evacuated from their homes and taken

16     to Trnopolje and I don't know what exactly happened to the -- the

17     civilians from that village, but I would be surprised if any of them had

18     got back to their houses before about 1999, if at all.  But I don't

19     dispute what you're saying and what I wrote about this boy.  Obviously it

20     appears caught in the line of fire and as the village was, as the article

21     says, cleared and taking refuge with -- with soldiers under your command

22     and going to Trnopolje.  I don't dispute that at all.

23        Q.   Thank you.  As for this deportation, do you know that these

24     persons who after the Muslim extremists, the Green Berets, the Muslim

25     extremists turned Prijedor into a theatre of war through their own

Page 21106

 1     actions, do you know that they asked to be evacuated either to

 2     Central Bosnia or to Europe, that they obtained many documents, that they

 3     paid for them?  So that was not deportation.  The Defence says that that

 4     was not deportation.  This was evacuation, of course due to difficulties.

 5     However, it was based on requests made by these persons.

 6        A.   I didn't know that, no, because when I went with the people on

 7     that convoy, they told me something different, that -- that -- that

 8     soldiers and policemen had come around to their houses and given them

 9     ultimata to leave and sometimes they had some squabble over who was going

10     to get the house and that they had been corralled, in this case, into a

11     location in the village of -- town, sorry, of Sanski Most, and that

12     the -- the people on the convoy that I travelled with were leaving

13     anything but voluntarily.  The convoy was marshalled to order by armed

14     guards and patrolled along its way by armed guards.  Nobody I spoke to

15     had any idea where -- where they were going.  Correction.  Some people

16     did know later, that I talked to later in the night when we were on foot,

17     that they were going to -- to government-held territory.  But I didn't

18     meet anybody who gave me that account nor have I since spoken to anyone

19     who has given me that account for what I did not know that night of

20     August the 17th, 1992, but soon after knew when nightly deportation

21     convoys, and indeed four nights after ours on August the 17th.  There was

22     one on August the 21st [Realtime transcript read in error "24th"] during

23     which large numbers of people were taken off the buses and executed on

24     Mount Vlasic, so -- known to this Tribunal as the Vlasic massacre.

25             So, no, sir, I didn't know that those were the reasons why those

Page 21107

 1     convoys were going over Vlasic.

 2             JUDGE KWON:  Mr. Karadzic, we'll take a break now for half an

 3     hour.  We will resume at half past 12.00.

 4                           --- Recess taken at 12.01 p.m.

 5                           --- On resuming at 12.33 p.m.

 6             JUDGE KWON:  Yes, Ms. Sutherland.

 7             MS. SUTHERLAND:  Your Honour, very quickly.  Back on page 64, I

 8     said that the Vulliamy article that was published on the 7th of August

 9     was an associated exhibit, and it is -- it is P3788.  Correct me if I am

10     wrong, Mr. Registrar.

11             JUDGE KWON:  Which is 65 ter number 19682.

12             MS. SUTHERLAND:  Yes, Your Honour.  And that was the "Guardian"

13     article, whereas Mr. Karadzic has been using a copy of that article from

14     the "Toronto Star" and has -- had certain -- taken the witness to certain

15     boxes in that article so I think it's perhaps better that we keep a

16     Prosecution and Defence exhibit unless Your Honours are minded to -- to

17     cross-reference both in e-court perhaps.

18             JUDGE KWON:  Why don't we just leave it as it is.

19             MS. SUTHERLAND:  Yes.  That's what I was suggesting, Your Honour.

20     I'm sorry if I wasn't clear.

21             And the other thing, just for the record so that it's clear, the

22     interview that Mr. Karadzic keeps referring to that -- that the witness

23     has had with him is an interview that was conducted yesterday afternoon.

24             JUDGE KWON:  Thank you.  Yes, Mr. Karadzic.  Please continue.

25             THE ACCUSED: [Interpretation] I would like to call up 1D04816 in

Page 21108

 1     e-court.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Mr. Vulliamy, I would kindly ask you to just answer by yes or no

 4     whenever possible, because we don't have that much time, and secondly,

 5     please do not rely on what you have heard in this court or elsewhere,

 6     from somebody else.  Just share with us what you know yourself.  This is

 7     the most important thing for us here.

 8             Do you remember this text?

 9        A.   Yes.

10        Q.   Thank you.  Let's look at the subtitle.  It says that:

11             "Ed Vulliamy is one of only two journalists to take the stand in

12     the historic Bosnia war crimes trial at The Hague."

13             Right?

14        A.   Yes.  I wouldn't have written that.

15        Q.   The way Mr. Karadzic put the question was that you took side --

16     sides with somebody.

17             [In English] "He describes his day in court as witness for the

18     Prosecution confronting an alleged torturer.

19        A.   That's what's called a stand first.  I wouldn't have written it,

20     but I was a witness for the Prosecution, yes.  Your Honours, I've spotted

21     quite an important error further up the transcript.  I don't know what to

22     do about that.  Sorry to interrupt.

23             JUDGE KWON:  Yes.  Our usher could assist you.  I'm not sure

24     whether your monitor can have that scroll.  No.  If you remember some

25     word that we can find it, I will read it to you so that you can correct

Page 21109

 1     it.

 2             THE WITNESS:  Thank you, sorry.  Yes, this is a stand first.  I

 3     wouldn't have written it but it does say accurately, sir, that I

 4     testified for the Prosecution, which I did.  I think this is the Tadic

 5     case.

 6             JUDGE KWON:  Now you can scroll.  I think you can find the text

 7     you have in mind.  Could you took -- take a look.

 8             THE WITNESS:  Yes.  It's -- sorry, Your Honours.  It's just

 9     before we went for the break there are dates and things that are wrong.

10     Our convoy was August the 17th, 1992, and the massacre was four days

11     after ours on August the -- ours was on the 17th.  The massacre was on

12     the 21st, not the 24th.  I do apologise for interrupting.  Sorry,

13     Dr. Karadzic for --

14             JUDGE KWON:  Four days after ours.

15             THE WITNESS:  Four days after.  Ours is on the 17th, not the

16     18th, and the massacre is on the 21st.

17             JUDGE KWON:  Thank you.

18             THE WITNESS:  I apologise to Your Honours and Dr. Karadzic for

19     spoiling the -- interrupting the proceedings.

20             JUDGE KWON:  Not at all.

21             Yes, Mr. Karadzic.

22             MR. KARADZIC: [Interpretation]

23        Q.   Let me just ask you this:  You said that there was police escort.

24     Do you know that on the 22nd of May we signed a commitment to escort

25     civilians who were transferring from one side to the other?  Just yes or

Page 21110

 1     no.  In other words, UNHCR was a middle man and the three sides signed an

 2     agreement for the police to escort all civilian convoys crossing from one

 3     side to the other.

 4        A.   No, I didn't know about this agreement, sir.

 5        Q.   Thank you.  Can we go to the following page, please.  Let's look

 6     at the second paragraph at the bottom above the advert.  Yes, this is it.

 7     There is a reference here to Dr. Azra Blazevic.  You mentioned her

 8     yourself earlier today.  It is also stated that Trnopolje camp is a

 9     concentration camp; right?  A bit further up there is a reference to

10     Omarska and the other camps in the Serbian gulag.  Do you see that?  We

11     have lost it now.  Can we scope up a little.  Scroll up.  The second

12     column.  Scroll down, scroll down.  Very well, now that's it.  Yes.

13             There's a reference to Omarska:

14             [In English] "In the other camps in Serbia's gulag, and --"

15     [Interpretation] It says here that Trnopolje's a concentration camp just

16     after the reference is being made to Dr. Azra Blazevic; right?

17        A.   Yes.

18        Q.   Can we go to the far right end of the document.  Here you are

19     quoted as saying [In English] I would have been as proud to testify --"

20     no, no, no, no, no. "... to testify for Sir Hartley against the Nazis as

21     I am to do so at The Hague against those who echoed them with a pale but

22     unmistakable imitation."

23             [Interpretation] Is it your view indeed that we are a pale but

24     unmistakable imitation of the Nazis?

25        A.   I'll stand by that.  We discussed this.  Indeed it's a point of

Page 21111

 1     semantics and a point of history.  The word "echo" I -- was, what was it,

 2     forged, if you like, the right to use that word in consultation with

 3     people at the Holocaust Memorial Museum in Washington.  Pale, yes.

 4     Unmistakable, yes.  And again, it's -- we're back to this point about the

 5     internment, murder of people for reasons of ethnicity, mass deportation

 6     for reasons of ethnicity, and so, yes --

 7        Q.   [Overlapping speakers]

 8        A.   -- I will stand by that.

 9        Q.   Thank you.  Thank you.  We've already heard that and we don't

10     have time.  Thank you.

11             JUDGE KWON:  Mr. Karadzic, if you ask the question, you should

12     allow the witness to complete his answer.

13             THE ACCUSED: [Interpretation] Well, I apologise.  I believe that

14     the side questioning the witness should control them.  If I had the time,

15     I would only be too glad to listen to Mr. Vulliamy, but if not, then I

16     just wanted to know whether this is Mr. Vulliamy's view or not.

17             MR. KARADZIC: [Interpretation]

18        Q.   Now, my next question is this:  Do you now think that this

19     contributed to the fact that some Serbs consider you as having anti-Serb


21        A.   Well, if some do, then perhaps they're the ones who support what

22     was being done in their name.  The Serbian friends that I have and have

23     had throughout -- throughout the war and still have do not, and many of

24     them, I think, would probably agree with this -- with this estimation.

25     There are -- if we're going to continue with this echo, there are very

Page 21112

 1     large numbers of Germans who were appalled by what was done in their name

 2     and have been part of the reckoning in that country to -- to come to

 3     terms with it.  If any Serb thinks I'm against all Serbs, they are, A,

 4     wrong, and I regret that they held that view.

 5        Q.   Thank you.

 6             THE ACCUSED: [Interpretation] Can this be admitted?

 7             JUDGE KWON:  Yes.

 8             THE REGISTRAR:  Exhibit D1900, Your Honours.

 9             MR. KARADZIC: [Interpretation]

10        Q.   And now I would like to show you an exhibit, a Prosecution

11     exhibit, an excerpt from a visit to Trnopolje.  You know very well the

12     dispute that broke out between the "Living Marxism" where Thomas

13     Deichmann published that that was staged.  And now I'm going to show you

14     that the wire that is depict -- depicted actually the wire surrounding

15     building tools protected them and not the people who were detained in

16     Trnopolje.  4504.  65 ter 40504, and the English transcript page is 6.

17     No, no, not that, no.

18                           [Video-clip played]

19             MR. KARADZIC: [Interpretation]

20        Q.   Can we stop here?  Do you see any wire here, Mr. Vulliamy, or are

21     these people seated in a totally open area?

22        A.   I -- it's hard -- I can't see any wire, and I don't know whether

23     this was shot on August the 5th or when the -- as I called it, the circus

24     went back by which time the wire had come down, as I understand it.

25                           [Video-clip played]

Page 21113

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Now we will see.  Let's move on.

 3                           [Video-clip played]

 4             MR. KARADZIC: [Interpretation]

 5        Q.   This is just one part.  Do you agree -- we will see that that was

 6     taken on the same day when you and Penny Marshall were there, the same

 7     journalist.  Everything is the same.

 8        A.   That last picture, yes, sir, that appears to be August the 5th.

 9     I think we've seen an excerpt from that before.  That's when we were

10     there, yes, sir.

11        Q.   And please bear with me while I'm looking for the number of that

12     excerpt where you will also see Mr. Bozanic.

13             MS. SUTHERLAND:  Your Honour, I can -- if Mr. Karadzic is wanting

14     the exhibit number of that excerpted, it's P03697.

15             THE ACCUSED: [Interpretation] Yes.  Thank you very much.  I would

16     like to call that up, if possible.

17                           [Video-clip played]

18             MS. SUTHERLAND:  Your Honour, this isn't --

19             THE ACCUSED: [Interpretation] We have to go back to the

20     beginning.  This is not the beginning.

21             JUDGE KWON:  Just a --

22             MS. SUTHERLAND:  This is -- this is still taken from the -- this

23     footage that was just played is coming from the bigger video-tape.  I

24     thought Mr. Karadzic just wanted the excerpt that was shown through a

25     witness last week or just very recently that was admitted through him,

Page 21114

 1     and that is Exhibit P03697 and it's 65 ter number 40504B.  It's a

 2     15-second clip.

 3             THE ACCUSED: [Interpretation] Yes.  That's -- that's precisely

 4     that.  I apologise for not being precise enough.  40504B.  Can we see

 5     that?

 6             Do we have it?

 7             JUDGE KWON:  What I was told is that we -- e-court has the

 8     transcript but not the -- not the video itself.

 9             MS. SUTHERLAND:  Your Honour, this morning I played that -- I

10     played that excerpt this morning.  Mr. --

11             JUDGE KWON:  Reid.

12             MS. SUTHERLAND:  Mr. Reid is getting it in Sanction.

13             MR. KARADZIC: [Interpretation]

14        Q.   Our thesis which was also proposed by Mr. Deichmann that the

15     fence around the compound with building tools is what we saw and that

16     Ms. Marshall entered the compound and that she was on the other side

17     within the wire and not the detainees.  You in your turn contest that;

18     right?

19        A.   Yes, I do.  This thesis, as you call it, was advanced in 1996 or

20     1997.  We'd heard nothing of it in between 1992 and that year from you or

21     anybody else.  And I do contest it, yes.  I am, if anything, more

22     convinced now than I was even on that day that those men were detained

23     and under guard.

24        Q.   How come you are more convinced today than when you saw things

25     with your own two eyes.  What is it that makes you more convinced today

Page 21115

 1     than ever before?

 2        A.   Well, at the time, it was very obvious to me that they were

 3     prisoners, but since then, as you know and the Bench may know, there has

 4     been a court case in London -- when you mentioned "Living Marxism" who

 5     published this thesis, your word, were sued by ITN and lost.  ITN won the

 6     case.  It was a civil case, I agree, at lower burden of proof, and I had

 7     the opportunity to interview a number of the prisoners since who have

 8     described to me how they got there, why they were there, and they were

 9     certainly -- we were not filming -- they were not filming, sorry, from

10     inside any compound outside, nor was I, let's talk about me, not ITN,

11     interviewing people through that fence from inside any kind of detention

12     facility taking notes from people who were at liberty wandering around.

13        Q.   Thank you.  You derive the additional information from the events

14     and developments at various courts and you tend to believe that

15     information more than you believe what you saw with your own two eyes;

16     right?

17        A.   No.  I believed what I saw with my own two eyes that they were

18     prisoners and were detained and under guard behind that fence and others,

19     and on talking to them I have that belief confirmed and this has been

20     gone over and over on oath many times, and -- I'm not saying

21     especially more -- I'm saying that my description of them as prisoners

22     has been proved accurate over and over again.

23             MS. SUTHERLAND:  The video-clip's ready, if Mr. Karadzic wishes

24     to play it.

25             THE ACCUSED:  Thank you.

Page 21116

 1                           [Video-clip played]

 2             THE ACCUSED: [Interpretation] Can I stop here, please.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Mr. Vulliamy, do you see a single emaciated person like that

 5     person Alic was?

 6        A.   Not in this picture, no.  They were in various states of decay I

 7     think was the word I used.  But I'm -- I'm -- I'm saying they're

 8     prisoners.  No, sorry.

 9             THE ACCUSED: [Interpretation] Can we continue.

10                           [Video-clip played] 6c

11             THE ACCUSED: [Interpretation] Stop.

12             MR. KARADZIC: [Interpretation]

13        Q.   Do you see the tools here?  Do you see that this is actually a

14     storage of all the building tools and equipment?  Do you see the

15     wheelbarrows and things like that?

16        A.   I can see wheelbarrows by the fence, yes.  I didn't notice them

17     at the time.  There were other things to look at.

18        Q.   Thank you.  Did you at the time notice and did you make a note of

19     what you noticed, and that was that the fourth side did not have any

20     wire, that it was open?

21        A.   To my recollection, the compound was wire on three sides and a

22     building on the fourth side.

23        Q.   Thank you.  1D04818 is what would I like to call up now.

24     1D04818.  Do you remember that you were interviewed by Slobodna Bosna on

25     the 10th of August, 1997?  The title here is "I live for the day when I'm

Page 21117

 1     going to take a stand in The Hague against Karadzic."

 2        A.   I don't remember doing that interview.  I don't deny that I did

 3     it, and I take no responsibility for the headline they put on it.  No

 4     disrespect.  I have not lived for this day.

 5        Q.   Thank you.  Can we see the next page, please.  It seems that you

 6     also had to say something about Minister Douglas Hurd.  Can we also see

 7     the following page in Serbian, and now we can see the title here, "How

 8     did Karadzic make a mistake?"  The question here is:  How come you were

 9     invited to visit the camps?  And you say that while you were in London,

10     Karadzic invited me to see Omarska, Manjaca, and Trnopolje, and so on and

11     so forth.  The next question is about the permit that you received to

12     visit those camps.  Why do you think that Karadzic allowed you to visit

13     the camps?  He could have changed your mind.  And your answer is:  God

14     knows.  My assumption is that he did not intend to let us see Omarska.

15     We know that because there was a prank set up for us in the form of a

16     false battle, and our escorts told us that those were Mujahedin in the

17     forest.  We demanded that we should continue.  The Red Cross was already

18     in Manjaca.  I suppose that he wanted to show us a small part of

19     Trnopolje.  He certainly didn't want us to see the part where people from

20     Keraterm and Omarska were brought or else Karadzic is as stupid as

21     happens [as interpreted].  After all, he was the last one to laugh,

22     right, and so on and so forth.

23             Wouldn't you say that this is another thing that has prompted

24     some Serbs to believe that you are impartial and that you will not be an

25     objective witness in my trial?  Things have not been recorded properly.

Page 21118

 1     You said "or else Karadzic is as stupid as he appears."  This is what you

 2     said, and this was not recorded.

 3             This interview of yours, did it contribute or did it provide the

 4     basis for people's concerns and doubts about your impartiality as a

 5     witness in -- in my trial?

 6        A.   I'd like to, in response to many questions there, first of all,

 7     establish some distance between what I say and what appears in Bosnian

 8     magazines.  I haven't had this translated back to me before, but I have

 9     had other articles translated back to me which -- and I do not recognise

10     what I said.  I would just like to put it on record that whatever else I

11     might think about what had happened under your authority, I do not think

12     you're stupid, sir.  I have actually said to a number of people over the

13     last 48 hours that you are clever and I would like that put on record.

14     As regards the other matters, yes, I was and remained curious and

15     sometimes baffled as to why you did authorise the visit to Omarska.  What

16     I suppose I was trying to explain to this magazine is that when we got

17     there, judging from what we were told and what happened and our inability

18     to see inside the hangar, that, as it was put by Mrs. Balaban earlier in

19     evidence, we could see this and this and that but not that.  And he

20     quotes her again.  He promised us something else.  So I suppose what I

21     was trying to convey to them was that perhaps you had intended us to see

22     one part of the camp and not the other.  That was my inference from what

23     Mrs. Balaban was saying.

24             With regard to Trnopolje, and I'm inferring here, I -- perhaps

25     you did think that it would be all right for us to see the main area with

Page 21119

 1     the buildings and the -- where the medical centres were but perhaps could

 2     not have anticipated our coming upon the men who were in that compound

 3     who had that day, August the 5th, arrived from Omarska and Keraterm, but

 4     I would like to use this opportunity to retract and perhaps to rebuke

 5     this magazine for translating me as calling you stupid because I do not

 6     think you're stupid and I never did.

 7        Q.   Thank you.  Why do you presume so much when I openly told you you

 8     could see everything for yourselves?  Yet you revert to your presumptions

 9     again trying to guess what my intention was.  My intention was for you to

10     go and see it all and to make sure that the people in the field will --

11     were aware of the fact that someone was going to see it.  Why do you back

12     to presumptions?

13        A.   I suppose because they're not presumptions.  They're based on --

14     just on what we were told when we went in there.  When we tried to cross

15     the tarmac pista to go into the hangar, we were told that you -- we were,

16     sorry.  We were told, I was told - I can't say I -- I was told -- I was

17     standing behind Ms. Marshall at the time that you had told them we

18     couldn't and, as I think is clear from the film, so that's the basis of

19     what you call my presumption.  I wish you had -- we had been allowed

20     to -- I -- I don't know what your exact instructions to them were because

21     I wasn't privy to them, but my understanding was that we would see

22     everything and we didn't see everything.  In fact, we hardly -- we saw

23     the tip of the iceberg but it was explained to us that your authority did

24     not extend to us seeing all the camp.

25        Q.   Thank you.  Yesterday when we met, we discussed Mr. Williams

Page 21120

 1     having conveyed something and you overheard that.  Supposedly someone

 2     said that my instructions are not abided by there, and in the interview I

 3     repeated my words when I said that if there were people there who were

 4     disobedient, I'd be most interested in seeing who they were.

 5        A.   Yes.  I -- I recall us looking at Mr. Williams's remarks on paper

 6     and his inference was that your -- hang on.  His inference in the

 7     transcript that we looked at was that your authority didn't, as I think

 8     you put it, carry weight in Omarska but this is between -- this is for

 9     Mr. Williams to -- to talk about.  What I understood was that what was

10     being explained was that we had been told that we would be able to see

11     that the camp, indeed the whole region, unfettered and it turned out that

12     we were fettered, and it was explained to me, us, that -- that that was

13     not the case, that your instruction were, as Mrs. Balaban translated,

14     otherwise.  What Mr. Williams made of that, you'd better call him.

15        Q.   But Mr. Williams quoted someone else, a local Serb.  Apparently

16     he was told that Karadzic's instructions or orders do not carry weight

17     there.  He was quoting someone.  It wasn't his conclusion, was it?

18        A.   I didn't hear those words being used by anybody else, but -- but

19     I was dependent on -- on -- because I don't understand the language, I

20     was dependent on what Mrs. Balaban was saying, which we've seen part of

21     it.  A relevant part of which was -- and again I don't recall the exact

22     words but that -- I think he says he promised us something else and that

23     we could see this and this but not that.  That there was a dichotomy

24     between our understanding -- our respective understandings on what you

25     had authorised.

Page 21121

 1        Q.   Thank you.  Do you agree that on page 15, line 21, we have her

 2     words incorrectly interpreted.  She only said, "I was only there to

 3     interpret."  She wasn't interpreting my words.  She simply placed a hedge

 4     protecting herself having said I'm here only to interpret.

 5        A.   Yes.  I didn't infer that she was making the decisions herself.

 6     My inference, as she was interpreting as she said, was that the -- as it

 7     were the block on our further visiting and going into the part of the

 8     camp that I now understand to be the bit that mattered was being imposed

 9     by Mr. Drljaca, Colonel Milutinovic, and Mr. Meakic who would have been

10     in a position of authority, not her.  As she said, she was translating

11     for them.

12        Q.   Thank you.

13             THE ACCUSED: [Interpretation] Could this interview be admitted.

14     Unfortunately, only this column was translated.  If necessary, we could

15     have it all translated, although I don't see the need.

16             JUDGE KWON:  Original is four pages and the translation is three

17     pages.  I think that's sufficient, Ms. Sutherland.

18             MS. SUTHERLAND:  Your Honour, we will, ourselves, take a --

19     review this article in B/C/S and bring anything to your attention that we

20     need to.

21             JUDGE KWON:  I think we can admit only those part then which has

22     been translated.

23             MS. SUTHERLAND:  Yes, Your Honour.  At the moment, yes.

24             JUDGE KWON:  Yes, we'll admit it.

25             THE REGISTRAR:  Exhibit D1901, Your Honours.

Page 21122

 1             Mr. KARADZIC: [Interpretation]

 2        Q.   I briefly wanted you to see what the deportations in question

 3     looked like.  For that purpose, could we see 1D4820.  Of course when it

 4     refers to me deportation is in inverted commas.  Please have a look at

 5     this article, interview with an official of the Red Cross.  It was in

 6     Banja Luka, and the Red Cross director said Muslims must be moved.  The

 7     entire interview, have a look at the fourth paragraph, for instance, says

 8     that there are people who wished to leave and there were between 1- and

 9     200.000 alone in this region around Banja Luka.  It goes on to say even

10     if we were to find a solution now for these 3- or 4.000 people, we would

11     immediately have to deal with 10.000 who would follow, and so on and so

12     forth.  Did you know of this position taken by the Red Cross?

13        A.   I've had various altercations with the Red Cross over their

14     handling of the camps.  I didn't know about this particular position but

15     it doesn't surprise me.  The word desperately strikes me in this text,

16     but I -- this is a conversation between -- someone called Jakovsky and

17     someone called Schweizen.  I can't really comment on it.  I have to read

18     it to know exactly what they're saying.  I take it this is the Red Cross

19     -- as I understand it, this is the Red Cross, but I don't know if it's

20     the ICRC or the local Red Cross saying that people are desperate to

21     leave.  What I do have direct experience of is a deportation convoy and I

22     can testify to that if -- if Your Honours want me to or if you ask me

23     about it.  And certainly none of these people asked to leave, quite the

24     opposite.

25        Q.   We can go back to the top.  It appears to be the director of the

Page 21123

 1     ICRC who was in Banja Luka at the time.

 2             THE ACCUSED: [Interpretation] Could we have the document

 3     admitted?

 4             JUDGE KWON:  If Mr. Robinson can help us on what basis we should

 5     admit this.

 6             MR. ROBINSON:  Well, frankly, Mr. President, I don't see any

 7     basis on which you can admit it, based on what the witness has testified

 8     to so far.

 9             JUDGE KWON:  Mr. Karadzic, you'll have another opportunity to

10     tender that through another witness.

11             THE ACCUSED: [Interpretation] Thank you.  Could we have 1D04817,

12     please.  Please zoom in on the bottom half.

13             MR. KARADZIC: [Interpretation]

14        Q.   Is this your commentary concerning the arrest of Saddam Hussein?

15     And there is a reference to me.

16        A.   Yes.

17        Q.   Do you have any proof that I was a tyrant?

18        A.   Can we just -- sorry, sir, to answer your question, no.  No, I'm

19     aware that you were elected by your party, though not in -- though not

20     in -- not in the Presidency with regard to the whole of

21     Bosnia-Herzegovina.  Do I use the term "tyrant" in the copy?  Because can

22     we just -- the thing is I wouldn't have written the headline.

23        Q.    I believe so.  Could we go to the next page.  Look at the

24     paragraph beginning with "Imagine Radovan Karadzic."

25        A.   Yep.

Page 21124

 1        Q.   Is this your position about me?

 2        A.   Forgive the cocksure swagger.  You did have one at the time.  The

 3     language is a little strong, I'll admit, but I don't see me describe you

 4     as a tyrant.  I'm aware that you were elected.  Rhetoric, yes.

 5     Bloodlust, I'm not sure about you personally but certainly in your name.

 6     And I was not particularly gratified by the site of the stuck

 7     [indiscernible] as much as I despised him.  I'll grant you the language

 8     is a little strong.

 9        Q.   At the bottom:

10             [In English] "There will be no Guantanamo Bay for the camp guards

11     of Omarska or the execution at Srebrenica."

12             [Interpretation] Can we go to the next page then.

13             [In English] "For three years --" [Interpretation] Have a look at

14     that paragraph:

15             [In English] "For three years the great powers wined and dinned

16     Karadzic, flattering this tin-pot tyrant's delusions of statesmanship."

17        A.   Right.  Well, you have that.  I called you a tin-pot tyrant.  And

18     the point is that this is actually directed not so much as you as at the

19     people in the West who I saw as, indeed, wining and dining you and

20     shaking your hand under the chandeliers.  Those of us working on the

21     ground found this fairly baffling and much of -- many of those people

22     were, after you were indicted, bayed for you to be arrested as a war

23     criminal.  As for the how Karadzic must have laughed to himself, I now

24     know that from interviewing several of your entourage and friends in

25     Belgrade, Pale and Sokolac and elsewhere that you did indeed find it, or

Page 21125

 1     at least they did -- and describe you finding it, yeah, fairly amusing

 2     that you were being feted in this way and that they took your -- that

 3     they took your -- I mean -- I -- I talk about tin-pot statesmanship.

 4     That's a little arrogant, I agree, but that -- that you were -- that I --

 5     it has been described to me that you are -- found the seriousness with

 6     which you were being taken by these people very flattering, but that's

 7     hearsay again.  These are your -- your entourage.  No, they not in your

 8     garage, they're your entourage.

 9        Q.   Well, yes.  Do you know that Mr. Akashi was on the Muslim's

10     blacklist because he addressed his letter to me as His Excellency, as I

11     did to him?  Do you know he ended up on their blacklist for that?  And

12     does it reconcile with the position you express?

13        A.   Sorry.  No, I didn't know he was on any particular blacklist.  I

14     personally found his -- if Your Honours will accept political discourse,

15     diplomatic assessments, I found his tolerance of what was going on for

16     these three long bloody years -- I didn't agree with it.

17        Q.   Do you agree that Mr. Akashi must have been more familiar with

18     the reasons of the conflict than you were because he dealt with all four

19     warring parties?  He was in discussions with all of them.

20        A.   He listened to many more politicians and diplomats than I did.  I

21     didn't talk to many of either, but he saw a lot less of what was

22     happening on the ground than I did.

23        Q.   Thank you.  May we have this admitted?

24             JUDGE KWON:  Yes.

25             THE REGISTRAR:  Exhibit D1902, Your Honours.

Page 21126

 1             THE ACCUSED: [Interpretation] Could we please have 1D4805.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Is this another text of yours from 2010?

 4        A.   Yes, absolutely.

 5        Q.   Is this your commentary of my introductory remarks or my opening

 6     statement, rather, when the trial began?

 7        A.   Yes.  Yes.

 8        Q.   Could we go to the next page please.  Have a look at the second

 9     paragraph.

10             [In English] "Karadzic's arguments," and so on.

11             [Interpretation] And the third paragraph I won't read them all.

12     Could this have contributed to the Serb belief that you are not biased,

13     that you see things to our detriment?

14        A.   It depends who we are.  Serbian -- it's -- it's not for me to

15     second-guess what Serbian people think, but what I'm saying here is that

16     this continual denial and revision, to use the term of -- of what

17     happened in those camps and the existence of the camps, has a searing

18     effect on those who survive them and were bereaved by them and that's the

19     point I'm making in -- in the penultimate picture -- at paragraph, sorry.

20     But the -- with regard to what Serbs think about me, I would suppose

21     answer that Serbs who supported what happened and who approve of what

22     happened in those camps might dislike me and feel I was attacking them

23     for -- for objecting to this grotesque notion that the camps were in some

24     way fabricated by me and others but that those who disapprove of or never

25     wanted anything to do with or indeed approved of but are now ashamed of

Page 21127

 1     such camps would have no reason to object to my objections to the notion

 2     that they were fabricated in an a media conspiracy because they were not.

 3     I hope that makes sense.

 4        Q.   Thank you.  But your position here is as if a judgement had

 5     already been pronounced.  There isn't a single question mark.  You simply

 6     appear to know things, and you assume your position; correct?

 7        A.   I'm talking about here about -- sorry, it starts "invoke today"

 8     that I can see.  I'm going certainly down that chain of command yourself,

 9     Dr. Koljevic, Milutinovic, Stakic, Kovacevic, et cetera, through the

10     gates of the camp.  That was seamless but this was about -- about the

11     fake pictures argument that's been heard in this Tribunal many times.  As

12     I say here it's been destroyed by the Prosecution serially, run like a

13     Basel through the internet.  It does repeated in [indiscernible] it was.

14     It is old.  It goes back to 1996 but significantly not to 1992.  It is

15     tired because it keeps getting overthrown, and serially unsuccessful.

16     But here, what I'm saying, sir, is it's heartless and poisonous because

17     the people who advance it don't seem to imagine what it's like to survive

18     or be bereaved by those camps and it has a terrible effect on them, this

19     idea that somehow their suffering did not happen.

20        Q.   Thank you.

21             THE ACCUSED: [Interpretation] could we have this admitted?

22             MR. KARADZIC: [Interpretation]

23        Q.   While we are waiting for that, Mr. Vulliamy, I'll tell you this.

24     The prisons for POWs were Kula, Batkovic and Manjaca.  Omarska was an

25     investigation centre.  It was a factory, or rather, a mine which had to

Page 21128

 1     be brought to its original purpose.  You, yourself, confirm that it was

 2     an investigation centre and that there were investigators working there

 3     around the clock in order to screen --

 4             JUDGE KWON:  I think that has been asked and answered.  We'll

 5     admit that article as Exhibit D1903.  Let us continue.

 6        Q.   1D04819 is the document that I would like to call up.  1D04819.

 7     While we're waiting, Mr. Vulliamy, could you please tell us how many

 8     interviews did you give?  How many articles did you write after your

 9     visit to Omarska and Trnopolje?  You said there were about 40 interviews;

10     right?

11        A.   That day, August the 7th, in Belgrade was endless interviews and

12     I was not enjoying it, as I think I've indicated in print and in my

13     testimony, and some of them annoyed me very much, but it was -- it was

14     seen as something that people wanted to hear about.  I don't know how

15     many exactly.  I think it was -- it must -- it was 40, 50.  I mean, it

16     was non-stop.

17        Q.   Thank you.  In your book you say 54.  How many article, how many

18     texts you based on your visit?  You say that there were about 200 or even

19     300 texts; right?

20        A.   I don't know how many, but I've written a lot about it.

21        Q.   Thank you.  Can we scroll up a little.  You wrote this when I was

22     arrested; right?

23        A.   Yes.

24        Q.   Your position in the article was clear.  Again you were biased.

25     Let me not read everything.  You say that this was the first time after

Page 21129

 1     the Third Reich and you say that I arranged the mass murder of 100.000

 2     people and the enforced deportation of 2 million people, and so on and so

 3     forth.  Is this still your position even today?

 4        A.   It's for the Court to adjudicate whether you're directly

 5     responsible for it, but since that day we met and I went into the camps I

 6     can't deny that I haven't had a direct interest in it.  It would be weird

 7     if it hadn't had an effect on my life.  I have remained in touch with a

 8     large number of survivors and the bereaved, and I have been of the

 9     belief, again subject to the Court, that you were in a position of

10     leadership over all this, as I say here.

11        Q.   Thank you.

12             THE ACCUSED: [Interpretation] Can this be admitted?

13             JUDGE KWON:  Yes.

14             THE REGISTRAR:  Exhibit D1904, Your Honours.

15             MR. KARADZIC: [Interpretation]

16        Q.   You received several coveted awards for journalism and for the

17     results in writing of your visit to Omarska; right?

18        A.   I've specifically for that three or four, yes.  Hang on.  Four.

19        Q.   Thank you.  1D04805 is the next document that I would like to

20     call up.  So we can say that this was the most productive ever visit to a

21     place 54 interviews, hundreds of pages of articles and four coveted

22     awards; right?  No, that's not the document I want.  We already saw that.

23     Just a moment, bear with me.

24             Do you agree that that was the most productive visit to anyplace

25     during the war?

Page 21130

 1        A.   No, I don't see it as productive.  I would much rather have not

 2     found Omarska and as much as I did.  Well, would -- 54 interviews would

 3     be irrelevant.  I didn't enjoy any of them.  I'm still on the same salary

 4     band as I was then.  I am a working reporter.  My pay has only increased

 5     incrementally.  The awards mean a lot to some people, less to me, but

 6     I -- I'm -- I'm happy to have them.  I have written another book and lost

 7     an awful lot of money in doing so.  So, you know, it depends how one

 8     measures this word "productive."  Do I wish that the world had never had

 9     Omarska in it?  Yes.

10             JUDGE KWON:  Mr. Karadzic, how much more do you have to conclude

11     your cross-examination?

12             THE ACCUSED: [Interpretation] I will try and finish everything

13     within the next 20 minutes.

14             JUDGE KWON:  Do you have some re-examination, Ms. Sutherland?

15             MS. SUTHERLAND:  A few minutes, Your Honour.

16             JUDGE KWON:  Mr. Karadzic, please do so in 15 minutes.

17             MS. SUTHERLAND:  And so, Your Honour, for witness scheduling can

18     we excuse the witness that's waiting.

19             JUDGE KWON:  I don't think we're going to there -- going there --

20             MS. SUTHERLAND:  Yeah, thank you.

21             JUDGE KWON:  -- today.  That's fair enough.

22        Q.   1D4086 is the document number.  This is your text, is it not, and

23     this was written after General Mladic was arrested; right?

24        A.   Yes, absolutely.

25        Q.   Thank you.  First, let's look at the photo.  This person, Alic,

Page 21131

 1     does he appear to be joyful and happy?  And what about the others?  Do

 2     they appear to look differently than him?  In other words, how can you be

 3     so certain that this is not just the way he normally looks, that this is

 4     not the way he is built but, rather, that he is emaciated?

 5        A.   In all this I've heard that he's got TB, tuberculosis, which I

 6     know him not to have had.  Sorry, what's the question?  Do they appear to

 7     look different than him?  Yes, but not from others inside the camp.  And

 8     I -- I know that's not how he normally looks.  I met him shortly -- well,

 9     I met him about ten months later and he looked very different.

10        Q.   Thank you.  Are you saying that the TBC that broke out two months

11     before, that, for example, if he -- his TBC had resulted from stress,

12     from the fact that he was arrested, that his appearance could have

13     deteriorated so much within the two months?  If he didn't have TBC before

14     he was arrested and if he contracted it on the day he was arrested, are

15     you saying that within the two months his condition deteriorated so much

16     that he was on the verge of extinction?

17        A.   I -- yes, I would concede that perhaps the conditions in Keraterm

18     were so appalling that his condition had deteriorated in two months and

19     perhaps he had become sick there, but when I met him again in Slovenia

20     the following spring, he was of a normal build.  And he hadn't had much

21     medical attention.  He just had something to eat.

22        Q.   Did you see him half naked when you saw him in Ljubljana also

23     without his clothes on?

24        A.   No, he was clothed.

25        Q.   Thank you.  Can we --

Page 21132

 1        A.   [Overlapping speakers] unfortunately, my figure is visible

 2     through my clothing, too.

 3        Q.   And, now, look what you said here.  You mentioned Dachau, and it

 4     doesn't really matter what you said about Dachau, there is a reference to

 5     Dachau in this text.  Do you truly believe that this is unbiased

 6     journalism of the kind that makes you a good witness?

 7        A.   It is not up biased with regard to atrocities committed in

 8     concentration camps.  It is not unbiased in terms of the neutrality that

 9     I tried to explain earlier.  I think it is subjective in terms of facts

10     and I stand by the argument in there which is an argument about people

11     coming to terms with what is -- what has happened and what has been done.

12     I am not unbiased over mass murder and beating and the kind of things

13     that -- that are involved in these cases, but I am unbiased between

14     peoples.

15        Q.   On a condition that you were able to determine that there had

16     been mass murder, did you establish it yourself or did you hear it from

17     others and believed it?

18        A.   I've -- by the time I'd written this, which is recently, I had

19     seen the exhumation of the mass graves, in particular the one at Kevljani

20     which is just right next door to Omarska.  I had been much in the

21     Srebrenica area.  I had met, I say, hundreds if not scores of people who

22     had survived the camps and hundreds, if not scores, of people bereaved by

23     the camps.  And I have testified at and followed the proceedings of and

24     the verdicts at this Tribunal.  And I've been to the -- they're called

25     the reassociation places where teams of forensic scientists and

Page 21133

 1     anthropologists and other experts are trying to put together the human

 2     remains from graves, secondary graves, and tertiary graves in an attempt

 3     to identify them and find their families.  That's the basis on which I

 4     say that mass murder happened during this time in Bosnia-Herzegovina.

 5        Q.   Thank you.  Do you believe that people were also killed in

 6     combat, that a lot of people were killed in combat, as a matter of fact?

 7        A.   Yes, I do, without doubt.

 8        Q.   Thank you.

 9             THE ACCUSED: [Interpretation] Can the document be admitted?

10             JUDGE KWON:  Yes.

11             THE REGISTRAR:  Exhibit D1905, Your Honours.

12             THE ACCUSED: [Interpretation] 1D4822 is the next document I would

13     like to call up.

14             MR. KARADZIC: [Interpretation]

15        Q.   This is about your visits is to Mostar.  Do you remember these

16     texts as well?

17        A.   Certainly I remember, yes.

18        Q.   Can we go to the following page.  You describe the conditions

19     under which the Serbs were held by the HOS, and you identified the HOS as

20     a pro-Nazi or a neo-Nazi organisation; right?

21        A.   Yes.  I think that's fair.  The HOS was a mixed Croatian with

22     some Muslim soldiers, and I think it's accurate to say that it was a

23     neo-Ustasha militia and this was a camp run by them for Serbian

24     prisoners.

25             THE ACCUSED: [Interpretation] Can this be admitted?

Page 21134

 1             JUDGE KWON:  Very well, yes.

 2             THE REGISTRAR:  As Exhibit D1906, Your Honours.

 3             JUDGE KWON:  Now, please conclude in five minutes.

 4             THE ACCUSED: [Interpretation] Thank you.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   In that case, I'm not going to show some documents.  Let me ask

 7     you, you were engaged in some activities, and you looked at the conduct

 8     of both Serbs and Croats.  Did you find the Muslim prisons that we talked

 9     about?  For example, there were three in Sarajevo.  Did you see any

10     Muslim prisons for the Serbs?  You can just say yes or no.  No need to

11     expand.

12        A.   The prison at Dretelj, which is the one you're referring to, at

13     Capljina, was run jointly by Croats and Muslims.  I endeavoured to look

14     at another site which you recommended, sir, to Tarcin, a tunnel and a

15     silo, and they were empty at the time.  I either was -- you know, failed

16     to see prisoners if they were still there, I don't know, or they had been

17     moved somewhere else.  I wanted to get -- to do this -- this -- this --

18     this work on the other side, too, and proceeded straight to Capljina,

19     which is the story you have there.

20        Q.   Thank you.  In Sarajevo did you see any of the prisons that we

21     talked about?

22        A.   I -- I didn't actually go to the city itself of Sarajevo until

23     well into 1993, by which time, and I don't mean to at all belittle the

24     issue of camps, and I don't think I can be accused of that, there was

25     another war going on in Mostar and in Central Bosnia in which your

Page 21135

 1     people, troops, whatever, were not involved, and I did not check out

 2     any -- any camps in the actual city of Sarajevo itself.

 3        Q.   Thank you.  Did you observe the presence of Muslim troops?  Let's

 4     call it the Army of Bosnia and Herzegovina.  In the city did you also

 5     observe weapons, cannons, mortars, tanks?

 6        A.   In the city of Sarajevo?

 7        Q.   Yes.  In the part of the city which was under Muslim control.

 8        A.   Yes.  SDA control, yes.  It was -- it was ethnically mixed.  Yes.

 9     I was up in the front lines there and did see the weaponry.  I didn't see

10     any artillery.  A source of -- I saw that they had mortars, and they had

11     guns in -- not in very -- not in very plentiful supply, but they -- they

12     were equipped, yes, and became more so.  By the -- 1994, they were better

13     equipped.

14        Q.   Thank you.  Now I would like to ask you about the sources from

15     which you learned things.  Can it be said that most of your information

16     came from Muslim sources?  Is it true that you had a good exchange of

17     information with the Red Cross, UNHCR, NGOs, and so on and so forth?  Is

18     all this correct?

19        A.   Not -- not quite, sir.  I mean, my main source was what I saw and

20     what was happening before my eyes in most cases.  I had little or no

21     briefing from Bosnian government, SDA, Muslim authorities.  Fairly scant

22     connections with the Red Cross, didn't talk to them much.  We disagreed,

23     and they disagreed with me and I with them over their performance in

24     failing to get into and report the camps that we've been discussing.

25     UNHCR some communication, yes.  The British Army, some communication,

Page 21136

 1     yes, because that's obviously what the newspaper was interested in --

 2     in -- in, our British section of the UNPROFOR.  And certainly soldiers,

 3     yeah.  That I will -- I will grant that most of the military I talked to

 4     after the convoy over Vlasic was the -- were -- were the Bosnian Army,

 5     not the Mujahedin, who I understood just recently had a contract out on

 6     me.  They didn't like me at all nor me them, and -- but I would say to

 7     the Court, if I may, that I did try to get back into Serbian-held

 8     territory after that convoy over Vlasic, which was my first time into the

 9     government-held territory apart from 36 hours at Sarajevo airport during

10     the spring, and I was unable to get permission to travel through the

11     Bosnian-held -- sorry, Bosnian Serb-held territory.  I made a number of

12     attempts by going to Pale where a member of your family, indeed, and

13     others were vetting and giving licence to some and others not to travel,

14     and I never succeeded in getting official permission.  They didn't like

15     me.

16             When I did next go into the Republika Srpska was after the war

17     when I went to Visegrad without authorisation.

18        Q.   Thank you.  Let's -- let me bring this to an end.  In the Tadic

19     case, on the 6th of June, 1996, on page 2076 you described the situation,

20     and you said that you monitored official reports by many organisations

21     such as UNHCR, the Red Cross, and so on and so forth.  This is 1D04801,

22     and in that transcript, page number is 2075 and also 2076.

23             You have just said a very important thing.  You said that you

24     based most of your information on what you saw.  Does this mean that you

25     still stand by your first text that we saw today dated the 7th of August,

Page 21137

 1     because it says there that you saw things with your own eyes.

 2        A.   On the 7th of August, the article, yes.  That's mostly based on

 3     our visits on the 5th of August to the camps, and -- yes, of course I saw

 4     the reports by these various international organisations.  I didn't use

 5     them as much as many other people did, nor did I go to their briefings as

 6     often as others.  Sorry, to clarify the, 7th of August article is based

 7     upon what -- in most part upon what I saw in Omarska and Trnopolje that

 8     day, 5th of August.

 9             JUDGE KWON:  Yes.  We have to wrap up, Mr. Karadzic.  I think you

10     have concluded, Mr. Karadzic.

11             THE ACCUSED: [Interpretation] Just one more question, please.

12             MR. KARADZIC: [Interpretation]

13        Q.   So there are no other texts based on what you saw, based on your

14     visit, but that one.  This is the first text which was written before the

15     media circus descended upon Bosnia; right?

16        A.   Yes.  Apart from 36 hours at Sarajevo airport back in April, I

17     had not set foot in -- in Bosnian government controlled territory.  I had

18     no other sources apart from what we saw that day in addition to the

19     briefing -- apart from the briefing with you, which I acted upon

20     immediately, as we've discussed, going to Capljina to Dretelj, and -- but

21     I had not been briefed by -- if you're asking me if I'd been briefed by

22     the Bosnian side, I'd seen their lists, but I had not actually set foot

23     in Bosnian government controlled territory apart from Sarajevo airport,

24     which was a demilitarised zone, a UN zone.

25        Q.   Thank you.  Let me just inform you, Mr. Vulliamy, that the text

Page 21138

 1     dated the 7th of August is accepted by every Serb as a piece of

 2     journalism, the only piece of journalist -- journalism.  The rest is

 3     nothing but a big story, and I'm really sorry that you put yourself in

 4     such a position, and that you were finally proclaimed an anti-Serb.  And

 5     that is not on the basis of the text that you authored on the 7th of

 6     August, but based on everything else that can be called a big story and

 7     was written after the 7th of August.

 8             JUDGE KWON:  Unnecessary comment.  Unless you wish to comment on

 9     that, I'll ask the -- ask Ms. Sutherland to take the floor.

10             THE WITNESS:  Just to say that I have absolutely nothing against

11     the Serbian people whatsoever.  I -- my complaint is against things that

12     were done in their name.

13             JUDGE KWON:  Ms. Sutherland.

14             MS. SUTHERLAND:  Thank you, Your Honour.

15                           Re-examination by Ms. Sutherland:

16        Q.   Just quickly, Mr. Vulliamy.  At page -- transcript page 81 today,

17     Mr. Karadzic asked you that you saw no single emaciated person like that

18     person Alic was, actually looking at a still on the screen.  I wanted to

19     show you some short video footage.  Mr. Reid has that ready.  If you

20     could just watch this.  And this is starting at -- from

21     65 ter number 40437, and it's at 9:02 to 9:25.

22                           [Video-clip played]

23             MS. SUTHERLAND:  And again at 13:33 to 14:09, please.

24                           [Video-clip played]

25             THE ACCUSED: [Interpretation] Maybe I can be of assistance.  I

Page 21139

 1     can hear in the background:  "Give me all the emaciated ones."  You can

 2     check that.  The cameraman says:  "Bring me those emaciated ones."  You

 3     can rewind and perhaps you can check.

 4             MS. SUTHERLAND:  Your Honour, clearly there are emaciated

 5     prisoners -- detainees in the camp, if that's what's being said in the

 6     background.

 7        Q.   But my question, Mr. Vulliamy, is did you see these men that

 8     we've just seen and/or people like it when you were there?

 9        A.   In that compound, yes.

10        Q.   Thank you.  The second point -- the second topic:  On transcript

11     pages 85 and 86 today, just earlier there was discussion about

12     Mrs. Balaban interpreting, and you said that -- you mentioned that

13     Drljaca, Meakic, and Milutinovic were in authority and that Balaban was

14     interpreting for them.  When Ian Williams, the ITN reporter, said, "Why

15     aren't you fulfilling Karadzic's promise?"  And Mrs. Balaban said, "He

16     said you can see this and this and not that," was that the restrictions

17     on access that you referred to earlier as imposed by Karadzic?  Is that

18     what you were talking about when you said there was the bit that

19     mattered?  Were you --

20        A.   Yes.

21        Q.   -- referring --

22        A.   That was what --

23        Q.   -- to the restrictions on access that were referred to earlier as

24     being imposed by Karadzic?

25        A.   That was one of the passages, and be it coming from her own mouth

Page 21140

 1     or translated, I'm not in a position always to know which is -- which is

 2     which, when she's translating and when she's just talking, but, yes, that

 3     was one of the passages in which it was -- it appeared to be being made

 4     clear to her that there were two sets of instructions and that their's

 5     was not to allow us into the hangar.

 6        Q.   But the instructions -- when -- when Ian Williams says, "Why are

 7     you not fulfilling Dr. Karadzic's promise to us?"  And she said, "He

 8     promised us something else and said that you can do this and this and

 9     that and not that" --

10        A.   That's --

11        Q.   If they say this is the protocol of your stay, that will be all,

12     that -- that he was -- she was talking about Mr. Karadzic was imposing

13     the restriction?

14        A.   That -- [overlapping speakers]

15        Q.   Is that how you understood it?

16        A.   That was my inference, yes.

17             MS. SUTHERLAND:  Thank you.  I have no further questions,

18     Your Honour, and if I can tender the video-clip shown.

19             JUDGE KWON:  Into two parts?

20             MS. SUTHERLAND:  Or it's already in evidence.

21             JUDGE KWON:  That's already in evidence.

22             MS. SUTHERLAND:  Yes.

23             JUDGE KWON:  Thank you.

24             THE ACCUSED: [Interpretation] I have just one additional question

25     if I may, please, concerning the protocol.

Page 21141

 1             JUDGE KWON:  Mr. Karadzic, I don't think it's necessary.

 2             THE ACCUSED: [Interpretation]  I just wanted to ask the witness

 3     whether he ever saw the protocol.

 4             JUDGE KWON:  No it's for the Chamber to assess it later.

 5     That concludes your evidence, Mr. Vulliamy.  We didn't allow the accused

 6     to put the question.  Please don't mind.

 7             So on behalf of my colleagues and the Tribunal, I would like to

 8     thank you --

 9             THE WITNESS:  Thank you.

10             JUDGE KWON:  -- for coming to The Hague --

11             THE WITNESS:  Thank you, Your Honours.

12             JUDGE KWON:  -- yet again to give it.

13             THE WITNESS:  Thank you, Your Honours.  Most kind.  Thank you.

14             JUDGE KWON:  Now you're free to go.

15             THE WITNESS:  Most kind.  Thank you.

16             JUDGE KWON:  If the witness could be excused.

17             With the indulgence of the staff, I have just one brief

18     administrative matter to deal with before we adjourn today.

19                           [The witness withdrew]

20             JUDGE KWON:  Mr. Tieger, it's going back to your brief response

21     on the accused's motion for access to Oric document that relates to the

22     witness Tucker, I think.  The Chamber would prefer to get a written

23     response from you by the end of this week indicating as follows:  Number

24     one, whether or not you -- the Prosecution opposes the motion in light of

25     the developments you mentioned yesterday and the fact that all documents,

Page 21142

 1     save for one, seem to have been disclosed.

 2             Number two, whether or not the Prosecution has disclosed any

 3     confidential document to the accused already.

 4             Number three, if so, on what basis were these disclosed given

 5     that the Pre-Trial Chamber ruled that the accused should have -- should

 6     not have access to the confidential materials in the Oric case?

 7             Number four, if confidential documents were, nevertheless,

 8     disclosed, the Chamber would like to know the exact numbers from the Oric

 9     case that were disclosed and whether these include Defence exhibits.

10             And number five, finally, with respect to the Rule 70 document

11     that remains outstanding, the Chamber would like to know what that

12     document is as well as its exhibit number in the Oric case.

13             Thank you.  Hearing is now adjourned.  Tomorrow 9.00.

14                           --- Whereupon the hearing adjourned at 2.04 p.m.,

15                           to be reconvened on Thursday, the 10th day

16                           of November, 2011, at 9.00 a.m.