Tribunal Criminal Tribunal for the Former Yugoslavia

Page 23551

 1                           Wednesday, 25 January 2012

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- Upon commencing at 9.01 a.m.

 6             JUDGE KWON:  Good morning, everyone.  Good morning,

 7     Mr. Blaszczyk.

 8             THE WITNESS:  Good morning, Your Honours.

 9             JUDGE KWON:  Yes, Mr. Robinson.

10             MR. ROBINSON:  Yes, good morning, Mr. President.  I'd like to

11     introduce to the Chamber John Tso, from China, who is one of our legal

12     interns who will be joining us this session.  Thank you.

13             JUDGE KWON:  Thank you.  Yes, Mr. Nicholls, please continue.

14             MR. NICHOLLS:  Good morning, Your Honours.  Good morning,

15     everyone.  Just before I start, if I could give an update on the

16     schedule.

17             We have tried to bring Professor Haglund back as soon as

18     possible.  As you know, before the break he had to go home, and we plan

19     on having him testify on Monday.  He will be available this coming

20     Monday.  I'm not sure exactly where we will be with Mr. Ruez at that

21     point, but our plan would be to call Mr. Haglund on Monday morning and

22     have him start and finish because he needs to get back to his other

23     duties, and he had a window here where he could come and I've informed my

24     friends of that.

25             We would then, I anticipate, continue with Mr. Ruez, some

Page 23552

 1     cross-examination likely.  Following him we would be calling

 2     Mr. Todorovic, KDZ351.  He does not have protective measures.  Followed

 3     by KDZ333, who I won't say the name because he does have protective

 4     measures.  And lastly, it seems likely that we will not have a witness

 5     available today after Mr. Blaszczyk should he finish early.

 6             JUDGE KWON:  Meaning that Mr. Ruez can only start tomorrow.

 7             MR. NICHOLLS:  Yes.  I believe that is the case.  I can check

 8     later in the day, but he came in, I believe, late last night.

 9             JUDGE KWON:  Thank you.

10             MR. NICHOLLS:  Thank you.

11             JUDGE KWON:  Thank you for that information.  I take the Defence

12     would appreciate it as well.

13             MR. ROBINSON:  We do, Mr. President.  Thank you.

14             JUDGE KWON:  Yes, Mr. Tieger.

15             MR. TIEGER:  And as long as we're dealing with such matters, if

16     we could move briefly into private session for another housekeeping

17     matter.

18             JUDGE KWON:  Is it okay to proceed in the presence of

19     Mr. Blaszczyk?

20             MR. TIEGER:  Oh, that's -- you're quite right.  We can deal with

21     this at the beginning of the session before -- beginning the next session

22     before the witness comes in.  Thank you, Mr. President.

23             JUDGE KWON:  Thank you.  Yes, Mr. Nicholls.

24             MR. NICHOLLS:  Thank you.

25                           WITNESS:  TOMASZ BLASZCZYK [Resumed]

Page 23553

 1                           Further Examination by Mr. Nicholls:  [Continued]

 2        Q.   Good morning, Mr. Blaszczyk.

 3        A.   Good morning, sir.

 4        Q.   What I want to do now is as -- as efficiently as we can is move

 5     through the road book and the video and explain where the different

 6     places are.

 7             MR. NICHOLLS:  And I'll say for Your Honours and the Registry to

 8     make it -- it's a bit complicated because we will be showing videos and

 9     showing the road book at the same time.  So Mr. Reid will bring up the

10     pages of the road book rather than in e-court, because he is able to do

11     that.  So that's the way we plan on -- on proceeding now.

12             JUDGE KWON:  Thank you.

13             MR. NICHOLLS:

14        Q.   All right.  We left off yesterday, you explained where we -- the

15     OTP obtained the Petrovic Pirocanac raw video, which is the subject of

16     the road book.

17             MR. NICHOLLS:  I'll ask Mr. Reid to please bring up -- we'll just

18     go through the first few pages.  This would be page 2 in e-court, the

19     first map.  And if we can quickly go to page 3, the next page, and

20     page 4, the next page.

21        Q.   Now, quite simply, Mr. Blaszczyk, do these maps and the

22     highlighted regions show the areas contained in the road book and on the

23     video?

24        A.   Yes.  This map contains the area when the video was recorded.

25     This is area of Potocari, of course, Srebrenica, Zeleni Jadar and

Page 23554

 1     Kravica, Sandici, and Pervani.  There is -- this map depicts the eastern

 2     part of Bosnia-Herzegovina, including Bratunac.

 3        Q.   Thank you.  If we can go to the next page, which would be page 5

 4     in e-court.  If I'm right, this is simply an aerial image of the same

 5     areas?

 6        A.   Yeah.  This is correct.  This is the aerial image on the same

 7     area.  If we look at the map before, we see that it's covering the same

 8     area.

 9             JUDGE KWON:  What does a star represent?

10             THE WITNESS:  Sorry, Your Honour.  You are referring to which

11     star?

12             JUDGE KWON:  Can we go back to -- you see a star in Srebrenica,

13     and then shall we go back to the previous page.

14             THE WITNESS:  No.  This is -- represents the city, the towns.

15     Ljubovija, Bratunac, Srebrenica.

16             JUDGE KWON:  Han Pijesak.  Shall we go back to one page.

17     Vlasenica, Han Pijesak, Zvornik.  With stars.

18             THE WITNESS:  Yes, yes, yes.

19             JUDGE KWON:  What do those stars represent?  We can go back one

20     page further.

21             THE ACCUSED:  If I may help, this is seats of municipalities.

22             THE WITNESS:  Yes.  Mr. President, he's right.  They represent

23     municipalities.

24             JUDGE KWON:  So in Eastern Bosnia or, I don't know, Drina region,

25     we have Bratunac, Srebrenica, Zepa.  They are all municipalities.

Page 23555

 1             THE WITNESS:  Yes, it's correct.  Sarajevo, then you have --

 2             JUDGE KWON:  Thank you.  Thank you, Mr. Karadzic.

 3             Let's continue, Mr. Nicholls.

 4             MR. NICHOLLS:  Thank you.

 5             THE ACCUSED:  With just one correction.  Zepa was not

 6     municipality but is ...

 7             JUDGE KWON:  Thank you.

 8             MR. NICHOLLS:

 9        Q.   And on page 5, Mr. Blaszczyk, simply this is an aerial image of

10     the same highlighted regions?

11        A.   Yes, it's correct.

12        Q.   We can go to the next page, page 6.  It says chapter 1, Potocari.

13     Can you tell us how you divided -- when you made this book, how you

14     divided it into chapters, which chapters you picked?

15        A.   This book is divided for five chapters.  First chapter, this is

16     Potocari.  Then we have the second chapter, this is on the road.  Area

17     Sandici, Kravica, Pervani.  Then we are -- we on chapter number 3, this

18     is -- let me check.  I believe this is Srebrenica chapter.  Srebrenica

19     town chapter.  Number 4, this is Zeleni Jadar chapter, and number 5 this

20     is Mosque Azemina chapter.  It's on the suburb of Srebrenica if we are

21     going towards Bratunac.  I divided this book, you know, for these

22     chapters because Mr. Petrovic during his travel in this area on the

23     13 and 14 of July 1995, he was on all this area -- areas.  And from the

24     video we are going to play we see -- we see these -- these particular

25     areas.

Page 23556

 1        Q.   Thank you.  If we can go to the next page, page 7.  Can you tell

 2     us what you -- what this page represents that you've created.

 3        A.   This is more detailed map of -- of Potocari and -- Potocari area,

 4     and in this map you see that I plotted on this map few dots, just yellow

 5     dots with black dot inside, you know, and just marked them with number 1,

 6     1A, 2A, 2B.  This is the location.  If we go to the following --

 7     following pages we see the picture, you know, and the frames or just

 8     stills from the Petrovic video I located on this particular area and

 9     using GPS readings I spotted on the map.

10        Q.   Okay.  Can we go to the next page, page 8.  And here where it's

11     hard to show both pages at once, but could you explain before we get to

12     the video, Mr. Blaszczyk, how this photo works.  If we look at page 8 on

13     the left and page 9 on the right we see a still from the Petrovic video

14     on the left and a photo taken on the right.  Can you just explain how you

15     put it together in this manner.

16        A.   Yes.  I try to organise this book --

17        Q.   Sorry, one moment.  Can we show page 9 on the screen now.  We can

18     bring up both.  Please continue.

19        A.   I organise this book in this way, mostly in this way, that on the

20     left-hand side of the book -- left-hand side page we have the still

21     capture from the video, from the Petrovic video, and the right -- on the

22     right-hand side page we have the picture taken by us of the same location

23     spotted by us during our mission in May 2006.  And as you see,

24     Your Honours, I marked on -- on the page on the left-hand side, you know,

25     just on the page 8 of the book I marked the picture as picture number A.

Page 23557

 1     And on the -- our picture on the page 9, I marked the same location what

 2     is depicted on the picture 8 as A.  And below on the left-hand side,

 3     below the still capture from the Petrovic video, I marked the location --

 4     I marked the location I mean the name -- name of the location and the

 5     position on the map, the map we saw the page before with this yellow

 6     circle with the black dot in.  This position on the map is number 1.  And

 7     we see on this picture on the frame and on my picture we see the same --

 8     the same premises.  This is DutchBat UNPROFOR base in Potocari.

 9             JUDGE KWON:  Yes.  We can blow-up the bottom on the left side.

10     Yes.

11             THE WITNESS:  And also -- also below the still captured from the

12     video Petrovic I -- we put the time --

13             JUDGE KWON:  Just a second.  Yes, the position on map number 1

14     depicts the position 1 in the previous map.

15             THE WITNESS:  Yes, it's correct, Your Honour.

16             JUDGE KWON:  Thank you.  Yes, Mr. Nicholls.

17             MR. NICHOLLS:  Thank you.

18        Q.   So then, yes, as His Honour said, if we looked at the map on

19     page 7 - we don't need to bring it up again - we see position 1 marked,

20     and we look at page 8, the DutchBat base, we see that this is position on

21     map number 1.

22             Just before we move on, Mr. Blaszczyk, we see that the counter on

23     the left-hand side, page 8, underneath the still photo is 00:37:13.  What

24     does that counter represent?  What does that come from?

25        A.   This is counter of the time-code.  This is time-code from the

Page 23558

 1     counter of -- of device we use to copy this -- this particular Petrovic

 2     raw video.

 3        Q.   And is it right that this counter is from the actual raw

 4     video-tape you provided to us at 37 seconds, in this case, frame 13 of

 5     that second?

 6        A.   Yes, this is correct.

 7        Q.   Now, finally you said you used GPS.  How were you able -- how

 8     familiar are you with this area?  How often have you been to the areas in

 9     the map book and on the video, and how were you able to precisely locate

10     and GPS these locations?  What did you do to make sure you had the right

11     places?

12        A.   I've been in this area -- area many times and before -- before

13     this mission in -- in May 2006, and -- and I'm quite familiar with this

14     area, well familiar, I would say.

15        Q.   And --

16        A.   And even before -- before we decided to -- to spot it, all these

17     locations, and get the GPS readings and get a proper photo of this

18     location, I had a rough idea of where the location were, in fact.  Before

19     we went on the mission we just in May 2000 -- 2006, together with video

20     assistant, we made the stills from the Petrovic video interested for us

21     stills.  We -- we printed out the stills.  We took -- we brought a

22     portable device to play the video itself, a good quality copy of the

23     video, and we went to these places.  We compared the stills from the

24     Petrovic video, we compared the features of the terrain, you know, the

25     make-up of the roads, the buildings, the location of the buildings, and

Page 23559

 1     looking at -- at these features we spotted the places.  As soon as we

 2     spotted the place we took the GPS readings.  We had a GPS with us.

 3        Q.   And did you use two GPS devices in order to make sure you had the

 4     locations correct?

 5        A.   Yes.  This is correct.  We have -- as far as I remember, we had

 6     two.  I had one, my own GPS, and my colleague had another one.

 7        Q.   And I believe did you have a portable video player so you could

 8     play the video while you were at the locations?

 9        A.   Yes, yes, we did have.

10        Q.   And final question on that:  Was I present for part of that

11     mission?

12        A.   Yes, correct.  You were present in part of this mission.

13        Q.   All right.

14             MR. NICHOLLS:  Now I'll ask Mr. Reid -- what I'd like to do now

15     is start playing the raw video footage, P00667, and I'll ask you to stop

16     when we get to the appropriate place.  So we need to bring that up in

17     Sanction, please.

18             Sorry, just before that, Your Honours, the Sanction counter is

19     about 4 seconds past what we see as the counter number in the video book.

20     That is because the raw data video we captured was digitised and this was

21     as precise a match as it was possible to achieve.  If you put -- we found

22     any video on a different DVD or CD player, it's often off by one or two

23     seconds.  So the numbers we see on Sanction will be consistently

24     approximately 4 seconds past what we see in the book.

25             JUDGE KWON:  Thank you.

Page 23560

 1             MR. NICHOLLS:  Start playing, please.

 2                           [Video-clip played]

 3             MR. NICHOLLS:

 4        Q.   All right.  We stopped at 41.2 seconds in the Sanction

 5     presentation, which matches just about the photo depicted on page 8,

 6     photo A that we were talking about of DutchBat, the UNPROFOR base.  Can

 7     you please tell us, Mr. Blaszczyk, where -- where is Mr. Petrovic

 8     Pirocanac and Mr. Borovcanin, in which direction are they travelling now?

 9     Where are they going?

10        A.   Mr. Petrovic Pirocanac and Mr. Ljubisa Borovcanin, together with

11     their driver, they're travelling towards Srebrenica.  They're passing by

12     UN DutchBat now.  We see the UN DutchBat location.  It's almost reflect

13     the same picture in my book, but on my book, on page 9, I mark the same

14     location but with a little bit bigger perspective.

15        Q.   Thank you.  And just again, you've marked the directions of

16     travel in each photo on the road book; correct?

17        A.   Yes, correct.  Below -- below the stills from Petrovic video I

18     mark in red arrows direction of Bratunac and Srebrenica, and we see when

19     Mr. Petrovic and Mr. Borovcanin are passing by, they're driving from

20     Bratunac towards Srebrenica.

21        Q.   And just again, what is the date?

22        A.   This is 13 of July, 1995.

23        Q.   If we could continue playing, please.

24                           [Video-clip played]

25             MR. NICHOLLS:  Thank you.  We've stopped at 54.2 in Sanction.

Page 23561

 1     And I'll ask Mr. Reid if he can also bring up page 10 of the book so we

 2     can compare.  All right.  And I'll ask Mr. Reid if he could pull up

 3     page -- yes.  He's got it without me saying the photo.

 4        Q.   All right.  There we see the still of the men walking as you've

 5     got it in the book, and in the video how were you -- sorry, if we could

 6     now go to page -- the next page of the book, page 11.  And you've marked

 7     the area below A and B and C where these photos were taken.  How were you

 8     able to determine this location?  Tell us where we are when this photo is

 9     taken.

10        A.   We are right now in -- in -- in the front of the main gate of the

11     DutchBat and in the front of so-called white house.  And this photo was

12     taken from -- from the location exactly where Mr. Petrovic is standing in

13     front of the white house in Potocari.  It was very easy to -- to locate

14     this place, because we see also the features and all of the features

15     here, and if -- if we follow the video, we see what Mr. Petrovic and

16     Mr. Borovcanin stop the car, at least when Mr. Petrovic started to record

17     his -- his material.

18        Q.   Okay.  Let's keep playing then.

19             JUDGE KWON:  Just a second.  Can we see page 10.

20             MR. NICHOLLS:  Yes.

21             JUDGE KWON:  I'm sorry.  Yes.  The right arrow says that's the

22     Feros building.  Is it near white house?

23             THE WITNESS:  This is across the road from the white house,

24     Your Honour.  This is -- we called it Feros building.

25             JUDGE KWON:  Just across the white --

Page 23562

 1             THE WITNESS:  Yes, exactly.  If -- later on if we come to this

 2     digital presentation, I will really show it more closely.

 3             JUDGE KWON:  Thank you.

 4             THE WITNESS:  It will be more visible for you.

 5             JUDGE KWON:  Yes.  Please proceed, Mr. Nicholls.

 6             MR. NICHOLLS:  Could we keep playing the video, please, Mr. Reid.

 7                           [Video-clip played]

 8             MR. NICHOLLS:

 9        Q.   And sorry, let's -- a little bit more.  Stop.  Thank you.  We're

10     at 1:02.9, a little bit past photo B on page 10.  We can see the building

11     behind where the civilians are walking, the women on one side, the men on

12     the others.

13             MR. NICHOLLS:  If we could perhaps bring up the photo, Mr. Reid,

14     photo B.

15        Q.   Just very simply, can you tell us what building that is just

16     behind the woman we see with the headscarf.

17        A.   This is Feros administration building.  Behind this building

18     we -- we called it sometimes Blue Factory, but in the same compound.

19     Feros Factory, but this is administration building of Feros company.

20        Q.   And if we could keep playing, please, to 1:23, approximately.

21                           [Video-clip played]

22             MR. NICHOLLS:

23        Q.   All right.  Mr. Blaszczyk, we've stopped at photo C, 1:23.1.

24             MR. NICHOLLS:  And I think it may be easier, Mr. Reid, if we just

25     have the still from the video we're playing, if we just have the Sanction

Page 23563

 1     video.

 2        Q.   You've marked it as the woman is walking towards Bratunac; is

 3     that right?  Can you just tell us briefly how you can tell which

 4     direction the people are walking in this video?  I'm talking about the

 5     civilians, people in civilian clothing.

 6        A.   Yeah.  We see here that Mr. Petrovic with his camera, he pass the

 7     road from -- from nearby the white house and he's on the -- in front of

 8     this Feros administration building and he's capturing -- he's recording

 9     the people who are walking on the left-hand side of the road, you know,

10     just road leading from Bratunac to Srebrenica.

11             MR. NICHOLLS:  Thank you.  And if we could continue playing.

12                           [Video-clip played]

13             MR. NICHOLLS:

14        Q.   Thank you.  The photo we now have -- the still we're at in the

15     Sanction video at 1:38.1 corresponds to photo D.  This is the same

16     location, is that right, Mr. Blaszczyk, that you've plotted?

17        A.   Yes.  This is the same location on the left-hand side of the road

18     leading from Bratunac to Srebrenica.

19        Q.   Thank you.

20             MR. NICHOLLS:  Just to help get an overview, if I could have now

21     in e-court 65 ter 03199.  E-court page 16.  All right.

22        Q.   There we have an overview of Potocari, an aerial overview.

23     Without you marking it, you see the Feros building marking and a spot

24     marked the white house with a circle.  Can you just tell us where -- and

25     we see buses in this aerial.  Where the people we just saw walking after

Page 23564

 1     Mr. Petrovic had stopped and gotten out of the car, which area was that?

 2        A.   This is area near to Feros building and to the white house.  He

 3     was one -- one point he was on the -- on the hand right side of the road,

 4     you know, just near the white house, and then he passed the road and he's

 5     in the front of this Feros building.

 6        Q.   Thank you.  And just -- actually, could we -- I would like

 7     Mr. Blaszczyk to mark one point on this aerial.

 8             Not that -- if you wait a sec.  We're going to get to an area in

 9     a minute called the Blue Building.  Is that the same as the Blue Factory

10     or a different building?

11        A.   Your Honour, this is a different building.  We called it

12     Blue Factory.  This belongs to this Feros company.  And there is another

13     building, we call it Blue Building.  It at that time was coloured by

14     blue -- is blue, in fact, but this is -- distance between these two --

15     two compounds is about 150, 200 metres, less even.

16        Q.   And if you can, can you just circle the area you called the

17     Blue Building.

18        A.   [Marks]

19        Q.   All right.  And you've marked that with a red circle, and we'll

20     get to that building in a minute.  Could we save that --

21        A.   In fact, I think I didn't locate this building inside the circle

22     but --

23        Q.   Could we erase --

24        A.   -- can I mark it again here?

25        Q.   Could we erase that and start again, please.

Page 23565

 1        A.   [Marks]

 2        Q.   Thank you.  And it's that rectangular building we can see inside

 3     the red circle?

 4        A.   Yes, it's correct.

 5        Q.   Perhaps could you just write "Blue Building" next to that so it

 6     will be very clear when we look at this in the future what you've marked.

 7        A.   [Marks]

 8             JUDGE KWON:  Shall we ask Mr. Blaszczyk to -- to date and initial

 9     on this aerial image.

10             THE WITNESS: [Marks]

11             MR. NICHOLLS:  Thank you.  I tender that, please, Your Honour.

12             JUDGE KWON:  That will be admitted as next Prosecution Exhibit.

13             THE REGISTRAR:  Exhibit P4268, Your Honours.

14             MR. NICHOLLS:  Thank you.  Now, sorry, it's a bit complicated.

15     If we could go back to Sanction, we'll keep playing the video.  If could

16     you play, please, Mr. Reid.

17                           [Video-clip played]

18             MR. NICHOLLS:

19        Q.   Thank you.  We've stopped at 5:08.2.  A few -- and if we could go

20     to page 12 of the road book.

21             All right.  The still we're now at in the video 5:08.2

22     corresponds to photo B on page 12 approximately.  This is position 2 in

23     the photo book, Potocari, 50 metres north of the Express Bus Compound.

24             First, can you just tell us who are the two men we see in the

25     foreground, the man on the right wearing the blue UNPROFOR cap and the

Page 23566

 1     man on the left in a camouflage uniform.

 2        A.   The man with the blue cap, this is Dutch soldier, Dutch Officer

 3     van Duijn, and the man talking to him on the left-hand side, this is

 4     Mane Djuric.  This is commander of the 1st Company of Jahorina Unit from

 5     Special Police Brigade of Republika Srpska.

 6        Q.   And if we could just keep playing for a moment.  Sorry, go ahead.

 7        A.   And to be more clear, Your Honours, I noted here that this

 8     location is located 50 metres north of the Express Bus Compound, but a

 9     few minutes ago we talk about this Blue Building.  This is exactly the

10     Blue Building we have on the right-hand side if we're looking towards

11     Srebrenica.  This is in front, not in there, because Blue Building has

12     this only yard and this is on the main road leading from Bratunac to

13     Srebrenica.  These two men, they are discussing exactly in this location

14     in front of the yard of the Blue Building.

15        Q.   Thank you.  If we could keep playing for a moment.

16                           [Video-clip played]

17             MR. NICHOLLS:

18        Q.   Thank you.  We've now stopped at 5:23.3 on video we're playing,

19     which is photo D on page 12.

20             You've got the location mapped out on page 13 of the road book,

21     the photo you took on mission.

22             MR. NICHOLLS:  If I could bring that up, please, Mr. Reid.

23        Q.   All right.  Now if you could just describe how you were able to

24     tell that this is the correct location for the video segment we've just

25     seen with Mr. Van Duijn and with this woman walking towards us in the

Page 23567

 1     picture we have now.

 2        A.   If you notice, Your Honour, this is on the picture D from the

 3     page 12 of my book.  We see the check-point of -- of Dutch APCs over

 4     there, and we see the small -- small bridge.  We can call it the small

 5     bridge, just small stream is coming behind -- under the bridge over

 6     there.  On my photo on the page 13 I located this bridge, I mark here

 7     this bridge, and the building on the left-hand side on this photo from

 8     the page 13, this is new building.  It not existed at that time in

 9     July 1995.  It's a little different view.  And, yes, and also the hill

10     behind, in front of us, you know, is visible on the picture from the

11     page 13 is not very clear on this picture D, but it is the same location.

12        Q.   Thank you.  And if we could continue playing now, please.

13                           [Video-clip played]

14             MR. NICHOLLS:

15        Q.   Thank you.  We've stopped at 6:16.1 on the video.  If we could

16     show page 14 of the book.  This corresponds closely to photograph C on

17     that page.  You've marked this the Blue Building.  We've just seen

18     Major Kingori walking here and this DutchBat officer.  Just quickly, this

19     is the same Blue Building, not Blue Factory that you circled a minute

20     ago; is that right?

21        A.   Yes, this is correct.  This is Blue Building I referred to just a

22     few minutes ago, and yard of this building, and, yes, we cannot mistake

23     with Blue Factory which is located next to DutchBat.  That Blue Factory

24     is located -- is across the road about 100, 150 metres from this

25     Blue Building.

Page 23568

 1        Q.   And if we could bring up page 15 now, the recent photo you used

 2     to determine this location.  That's from your mission to create the road

 3     book.  Is that the same building we see in photo 1 on page 15, it's the

 4     one we were just looking at?

 5        A.   Yes, this is correct.  This is the same building.  We can compare

 6     in the still from Petrovic video and this photo and we see that this is

 7     exactly the same building.  It -- how this building looked in 2006.  Now,

 8     it has been reconstructed and totally it looks different.

 9             MR. NICHOLLS:  All right.  If we can keep playing the video and

10     see what Mr. Petrovic has filmed when he has now walked to the

11     Blue Building location with Mr. Borovcanin.

12                           [Video-clip played]

13             MR. NICHOLLS:

14        Q.   All right.  We've stopped at 6:33.6, quite close to photo D on

15     page 14 of the road book.  The man in the foreground in the camouflage

16     uniform with the black patch on his left arm, just for the record who's

17     that?

18        A.   This is Ljubisa Borovcanin, deputy commander of the

19     Special Police Brigade of Republika Srpska, at that time the commander of

20     the police forces in this area.

21        Q.   We could continue, please.

22                           [Video-clip played]

23             MR. NICHOLLS:  All right.  We can't see much where I've stopped

24     it at 7:52.3, but just to try to keep the route clear, we just saw the

25     scene at the Blue Building where Major Kingori was discussing the place

Page 23569

 1     that was too crowded, where the men were sitting on each other, and now

 2     we see that he is walking with his camera and going somewhere else.  Can

 3     we play, please.

 4                           [Video-clip played]

 5             MR. NICHOLLS:  Maybe go another frame or two until we get a

 6     clearer picture.  Okay.  We're now at 8:03.5 on the video.  If I could

 7     bring up page 16 of the road book, please.  Picture A.  That's the still

 8     we have.

 9        Q.   Which location -- where are we now, Mr. Blaszczyk?

10        A.   Right now we are in the front of the white house.  I marked this

11     location when Mr. Borovcanin with -- with Dutch officer over there and

12     interpreter is standing, and my picture from -- on the page 17 A and C,

13     and in the background we -- on the left-hand side of this picture,

14     picture 1 from the page 17, we see the white house.

15             MR. NICHOLLS:  And let's just keep playing a little bit.

16                           [Video-clip played]

17             MR. NICHOLLS:  All right.  We've stopped at 8:34.5.

18        Q.   Again, kind of across -- across the road from the white house; is

19     that right?  Not the Bratunac-Konjevic Polje road but the small access

20     road.

21        A.   Yeah.  This is across the small access road, this gravel road,

22     narrow road.

23        Q.   And --

24        A.   Literally about 10 metres or 15 metres from -- from the gate of

25     the white house.

Page 23570

 1             MR. NICHOLLS:  And that corresponds to photo C on page 16.  If we

 2     can keep playing now.

 3                           [Video-clip played]

 4             MR. NICHOLLS:  Okay.  We stopped at 8:51.2 on the video with the

 5     still image of the white house with a lot of bags in front and you can

 6     see part of the balcony.  It's approximately the same as -- still as

 7     photo D on page 16.

 8             Just to be clear now can we bring up page 17, please, Mr. Reid,

 9     and just the whole page.

10        Q.   Okay.  Just very simply this helps point out what you were

11     discussing a minute ago.  On page 17 of the road book, photos A and C

12     which you've marked, that's the location - excuse me - where

13     Mr. Borovcanin and Mr. Kingori and others were standing talking just

14     across from the white house.

15        A.   Yes, this is correct.  And on the page -- page 2 -- on page 17,

16     picture 2, we see the photo taken from the position of -- of where

17     Mr. Borovcanin, Kingori, and others are standing in front of the

18     white house.  This is Feros building.

19             MR. NICHOLLS:  All right.  If we could keep playing the video

20     now, please.

21                           [Video-clip played]

22             MR. NICHOLLS:  We need to go back, Mr. Reid.  All right.  We're

23     starting at 8:50.7.  If we could play now.

24                           [Video-clip played]

25             MR. NICHOLLS:  And stop at 9:05.

Page 23571

 1        Q.   Now, during that segment, this is what is depicted as we received

 2     the raw video from Mr. Petrovic Pirocanac; is that right?

 3        A.   Yes, this is correct.  This is the segment from -- from the raw

 4     material given to us by -- by Mr. Pirocanac.

 5             MR. NICHOLLS:  Could we go back a little bit, Mr. Reid, to the --

 6     keep going.  Keep going.  Stop.  Forwards.  Okay.

 7        Q.   At 8:51.8 we see a big shell casing.  Have you seen that shell

 8     before in this scene we see here?

 9        A.   Yes.  I saw this shell.  This shell was shown to me by

10     Mr. Petrovic in -- in February 2006 when we conducted interview with him.

11     The shell was located at his -- his home, on the balcony of his home.  In

12     fact this is shot from his house.

13             MR. NICHOLLS:  Okay.  Now let's play -- I'm going to now play,

14     Your Honours, a bit of video not from the raw footage but from the

15     Studio B documentary, which is P01193.

16             JUDGE KWON:  Could you tell me the exhibit number again.

17             MR. NICHOLLS:  I had the --

18             JUDGE KWON:  P --

19             MR. NICHOLLS:  If you give me one minute, Your Honour.  This is

20     actually in the trial video.  Sorry.  I need one moment.

21                           [Prosecution counsel and Case Manager confer]

22             JUDGE KWON:  Yes.  I confirm that the number you have given,

23     i.e., P1193, is that Studio B footage.

24             MR. NICHOLLS:  [Microphone not activated] Yes, Your Honour.  It's

25     just we're trying to find it in Sanction.  I'll play P0666.  And if we

Page 23572

 1     can go back and just get that ready.  That is a split screen.  You can

 2     stop for one second.

 3             THE INTERPRETER:  Microphone, please.

 4             MR. NICHOLLS:

 5        Q.   Mr. Blaszczyk, I think you helped create this video.  If you can

 6     explain it to us, please, which shows footage of the white house that was

 7     obtained from the Studio B documentary on one side and Mr. Petrovic's raw

 8     video that he provided to us on the other side.  Before we play it, can

 9     you just tell us a little bit what we're going to see?

10        A.   Yes.  Together with my colleague video assistant we tried to

11     create exactly the location on the raw footage where -- where this -- the

12     frames from the Studio B were recorded, and we compared to part of -- one

13     part -- two part of the videos, one from the Studio B and another one

14     from -- from the raw material.  We were able to -- to spotted the places

15     where -- where the material from -- when the footage from raw material

16     was over-recorded.  And if we play these two footages together, we will

17     see exactly where -- where was -- where and how it was over-recorded, you

18     know, on the raw material.

19             MR. NICHOLLS:  Okay.

20             JUDGE KWON:  Yes.  Now I understood.  This P666 was one of the

21     associate exhibits that we admitted into evidence together with

22     Petrovic's 92 bis statement.

23             MR. NICHOLLS:  Yes, Your Honour.

24             JUDGE KWON:  Yes, thank you.

25             MR. NICHOLLS:  Thank you.  If we could play that, please,

Page 23573

 1     Mr. Reid.

 2                           [Video-clip played]

 3             MR. NICHOLLS:  And I've just stopped for a moment at 11.1.

 4        Q.   And we can see -- it's a little bit hard to see, but is that the

 5     Studio B logo we see on the left frame, Mr. Blaszczyk?

 6        A.   Yes, this is correct.  This is logo of Studio B television in

 7     Belgrade.

 8        Q.   And the words running below on the left, that's actually

 9     advertising from when this documentary was broadcast in Belgrade; is that

10     right?

11        A.   That is correct.  It is Serbian language, some advertising not

12     connected to this particular video.

13        Q.   And on the right-hand side, that's the raw video from

14     Mr. Petrovic Pirocanac that he provided us.

15        A.   Yes, on the right-hand side we have the footage from the raw

16     material from Mr. Pirocanac.

17             MR. NICHOLLS:  If we can play now, please.

18                           [Video-clip played]

19             THE ACCUSED: [Interpretation] Can we have this transcript,

20     please?

21             JUDGE KWON:  I see the transcript in hard copy, page -- last

22     four digits 7892 in the transcript, but I don't know where we can find it

23     in e-court.

24             Can you help us, Mr. Nicholls?

25             MR. NICHOLLS:  Yes.

Page 23574

 1             JUDGE KWON:  What I said is last four digits.

 2             It's just simple.  It reads as it is written here:

 3              "There were some people who tried to smuggle themselves onto a

 4     convoy and who are registered criminals."

 5             MR. NICHOLLS:  It's e-court page 274, please.

 6             JUDGE KWON:  I don't know whether -- where is the Serbian

 7     version.  It's -- it should be there.

 8             Shall we continue, or shall we begin from the -- from the

 9     beginning?

10             MR. NICHOLLS:  We could play it one more time, Your Honours.

11             JUDGE KWON:  Yes.

12             MR. NICHOLLS:  I should say that P01193, which is admitted,

13     unfortunately we had trouble bringing it up, that I intended to play does

14     have the transcript synced with it.  So it's available there.

15             JUDGE KWON:  Thank you.

16             MR. NICHOLLS:  Let's play this one more time, this clip, please.

17                           [Video-clip played]

18             MR. NICHOLLS:

19        Q.   We can stop there.  Mr. Blaszczyk, we saw a two-second blank on

20     the one side.  That was also as the original as we received it; is that

21     right?

22        A.   Yes, it's correct.

23        Q.   Now, what was -- did you ask Mr. Petrovic about his explanation

24     for why the scene of the balcony with the men on it now had a -- on the

25     raw material we had a shell casing from his balcony?

Page 23575

 1        A.   Of course I did ask him.  We did ask him during our interview

 2     why -- why it happened.  He explained situation that he was very

 3     unexperienced to operate the camera and coincidentally and not

 4     intentionally he over-recorded this material when he returned to home.

 5     And he doesn't know exactly.  He -- his explanation was that he's not

 6     able to tell, you know, how it happened and why it happened.

 7        Q.   But the scene of the men on the balcony, just to be clear, is

 8     completely absent from the raw material he gave us.

 9        A.   Yes, it's correct.  This footage is not -- not -- not on the raw

10     material handed over to us, and if we compare the time-code from the raw

11     material, we see that originally there is missing about 11 seconds of

12     recordings.

13        Q.   Thank you.  What I'd like to do now is have you show to us and to

14     the Trial Chamber the interactive CD presentation that was created which

15     shows this chapter, Potocari.  If we could go through it quickly and let

16     me know if you need a minute to set that up.

17        A.   Your Honour, this is presentation we prepared just for better

18     understanding of Petrovic video of location where that video was

19     recorded.  I will try to explain how we can operate with this

20     presentation and how we go in.  If we -- on the -- on the bottom of this

21     picture we have few -- few buttons over here.  We can zoom button here.

22     We can blow-up little bit the picture.  Zoom out and go -- this one is

23     go -- is back to the -- the previous page, if we need to use that one.

24     This one which mark the places which is the linkage to another page or

25     photo or photos or image from Petrovic video.

Page 23576

 1             If we open this first page, if we go to the first page we see

 2     again the map of Bosnia-Herzegovina, and if you like -- would like to go

 3     to the area -- the Eastern Bosnia area, to Bratunac/Srebrenica area, we

 4     can press this -- this field, and we again we are in the next map.

 5     Coming closer, we are in -- in much detail map of area of Srebrenica,

 6     Bratunac, Konjevic Polje, but before I go in, I would like to tell that

 7     this presentation contains only two segments of Petrovic video, the most

 8     significant segments.  This is segment of Potocari and segment of

 9     Kravica, Sandici, and Pervani area.  Right now we passed -- we -- we were

10     through the Petrovic video of chapter 1 of Potocari.  Then let's go to

11     Potocari.  And we have map -- more detailed map of the area of Potocari.

12     We're marked some -- some arrows here.

13             And again if you'd like to get in to linkage to the photos from

14     my trip to Bosnia or to the image from Petrovic video, we have to go

15     to -- to these fields, but knowing where the fields are can be

16     activated -- we can use this button.

17        Q.   If you could maybe just take us through quickly and show us the

18     different places that we've just seen on video, how you can find them in

19     this presentation.

20        A.   Yes.  Let's go to the first place.  We are in the front of the

21     white house now.  We can move around.  We can see entire area.

22             If we go -- if we mark this -- the field here where the -- if you

23     remember, Your Honours, where Mr. Kingori, Borovcanin, and others were

24     talking in -- near, we see the image from Petrovic video.  And also if

25     you would like to zoom in, we can do that.  Going back --

Page 23577

 1             JUDGE KWON:  Could you go back to the first page again, kindly.

 2     Cover page.

 3             THE WITNESS:  Cover page.  Of course, Your Honour.

 4             JUDGE KWON:  Could you tell me again how you turn the page?

 5             THE WITNESS:  Just pressing the button of the mouse.  You know,

 6     just -- if you --

 7             JUDGE KWON:  Oh, yes.  Okay.  Yes.

 8             THE WITNESS:  Yes.  Your Honour, if you want to know where to

 9     press the button, it's perfect if you use this help button here, marking

10     the area when -- when you have linkage to another photos, map, or other

11     Petrovic video.

12             MR. NICHOLLS:

13        Q.   But it's correct that in the beginning if you just click anywhere

14     on the cover page, it brings you into the presentation and then into

15     highlighted area.

16        A.   Yes.  I think it's only the first page.  You know, the cover page

17     is linkage to the presentation itself.

18             Let's go back to the area of -- we are again in front of the

19     white house.  We saw already Mr. Borovcanin and Mr. Kingori talking in

20     front of the white house.  This is the footage from raw material of

21     Mr. Petrovic.  We are coming back.  We can enter.  We can go in here.

22     Also if you like to see which area we need to click to be linked to

23     another picture or photo we can use this button.

24             We are in the front house.  You know, this is also image from

25     Petrovic video, it's from his raw material, and the picture taken in

Page 23578

 1     2006.  If we click on the balcony here, we are getting image from -- from

 2     Studio B's -- mark of the Studio B is very visible here on the right-hand

 3     side on the top of this picture.  We can close-up to the balcony.  We see

 4     the people sitting on the balcony.  One more time, we have the closest

 5     view of these people.

 6        Q.   All right.  Thank you.

 7        A.   We are back to the picture from 2006.  And as I said, if we would

 8     like to see the view from -- from the Feros building, let's go to the

 9     other side of the road using this button.  In fact, we see the

10     Feros building from -- from this location.  This is the Feros building

11     here.

12        Q.   Seen from the white house?

13        A.   Yes, exactly.  We have the Feros building, the blue -- we call

14     this Blue Factory but belonged to Feros company behind.  And DutchBat and

15     road leading towards Bratunac.  Here at that time it was the main gate of

16     and check-point of DutchBat.

17             Again we have a linkage here to the photo from Petrovic raw

18     material.  We see the Feros building behind, the Feros administration

19     building behind.

20             If we move up, we are in direction to Srebrenica now.  If we --

21     yeah.  This is -- this is also footage from Petrovic video.

22     Approximately it was taken in this -- this location on the right-hand

23     side of the road leading from Bratunac to Srebrenica.  You see the man

24     working on the right, right side of the road.

25        Q.   And again, Mr. Blaszczyk, if I could stop you for a minute.  If

Page 23579

 1     you go back one frame to the overview.  You were able to determine, I

 2     think you said, the location of these photos by the Feros building on the

 3     one side where the people are walking, and if you turn the other -- keep

 4     scrolling to the right, the topography of the mountains you can see

 5     behind in some of the videos; is that right?

 6        A.   Yes.

 7        Q.   Thank you.  If you could just show us the other links in the

 8     Potocari part.

 9        A.   Uh-huh.  This is another side of the road also, road leading --

10     if we look straight we are faced towards Srebrenica and we see people

11     walking on the left-hand side of the road.

12             And we can move closer to the blue -- Blue Building and the

13     check-point containing -- check-point of DutchBat APCs.  You should

14     remember, Your Honours, this picture from the book but more wider picture

15     in panorama picture.

16             This building is -- this was built after the war.  It didn't

17     exist in July 1995.  Behind this new building we see the part of the bus

18     compound here.

19             We see the footage from July 1995 recorded by Mr. Petrovic.

20        Q.   And again that -- what you just showed us, if you can scroll

21     back, is the area with that small bridge or drainage ditch and the

22     check-point we saw.

23        A.   Yes, it's hard really to see it, but I'm standing probably on

24     this bridge now taking the photo.

25        Q.   All right.

Page 23580

 1        A.   And again, Your Honour, if -- these arrows mark the area or the

 2     field, you can link to another photos, but if you would have -- or if

 3     anybody would have a problem to find additional linkage fields, you can

 4     use this button and this mark here.

 5             Let's go back.  We are in the map, map of Potocari.  Now we are

 6     in front of -- in the yard of the Blue Building.  We see the

 7     Blue Building.  This building is located about 100 metres from the

 8     white house, and on the same side of the road.  The white house is not

 9     visible here, but it's visible Feros administration building and the

10     blue -- Blue Factory, Feros company behind is, as I said, about 100,

11     150 metres.

12             I check the linkage here.  If you remember, we see the APC, part

13     of the APC and the Dutch soldiers.  And behind we also see the DutchBat

14     and part of the Blue Factory.

15             Another linkage, we see here Mr. Beara and Mr. Kingori.  They are

16     on the yard of Blue Factory exactly in this location.

17        Q.   Can I stop you one second.  I think I heard you say that last --

18     could you bring that --

19        A.   Yes, I realised.  That's not Blue Factory, of course.  This is

20     Blue Building.

21        Q.   And I think I heard you say Mr. Beara.

22             THE INTERPRETER:  Microphone, please.

23             MR. NICHOLLS:

24        Q.   Could you bring up the photo you just showed us of the men with

25     Mr. Kingori.  Yeah.  Who is that, with the black patch?

Page 23581

 1        A.   Did I say Mr. Beara?  No, this is Mr. Borovcanin.

 2     Mr. Borovcanin, of course.

 3        Q.   Thank you.  Please continue, just show us the rest of the links

 4     here.

 5        A.   We are again in the yard of the Blue Factory -- Blue Building.

 6     And behind this Blue Building here we see -- we see power plant,

 7     electrical station of -- of -- behind this electrical station is also

 8     behind of -- of white house.

 9             Let's go to the footage from July 1995, 13 July 1995.  We are

10     again in the yard of the Blue Building.  We see the tractor with water

11     tank.

12             One more general view of the area.  Let's go back to the view.  I

13     think we were here already.

14             And we're again in the front of the white house.  Across the road

15     we have the Feros building.  And this is presentation regarding Potocari

16     and events in Potocari from July 13, 1995.

17        Q.   Thank you.  And we can --

18             JUDGE KWON: [Microphone not activated]

19             MR. NICHOLLS:  Thank you.  We can leave that now.  And just to be

20     clear, these -- the photographs used in the presentation you've just

21     shown us are the same ones used in the road book, stitched together,

22     taken at the same time.

23        A.   Yes.  Yes.  This is -- I think each photograph is taken during

24     our mission in -- in May 2000 -- 2000 -- 2006.  The photograph in -- of

25     Potocari, yeah, yeah.  And also we -- you see the same photos or very

Page 23582

 1     similar photos in our road book.

 2        Q.   So then just to confirm what we saw in this segment of video and

 3     in the book was Mr. Pirocanac coming in past the UN DutchBat base,

 4     stopping and being out of the car by the Feros building, walking by the

 5     check-point --

 6        A.   Yes.

 7        Q.   -- being at the Blue Building and then going to the white house.

 8     Is that the correct sequence?

 9        A.   Yes, this is correct sequence.  The first footage of

10     Mr. Pirocanac being in Potocari, not driving in Potocari but being in

11     Potocari we have in the front of the white house, in front of the Feros

12     building.  He's entering the bus with the people in, and he's walking

13     towards Blue Building, recording some events and some conversation or --

14     in -- in front of -- at the check-point place, then on the yard of the

15     Blue Building, returning again to the white house.  Location of the white

16     house.

17             MR. NICHOLLS:  Okay.  If we could go back to playing the video

18     now, please.  The raw video.  We can start just about where we left off

19     at 9:04.6, and if we can play.

20                           [Video-clip played]

21             MR. NICHOLLS:  And stop, please.

22        Q.   Now, just before we -- that is the end of the Potocari segment we

23     just saw on the 13th of July; is that right?

24        A.   Yes, that is correct.  This is the end of the Potocari segment.

25             MR. NICHOLLS:  Could I now have - we can do this before the

Page 23583

 1     break - page 20 of the road book, chapter 2.  And go to the next page,

 2     please, page 21.

 3        Q.   This is the next sequence of footage we're coming to that was

 4     shot by Mr. Pirocanac at that day.  We've got the map here of the

 5     locations that you plotted with the GPS from your trip.  Just before we

 6     begin watching the video, can you tell us what this -- what this area is

 7     that -- that appears on video we're about to see, the locations, and just

 8     quickly tell us which way the car was travelling and when it turned

 9     around.

10        A.   This is area of Sandici, Pervani, and Lolici, and Kravica.  We

11     see the footage -- the first footage that Mr. -- Mr. Pirocanac together

12     with Mr. Borovcanin, they are in Sandici, in Sandici meadow, and then are

13     driving towards Konjevic Polje.  They are following two APCs -- in fact,

14     one APC and one BOV and one Praga, and they are returning to Sandici

15     meadow and they are driving towards Kravica.

16        Q.   And can we just -- before we begin playing the video, I think it

17     would be helpful go to the next page of the book, please, page 22.  We'll

18     start off near Sandici meadow when we watch the video.  It's a little bit

19     of a complicated scene so can you just tell us about this large picture

20     you took which set it out and the locations you've marked.

21        A.   Yes.  This is overview picture of the area of Sandici meadow.  We

22     took this picture from the hill above the Sandici meadow, and I plotted

23     here -- I just connected -- I showed here the location of destroyed

24     white house opposite the road of the Sandici meadow and destroyed house

25     in Sandici meadow itself.

Page 23584

 1             On the right -- left-hand side of the picture on the top we have

 2     the -- the close-up of the picture of the destroyed white house across

 3     the road, and on the right-hand side on -- on the top we have destroyed

 4     house in Sandici.  These houses -- these two houses would be visible on

 5     the Petrovic video.  When we play the Petrovic raw material we see these

 6     houses and -- in this video.  And we have general view of the

 7     Sandici meadow.  We see the road leading from -- I marked the direction

 8     here Konjevic Polje and Kravica-Bratunac, and somebody who never been

 9     there can -- can see, you know, which direction we are going to.

10        Q.   All right.  Thank you.

11        A.   On the ...

12        Q.   Continue, please.  Continue, please, if you had something.

13        A.   And opposite like in the previous pages, you know, I didn't --

14     this page didn't follow by the -- in fact, this page on the left-hand

15     side is not the -- not the picture from Petrovic video, but I tried to --

16     to make it as easy as possible to understand the area over there.  And on

17     the page 23 we have close-up of -- of destroyed white house.  We have

18     Sandici meadow and we have also panorama picture of the road including

19     the destroyed white house.

20        Q.   All right.  And that's page 23.  If we could bring it up for

21     one minute for the public to see what you've just described.

22             MR. NICHOLLS:  Thank you, Your Honours.  I see it's almost the

23     break.  I'm going to play some video now but I'd rather just start

24     playing it and play it through rather than play two minutes and stop, if

25     I may.

Page 23585

 1             JUDGE KWON:  Yes, please.

 2             MR. NICHOLLS:  Thank you.  But I just wonder if we could take the

 3     break now rather than start the video.

 4             JUDGE KWON:  Yes, we'll do that.

 5             MR. NICHOLLS:  Thank you.

 6             JUDGE KWON:  We'll take a break for half an hour and resume at

 7     11.00.

 8                           --- Recess taken at 10.27 a.m.

 9                           --- On resuming at 11.00 a.m.

10             JUDGE KWON:  Yes, Mr. Nicholls.

11             MR. NICHOLLS:  Thank you, Your Honours.  Now we're going to start

12     with chapter 2 of the book entitled "On the road."  It begins at Sandici.

13     I'll just say for the record, in the trial video book, P04202, there are

14     some stills from this beginning at page 98 of the hardcover, page 137 in

15     e-court, which identifies some of the people we're see on the video.  I

16     don't propose to stop and identify each person as we go along, but that's

17     where it can be found.  The transcript for this section begins in the

18     same exhibit at e-court page 274.

19        Q.   Now, to begin with, could we just -- before we start playing,

20     just show page -- the next two pages of the road book, pages 24 and 25,

21     to orient ourselves.  That's up on the screen now.

22             And, Mr. Blaszczyk, the still from the video on the left, which

23     is from page 24, shows a man in camouflage uniform standing in front of

24     the small destroyed house, and on the photo at the right, the one taken

25     on your mission, there's a man, I believe it's you, standing in front of

Page 23586

 1     the same destroyed house, and an image on right showing where we are.  So

 2     just to be clear, and correct me if I am wrong, but this image where we

 3     begin is now kind of right in the middle of Sandici meadow; is that

 4     right?

 5        A.   Yes, this is correct.  This is right in the Sandici meadow.

 6        Q.   All right.  And you've marked that as position 5 on the map for

 7     this chapter?

 8        A.   Yes, correct.  If you go back to the map, it's marked as

 9     number 5.

10             MR. NICHOLLS:  All right.  Mr. Reid, if we could now start

11     playing the video.

12                           [Video-clip played]

13             MR. NICHOLLS:  Can we stop, please.  Go back one frame.

14        Q.   All right.  We've stopped at 10:22.6.  I just wanted to stop

15     here, Mr. Blaszczyk, because we've got the date stamp 13 July 1995 on the

16     original raw video.  Just to ask you, is that the right date?

17        A.   Yeah, this is the right date.  13 July 1995.

18        Q.   And we don't need to bring them up now, but you've marked this

19     man who is calling out to his son and the location on pages 26 and 27 of

20     the road book; is that right?

21        A.   Yes, it's correct.  On the page 26 we have stills from

22     Petrovic video.  And on page 27 we have my photos with marked location or

23     spotted location where the man was standing.

24             JUDGE KWON:  How do we know he's calling his son, Mr. Nicholls?

25             MR. NICHOLLS:  Perhaps I shouldn't have said that.  I believe

Page 23587

 1     that's from some other evidence, Your Honours.  I'll strike that.

 2             JUDGE KWON:  Thank you.

 3             MR. NICHOLLS:  If we could continue playing, please.

 4                           [Video-clip played]

 5             MR. NICHOLLS:  Stop.

 6        Q.   All right.  Can you just tell us what that part we saw is,

 7     Mr. Blaszczyk, with no picture but just a recording of Mr. Petrovic

 8     talking about himself?

 9        A.   This is -- according to Mr. Petrovic, this is his conversation

10     with somebody on the phone, and it was recorded at his -- his apartment

11     or house in Belgrade.  It's over-recorded for the original material.

12        Q.   All right.  So again, he's recorded over a portion there that we

13     don't have.

14        A.   Yes, it's correct.

15        Q.   Now, if we could keep playing, please.  We're at 11:16.6.

16                           [Video-clip played]

17             MR. NICHOLLS:  Stop, please.  We stopped at 11:50.4, after seeing

18     Mr. Borovcanin speaking with two armed men about swapping pistols.  I'll

19     ask Mr. Reid if we can now bring up pages 30 and 31 of the road book.

20        Q.   And we saw the camera at the end pan from Mr. Borovcanin and

21     these two men back to Sandici meadow.  Can you tell us how you determined

22     where they are?  Where is this conversation taking place with

23     Commander Borovcanin?

24        A.   If we would play this video again in slow motion, we could see

25     even the part of the destroyed white house which is located across the --

Page 23588

 1     the road from Sandici meadow, and watching carefully the move of the

 2     camera, I easily could -- could -- could locate the place where

 3     Mr. Borovcanin is talking to these two -- two men.  One is from the --

 4     from the Special Police Brigade, another one from PJP Company.

 5        Q.   All right.  And on page 31 of the map book, you've marked A and

 6     B, the location where this conversation took place?

 7        A.   Yes.  This is correct.  I can be wrong, but my mistake would be

 8     in one matter, two matters, maybe, but no -- no more.

 9        Q.   All right.  I'll -- since you suggested it, I'll ask Mr. Reid to

10     play that clip again.  I don't know that we can play it in slow motion,

11     but we'll just play it to show the proximity of Mr. Borovcanin and these

12     men to the prisoners.

13                           [Video-clip played]

14             THE WITNESS:  It was a little bit early.

15             MR. NICHOLLS:  Go back again, Mr. Reid, sorry.

16                           [Video-clip played]

17             THE WITNESS:  Could you stop here?  Yeah.  This is --

18             MR. NICHOLLS:  If we can go back two frames.  Yes.

19             THE WITNESS:  You -- just above Mr. Borovcanin's head we see -- I

20     believe this is the part of the wall of white house, destroyed white

21     house.  And later on when we -- you follow the move of the camera, you --

22     you could see the road, the main road, and also part of the

23     Sandici meadow.  And just taking into consideration all this movement and

24     this feature, I located this spot.

25             MR. NICHOLLS:

Page 23589

 1        Q.   All right.  And we're at 11:34.7, where you say there's a small

 2     portion of the white house we can see.

 3             MR. NICHOLLS:  If we can play, please, again.

 4                           [Video-clip played]

 5             MR. NICHOLLS:  Stop there, please.

 6        Q.   And we'll just do this quickly.  If we could look at page 32 and

 7     33 of the road book.  Yeah.  Here you've marked just the section of

 8     Sandici meadow where these men were gathered just before the camera once

 9     again went black; is that right?

10        A.   Yes.  This is correct.  This is on page 33.  We have the panorama

11     picture of Sandici meadow, and I marked the location where the men were

12     gathered.

13        Q.   And the photo on page 33 is approximately taken with the

14     photographer's back to the white house.  Is that about right?

15        A.   Yes.  This is correct.  The photos was taken on the side of the

16     road where the destroyed white house is located.  Just -- we do the photo

17     from -- it was several photos, just matched together.

18             MR. NICHOLLS:  All right.  And, Your Honours, on page 32,

19     photo B, there's a typo in the counter code.  It should be 11:44.10, not

20     11:54.10.  I apologise for that.

21             If we could continue playing the video now.

22                           [Video-clip played]

23             MR. NICHOLLS:  Stop.  We don't need to go back to the still.  We

24     can stop.  We don't need to go back to the still.  This area's on page 34

25     and 35 of the road book, marked as map position 9.

Page 23590

 1        Q.   Can you just tell us approximately where this is taking place in

 2     relation to Sandici meadow and what we saw in this picture of the guns

 3     firing into the woods.

 4        A.   This footage was recorded about 200 -- 2.800 metres from Sandici

 5     meadow, on the road leading towards Konjevic Polje, and we see on this --

 6     this footage we see one Praga and one BOV, the armed vehicles of

 7     Special Police Brigade, Sekovici Detachment.

 8        Q.   And just quickly, how were you able to determine this location

 9     heading towards Konjevic Polje now from Sandici meadow?

10        A.   Again, it wasn't difficult.  Just looking at the features of the

11     terrain especially of the road and the hills, surrounding hills, we could

12     easily determine the place where the footage was recorded.

13             MR. NICHOLLS:  All right.  We'll keep playing now.

14                           [Video-clip played]

15             THE WITNESS:  Could you stop here?

16             MR. NICHOLLS:

17        Q.   We stopped at 13:23.9.

18        A.   And it's not mentioned here in my road book, but it's visible on

19     the video.  If you look at the smoke coming out from the forest after the

20     shelling, we see the people moving around.  We just see the shape of the

21     men, probably of the men.  If you look very carefully on it.  But we

22     should play it again.  It's not visible now.  The quality is not so good

23     now in this version, but if you play, we see that these men is -- or

24     whoever it is just moving.

25                           [Video-clip played]

Page 23591

 1             MR. NICHOLLS:  Can you go back just a tiny bit, Mr. Reid.  Yeah.

 2     We're at 14:13.1 in the video.  That picture approximately is shown on

 3     page 36 of the road book in picture B.  It's off by a tiny amount.  And

 4     if we look at page 37 of the road book, if we could, Mr. Reid, picture

 5     A1.  And we see a house and a sloping hill behind it.

 6        Q.   Were you able -- just tell us how -- where we are now in this

 7     location still and how you were able to tell where we are.

 8        A.   We see that these two -- two vehicles moved towards

 9     Konjevic Polje about 300 metres.  It's also Pervani, Pervani area.  And,

10     yes, I spotted the houses, which is also recorded by Mr. Pirocanac here.

11     If you look at my picture from the page 37, it is -- maybe it doesn't

12     look the same, but is -- is the same house re-builded after the war, and

13     looking also at the features of the terrain, as I said, at the hills and

14     the road and the location of the houses and their relation to the other

15     houses, we could easily spot the place where the -- the footage was

16     recorded.

17             JUDGE KWON:  Mr. Blaszczyk, did you say page 57 or it's 37?

18             THE WITNESS:  Thirty-seven.  Sorry, Your Honour.

19             JUDGE KWON:  I'm sorry?

20             THE WITNESS:  Thirty seven, Your Honour, 3-7.

21             MR. NICHOLLS:  Thank you, Your Honour.

22        Q.   Picture A on page 37.  Correct, Mr. Blaszczyk?

23        A.   Yes, it's correct.  This is picture A on the page 37.  We have

24     the same -- the same house depicted on the still from Petrovic video on

25     the page 36 as marked here as -- as still A.

Page 23592

 1        Q.   So what we're seeing is Mr. Petrovic and Mr. Borovcanin have left

 2     Sandici meadow, heading along the road towards Konjevic Polje, stopping

 3     occasionally and filming this firing into the woods.

 4        A.   It is quite correct.  Just we see that Mr. Borovcanin and

 5     Mr. Pirocanac, they are following these two APCs along the road.  In

 6     Pervani.  This place is located, according to our measurement, about 3 --

 7     3.000 metres from Sandici meadow.

 8             MR. NICHOLLS:  All right.  If we could continue playing the

 9     video, please.

10             JUDGE KWON:  Just a second.

11             Mr. Blaszczyk, did you say Mr. -- Mr. Pirocanac was following

12     these two APCs along the road?

13             THE WITNESS:  Yes, Your Honour, because we -- we hear the voice

14     even coming from -- in fact, we know that it's coming from the car of

15     Mr. Borovcanin and -- and Mr. Pirocanac, and we know also from other

16     witnesses, including Mr. Petrovic Pirocanac, that they -- they follow

17     these two APCs at the beginning.

18             JUDGE KWON:  Thank you.

19             MR. NICHOLLS:  Thank you, Your Honour.  If we could play now,

20     please.

21                           [Video-clip played]

22             MR. NICHOLLS:  All right.  We've stopped now at 16:39.2.  This is

23     a shot -- a still from video which was clearly filmed from inside of the

24     car, from the front passenger side, while the car was being driven.

25             If we could look, Mr. Reid, at pages 38 and 39 of the road book.

Page 23593

 1     For now just page 39.

 2        Q.   On page 38 we've got the stills A and B which correspond to where

 3     we stopped the video.  This is map position 11 you've marked on your map

 4     on page 21 of the road book.  And I can see from the way you've marked

 5     the road directions in -- on pages 38 and 39 that the car now appears to

 6     be heading back towards Sandici and Bratunac.  In other words, the

 7     opposite direction of the video we saw up to this point.  Is that -- it's

 8     a long summary.  Is that -- is that correct?  Which direction now are

 9     Mr. Petrovic and Mr. Borovcanin travelling?

10        A.   Yes.  You are right.  The car is now heading towards

11     Sandici meadow again.  This is the first footage which we see that the

12     car made a U-turn and heading towards Sandici meadow.

13        Q.   And were you able to determine the precise location of the U-turn

14     from watching the video or not?

15        A.   No.  I wasn't able to do it, because I -- as you see here, the

16     images on this page 38, the stills from Petrovic video, these two houses

17     are located about 1.000 metres, you know, just from the previous location

18     when we saw the Praga and BOV shooting towards the hills, but as far as I

19     remember from interview of Mr. Petrovic, they drove towards

20     Konjevic Polje.  They made a U-turn, I think, in Konjevic Polje, but I

21     was not able to determine the place where they made this U-turn on this

22     video.

23        Q.   All right.  Thank you.  And so just to be clear for the map book,

24     from Sandici meadow up to map position 10, which we saw on the previous

25     pages, the direction of travel is towards Konjevic Polje.  At some point

Page 23594

 1     there's a U-turn, and from map position 11 as we continue now it's back

 2     towards Sandici meadow.  They've made a -- they're returning to where we

 3     started.

 4        A.   Yes.  This is -- this is correct.  From -- from -- from 11 on the

 5     map this is direction towards Sandici and Kravica, in fact.

 6        Q.   And very simply, we see some houses on page 38 and 39.  Did that

 7     assist you in locating where we see this conversation taking place in the

 8     car as you've marked it on the map book.

 9        A.   Yes, this house, especially this one help me to locate -- spotted

10     this location, and this is the house marked here as house B here.  This

11     is the house -- I believe this is that one from the -- from the picture,

12     from the still from Petrovic video.  And at the beginning I wasn't so

13     sure, you know, just whether this is the proper house or not, but I

14     talked to the owner of this house and renovated house next to this

15     destroyed house, and I showed him the footage, the stills from the

16     Petrovic video and he confirmed that these two houses belonged to his

17     family.

18        Q.   All right.  Thank you.

19        A.   And, of course, the features of the -- the terrain and the road.

20     Which is another confirmation.

21             MR. NICHOLLS:  Thank you.  And now if we'll continue playing now

22     the footage as we return to Sandici meadow direction.

23                           [Video-clip played]

24             MR. NICHOLLS:

25        Q.   Sorry, just a quick question.  We see Mr. Borovcanin speaking

Page 23595

 1     here about stopping the traffic, and we saw a reference to Bor.  Whose's

 2     nickname is Bor, if you know?

 3        A.   Yes, Mr. Borovcanin, Ljubisa Borovcanin, he used the nickname

 4     Bor.  Or the other people used to call him as Bor on the radio.

 5             MR. NICHOLLS:  You can play, please.

 6             THE WITNESS:  And --

 7             MR. NICHOLLS:

 8        Q.   Yes?  Continue.

 9        A.   And I think we have confirmation because when we saw the previous

10     footage, they went to these two brothers who were dealing with the

11     pistol, showing the pistol to Mr. Borovcanin, one of them called him also

12     Bor, if I could remember.

13             MR. NICHOLLS:  Yes.  If we could play, please.

14                           [Video-clip played]

15             MR. NICHOLLS:  This one is very hard to capture.  We stopped at

16     17:06.3.  On page 40 of your book, we see the still at photo A, and if we

17     were to continue for just a few seconds, in position A we see a man with

18     a rifle and another man.  We can see actually where we stopped at

19     17:06.3, further down, two soldiers.  Again this is map position 12 on

20     pages 40 and 41.  We'll keep playing, but how were you able to determine

21     this location?

22        A.   This is again, like in the previous cases, just looking at the --

23     at the features of the terrain.  But looking at this retaining wall, in

24     this area near Sandici meadow there are two retaining walls from Sandici

25     meadow towards the direction of Konjevic Polje.  This is one of these --

Page 23596

 1     these retaining walls.  Later on we should see another one.

 2        Q.   And how far now is Mr. Petrovic and Borovcanin from Sandici

 3     meadow?

 4        A.   We are about 900 metres from Sandici meadow.  Mr. Borovcanin

 5     heading from Konjevic Polje direction towards Bratunac and, of course,

 6     Sandici meadow.

 7             MR. NICHOLLS:  All right.  Keep playing, please.

 8                           [Video-clip played]

 9             MR. NICHOLLS:  All right.  We stopped at 17:48.7.

10        Q.   This still we've stopped at, the frame corresponds to page 42 of

11     your road book, photo C, again filming from the car.  We can see a

12     soldier crouching just over the mirror, the rear-view mirror of the car.

13     These are positions on your map, 13, 14, 15.  The other soldiers I didn't

14     stop at.  How far are we now from -- or we're getting closer to Sandici

15     meadow; correct?

16        A.   Yes, this is correct.  We are getting closer to Sandici meadow.

17     We about 400 matters from Sandici meadow.

18             MR. NICHOLLS:  I ask Mr. Reid to bring up page 43 of the road

19     book.  And if we can perhaps make that larger, the road book page.

20     That's good.  And I think in hard copy it's easy to see.

21        Q.   You've marked -- just so we can see, does this show us where

22     these soldiers are lined up along the road, the same road where we saw

23     firing into the hills coming from earlier in relation to Sandici meadow,

24     the destroyed white house, and you've also marked in the small inset

25     photo the Kravica warehouse.  Can you confirm that and tell us just a

Page 23597

 1     little bit about how far these distances are from here to the Kravica

 2     warehouse?

 3        A.   Yes, I can confirm it.  It's not visible here on this picture, of

 4     course, it's too small one, but if we zoom -- zoom in this picture, you

 5     know, we can -- we could see also Kravica warehouse.  It's very visible

 6     from Sandici meadow.  It's -- the location of Kravica warehouse in

 7     relation to the Sandici meadow, the distance is about 900 metres,

 8     1 kilometre at the most.  900 metres, I would say.

 9        Q.   And there's one -- on page 43, one area marked with a white X.

10     It's not a -- can you just tell us what that location indicates.

11        A.   In such way I marked the position or the location when -- where

12     the Bosnia Federal Commission for Missing Persons made exhumation of

13     70 bodies.  It was June 2004.  The bodies were dumped behind this

14     barrier.  There is a small stream going along this road.

15             MR. NICHOLLS:  All right.  Let's continue playing.  From 17:48.7

16     we'll continue playing.

17                           [Video-clip played]

18             MR. NICHOLLS:  Keep playing.

19                           [Video-clip played]

20             MR. NICHOLLS:  All right.  We've stopped at 18:06.08.

21        Q.   This is shown on photo B of page 46 of the map book, and you've

22     marked it as position 17, 17A.  On page 47 of the map book, A and B,

23     you've marked where this man calling for people to come out of the woods

24     is.  If you just tell us now how -- how close is this to -- well, we

25     could -- how close is this to Sandici meadow?  We can see on the photo on

Page 23598

 1     page 47 the approximate location.

 2        A.   This place is visible from Sandici meadow itself and is located

 3     about 200 metres from Sandici meadow.  On page 47 I tried to -- to make

 4     it clear as much as possible, you know, just to -- to point out this --

 5     this particular location and relation to Sandici meadow.

 6        Q.   All right.  So this just shows us the location of where some of

 7     the soldiers are arranged along the road by Sandici meadow where they're

 8     calling out to the prisoners to surrender.

 9        A.   Yes, exactly.  They are members of Special Police Brigade,

10     Jahorina Unit.

11        Q.   And just if I can look at the bottom photo, photo 2 on page 47.

12     That's that big panoramic photo.  The way the road is so curved there, is

13     that accurate or is that distorted a bit from putting the pictures

14     together?

15        A.   This picture, in fact, is a little bit distorted, and we tried to

16     merge this picture, you know, as much as possible to reflect the real

17     situation, but it's a little bit distorted, you know.  The road is more

18     straight.  If you are planning to visit this area it would be very

19     visible.

20             MR. NICHOLLS:  Keep playing now, please.

21                           [Video-clip played]

22             THE WITNESS:  Could you stop here?

23             MR. NICHOLLS:  Stopped at 19:31.8.

24        Q.   You asked us to stop, Mr. Blaszczyk.

25        A.   Yes, Your Honour, if you pay attention to the hill, you will see

Page 23599

 1     the people moving.

 2        Q.   Which people?

 3        A.   I mean Muslim population.

 4             MR. NICHOLLS:  Can we back up just a bit, Mr. Reid, and we'll

 5     play again.  Okay.

 6                           [Video-clip played]

 7             MR. NICHOLLS:  All right.  I stopped us at 20:13.1 on the video.

 8     The photo there, it's a little bit blurry on the frame we're on, but it

 9     corresponds to photo C on page 48 of the map book.

10        Q.   You've marked this as position map 18.  Again, now about

11     150 metres from Sandici meadow; is that right?

12        A.   Yes, this is correct.  In the vicinity of Sandici meadow.

13        Q.   And they've stop the car and are walking around, obviously.  And

14     just again, it's a bit blurry on the frame, but is this Mr. Borovcanin we

15     see on the screen on the far left?

16        A.   Yes, this is correct.  On the left-hand side I see Mr. Borovcanin

17     here.  And these two men on the right-hand side, they're members of

18     1st Company of PJP, CJB Zvornik.

19             MR. NICHOLLS:  Thank you.  And I won't bring it up to save time,

20     but I'll just say on page 49 of the road book, with these photos we can

21     see that this is just up the curve of the road, nearly now back to

22     Sandici meadow and the white house where we started this -- seeing this

23     section of the film by Mr. Petrovic.

24             We can keep playing now.

25                           [Video-clip played]

Page 23600

 1             MR. NICHOLLS:  All right.  We're at 21:03:7.  That corresponds

 2     nearly identically to photo B on page 50 of the map book, now a hundred

 3     metres or just a little bit closer to Sandici meadow.

 4        Q.   Do you know who these men are?

 5        A.   Yes.  These two men, they are members of Jahorina Company of the

 6     Special Police Brigade.

 7        Q.   Okay.  And we saw them pointing their rifles down, downwards, and

 8     Mr. Petrovic filmed just down towards the ground through some trees and

 9     we heard some running water.  What's down there, and why are they -- what

10     is in that direction from this part of the road?

11        A.   Mr. Petrovic filming here little bit stream and they're waiting

12     for -- expecting some Muslims coming down from -- from the hills through

13     these bushes towards the -- the road how they were called by -- by the

14     Serbs.

15        Q.   All right.  Thank you.  And I won't bring it up to save time, but

16     you've marked this clearly on page 51 of the road book.

17             MR. NICHOLLS:  Let's keep playing, please.

18                           [Video-clip played]

19             MR. NICHOLLS:  All right.  We've stopped now at 21:12.9 in the

20     video.  This corresponds to photo B on page 52 of the road book.  The

21     location's marked as now about 50 metres from Sandici meadow, getting

22     closer.

23        Q.   You've marked it on page 53 as well.  I just wanted to stop here.

24     Is that Mr. Borovcanin we see talking to the soldier wearing the blue

25     helmet?

Page 23601

 1        A.   Yeah, this is correct.  This is Mr. Ljubisa Borovcanin talking to

 2     this soldier with the blue helmet, but we see that this is member of

 3     Special Police Brigade.  If you look at the left arm is visible -- I

 4     believe this is visible badge of Special Police Brigade.  We saw this

 5     similar badge on the arm of one of the brothers with the gun.

 6        Q.   And which force would these blue helmets belong to?

 7        A.   The blue helmet itself, not to the Serb forces but definitely

 8     this is not Serbian equipment.  It belonged, I believe, to UNPROFOR.  And

 9     we see also the man next to the car, just looking by the white car.  This

10     is the car used by Mr. Borovcanin, Mr. Pirocanac Petrovic, and the man

11     just getting in the car or getting something from the car, he's his

12     driver Nedjo Jovicic, I believe.

13        Q.   All right.  Thank you.  And again what you've just described we

14     can see on page 52 of the road book.  It's the same in e-court, page 52.

15     Photograph B.

16             MR. NICHOLLS:  Keep playing.

17                           [Video-clip played]

18             MR. NICHOLLS:  All right.  We're at 21:56.8 of the video.  It's

19     an almost perfect match with photo C on page 54.  Just before this man

20     with the back-pack and the dark jacket, we saw a man in a white shirt and

21     two men, one of them helping the other, walking up this path uphill

22     towards where this man is.

23        Q.   Could we go to page 55, please, of the road book where you have

24     marked out the path or route taken by these Muslim men as they come out

25     of the woods up towards Sandici meadow.  Can you just tell us how you

Page 23602

 1     figured it out.

 2        A.   Yes.  This is correct.  I tried to -- I tried to establish the

 3     pattern of how the people were coming out from the woods and from the

 4     hills to -- to Sandici meadow, and also looking at the features of the

 5     terrain, looking at the white house, destroyed white house behind the

 6     road and checking out the features of this house, and checking how the

 7     people were getting the road, it's visible that this is this location,

 8     exactly this location.

 9        Q.   All right.

10        A.   If we play later on we see more details of the destroyed white

11     house including the pillars.  And entire white house, I believe.

12        Q.   Okay.  And if we look at where we stopped, the men rounding a

13     corner, which is photo C on page 54, you've marked that -- it's hard to

14     see on the screen we've got.  On page 55, as he's just at the corner of

15     the white house; is that right?

16        A.   Yes, this is correct.  It is on the bottom -- on the page 55, the

17     picture number 3, I've marked as his position C here and also on the

18     first picture from the same page 55, and C, where the man is passing by

19     the corner of this building.

20        Q.   All right.  And just to be clear, if I can go back one second,

21     the hills we see behind the white house on the right side of the road if

22     you're heading towards Kravica/Bratunac, that's the same side of the road

23     or is it a different side of the road that we saw the Pragas and the

24     firing going on into the woods?

25        A.   This is the same side of the road.

Page 23603

 1             MR. NICHOLLS:  Let's keep playing, please.

 2                           [Video-clip played]

 3             MR. NICHOLLS:  Sorry, can we back up a bit to -- I should have

 4     told you, Mr. Reid.  Thank you.

 5        Q.   We're at 23:05.9, approximately the same as photo F on page 56 of

 6     your book.  You talked about the white columns.  These men who were

 7     coming up, walking up the hill and rounding this white pillar, can you

 8     tell us where this is and how you were able to determine it.

 9        A.   Yes.  These -- these pillars, this is the western part of the

10     destroyed white house.  I reconstructed the path of these men, how they

11     were walking, and we see this on page 57, and the pillars are the same.

12     I think they're more visible on the page before even.

13        Q.   Thank you.

14             MR. NICHOLLS:  And could we bring up page 56, please, Mr. Reid.

15     And just make that larger.  We'll leave it as it is.

16             Your Honour, could we go into private session for one moment?

17             JUDGE KWON:  Yes.

18                           [Private session]

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 23604

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11                           [Open session]

12             JUDGE KWON:  Yes.  We are now in open session.

13             MR. NICHOLLS:  Let's keep playing, please.

14                           [Video-clip played]

15             MR. NICHOLLS:  And stop.  I need to go back to it.  We just saw a

16     one-second photo from Mr. Karadzic on TV.

17        Q.   Do you know why that's there -- was there?

18        A.   Yes.  As Mr. Petrovic explained during his interview, he says

19     that it was over-recorded or even it's possible that he used the old tape

20     and this very short footage of Mr. Karadzic is -- is just from another

21     event, another interview, whatever, just that he says that

22     [indiscernible] this is not the part of -- of this trip.

23        Q.   He said that was -- inadvertently that he has that piece on

24     there?

25        A.   Yes, correct.

Page 23605

 1             MR. NICHOLLS:  Play, please.

 2                           [Video-clip played]

 3             MR. NICHOLLS:  Okay.  We stopped at 23:50.4.  Corresponds a

 4     little bit zoomed in to page 58 of the road book, photo C.

 5        Q.   The point I wanted to see if you can make clear here,

 6     Mr. Blaszczyk, is the man we saw in the black leather jacket who walked

 7     up out of the woods, asked for some water and crossed the road.  He's

 8     coming, we saw, around the corner from the white house.  Where is he

 9     going now across road?

10        A.   He's crossing the road and going to Sandici meadow.

11        Q.   All right.

12        A.   And on page 59 I just reconstructed the path he used.

13        Q.   Thank you.  And so just to be clear, behind this group we see

14     here picking up a man who is either injured or dead or something, picking

15     somebody up, is that the slope which leads up to Sandici meadow?

16        A.   Yes, correct.  And I believe we see these people taking this man

17     also in the previous footage.

18             MR. NICHOLLS:  Okay.  We can keep playing, please.

19                           [Video-clip played]

20             MR. NICHOLLS:  Okay.  Can we stop?  We're at 24:20.3.  We'll keep

21     playing, but we see "French Army NATO approved" box and we'll play in a

22     minute.  Just on the transcript we see the portion we just finished.  I

23     won't go back to it, but what we heard coming through on the tape was an

24     unknown man saying, "Laser 2 is calling you."  Do you remember -- do you

25     know who Laser 2's call-sign was, who that belonged to?

Page 23606

 1        A.   I don't remember right now whose -- whose code-name it was.  I

 2     think it was Borovcanin's code game, but I'm -- I believe this is

 3     Borovcanin.  I believe this is Borovcanin code-name.

 4             MR. NICHOLLS:  Keep playing, please.

 5                           [Video-clip played]

 6             MR. NICHOLLS:

 7        Q.   Now, the video we just saw of the food rations box, do you have

 8     any -- do you know why that is suddenly there on the video?  It has

 9     nothing to do with Sandici meadow.

10        A.   Yeah, this part of the video has nothing to do with Sandici

11     meadow.  This part was recorded over after that.  According to the

12     explanation of Mr. Pirocanac, it wasn't intentionally, but anyway, it was

13     over-recorded.  We later on just sure that this part of the video should

14     also contain the footage we saw in Studio B, the footage of Kravica

15     warehouse and bodies in the front of Kravica warehouse.

16             And this ration portion, the French ration portion, it's also

17     visible that it was recorded over at -- it was recorded at the house of

18     Mr. Pirocanac, because I recognise the typing machine, I think, I believe

19     I saw at his house.

20        Q.   Thank you.  Do you know of any explanation from him about why -

21     just while we're here - about why that box appears?

22        A.   It was coincidence.  According to Mr. Petrovic, of course.

23        Q.   All right.

24             MR. NICHOLLS:  What I'd like to do now is play a portion of the

25     Studio B video.  This is not from the raw footage.  This is from the

Page 23607

 1     documentary Studio B.  It's on our trial video at P4 --- P4201.  For our

 2     record, this is part 3 of the trial video.  It should be at 36 to 37:05.

 3     If we could play that, this Studio B section, Mr. Reid.

 4                           [Video-clip played]

 5             MR. NICHOLLS:  Stop.  And we'll now play that again just in slow

 6     motion because it is such a quick little clip.  If you could play that,

 7     Mr. Reid.

 8                           [Video-clip played]

 9             MR. NICHOLLS:  I'll stop that at 36:36.3.

10        Q.   As you said, Mr. Blaszczyk, you'd already said this is not on the

11     raw video footage shot by Mr. Pirocanac that he provided to us.  This is

12     on the Studio B broadcast.  Do you know where this location is?  Do you

13     have any doubt about where this location is that we see in front of us,

14     the bodies in front of this building?

15        A.   I am sure that we are in front of Kravica warehouse and we see

16     the bodies in front of the Kravica warehouse.  We see the western door of

17     the first Kravica warehouse.

18             MR. NICHOLLS:  Let's keep playing, please.

19                           [Video-clip played]

20             MR. NICHOLLS:  Stop, please.  Stopped at 36:48.8.  Now if we can

21     look at pages 60 and 61 of the road book.  I don't know, Mr. Reid, if you

22     can also bring up -- can you bring up page 60 on the left?  Is that

23     possible?  If we leave the video.

24        Q.   All right.  So on the left we have page 60 of the road book with

25     the two stills from Studio B.  You've marked this as map position 20 in

Page 23608

 1     Kravica.  And on the right we have the photos taken on your visit there,

 2     on page 61, and you've marked the directions of the road, Bratunac and -

 3     excuse me - Sandici, Konjevic Polje.  Can you just tell us how these

 4     photos match up?

 5        A.   I take it it's my photos or our photos from the road leading from

 6     Bratunac towards Sandici-Konjevic Polje.  I took the picture of the

 7     western door of Kravica warehouse.  If you look at the, let's say,

 8     pillars -- no, just maybe not pillars, but the strips along the door, we

 9     see that they're the same strips.

10        Q.   Sorry, you mean the vertical concrete strips?

11        A.   Yes, yes, correct.  Correct.  If we look at the general picture

12     of the Kravica warehouse and we compare with the footage from Studio B,

13     it's visible that this is the same house.  I believe the next witness,

14     also an investigator, will explain more about the investigation related

15     to this Kravica warehouse.

16        Q.   All right.  Thank you.  That, I think, about --

17             JUDGE KWON:  Could I see the slow-motion video again?

18             MR. NICHOLLS:  Yes, Your Honour.

19             JUDGE KWON:  And I wonder whether you also have a split

20     comparison video for this part?

21             MR. NICHOLLS:  We do not have a split video, Your Honour.

22             THE WITNESS:  May --

23             JUDGE KWON:  Yes, Mr. Blaszczyk.

24             MR. NICHOLLS:  But I will --

25             JUDGE KWON:  Yes.  Please go on.  I'm asking.

Page 23609

 1             THE WITNESS:  It's very difficult to make this comparison part

 2     like we did with the white house.  I will explain why.  Because --

 3     because in the raw footage, raw material, this is about 24 seconds

 4     recorded over, but, in fact, the footage of Studio B we have only few

 5     seconds, one or two seconds of Kravica warehouse and the bodies in front

 6     of it, but we couldn't locate exactly in which part.  Definitely it was

 7     the part, these 24 seconds, recorded over in the raw footage where we see

 8     the ration package and the blank portion.

 9             JUDGE KWON:  The scene with people moving around, with music,

10     it's already in the raw clipping, raw tape, and they are not ones that

11     were -- the ones that have been recorded over.

12             THE WITNESS:  It's correct, Your Honour.  This is the -- the

13     clips where people are moving around, you know, on the horses, there are

14     clips but recorded day after, it means on the 14th, and we have this

15     material on -- on -- on raw -- on the raw material received from

16     Mr. Pirocanac.  We -- I believe if we played the raw material, we see the

17     same clips later on.

18             JUDGE KWON:  Very well.  Shall we --

19             THE WITNESS:  But --

20             JUDGE KWON:  Yes.

21             THE WITNESS:  -- the Studio B material is, of course, edited

22     material.  This was not possible to ...

23             JUDGE KWON:  Yes.  Yes, Mr. Nicholls.

24             MR. NICHOLLS:

25        Q.   And just to be clear, on the -- on the Studio B which is edited

Page 23610

 1     material, this Kravica warehouse clip appears -- I think you were saying

 2     it appears to be on the 14th of July, the next day of video shooting, not

 3     on the 13th when the -- when these killings took place.

 4        A.   Could you repeat your question, please?

 5        Q.   Yes.

 6        A.   I'm a bit confused.

 7        Q.   Yes.  It was a bad question.  If one looks at the Studio B

 8     footage which has been edited, the brief clip that's there of the Kravica

 9     warehouse is mixed in with video -- other video that was shot on the

10     14th of July --

11        A.   Yes.

12        Q.   -- is that right?

13        A.   Yes.  This is correct.  Before -- before Kravica clip we have the

14     footage from the 14th July, and after -- just after we have the footage

15     also from the 14th July.

16        Q.   Thank you.  What I'd like you to do now is --

17             JUDGE KWON:  Could we play the slow video part again.

18             MR. NICHOLLS:  Sorry, yes.  Let's play that again, please,

19     Mr. Reid.  It's easier, I think, to play the whole clip than to find just

20     the slow, the rapid first.  It won't take long.

21                           [Video-clip played]

22             JUDGE KWON:  Thank you.  Mr. Blaszczyk, was this part filmed from

23     inside the car, in your opinion?

24             THE WITNESS:  Yes.  Yes, Your Honour.  In my opinion it was -- it

25     was done from inside the car.

Page 23611

 1             JUDGE KWON:  And the car was moving from which to which

 2     direction?

 3             THE WITNESS:  The car was moving from Sandici towards

 4     Kravica/Bratunac.

 5             JUDGE KWON:  Although from Konjevic Polje to Bratunac.

 6             THE WITNESS:  Yes, is correct.  Just with the last footage we saw

 7     the raw material is recorded on Sandici meadow and the car is moving from

 8     direction of Sandici-Konjevic Polje towards Bratunac, and Kravica is

 9     located about 900 metres from Sandici towards Bratunac.  And definitely

10     it has been recorded from the car.

11             JUDGE KWON:  Can I see once again, if you don't mind.

12             MR. NICHOLLS:  Yes, Your Honour, of course.

13                           [Video-clip played]

14             JUDGE KWON:  Thank you, Mr. Nicholls.

15             MR. NICHOLLS:  Your Honours, I'll ask my -- I'll ask the Defence

16     this, we have a -- which may be helpful.  We have a composite photo put

17     together of the Kravica warehouse, the front of it, from the pan of the

18     Studio B footage.  In other words, we've taken the stills from the

19     Studio B footage and pasted them together so you can see it all in one

20     panoramic photo.  It's not listed for use with Mr. Blaszczyk.  I don't

21     believe it has a 65 ter number, but I could bring that up.  I think it

22     might be helpful if there's no objection.

23             MR. ROBINSON:  We don't object, Mr. President.

24             JUDGE KWON:  Thank you.  Yes, we grant it.

25             MR. NICHOLLS:  Thank you, Your Honours.  Thank you, Mr. Robinson.

Page 23612

 1             This is a photo with ERN number 07041106 and this was created by

 2     the OTP from the Petrovic/Studio B stills, and you can see that's why it

 3     has several Studio B logos on it.  But that shows you what you see in the

 4     clip if you were able to see it not in a pan but in one photo, from the

 5     man in military uniform, police uniform on the far right, you can't quite

 6     see his face, to the back of the bus.  This is what was shot from the

 7     moving car.

 8             And if I could tender that, Your Honour, if there's no objection.

 9     It would be --

10             JUDGE KWON:  We didn't hear the confirmation from the witness.

11             MR. NICHOLLS:  Oh, I'm sorry.  I shouldn't be testifying.

12        Q.   Can you tell us what this is, Mr. Blaszczyk?

13        A.   Yes, this is a picture created by -- by us.  This is compilation

14     of the footage -- the stills from the Studio B segment.

15        Q.   Thank you.

16             JUDGE KWON:  Thank you.  That will be admitted.

17             THE REGISTRAR:  As Exhibit P4269, Your Honours.

18             MR. NICHOLLS:  And for the record, the 65 ter number for this

19     would be 23585.

20        Q.   Mr. Blaszczyk, before the break if you could now, and I think

21     this is also helpful for the location of the warehouse and the

22     surroundings, if we could go to the interactive CD as we call it, and if

23     you could start off with Kravica and then show some of the other places

24     we've seen in this clip, in this chapter of your book.

25             MR. NICHOLLS:  I think we may need to switch the feed, whatever

Page 23613

 1     that means, to allow him to use the laptop.

 2             THE WITNESS:  I have problem.  Okay.  Okay.  Your Honour, we are

 3     again in detailed map of the area of Bratunac and Srebrenica and

 4     Konjevic Polje.  We are going to the segment related to Sandici portion

 5     of this -- our raw material and Studio B material.

 6             We are in more detailed map here.  I marked here the several

 7     locations we can get in, and I marked also Kravica warehouse.  As I said,

 8     if you would like to know which -- which part is linked to other photos

 9     and other stills you can always use the "Help" button.  This is entire

10     road where the action took place, in fact, in July 1995.  Now we are

11     going to Kravica warehouse.  You did ask me about Kravica warehouse, yes?

12             MR. NICHOLLS:

13        Q.   Because we were just on Kravica warehouse, yeah, let's please

14     start there and then we can look at some of the -- go along the road from

15     Sandici where the film started.  But let's begin at Kravica warehouse.

16        A.   Okay.  We are in Kravica.  That's getting in Kravica area.  We

17     have 360-degree view of Kravica warehouse.

18        Q.   Could you spin all the way around, please, so we can see how

19     close the road is?

20        A.   Yes.  This is road leading us to -- okay.  From the right-hand

21     side to the left this is -- to the left this is Sandici meadow.  On the

22     right-hand side this is direction of Bratunac.  This is the main road

23     from where this footage from Studio B had been recorded.

24             We are -- we are in the front of the western door of -- western

25     part of the Kravica warehouse.  We can get -- let's check first because

Page 23614

 1     it's not marked here, my mistake, but I should mark it.  The activated

 2     field.  It can be helpful.  Not always.  I put these -- unfortunately I

 3     put these yellow arrows.  If we click on the door of the warehouse we see

 4     the picture from Studio B, the still from Studio B.  The same location.

 5        Q.   The west door.

 6        A.   Yes, yes.  This is west door.  Western part of the Kravica

 7     warehouse, exactly this.

 8             Before we go -- get in, also in this location we see in the

 9     footage from 1995, July 1995, 13 July 1995, we have the footage of the

10     bus and the men walking along the bus.

11             If we would like to go inside the Kravica warehouse to the west

12     part of the Kravica warehouse, you have to click here and we are inside.

13     We can move around.

14             This is how it looked in 2006 in -- during our mission in

15     May 2006.

16        Q.   Was there a shed or kind of small building in this area in

17     July 1995?

18        A.   One second.  If you go closer it would be more visible, you know,

19     because we are closer to the eastern part of this -- this part of

20     premises.

21             Your Honour, here we see the marks of small - how to say? -

22     guarding house inside the -- this, this warehouse.  One of the witness, I

23     believe, is going to describe how he was hidden during the execution.

24     And it does not exist anymore, you know, this guarding house, but we

25     still see the marks of this guarding house.  Very small one used by the

Page 23615

 1     guards who were by the counter.

 2        Q.   And just so we get an idea of the scale, have you measured the

 3     inside of this portion of the warehouse?

 4        A.   Yes, I did.  I did it by myself and also it was done in 1996 by

 5     our forensic team, I believe.  This part, as far as I remember, is about

 6     260 metres -- square metres, and another part, the eastern part of the

 7     Kravica warehouse had about -- has still about 300 square metres.

 8             We can go back to outside or going to the previous spot where we

 9     entered the Kravica in front of entrance.  Then you can go out.  We can

10     check the view of the Kravica warehouse from different perspective, I

11     mean, rather, from the eastern part.

12             Here is the eastern part of the Kravica warehouse where the other

13     people were kept also, the other group of the prisoners were kept.

14             Further down.  We are on the edge of the Kravica warehouse.  We

15     see entire -- not entire, but most of the compound of Kravica.

16        Q.   And just so we could see, if you pan back, the entrance would be

17     behind this building from the main road; correct?

18        A.   Yes.  You are facing towards direction of Sandici.  We are

19     walking down.  We are closer again.  Sandici's not very visible here, but

20     white destroyed house opposite the road it could be visible if we would

21     have a better picture or better resolution of this picture.  Somewhere

22     here.

23        Q.   Thank you.  And then if Their Honours have no questions, maybe

24     now we could, just before the break, go to Sandici meadow and you can

25     show us how the 360-CD works there.

Page 23616

 1             JUDGE KWON:  Yes.

 2             THE WITNESS:  We are again at the map.  Would you like me to

 3     start with Sandici meadow or with --

 4             MR. NICHOLLS:

 5        Q.   You could perhaps start with Sandici meadow and just quickly go

 6     through the sequence of the spots that are marked in the order we saw

 7     them in the video.  In other words, heading towards Konjevic Polje and

 8     then coming back.

 9        A.   Let's have the general view of Sandici meadow and surrounding

10     areas.

11             Your Honour, we are on the hill above Sandici meadow.  We see

12     Sandici meadow in front of us.  We see the white -- white destroyed house

13     across -- located across the road from Sandici meadow.  And I would like

14     to show now the same location but also from the hill but from another

15     hill, from the direction of Konjevic Polje.  Just a second ago we were

16     here.  Let's go back again to the other hill and to have the overview of

17     Sandici meadow surroundings.

18             Then we can go to Sandici meadow.  This is Sandici meadow.  This

19     is footage, of course, from raw material of Mr. Petrovic.

20             General view again.  We are on the west part of the destroyed

21     white house across the road from Sandici meadow.  We can follow the path

22     used by the people who are surrendering to the Bosnian Serbs army.

23             JUDGE KWON:  So, Mr. Blaszczyk, Mr. Pirocanac filmed at Sandici

24     meadow twice, on the way to the direction of Konjevic Polje and on his

25     way back to the direction of Bratunac.

Page 23617

 1             THE WITNESS:  It's correct, Your Honour.  It's correct.  It's

 2     correct.  Would you like me to follow the sequences of --

 3             JUDGE KWON:  Oh, yes, please.  Yes.

 4             THE WITNESS:  Let's come back here.  I think the first footages

 5     we have that one.  May I use the help of the book if you don't mind,

 6     Your Honour.

 7             MR. NICHOLLS:

 8        Q.   And that's right, Mr. Blaszczyk.  This is really the first frame

 9     of this portion of the Petrovic video.  It shows --

10        A.   Yes, this is exactly -- [Overlapping speakers]

11        Q.   -- this man.

12        A.   I'm sorry.  This is Sandici meadow.  Here we have entire still

13     from raw material of Mr. Petrovic.  We see here member of Special Police

14     Brigade, Sekovici Detachment.  How this place looks now, how it looked in

15     2006.

16             JUDGE KWON:  Do these people, Mr. Blaszczyk, appear in the second

17     clip taken at the Sandici meadow?

18             THE WITNESS:  You're referring to which -- sorry.

19             JUDGE KWON:  It's people appearing on page 32 in the book.

20             THE WITNESS:  Yes, yes, Your Honour.

21             JUDGE KWON:  That's the first shot filmed at Sandici meadow.

22             THE WITNESS:  Yes, yes, yes.  It's correct.

23             JUDGE KWON:  Do they appear in the second clip at Sandici meadow?

24             THE WITNESS:  On the second portion of Sandici meadow?

25             JUDGE KWON:  Yes.

Page 23618

 1             THE WITNESS:  I think -- I have to check.

 2             JUDGE KWON:  Yes.

 3             THE WITNESS:  But, yes, I think we have the -- yeah.  At least we

 4     have the portion of this.  It was captured, you know, the part of this

 5     group kept in Sandici meadow.

 6             JUDGE KWON:  So they are still there.

 7             THE WITNESS:  Yes.  They are still there.

 8             JUDGE KWON:  I note the time.  Shall we take a break, or if you

 9     could show me that portion after the break.

10             THE WITNESS:  Yes, Your Honour, I will.

11             MR. NICHOLLS:  Thank you.  We can --

12             JUDGE KWON:  Shall I allow the witness to communicate with

13     Mr. Nicholls to show us that -- that clip?

14             MR. ROBINSON:  Yes, Mr. President.  We don't mind.

15             MR. NICHOLLS:  Thank you.

16             THE WITNESS:  Your Honour, maybe this is not exactly the same

17     clip, but the same area the people are visible in the meadow.

18             JUDGE KWON:  I would like to see that portion after the break.

19     We'll break for an hour and resume at 1.30.

20                           --- Luncheon recess taken at 12.30 p.m.

21                           --- On resuming at 1.31 a.m.

22             JUDGE KWON:  Yes, Mr. Robinson.

23             MR. ROBINSON:  Yes, Mr. President.  I would like to make an oral

24     motion to strike a pleading that was filed today.  If I could have a few

25     minutes at the close of the day today to be heard on that.

Page 23619

 1             JUDGE KWON:  Are you referring to the Prosecution's response to

 2     your supplemental submission?

 3             MR. ROBINSON:  Yes.

 4             JUDGE KWON:  I think our staff forgot to copy the e-mail to the

 5     Prosecution, but it was triggered by the Chamber's invitation.  The

 6     Chamber wanted to hear from the Prosecution.

 7             MR. ROBINSON:  I see.  Okay.  If we could be informed of that in

 8     the future we would appreciate that --

 9             JUDGE KWON:  Yes.

10             MR. ROBINSON:  -- but that's fine.  Then in that case I won't

11     make a motion.  My point was that it appeared --

12             JUDGE KWON:  If it was filed, you are minded to withdraw it then.

13             MR. ROBINSON:  Yes.  I didn't file any --

14             JUDGE KWON:  No.  Thank you.

15             MR. ROBINSON:  -- motion.  Thank you very much.

16             JUDGE KWON:  Thank you.

17             Yes, Mr. -- Mr. Nicholls, please continue.

18             MR. NICHOLLS:  Thank you, Your Honours.

19        Q.   Mr. Blaszczyk, what I'd like to do now is just to make it very

20     precise about the filming, and clear, the filming on the 13th of July of

21     Sandici meadow.  Let's play the first clip again, where Mr. Petrovic

22     began filming on the 13th, when he then headed towards Konjevic Polje,

23     and then play the clip, the second clip, on the way back.  Okay?

24        A.   Yes.

25        Q.   So I'll ask Mr. Reid to start playing right at the beginning of

Page 23620

 1     what we call chapter 2, "On the road," at 9 -- which begins on page 24 of

 2     the book.

 3                           [Video-clip played]

 4             MR. NICHOLLS:

 5        Q.   All right.  I've stopped there at 09:58.3.  This again is the

 6     scene we see on page 26 now of the road book.  It's quite close to the

 7     photograph marked C.  Just to be clear, this is the beginning at Sandici

 8     meadow.  Do I have that right?

 9        A.   Yes, this is correct.  First we have the picture of -- yes.

10        Q.   Now I ask Mr. Reid to move ahead to show this - we only see a

11     part of the men here - to the second shot we have of Sandici meadow which

12     is just after we see Mr. Borovcanin talking about swapping pistols.  If

13     we could go there, please.

14                           [Video-clip played]

15             MR. NICHOLLS:  Stop.  We're now at page 32, around photograph B.

16        Q.   Again, can you just confirm where this is and when this was

17     taken, this group of men, which we also see in the interactive CD

18     presentation.

19        A.   This is -- this picture, this shot is taken on Sandici meadow

20     itself.  We see the group of the prisoners, we see the group of the

21     prisoners here.

22        Q.   All right.  Now I'd like to play this again in slow motion

23     starting from when the camera sweeps from Mr. Borovcanin and his

24     companions to Sandici meadow and the men on the field.  And,

25     Mr. Blaszczyk, I'd like to ask you to focus on the very top left portion

Page 23621

 1     of the screen and see what you see there, something happening that -- I

 2     want to see your comment on it.

 3                           [Video-clip played]

 4             MR. NICHOLLS:  Stop.  And can we go back a few frames.

 5                           [Video-clip played]

 6             MR. NICHOLLS:

 7        Q.   And what I'd ask you to look for is a man who appears to be

 8     falling down rapidly on the top left screen.

 9             MR. NICHOLLS:  Stop.

10        Q.   Did you notice what I was directing you to?

11        A.   Yes.  Yes, I do.

12        Q.   Have you noticed that before in this segment?

13        A.   I remember watching it, and we had some discussion, but it's

14     difficult to say exactly what was going on there.

15        Q.   And we don't hear any sound on this part of the video, do we,

16     just where that happens?

17        A.   No, we don't.

18        Q.   Thank you.

19             MR. NICHOLLS:  And I'd now like to ask Mr. Reid to show us the

20     clip of Sandici meadow again, this time now on the return trip from the

21     Konjevic Polje road, and this is at approximately the same section as at

22     page 54 of the road book.

23                           [Video-clip played]

24             MR. NICHOLLS:  I'll just say now for the record we're starting at

25     23:28.5, yes.  The man in the black jacket walking.  You can play it,

Page 23622

 1     please.

 2                           [Video-clip played]

 3             MR. NICHOLLS:  If you could stop.  We've stopped at 23:52.

 4        Q.   That's the Sandici meadow bit of film we have on the way back.

 5     So can you tell us, Mr. Blaszczyk, again, if you answer the question

 6     His Honour the Presiding Judge asked you about, do we see the same --

 7     what groups of men do we see going and coming back?

 8        A.   Yes, Your Honour.  I was mistaken.  You know, just we don't see

 9     the same group of the men standing in Sandici meadow because that camera

10     didn't capture the Sandici meadow itself, the centre of Sandici meadow.

11     We see only the men walking towards Sandici meadow carrying wounded or

12     body of one of the men, or woman, man, and we can come to the conclusion

13     that people were still gathering at Sandici meadow.  Why?  Because in

14     previous footages we see that lot of people still coming down from the

15     forest and going -- crossing the road and going across to Sandici meadow.

16     But we don't see this footage of Sandici meadow in this -- in this raw

17     material.

18             JUDGE KWON:  Thank you.

19             THE WITNESS:  I mean we don't see the prisoners on the Sandici

20     meadow on the way back when Mr. Pirocanac, together with Mr. Petrovic

21     [sic], went back again to Sandici meadow.

22             JUDGE KWON:  Thank you.  But we see that certain -- some people

23     were still surrendering at this point of time.

24             THE WITNESS:  Yes, Your Honour.  We see that some people still

25     are surrendering at this point of time, but we don't see people gathering

Page 23623

 1     on the Sandici meadow.  I believe this is because simply camera didn't

 2     catch this part of Sandici meadow.

 3             JUDGE KWON:  Yes.  Mr. Nicholls.

 4             MR. NICHOLLS:  Thank you.

 5        Q.   Mr. Blaszczyk, now I'm done with those clips.  If you could try

 6     to take us through on the video presentation starting at Sandici meadow.

 7     We already did Kravica, we don't need to do that again, but going through

 8     the trip that Mr. Petrovic Pirocanac and Borovcanin drove on that

 9     13th July.

10        A.   May I start?

11        Q.   Yes.

12        A.   Okay.  We are again in the detailed map of the area of Sandici.

13     Let's go to overlook on Sandici meadow itself and the surrounding areas.

14     We remember that first foot -- footage in Sandici meadow is the footage

15     of -- of Cop.  I mean -- I'm referring to Cop because the nickname of the

16     officer who is standing in front of us right now, bandanna man, his

17     nickname is Cop.

18             Next link showing us the area where Petrovic did his recording.

19     Unfortunately I made again mistake.  I didn't put the arrow here, but,

20     Your Honour, if you -- if somebody would like to operate with this

21     presentation, please click just in case this "Help" button here.  You

22     see, this is the blue -- blue field.  This is linkage page to -- linkage

23     to the still from Petrovic video.

24             Again, it was somewhere here.  Okay, I can be mistaken by 1,

25     2 metres, but no more.

Page 23624

 1        Q.   Mr. Blaszczyk, can I ask you to please just leave on that "Help"

 2     button while you're going through this so we can see where all those

 3     fields are.

 4        A.   The other fields are okay.  You can see.  Would you like me to

 5     keep this blue field?

 6        Q.   No.  If that's the only one you can remove it.

 7        A.   And the next action recorded by Mr. Pirocanac is Mr. Borovcanin

 8     together with two brothers and swapping his pistols with them.  Just

 9     watching the pistol.

10             And here we have also the still from Petrovic raw material.  We

11     see -- we see here the tank, which was located on Sandici meadow, and we

12     see also another part of the road, on another side of the road the BOV.

13     I believe this is BOV used by the Special Police Brigade, and I believe

14     this is also here, the car, the passenger car here, this is car belong to

15     Mr. Borovcanin.  This BOV is much better visible on -- I believe on the

16     page 28 on the picture B, on the still from Petrovic raw material B,

17     marked here as B.

18             This is the same BOV that we see that Mr. Borovcanin and Petrovic

19     following on the roads towards Pervani, Konjevic Polje.

20             And then we see that the next -- next -- and, of course, we have

21     the footage of the group of the people gathered at Sandici meadow.  This

22     is almost -- this is the same, in fact, picture from -- still from the

23     page 32, picture, still, A.  And also we see the roof of the car, the

24     passenger car, with antenna on it.  I believe this is the car of

25     Mr. Borovcanin.  We saw in the previous picture.

Page 23625

 1             We are coming to the most recent picture and now I would like to

 2     show you, Your Honour, the way which Mr. Borovcanin and Mr. Petrovic

 3     together with the driver, they followed the APCs.  They went towards

 4     Konjevic Polje.  We are coming -- we are about 200 metres down from

 5     Sandici meadow towards -- we are heading now towards Konjevic Polje.

 6             Let's go back to the map now.  And the first footage of -- of

 7     APCs recorded by Mr. Petrovic, this is in the area of Pervani.  Again you

 8     can link to the image from Petrovic video.

 9        Q.   Can I just say then -- can I just say that, Mr. Blaszczyk, the

10     link you've just shown us in Pervani, that's on -- those images are on

11     page 34 of the road book; correct?

12        A.   Yes, this is correct.  This is image from the page 34.  And

13     the -- these two APCs moved for a while towards Konjevic Polje, about

14     300 metres.  To get this place we have to get it on to the map.  It's

15     exactly here.  We are again on this place.  Buildings to -- the picture

16     from 1995.  We see the footage from Petrovic video.  This is the same

17     footage as on page 36, footage -- image, sorry, D.

18             And, Your Honour, at this point we have no more footage recorded

19     behind this point towards Konjevic Polje.  The first footage recorded by

20     Mr. Pirocanac Petrovic on the way back, this is closer to Sandici meadow.

21             I am back to the map.  It's about 1.000 metres closer than the

22     location at that time, these two APCs.  This is one of the first footage

23     recorded on the way back by Mr. Pirocanac Petrovic.  This --

24        Q.   Sorry, continue.

25        A.   This entire page, you know, we don't see again here --

Page 23626

 1     unfortunately, it's my mistake.  We don't see again this arrow leading us

 2     to -- linking us to the footage from 1995, but this -- you can use the

 3     "Help" button or I can say, of course, that this entire picture is linked

 4     to this footage.  And we can't get in.

 5        Q.   And just here we're at pages 38 and 39 of the map book; is that

 6     right?  Of the road book?

 7        A.   Yes, correct.  You will see if you -- if we get to the footage

 8     from 1995, Petrovic footage, we see the same picture.  This is on the

 9     page 38.

10             And then we see that Mr. Petrovic and Borovcanin, they are

11     driving back to Sandici meadow.  They're passing by the first wall.  They

12     are linked to the same location, but from 1995, July.  This is direction

13     to Sandici meadow.  Another image of Petrovic video.  And we are getting

14     closer to -- to Sandici meadow.

15        Q.   Thank you.  And the portion you've just described is on pages 40

16     and 41, is that right, of the road book?

17        A.   Yes, this is correct.  This portion was on the page 40 and 41.

18     Let's go back to the map.  This is again overview of Sandici meadow and

19     its surroundings.  Let's go back.  And if we are here, Mr. Borovcanin,

20     Mr. Petrovic, they are using this road to getting Sandici meadow.

21             Again, we are closer to Sandici.  I would refer to -- to page 43

22     from the -- from my book.  I believe this is the same picture.

23             If we link to the -- to the picture from 1995, we see the same

24     picture as is depicted on the page 42 as picture A.

25             This man standing on the right-hand side of the road if you are

Page 23627

 1     heading towards Sandici.

 2             Mr. Borovcanin passing more soldiers crouching behind the

 3     barrier.  This is also the same picture we have on the page 42,

 4     picture B.

 5             And next soldier visible on the page 42, picture C.

 6             And the last footage when he's coming out from the bench, in

 7     fact, is his picture D from page 42.

 8             Let's go back to the map.

 9             Your Honour, we were here exactly.  If we go to this road, this

10     road is leading to Konjevic Polje.  We are exactly on opposite side of --

11     of this retaining wall.

12             Let's go back.

13             If we go to page 44, this is link to the footage from 1995,

14     Petrovic footage.  It's again one soldier standing behind a barrier

15     looking forward, hills.  And we know that Mr. Petrovic stopped here.

16     He -- he recorded -- he recorded members of Jahorina Unit here.  From the

17     book this is page 46.  This particular picture, this is picture A from

18     page 46.

19             JUDGE KWON:  Sir, it's apparent from this video, according to

20     your explanation, that Pirocanac made a stop before they reached the

21     Kravica warehouse.

22             THE WITNESS:  It's correct.  It's correct, Your Honour, yes.

23             JUDGE KWON:  Thank you.

24             THE WITNESS:  He stopped -- in fact, he stopped just about

25     200 metres from Sandici meadow.  He walked towards Sandici meadow.  He

Page 23628

 1     stand behind the white destroyed house across the road from Sandici

 2     meadow, and they drove to -- towards Kravica.

 3             JUDGE KWON:  Thank you.  Yes, Mr. Nicholls.

 4             MR. NICHOLLS:

 5        Q.   If you could just -- I think we're almost done.  If you could

 6     just continue with the last couple links to show Their Honours what else

 7     is available on the CD.

 8        A.   Of course this is another link.  Another Jahorina Unit member.

 9             We -- we are getting closer to Sandici meadow.  Immediately we

10     went to the footage from -- from Petrovic video, but let's go back little

11     bit.  It's more visible here.

12             We have here link from the page -- I believe this is page --

13     picture from the page 52, the picture B.  Just opposite of the road from

14     Sandici meadow.

15             Okay.  Let's go back little bit.

16             If, Your Honour, you remember probably the two members of the

17     Jahorina Unit looking down to the screen -- to the creek, watching down.

18     This is also footage from page 50, footage B.

19             Let's go back to the overview of Sandici meadow and white

20     destroyed house.  And now we see that Mr. Petrovic is recording the

21     events surrounding the destroyed white house across -- across the road.

22        Q.   Across the road from Sandici meadow?

23        A.   Yes, yes, of course, this is across the road from Sandici meadow.

24     We are looking at the west wall of the destroyed white house.  We are

25     across the road from Sandici meadow.  We see the general view of the path

Page 23629

 1     used by the prisoners coming down from the hills and from the forest,

 2     passing the road and going to Sandici meadow.  And if I zoom in a little

 3     bit, it's very hardly too visible, but from this location if we would be

 4     there, it's visible Kravica warehouse.  It's somewhere here where I point

 5     now.  And I mark here some links to the picture from -- from Petrovic

 6     video.

 7             The first one, I believe this is on page 56, still A.  We see

 8     this man is coming using this path down here.  And the footage was

 9     recorded just in front of him.

10             We have next one.  We have -- we have the group of the prisoners

11     passing by the west wall of this destroyed white house, and it's very

12     visible here are pillars -- one pillar of this white destroyed house.

13             If we come closer to my picture, we see the same pillar here.

14             And this is a picture from Petrovic video depicted on the page 56

15     of this road book as picture F.

16             We have a link near the corner of destroyed white house, and

17     this -- this is Petrovic footage image and is depicted in -- in my road

18     book on the page 54.

19             And we are back to -- we are back to the map, and -- yeah.  We

20     were already in Kravica, but we see -- we analyse and we are sure that -

21     what was confirmed, by the way, by Mr. Petrovic as well - that they drove

22     from this location towards Kravica.

23        Q.   Thank you.  What I'd like to do now, Mr. Blaszczyk, - this will

24     go a little more quickly - is go through the remainder of the Petrovic

25     video and chapters in your book.

Page 23630

 1             MR. NICHOLLS:  So I'll ask Mr. Reid to start playing where we had

 2     left off, which was just after the end of the Sandici meadow return trip

 3     segment at around 23:48 or so.

 4             And think we need to switch a feed, please.

 5             All right.  So we're starting again with the man in the black

 6     jacket who has just come around the corner of the white house, and we'll

 7     start playing there, please.

 8                           [Video-clip played]

 9             THE WITNESS:  Can we stop here, please?

10             Your Honour, this is not depicted in my road book, but this is

11     obvious.  We know it from Mr. Pirocanac and from other witnesses that we

12     in the following day, on the 14th of July, 1995, and right now

13     Mr. Borovcanin together Petrovic and his driver, of course, they are

14     entering the enclave, Srebrenica enclave, and they are passing by

15     UN check-point known for us as check-point Papa.  I think.

16        Q.   Let me say we're at 24:58.9.

17        A.   This is UN check-point when we are approaching enclave from

18     Bratunac.  It's near Zuti Most.

19             MR. NICHOLLS:  Thank you.  Continue, Mr. Reid.

20                           [Video-clip played]

21             THE WITNESS:  Could you stop --

22             MR. NICHOLLS:

23        Q.   I was going to stop you.  It's 26:01.5.  Mr. Blaszczyk, you had

24     something to say about this point?

25        A.   Yes.  Your Honour, if you pay attention, this is footage depicted

Page 23631

 1     in the Studio B broadcast as the footage connected with Kravica warehouse

 2     incident.  And it is visible that it was recorded on the following day,

 3     on the 14, not on the 13th [Realtime transcript read in error "15th"].

 4        Q.   So just to be clear, if I understand you, this video from the

 5     14th of July that we're watching here, in the Studio B edited footage,

 6     it's at this point that we get to the Kravica warehouse clip with the

 7     bodies, which is absent from the raw footage.

 8        A.   Yes.  This is correct.

 9             THE PROSECUTOR:  You can keep playing, please.

10                           [Video-clip played]

11             MR. NICHOLLS:  I've just stopped.  It's at 27:25.7.

12        Q.   This is not contained, this stop, in your road book.  Can you

13     just tell us who the big man is on the right side in the short-sleeved

14     camouflage shirt?

15        A.   This is Tomislav Kovac.  He's Deputy Minister of Interior of

16     Republika Srpska.

17        Q.   And do you know where this location is in Srebrenica -- or I

18     should just say, where this location is?

19        A.   Yes, yes, this is in Srebrenica.  Unfortunately we don't have the

20     photo of this location.  We've decided that it's not so important, but

21     this is in the centre of Srebrenica, and in the front of the police

22     station -- at that time police station in Srebrenica.

23             MR. NICHOLLS:  Thank you.  Keep playing.

24                           [Video-clip played]

25             MR. NICHOLLS:  Stop.  Can I ask you to go back a bit.  And play.

Page 23632

 1                           [Video-clip played]

 2             MR. NICHOLLS:  Stop.

 3        Q.   At 27:38.9, that's a little bit fuzzy, but who is the man who

 4     just walked in front of Tomo Kovac?

 5        A.   This man is Dragomir Vasic.  He was the head of CJB of Zvornik.

 6             THE PROSECUTOR:  Keep playing, please.

 7                           [Video-clip played]

 8             MR. NICHOLLS:  Stop.

 9        Q.   I won't go back, but at 27:47.7, we just saw Mr. Borovcanin as

10     well; is that right?

11        A.   Yes, this is correct.  We saw just Mr. Borovcanin again.

12             MR. NICHOLLS:  Okay.  Play, please.

13                           [Video-clip played]

14             THE WITNESS:  Could you stop here.  Could you go back little bit.

15     Yeah.  Could you stop.

16             Okay.  We don't have the picture of this police station in our

17     road book here, but we see here also the department store in Srebrenica.

18     It's called Srebrencanka at that time, and we have the picture of this --

19     this -- the same department store is depicted on page 64 of my road book.

20     But we see [indiscernible] picture of the town, I believe.

21        Q.   Thank you.

22             MR. NICHOLLS:  Keep playing, please.

23             THE WITNESS:  We see the distance how far it is from the police

24     station in Srebrenica.  In fact, the picture does not reflect the exact

25     distance, but it's more or less.

Page 23633

 1             MR. NICHOLLS:  And before we move on, let me just say we were at

 2     approximately 28:10.  We can play now.

 3                           [Video-clip played]

 4             MR. NICHOLLS:  Just stop for a minute at 30:54.4.

 5        Q.   Nothing to do with this frame, but, Mr. Blaszczyk, do you recall

 6     whether Mr. Petrovic said that during this time in Srebrenica on the

 7     14th of July that for a time he walked around by himself without

 8     Mr. Borovcanin and shot some video downtown?

 9        A.   Could you repeat, please?

10        Q.   At some point on this trip on the 14th, do you know did

11     Mr. Petrovic on his own take some video in Srebrenica when he wasn't with

12     Mr. Borovcanin?

13        A.   Yes.  This is one of the situation when he walk around Srebrenica

14     without Mr. Borovcanin.  At least we don't see Mr. Borovcanin.  We don't

15     see any -- we don't hear any conversation with Mr. Borovcanin.

16             JUDGE KWON:  Mr. Nicholls, could you check whether we have the

17     transcript of this part in evidence.  You can come back later.

18             MR. NICHOLLS:  Yes, Your Honour.

19             JUDGE KWON:  Yes.  Please continue.

20             MR. NICHOLLS:  It's P667, Your Honour.  It's attached to the

21     video.  It should be in evidence.  It was admitted as an associated

22     exhibit with Mr. Petrovic's evidence.

23             JUDGE KWON:  Together with the transcript.

24             MR. NICHOLLS:  I believe so, Your Honour.

25             JUDGE KWON:  I was asking because I couldn't find it from this

Page 23634

 1     Srebrenica trial video book.

 2             MR. NICHOLLS:  We can continue playing, please.

 3                           [Video-clip played]

 4             MR. NICHOLLS:

 5        Q.   We're at 35:37.8.  Just tell us what this image is, which is at

 6     page 64 of your map book, position 24 and 23.

 7        A.   We are in the centre of Srebrenica.  We see the department store

 8     located in the centre of Srebrenica in front of us.  It's called

 9     Srebrencanka.  At that time, on the right-hand side we see part of the

10     municipality building in Srebrenica.

11        Q.   And from the video footage we've seen the apartment buildings.

12     Mr. Petrovic Pirocanac was talking to some people outside the apartments,

13     on the balconies.  From your trips to Srebrenica, are you able to tell

14     what vicinity we were in in relation to the department store and

15     downtown?

16        A.   It's not -- not far away, just 100 metres, 150 metres, maybe.

17        Q.   Okay.  So what we've been seeing is downtown Srebrenica?

18        A.   Yes.  We can say it's downtown Srebrenica.  Srebrenica is very

19     small town and just to reach each place in Srebrenica we need only few

20     minutes by walk.

21             MR. NICHOLLS:  Keep playing, please.

22                           [Video-clip played]

23             MR. NICHOLLS:  Stop there, please.

24        Q.   Can you just tell us, it's not in your book, but what building is

25     that, if you know?

Page 23635

 1        A.   I don't know what exactly was there, but I see that is written

 2     there "Energoinvest Srebrenica," but this is building located next to

 3     municipality building of Srebrenica.

 4        Q.   Thank you.

 5             MR. NICHOLLS:  I stopped us at 36:22.2.  Could we keep going.

 6                           [Video-clip played]

 7             MR. NICHOLLS:  Stop.  Could we go back a little bit.

 8        Q.   All right.  We're at 37:42.2.  We've stopped, and we'll play the

 9     video a bit more, but there's a corpse here, a dead man, and we'll see

10     that there are a couple of other men here with him.  Do you know this

11     location in Srebrenica?  Are you able to describe it?

12        A.   Yes.  I know this location very well.  This is in -- also in the

13     centre of Srebrenica, also located about 100, 150 metres maybe from the

14     municipality building but from another side, not the same side like

15     department store.  And in this footage there are depicted three bodies,

16     and we see the footage of one of the bodies.  I believe we see the same

17     body on the footage from recorded on the 12th of July, 1995, by the press

18     centre officer in the centre of Srebrenica but in different -- different

19     location, not far from -- from this location but little bit different

20     location further down to -- to the south, in front of one house,

21     storehouse, something like that.  And this is -- this is the body, I

22     believe, you know, just lying on the 12th in the centre of Srebrenica,

23     near mosque.

24        Q.   Okay.  Well, just a minute.  Let me get to that.  But you see

25     here this man, the colour of his greying hair, the jacket and the blue

Page 23636

 1     jeans.

 2        A.   Yes.  That is correct.

 3        Q.   I'd like to play another --

 4        A.   We have to remember, of course, that this -- this -- this footage

 5     was recorded on the 14, and the first footage of these men, I believe, we

 6     have on the 12th.

 7             MR. NICHOLLS:  All right.  I'd like to play a clip from the trial

 8     video from 12 July.  This is P40201 coming up.  It's from part 2 of the

 9     trial video, at the beginning of part 2.  If Mr. Reid could play that.

10                           [Video-clip played]

11             MR. NICHOLLS:

12        Q.   We've stopped here at 27.5, photo of a man with a lot of blood

13     lying on his stomach, face down.  Is this -- is this the video you were

14     referring to?  Do I have it right?

15        A.   Yes, this is correct.  You know, this is the video I referred

16     just few seconds ago, and this is also I believe the man who we see on

17     the Petrovic raw footage.  If we look at his jacket, at his jeans, at his

18     hair, I believe it's the same man.

19        Q.   And can you just tell us where we got this bit of video from

20     that's shot from the 12th?

21        A.   I think right now this is the part of the trial video, but video

22     itself we got -- we got from the seizure -- was seized at the apartment

23     of Mr. Ratko Mladic.  I don't remember whether it was the first search in

24     2008 or the second one, but I'm pretty sure.

25             MR. NICHOLLS:  Keep playing, please.  We'll just finish this

Page 23637

 1     clip.

 2                           [Video-clip played]

 3             MR. NICHOLLS:  We stopped at 51.4.  We can see a mosque with a

 4     minaret.  Can you just tell us where we are in Srebrenica now

 5     approximately.  If you can describe the location.

 6        A.   Yes.  We are in the centre -- central square in Srebrenica in

 7     front of the central mosque.

 8             MR. NICHOLLS:  Thank you.  We'll keep playing, we'll just finish

 9     this clip.

10                           [Video-clip played]

11             THE WITNESS:  Could you stop here, please.  And, Your Honour, the

12     same body and together with two other bodies we see on the Petrovic raw

13     material exactly behind this building visible on that right-hand side.

14     This is, I think, ten-floors building over there and little bit deep over

15     there and the bodies were visible there.

16             MR. NICHOLLS:  We're at 1:15.2.  Keep playing, please.

17                           [Video-clip played]

18             MR. NICHOLLS:  Thank you.  You can stop.  Now, if we can just go

19     back to the Petrovic raw video footage.  We're at the same point.

20             Keep playing.

21                           [Video-clip played]

22             THE WITNESS:  May I say something, Your Honour?

23             JUDGE KWON:  Yes.  Yes.  By all means, yes.

24             THE WITNESS:  And, Your Honour, we believe that this body is the

25     body of the man who was killed on 11 of July, 1995, in the centre of

Page 23638

 1     Srebrenica.  These killings have been described by one of our witness, I

 2     believe.  For sure this is Drazen Erdemovic.  We believe this is the body

 3     of --

 4             JUDGE KWON:  I think this is not the subject of his evidence.  We

 5     can continue.

 6                           [Video-clip played]

 7             MR. NICHOLLS:

 8        Q.   It's hard to stop on exactly the right frame.  We're at 39:35.2.

 9     Mr. Blaszczyk, did you notice the patch, the black patch on the left arm

10     of the man in the middle as we were playing?  We can play it a bit more.

11        A.   Yes, yes, I did, of course.  I watched this video several times

12     and this is patch of Drina Wolves unit.

13        Q.   You're familiar with that patch?

14        A.   Yes, I am.

15             MR. NICHOLLS:  Keep playing, please.

16                           [Video-clip played]

17             MR. NICHOLLS:  I'm not sure if there's an error in the

18     transcript.  No.  It's all right.  My mistake, sorry.  Keep playing.

19                           [Video-clip played]

20             MR. NICHOLLS:

21        Q.   And just to point out, Mr. Blaszczyk, 41:06.8, the date stamp has

22     appeared, 14 July 1995.  Just to ask again, is that the correct date when

23     this footage was taken based on all of the evidence?

24        A.   Yeah.  This is correct date.  This is the date when this

25     recording was done.

Page 23639

 1             MR. NICHOLLS:  Continue, please.

 2                           [Video-clip played]

 3             MR. NICHOLLS:

 4        Q.   Mr. Blaszczyk, I wanted to ask you one question about the road,

 5     but before we continue to the next chapter, to Zeleni Jadar and the wood

 6     factory, on page 66 of your book there are two photos, A and B, that

 7     occur -- that were taken, I believe, later on in sequence on the video on

 8     the way back from Zeleni Jadar towards Bratunac.  Can you tell us why

 9     you've put them in here at this spot?

10        A.   Yes.  It was created this -- these photos, they are stills from

11     the footage recorded on the way back from Zeleni Jadar by Mr. Pirocanac.

12     I put this photo of Srebrenica in one place.  I didn't want to create

13     additional chapters, whatever.  I didn't want to make this book quite

14     complicated.  And I put these photos in one chapter.

15        Q.   Thank you.

16             MR. NICHOLLS:  We can continue now, and we'll get to the next

17     chapter, just getting closer to the end.  Play, please.

18                           [Video-clip played]

19             THE WITNESS:  Can we stop here?  Your Honour, we are

20     approaching -- in fact, Mr. Pirocanac is approaching Zeleni Jadar

21     factory, wood factory, and if you notice some sandbags over there, this

22     is check-point OP Echo, UN check-point, UN observation point.

23             MR. NICHOLLS:  And we'd stopped at about 42:36.  If we can

24     continue.

25                           [Video-clip played]

Page 23640

 1             MR. NICHOLLS:  We're at 42:46.8.

 2        Q.   It's not exactly the same photo, but now this goes to page 70 of

 3     your map book in Zeleni Jadar.  This is a closer-up photo of the building

 4     at page -- of photo A, page 70, map position 22.  Can you just tell us

 5     where we are now and what this building is?

 6        A.   We are in Zeleni Jadar, and this is a wood factory in

 7     Zeleni Jadar.  On the left -- on the page 70 we see the footage from

 8     Petrovic video depicting this factory, the same factory, the same, in

 9     fact, part of the wall over there.  And we have the picture of the same

10     factory from -- taken in 2006 on page 71.

11             MR. NICHOLLS:  Keep playing, please.

12                           [Video-clip played]

13             MR. NICHOLLS:

14        Q.   We stopped now at 45:45.0.  Nearly the same exact still we have

15     before us is on page 70, B, in Zeleni Jadar.  Just for the record, who

16     are these three men now together that have now travelled to Zeleni Jadar

17     from -- we saw earlier in Srebrenica that Mr. Petrovic is filming?  Who

18     are these three in the frame?

19        A.   The first man is Tomo Kovac, the Deputy Minister of Interior.

20     The second man is Dragomir Vasic, the head of Zvornik CJB; and the last

21     one is Ljubisa Borovcanin, the Deputy Commander of the Special Police

22     Brigade.

23             MR. NICHOLLS:  Can it be played, please.

24                           [Video-clip played]

25             THE WITNESS:  Can we stop here?  This is observation -- OP Echo,

Page 23641

 1     the former Dutch OP.

 2             MR. NICHOLLS:  And we're at 46:31.5.  Continue, please.

 3                           [Video-clip played]

 4             MR. NICHOLLS:

 5        Q.   All right.  We were -- I stopped us at 48.24.5.  We're getting

 6     close to the end of his raw -- of Mr. Petrovic's raw footage.  Can you

 7     tell us now, Mr. Borovcanin and Mr. Petrovic Pirocanac are back in the

 8     car driving, where are they going and what is this we see where they've

 9     stopped for a minute?

10        A.   They are driving towards Srebrenica.  We see the view of

11     Srebrenica, of the hill above Srebrenica.

12             MR. NICHOLLS:  Continue, please.

13                           [Video-clip played]

14             MR. NICHOLLS:  Thank you.

15        Q.   We're at 49:46.3.  Could you tell us where we are here?

16        A.   We are coming to the centre of Srebrenica, and this photo

17     reflects the photo from my road book, from the page 66.  This is

18     two photos recorded by Mr. Pirocanac on the way back from Zeleni Jadar to

19     Srebrenica.

20             MR. NICHOLLS:  Okay.  And just to be clear, these are the ones

21     which are slightly out of sequence because now coming back from

22     Zeleni Jadar.  If we could continue.

23                           [Video-clip played]

24             THE WITNESS:  Can we stop here.  Your Honour, on the left-hand

25     side we are passing by UN compound, Company B compound in Srebrenica.

Page 23642

 1             JUDGE KWON:  How much more would you need to conclude,

 2     Mr. Nicholls?

 3             MR. NICHOLLS:  Well, Your Honour, there's, I think, a little bit

 4     less than 10 minutes of video and then I have one discrete topic which is

 5     the -- talking a little bit about the Drina Corps collection and where it

 6     came from, what it is, which I think that part will take me 15 minutes or

 7     less, so in total about 25 minutes.

 8             JUDGE KWON:  Very well.  Why don't we continue tomorrow.

 9             MR. NICHOLLS:  Thank you, Your Honour.

10             JUDGE KWON:  Can I draw your attention to transcript page of

11     today 77, line -- from 2 to 5, referring to the footage recorded in

12     Srebrenica town.  This is Mr. Blaszczyk's response:

13             "This is footage depicted in Studio B broadcast as footage

14     connected with the Kravica warehouse.  It is visible that it was recorded

15     on the following day, the 14th, not on the 15th," but the transcript

16     should read 13th, not 15th.

17             MR. NICHOLLS:  I think that is right, Your Honour, and I was

18     going ask Mr. Blaszczyk about that later, but maybe he can tell us now if

19     that's --

20             JUDGE KWON:  I noted he's nodding, but could you answer that

21     question, Mr. Blaszczyk.

22             THE WITNESS:  Yes, this is correct, Your Honour.  It should be

23     read 13, not 15.

24             JUDGE KWON:  Yes.  And I have to correct myself, Mr. Robinson.

25     It is not that our staff e-mailed the Prosecution but had a phone

Page 23643

 1     conversation when it is minded to respond.

 2             And on a separate note, the Chamber is seized of the accused's

 3     motion to compel the United Kingdom to produce certain documents.  Given

 4     the novelty of the issue raised in that motion, the Chamber would

 5     appreciate if it could have the response from the Prosecution.  Thank

 6     you.

 7             Can I ask how long it would take you to respond to that motion.

 8             MR. TIEGER:  Your Honour, I can get back to you.  I appreciate

 9     that that is a question that asks us to get back in the earliest possible

10     time, but I'll give you a more realistic appraisal if I can check our

11     resources against our ongoing obligations, and I wouldn't want to promise

12     anything right now unfairly to our staff as they're working on other

13     matters.

14             JUDGE KWON:  Thank you.

15             We'll adjourn until tomorrow morning at 9.00.  We will be sitting

16     in regular format tomorrow, i.e., until 1.45.

17             The hearing is now adjourned.

18                           --- Whereupon the hearing adjourned at 3.02 p.m.,

19                           to be reconvened on Thursday, the 26th day

20                           of January, 2012, at 9.00 a.m.