1 Monday, 2 April 2001

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 9.30 a.m.

6 JUDGE HUNT: Call the case, please.

7 THE REGISTRAR: Yes, Your Honour. This is the case number

8 IT-97-25-T, the Prosecutor versus Krnojelac.

9 JUDGE HUNT: Before we start this witness, I just want to raise

10 this motion by the Prosecution filed on the 27^th of March to tender

11 documentary evidence, and a notification of an agreed fact.

12 Mr. Bakrac, are you able to give us any sort of response to that

13 so we can get it out of the way, as it were?

14 MR. BAKRAC: [Interpretation] Yes, Your Honour. Thank you very

15 much. Good morning to all. The Defence has received the Prosecutor's

16 motions and indeed everything that is mentioned in this motion is

17 something that has been discussed by the Prosecution and the Defence, and

18 we have agreed thereon. We have consulted our client as well, and the

19 accused also does not wish to have the authenticity of the exhumation

20 remains tested once again. If the families agree to that, we will not

21 contest it.

22 Also, we do not object having these exhibits put into evidence

23 without bringing in an investigator or somebody else to testify. There

24 is a reservation, though, with regard to Exhibits B and B1 if we

25 understood it correctly, because the authenticity thereof has not been

1 confirmed. The Defence and the accused, namely, believe that one word or

2 two words, rather, added to his name were added subsequently by a person

3 who is unknown to us, and that is the only reservation that the Defence

4 has with regard to this.

5 If the Prosecution agrees, we can enter this document into

6 evidence without these additions, because it is obvious that the additions

7 were made in a different handwriting. What was handwritten was

8 handwritten in Cyrillic, whereas these words Commander of the Battalion

9 have been written in the Roman script. Obviously somebody added this onto

10 the document at a later stage, and that is the only objection the Defence

11 has with regard to the authenticity of this document and with regard to

12 our views concerning the entry into evidence of these documents.

13 JUDGE HUNT: You have no complaint about any of the other

14 handwriting on that typed document; it's just those two words following

15 your client's name at the top, in number 1 position?

16 MR. BAKRAC: [Interpretation] Yes, Your Honour. That is what we

17 challenge.

18 JUDGE HUNT: Thank you very much.

19 Well, Ms. Uertz-Retzlaff, can you prove the authenticity of the

20 two words that have been added to it?

21 MS. UERTZ-RETZLAFF: No, Your Honour. We don't know when they

22 were added and we do not know who added them and we do not dispute that it

23 was not Mr. Krnojelac.

24 JUDGE HUNT: Well, we will then have it noted that the

25 documents -- that that document is admitted subject to the challenge which

1 the Prosecution accepts to those two words; is that right? Do these have

2 any identification numbers?

3 MS. UERTZ-RETZLAFF: Not yet, Your Honour.

4 JUDGE HUNT: Well, then the document marked A will be Exhibit

5 P445, and the one marked A1 will be P445/A. And the document which

6 is presently marked B will be Exhibit P446 except for the words "Battalion

7 Commander" written in handwriting beside the accused's name. And the

8 document marked B1 will be Exhibit P446/1. I'm grateful to the parties

9 for having agreed to those documents.

10 Now, the business of the exhumations, the concession was stated in

11 these terms: If the families do not object. Is it the fact that they

12 have not objected to the reports going in?

13 MS. UERTZ-RETZLAFF: I don't think that Mr. Bakrac meant that.

14 The families had identified the bodies and, therefore, Mr. Bakrac does not

15 object regarding the identification and doesn't want the family members to

16 come here and tell us what they saw and how they recognised.

17 JUDGE HUNT: I see.

18 MS. UERTZ-RETZLAFF: I think that's the point.

19 JUDGE HUNT: I misunderstood him. Well, then, how do we deal with

20 that one, Ms. Uertz-Retzlaff? Have you got documents to be tendered or

21 are we dealing again with Exhibit 55.

22 MS. UERTZ-RETZLAFF: We are dealing with Exhibit 55. The

23 documents were already tendered and it's just the agreement that we do not

24 call any more witnesses. It's not disputed that the bodies were of these

25 two victims.

1 JUDGE HUNT: Thank you very much.

2 Well, now, we have a new witness. I'm sorry to have kept you

3 waiting, sir.

4 MS. UERTZ-RETZLAFF: Your Honour, there is still this business

5 with Mr. Cancar, document C and D.

6 JUDGE HUNT: Oh, I'm sorry. Yes. Well, you want this to go into

7 evidence in order to explain why you are not calling him; is that right?

8 To stop any inferences being drawn against the Prosecution.

9 MS. UERTZ-RETZLAFF: Yes, Your Honour. It was discussed in the

10 beginning when this trial started. We presented these documents and you

11 actually advised to try to get the witness here and testify. But we were

12 not able to do that. And it's just to prove that we made all efforts but

13 unsuccessful.

14 JUDGE HUNT: Well, then, Mr. Bakrac, what do you say about the

15 explanations in Exhibit C -- I'm sorry, the document C, D, and D1 going

16 into evidence?

17 MR. BAKRAC: [Interpretation] Your Honour, such an explanation by

18 the Prosecution is quite acceptable to the Defence, so we do not object to

19 these reasons that have been put forth in terms of why Mr. Cancar cannot

20 be brought in to testify.

21 JUDGE HUNT: Thank you very much. Well, then, Exhibit -- the

22 document marked C will be Exhibit P447, and the document marked D will be

23 448. The document marked D1 will be 448/A. Thank you.

24 Now, I'm told that there's a change in relation to the protective

25 measures; is that so.

1 MS. UERTZ-RETZLAFF: Yes, Your Honour. The next witness does not

2 request any protective measures any longer. At first he did but now he

3 wants to testify without protective measures.

4 JUDGE HUNT: Thank you very much. Well, sir, would you please

5 stand up and take the solemn declaration. Would you please make the

6 solemn declaration in the document which is being shown to you.

7 WITNESS: MUHAMED LISICA

8 [Witness answered through interpreter].

9 THE WITNESS: [Interpretation] I solemnly declare that I will speak

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

11 JUDGE HUNT: Sit down, please, sir, and I'm sorry that we've kept

12 you waiting.

13 Yes, Ms. Uertz-Retzlaff.

14 MS. UERTZ-RETZLAFF: Thank you, Your Honour.

15 Examined by Ms. Uertz-Retzlaff:

16 Q. Good morning, Witness.

17 A. Good morning.

18 Q. Please tell us your name and your date of birth.

19 A. The 5th of December, 1950, Sarajevo.

20 Q. And what is your name?

21 A. Muhamed Lisica. I beg your pardon.

22 Q. Do you also have a nickname?

23 A. I have two nicknames. They called me Hamdo in my family, and

24 people beyond my family called me Lija.

25 MS. UERTZ-RETZLAFF: Your Honour, although this witness has no

1 protective measures, we have prepared a witness sheet for him, and it

2 should be in front of the witness, with the names of other protected

3 witnesses.

4 JUDGE HUNT: Yes. That will be Exhibit P449 and it will be under

5 seal.

6 MS. UERTZ-RETZLAFF:

7 Q. Witness, in front of you is a sheet of people with names of other

8 protected witnesses, and I would like you to refer to their numbers when

9 you want to refer to them and not name them by their names.

10 A. I agree.

11 Q. What is your ethnicity?

12 A. Muslim.

13 Q. Are you married?

14 A. Yes.

15 Q. Do you have children?

16 A. Yes.

17 Q. How many children?

18 A. Two, a boy and a girl.

19 Q. You said that you were born in Sarajevo. Where did you live

20 before the war, immediately before the outbreak?

21 A. In Foca.

22 Q. In which part of Foca did you live?

23 A. Cohodar Mahala.

24 Q. Is it a Muslim neighbourhood or a mixed neighbourhood?

25 A. Cohodar Mahala is a big neighbourhood. In my immediate

1 neighbourhood, 80 per cent of the population, approximately, were Serb,

2 and 20 per cent was Muslim.

3 Q. What profession did you have before the war?

4 A. Welder. A welder/mechanic.

5 Q. Where did you work?

6 A. I worked in Ozren. This was a service company called Ozren.

7 Q. Before the war, were you a member of any of the newly formed

8 political parties?

9 A. I was not a member of any organisation as of three years prior to

10 the war.

11 Q. And before these three years?

12 A. Before those three years, I was in the trade union, some kind of

13 workers' council, things like that.

14 Q. Immediately before the outbreak of the war, did members of your

15 family leave Foca?

16 A. Yes.

17 Q. Where did they go?

18 A. To Vojvodina. To Vojvodina. That's Serbia.

19 Q. Why did they leave?

20 A. Should I give you a shorter version of this or should I tell you

21 all about it?

22 Q. A shorter version, please.

23 A. My brother was probably afraid of the war. He needed an alibi to

24 go to stay with my family, or rather my wife's family, so he took my

25 children to -- in order to bring my children to stay with their aunts and

1 uncles there. He simply took them away.

2 Q. Why was your brother particularly afraid? Was there a reason?

3 A. I can't really say, but he was probably close to the Serbs to --

4 he went to restaurants and bars where the SDA and the SDS went out, and he

5 probably heard lots of rumours. So I couldn't really tell you the exact

6 truth.

7 Q. Was your brother in the SDA?

8 A. 70 per cent is the probability of his having been a member and 30

9 per cent is the probability of his having not been a member. But I did

10 not look at his membership card.

11 Q. Okay. So you do not really know, but you think he was; is that

12 your answer?

13 A. I don't know. Right.

14 Q. Why did -- and your wife, what about your wife? Did she also

15 leave Foca?

16 A. Could you please repeat that once again? She was in Foca. Oh,

17 no. No. Well, she had worked too, and then she came home and then she

18 phoned me and told me that my brother had taken my son and daughter to

19 Vojvodina, and then she started to cry, and then I got her things ready

20 for her so that she could go to Vojvodina on the next day.

21 Q. Why did you stay?

22 A. It's a bit stupid to say this. I trusted the Serbs, that they

23 wouldn't do anything to me, because I was friends with them all the time.

24 Q. Did you continue to work when --

25 A. I don't remember exactly for how long, but I think I worked all

1 the way up to the 6th of April, or perhaps it was the 5th of April. I

2 can't say exactly.

3 Q. When the war broke out in Foca, did you participate in the

4 fighting at any point in time?

5 A. No, never. At no point.

6 Q. When the war started, where were you and where did you spend the

7 first days of the war?

8 A. Partly in Foca, partly with my Serb neighbours. With Serbs,

9 actually.

10 Q. Why did you spend these days with Serbs and not at your house?

11 A. Because I was alone at home. There was shooting. You'd get

12 afraid a bit. I didn't know what to do. I sought their advice, so I

13 stayed with them and then I'd go back home. I don't know. I can't really

14 say. I was sort of terrified. How should I put it?

15 Q. Did you have a weapon, you personally?

16 A. I personally did not.

17 Q. Did you have a weapon in your house?

18 A. Yes. My bother, when he escaped, he left a rifle there and two or

19 three grenades, something made out of dynamite. He left it there. I

20 don't know how he got that rifle, but he left it there, so those weapons

21 were in my house.

22 Q. What did you do with the weapons?

23 A. You want me to give you the shorter version of that too or the

24 longer version?

25 Q. The shorter version first and if you -- you always give me the

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1 shorter version first and if I need some additional details, I will ask

2 you these additional details.

3 A. All right. Milivoj Lucic took the weapons.

4 Q. Who is Mr. Lucic?

5 A. My neighbour.

6 Q. Was he a soldier when he took the weapons?

7 A. He was in military uniform. He probably was a soldier.

8 Q. How did he get the weapons? Did he know about the weapons, and if

9 so, how?

10 A. Yes, because I had been to his house before that, where there was

11 a gathering of soldiers who were sitting there, and I wished them good

12 luck. And they asked me to join their military and I said that I wouldn't

13 join any army, not even my own, because this was not my war. And I told

14 him that I had my brother's rifle, and he probably knew about it, and I

15 said that it was at my place and then I said that they should not come to

16 my house, that nobody should come to my house in the evening, and they

17 said "Don't," and I might shoot if somebody would come or throw those

18 grenades. They said, "No, do not shoot. Do not throw these grenades."

19 So that's how it all happened.

20 Q. Did Mr. Lucic actually take these weapons out of your house or

21 did you give them to him?

22 A. No. No. He didn't know how to find them. He searched the house,

23 but he didn't manage to find them. And then he asked me and then I

24 explained where it was and he personally took it and he put the rifle on

25 his shoulder and he was carrying a plastic bag in his hands too, and well,

1 I would say about 70 metres away from my house.

2 Q. Immediately after the outbreak of the war, did you observe the

3 arrest of Muslim neighbours?

4 A. Yes, I did. I don't know whether you could call it arrests, but

5 they were taken to a house that was called Planika. It was below my

6 house. Actually, this man worked in a Slovenian company, a shop that was

7 called Planika and that's why he and his house were called Planika, so

8 these people were taken to his house.

9 Q. Who took them to this house? Soldiers, the police, or --

10 A. Some wore civilian clothes, some wore military clothes. People

11 were saying that they would take them there only for security purposes,

12 safety purposes only, for a hearing or something like that. Some were

13 returned home, women and children, whereas others remained there.

14 Q. Were you yourself ever taken to Planika's house?

15 A. Yes.

16 Q. Can you tell us who took you there and what happened?

17 A. I cannot say who exactly took me, but I know how it happened. I

18 ran out of cigarettes and then I went out of my house to a shop, to buy

19 some cigarettes. Then some man, I don't know who it was. I think it

20 was a man from Serbia proper. He pointed a gun at me, at my back, and he

21 told me to walk ahead, and I told him that this hurt. Then he took me

22 to Planika's house, and then I asked this same man to let me speak to his

23 boss, right, his superior, and he said something like, "He's going to come

24 here, and boy, will you be in trouble then."

25 And then about an hour, an hour and a half later, a friend of

1 mine, a former friend of mine, came. Now, just a second. Let me try to

2 remember his name. Mitrasinovic, Goran. And he said hello to me and he

3 asked me how I got there. I explained that I went out to get some

4 cigarettes. And he gave me about a carton of cigarettes and he said to me

5 that I should go back home. In the meantime the one who brought me said

6 that he could take me back home, and he said, "He knows where he lives and

7 he can go back on his own." And he said, "Well you know, don't get him

8 out again." I can't give you his exact words, but that's the gist of it.

9 That's the message.

10 Q. Mr. Mitrasinovic, was he the commander? You said this soldier was

11 referring to a commander who would come. Was Mr. Mitrasinovic the

12 commander?

13 A. Well, he had a belt, the kind of belt that was worn by officers

14 and NCOs while I did my military service, and he also had a small bag

15 which was usually carried by officers and NCOs before. So I imagine he

16 was one of those who had some kind of authority or whatever. And he

17 managed to release me. But what position he exactly had, I don't know.

18 Q. Was he in military uniform?

19 A. Yes.

20 Q. Did he tell you what his position was or did he discuss what

21 powers he had?

22 A. Well, yes. I don't know whether I can define it very precisely

23 now, but he said -- I mean, this is a very long story. I have to give you

24 a shorter version again. He said something like he knew who the good

25 Muslims were, something like that.

1 Q. Do you know if other Muslim males had to stay in Planika house?

2 Did you see others there who had to stay?

3 A. Well, listen. Had to stay? I think they did have to stay there,

4 because when I came to that house - I can't say exactly, but there must

5 have been about 30 or 40 men there and the same number of women. The

6 house was full. In front of that house there was a guard, and I entered

7 the house and I did not manage to get out of the house until Goran

8 Mitrasinovic got there. So most probably yes, they had to stay.

9 Q. Were Muslims kept in other houses as well, other houses in your

10 area? Did you observe anything like this?

11 A. I know another house where I spent the night. That is the house

12 that belonged to this man called Sandal. I don't know any others in

13 Cohodar Mahala.

14 Q. Could you see -- from your house, could you see the Livade

15 warehouses?

16 A. Yes. My house is sort of on that side and I usually sat on the

17 balcony. And if there weren't lots of leaves in the trees, then I could

18 see the warehouse and that side of the road completely.

19 Q. Could you see if Muslim civilians were kept there in the Livade

20 warehouses? At that time we are talking about.

21 A. I couldn't see that. I couldn't see whether they were holding

22 Muslims there. I could see people walking about, but whether there were

23 Muslims inside or not, that I could not see. You cannot distinguish

24 between Serb and Muslim faces.

25 Q. Did you see soldiers using the warehouses?

1 A. I saw men in military uniform.

2 Q. Could you see civilians, and if so, what did they do there? What

3 could you see?

4 A. I saw them walk up to the house only once. I was watching this

5 from Mirko Kunarac's house through binoculars, because Mirko Kunarac asked

6 me to see whether I knew someone. This was a group of people who were

7 walking down the road toward this warehouse. There were soldiers in the

8 front and soldiers in the back. They came to this warehouse and I stopped

9 watching. So now, whether they entered this warehouse or not, that I

10 don't know.

11 JUDGE HUNT: Sir, I wonder if you could speak a little more

12 slowly. You are making it difficult for the interpreters, who have having

13 trouble keeping up with you.

14 A. Fine. Great.

15 MS. UERTZ-RETZLAFF:

16 Q. You mentioned Sandal's house and that you spent a night there.

17 When were you taken to Sandal's house?

18 A. I think I was taken away on the 17th of April, approximately

19 sometime around 10.00 or 11.00 in the morning.

20 Q. Who took you to Sandal's house?

21 A. Goran Milicevic invited me from over there. He said, "Hamdo, come

22 over." He said I should come there for some sort of interrogation. Then

23 I asked him to give me some time, let me go and see my neighbour on some

24 business. And he said, "Yes, go and see your neighbour, finish whatever

25 you have to do and then come over."

1 Q. Goran Milicevic, was he a soldier, a Serb soldier at that time?

2 A. He was wearing a military uniform and he held a rifle in his hand.

3 Q. Did you see the neighbour that you spoke about, and who was he?

4 A. Of course I did. That's my neighbour, a man I know very well.

5 Q. Who was he, this neighbour? Who was he?

6 A. What do you mean, who was he?

7 Q. The name. Can you give us the name of this neighbour?

8 A. The man I went to see or you mean Goran Mitrasinovic?

9 Q. Yes. The man you went to see, who was this man?

10 A. That is Mirko Kunarac, one of my good neighbours. In fact, I went

11 to see Lekso Kunarac, but he was busy at the time and he said, "Go and see

12 my brother." So I went to see his brother. I sat down and we had a chat

13 and I asked him to tell me why I was wanted over there and what they

14 wanted to do with me. Mirko Kunarac dialed a number. I don't know who he

15 called.

16 Q. Why did you go to Lekso Kunarac and Mirko? Did they have a

17 position that they could help you or why did you go to them?

18 A. Because as a child, while I was living in Foca, they were friends

19 of the family.

20 Q. My question was, actually: Were they in a command position or did

21 you simply go to them because they were friends?

22 A. Because we were friends, and in general, Mirko and Lekso Kunarac

23 were influential people in Foca. They were no leaders by any means,

24 but they had connections, they knew people that could help.

25 Q. You said Mirko called someone. Do you know who he called?

1 A. I wouldn't know.

2 Q. When he was making these telephone calls, were you present and

3 could you hear what was said?

4 A. Yes. I was there. He asked questions about me. He asked where

5 is he going, what is going to become of him, et cetera.

6 Q. What did Mirko tell you what was going to happen to you?

7 A. Yes. He said I should go to this interrogation. He said I was

8 going to the KP Dom and then I would spend 7 to 10 days there.

9 Q. Did he tell you why you were supposed to be in the KP Dom for 7 to

10 10 days, why it was necessary?

11 A. Because it was general wisdom that Foca was going to fall, the

12 Serbs were going to win, and there was not going to be a war at all.

13 Q. I was actually asking what Mr. Mirko told you. Did he tell you

14 this, or what exactly did he tell you?

15 A. He told me precisely what I've just told you.

16 Q. Did he tell you when you would be released, on which this would

17 depend?

18 A. Yes. He told me that as well. You told me to give you a brief

19 version and that's why I was trying to make it short. He said that

20 probably Muslims would be divided into three groups. The first group

21 would be the so-called honest people and then those who were guilty of

22 something would be convicted. They would be divided into three groups:

23 Honest people, less honest people, and completely dishonest people.

24 Q. Did he tell you what would happen to the honest people in the KP

25 Dom?

1 A. He said they would be -- he said I would be released and I would

2 go back to Ozren to work.

3 Q. What did he say about the not so honest people, the second group?

4 What would happen to them?

5 A. They would be tried, they would be punished, some with a prison

6 sentence, others would be put on probation, et cetera.

7 Q. This third group that he mentioned, did he say anything what would

8 happen to them?

9 A. He didn't say anything official, but I knew what he meant. It's a

10 group of people who are no good, who should be killed or would be given 20

11 to 25-year prison sentences.

12 Q. Is that what he said or is it what you simply thought?

13 A. Well, he said it and he didn't say it. He didn't say it in so

14 many words, but he was telling a story from which I could gather as much.

15 You know, you don't need to be told everything in so many words. If

16 somebody tells you the first group will be spared, the second group will

17 be punished, and the third group, he doesn't have to say what will happen

18 to the third group. You don't imagine they will be spared as well.

19 Q. When you arrived at Sandal's house, did you then actually go

20 there on your own or were you escorted there?

21 A. No. You see, Goran Mitrasinovic lives opposite Mirko Kunarac.

22 It's like east and west. I went back and I reached this Milorad's house,

23 and there was Goran Milicevic, who took me to his house.

24 Q. We wouldn't need these details, actually. Did you go to Sandal's

25 house alone or were you escorted there?

1 A. I went halfway under escort and the other half I went on my own.

2 Q. Who escorted you? Soldiers or --

3 A. Goran. Goran escorted me, but he told me he was actually

4 protecting me, since I was in civilian clothes.

5 Q. You mean you have mentioned two Gorans. You mean this Goran

6 Milicevic?

7 A. Milicevic, yes.

8 Q. When you arrived at Sandal's house, were there other persons

9 already there, civilians, I mean?

10 A. Yes, there were Muslims, women and men.

11 Q. How long did you stay in Sandal's house?

12 A. From 12.00 until the next day at 10.00.

13 Q. Were you interrogated at that house?

14 A. Yes, I was.

15 Q. Who interrogated you, and what were you asked?

16 A. I was interrogated by Vajo Kunarac. He was actually present.

17 They asked me what kind of weapons I had. That's all, I think.

18 Q. Were you eventually taken to the KP Dom then, the next day?

19 A. Yes.

20 Q. Were you taken alone or in a group of people?

21 A. The women were released, and men were put on a bus. Those were in

22 fact people from Serbia proper. I don't know whether they were eagles or

23 not, but they put us in a bus. And if you could put 50 people on a bus,

24 there were 10 more standing.

25 Q. Those on the bus, were they all Muslim men?

1 A. I think so.

2 Q. You said that there were people from Serbia proper there. Do you

3 mean soldiers who escorted you to the KP Dom?

4 A. Yes.

5 Q. You mentioned the bus. Was it a military bus?

6 A. No. It was a bus belonging to the Maglic company. That's a work

7 organisation.

8 Q. And the driver of the bus, was he also a soldier or was he a

9 civilian?

10 A. I cannot tell you for sure. I know who was driving, but I

11 wouldn't be able to tell you what kind of uniform he was wearing, if any,

12 because I got into the bus through the back door.

13 Q. When did you arrive at the KP Dom?

14 A. That could have been the 18th of April, between 1.00 and 3.00; in

15 fact, around 1.30.

16 Q. How long did you stay at the KP Dom?

17 A. In October 1994 I was released. I cannot remember the exact date,

18 but everybody knows when we left. I think it was in October 1994.

19 Q. When you arrived at the KP Dom, who received you?

20 A. Soldiers from Serbia proper.

21 Q. Did you see any regular guards at the KP Dom at that day when you

22 arrived?

23 A. I think that when I arrived, if I remember correctly, not a single

24 Serb from Foca was there. Everyone there were Serbian soldiers from the

25 Republic of Serbia.

1 Q. Were you mistreated or abused on your arrival?

2 A. They did mistreat us, but you would have to explain to me what you

3 mean by "abuse."

4 Q. What did they do to you?

5 A. They cursed us, they attacked us verbally, provoked us, in a

6 political sense, saying things like, "See what Alija has done to you."

7 Then they made us file into the KP Dom and I went into Room 11.

8 Q. When you arrived at the KP Dom, were you searched?

9 A. Before I got into the KP Dom I was searched.

10 Q. Were you registered? Were your particulars taken down on your

11 arrival?

12 A. When we came into the room, I found there a group of people who

13 had already come on the 17th from a place called Livade. There was a man

14 there nicknamed Uco, which means a teacher, and they came and took down

15 our personal details.

16 Q. This Uco, was he one of the Serb soldiers or was he a detainee?

17 A. That was a Serb soldier who didn't carry any weapons. He was

18 wearing a uniform. A Serb soldier from Serbia, the Republic of Serbia.

19 Q. You said, "They took down our personal details." How much of

20 your details? Just the name or the profession, the birth date? Do you

21 know?

22 A. As far as I'm concerned personally, I was asked my name and

23 surname. I told them, and that was it.

24 Q. You said that you were taken to Room 11. Where was it within the

25 building?

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1 A. Well, it was in the KP Dom of Foca.

2 Q. Yes, but can you describe in which building it was, I mean, in

3 which of the prisoners' buildings and on which floor?

4 A. When you come into the KP Dom, then it's on the left-hand side, on

5 the ground floor. The left building.

6 Q. How long did you stay in Room 11, approximately? Not the date, of

7 course.

8 A. I couldn't tell you exactly. I can tell you only roughly, because

9 I've been in many rooms. It was maybe two months, maybe three. I really

10 don't know exactly.

11 Q. Do you recall to which room you were taken next after Room 11?

12 A. I think I was once in a room where Alija Izetbegovic had been

13 because I saw his particulars there. I think it's Room 17. I'm saying

14 about Alija to make it more easily understandable for you.

15 MS. UERTZ-RETZLAFF: With the help of the usher I would like to

16 show the witness photograph 7512 of Exhibit 18. That's this photo.

17 Q. Can you -- you have to point it out --

18 A. I think this room here.

19 Q. You have to point it out on the ELMO.

20 A. This floor. I think -- in fact, I'm afraid I couldn't tell you

21 exactly. It's one of these two. I think it's more probably this one.

22 MS. UERTZ-RETZLAFF: The witness was pointing first at the first

23 floor and then at the second floor. That would be either Room 18 or Room

24 20, actually.

25 JUDGE HUNT: Thank you.

1 MS. UERTZ-RETZLAFF:

2 Q. And you said you were transferred to several other rooms. Have

3 you ever been on the top floor of this building which is marked with a

4 number 2 on this photo?

5 A. I was in Room 22. I think -- you are confusing me a little,

6 because I spent time in those rooms. I didn't look at the numbers. I

7 think they are located here somewhere. I don't know what the number is.

8 This is 18 and this is 22. That's what I think.

9 Q. Can we have a look at the lower photo? Can you please move the

10 photo so that we can look at this -- this is the photo 7513.

11 Witness, you were pointing at windows where you -- of a room on

12 the top floor. Here you have it a little bit better. Can you point out

13 in which room you were when you were on the top floor?

14 A. I was up here where these windows are. I wouldn't know what room

15 this is. I think it's 22. And that one is 23. I think that was Room 22.

16 MS. UERTZ-RETZLAFF: The witness was pointing at the building

17 marked with a 3, and he was pointing at the left windows of the top floor.

18 Yes, thank you.

19 Q. From this room, could you see the bridge over the Drina in front

20 of the KP Dom?

21 A. I didn't look much through that window. I think you can see the

22 bridge, but only the upper part, the arch of the bridge. I wouldn't dare

23 claim anything with any certainty. I didn't look much through that

24 window. I didn't look over to the other side. I think you can see across

25 the bridge, but whether you can really see what's under the bridge, like

1 the cars going underneath, I'm not sure. You could see across the bridge

2 and the road across the bridge.

3 JUDGE HUNT: Has there been any resolution about this problem with

4 the photographs yet?

5 MS. UERTZ-RETZLAFF: The Defence counsel had actually provided

6 photos that they made from the top floor, but I thought that they would

7 point it to the witness. I actually wanted to use our photos because we

8 have not yet any markings on the photos. But I can, of course, do that.

9 JUDGE HUNT: Well, it's a matter for you. The strict way in which

10 this should have been done, if we had had access to the KP Dom more

11 easily, would have been for the Prosecution to show a photograph if they

12 relied upon it, for the Defence to show if they relied upon it. Now that

13 you've got the photograph, are you able to identify from which windows

14 they were taken?

15 MS. UERTZ-RETZLAFF: No, I can't.

16 JUDGE HUNT: Well, you are in great difficulty, then. Perhaps you

17 had better waited for the Defence to use it. It's unfortunate, because

18 we're now running out of witnesses.

19 MS. UERTZ-RETZLAFF: I would like to show the witness the below-up

20 version of the photo 7528. It's a Prosecution photo.

21 Q. Would that be the view that you had from this room where you were

22 in on the top floor? Could you say?

23 A. Yes. Yes, I can say that. You could see this from the window --

24 because I remember I was looking at this house. This could be it, because

25 this is precisely the arch you can see that I mentioned before.

1 Q. Yes. Thank you.

2 JUDGE HUNT: He showed the -- he showed whatever it is marked with

3 the arrow.

4 MS. UERTZ-RETZLAFF: Yes. Thank you, Your Honour. Your Honour,

5 as I do not know if the Defence counsel will use their photos with this

6 witness, I would need to use them.

7 JUDGE HUNT: I think we can say quite safely that if the Defence

8 don't use their photographs, then the inference will be available that

9 they don't use them because they don't assist their case, now that we know

10 that they've got them.

11 What's the situation, Mr. Bakrac?

12 MR. BAKRAC: [Interpretation] Your Honour, I wish to apologise

13 first of all. We wanted to make the identification together with all the

14 other evidence and then present it when we have all the evidence

15 completed. But we were not able to use these photographs, because this

16 witness had not mentioned in his earlier statements that he had been in

17 the upper floor. However, since we now have this photograph presented by

18 the Prosecution, and he confirmed that he had been there, and we agreed,

19 moreover, that it is Room 22 indeed, then there is no need to present him

20 with our photographs, because he pointed to the room exactly and he said

21 that was the view from the room. So I don't think there is any need for

22 us to show anything further.

23 JUDGE HUNT: But I think that I should make it clear, Mr. Bakrac,

24 that the inference which I personally would draw from that statement is

25 that your photographs taken from that top floor and Room 22, do not

1 suggest that you cannot see at least the top of the arch of the bridge; is

2 that correct.

3 MR. BAKRAC: [Interpretation] Your Honour, the photograph presented

4 by the Prosecution is self-evident, and the Defence does not dispute that

5 it was made from Room 22. We can see only a small, tiny part of the upper

6 arch of the bridge, and the witness is showing a house, and this is not

7 explained very precisely in the transcript, which is on the slope on the

8 opposite bank. And he said he could see this tiny bit of the arch of the

9 bridge, and this is quite sufficient for the Defence and we don't see any

10 need to show him our photographs. Since the Defence has already made

11 them, we can show him a photograph made from the annex. We have, for

12 instance, a photograph from Room 23, which, as you remember, was

13 contested, that is, the left wing, marked with number 3; and we have a

14 photograph from Room 22, the annex. That's what we can show him, although

15 he claims that he had not been in the annex but in the part which he has

16 just shown us on the ELMO.

17 JUDGE HUNT: You've made it very clear. Thank you very much,

18 indeed.

19 Yes, Ms. Uertz-Retzlaff.

20 MS. UERTZ-RETZLAFF: Thank you, Your Honour.

21 Q. Witness, the soldiers from Serbia, how long did they stay in the

22 KP Dom?

23 A. Almost two weeks. I don't know exactly.

24 Q. After these two weeks, before the soldiers from Serbia left, did

25 anyone tell you what was going to happen?

1 A. Yes. I went out to work for people from Serbia proper, and one of

2 those Serbs told me, "We are leaving tomorrow, and your fate will depend

3 on the Serbs who are going to come now. To me, you are all Turks and you

4 are all the same to me."

5 Q. Did he indicate what may happen to you and the other detainees?

6 Did he indicate anything?

7 A. Well, yes, he did. I was working then with the Witness 54. He

8 said something like, "They will try you. They will know which ones among

9 you are good, which are bad. Simply, they will define where we belong, to

10 which category."

11 Q. Did he mention any category?

12 A. He didn't say three groups, but he did say we will be categorised,

13 and that was down to the same thing.

14 Q. You said that you were working at that time with Witness 54. What

15 were you doing? What were you asked to do?

16 A. Well, I don't know exactly, but I know that there had been snow.

17 As they were entering the building, there was an office with a furnace

18 where correction officers were before the war, and then I was supposed to

19 chop firewood and prepare it for the furnace.

20 Q. When the soldiers from Serbia left, on that day, who took over

21 from them?

22 A. The Serbs from Foca.

23 Q. What happened -- whom did you see come to the KP Dom after the

24 Serbs left, the Serbs from Serbia?

25 A. In the evening we got some kind of small sandwiches, and in the

1 morning when I got up, I don't know whether it was 9.00, 10.00, I saw in

2 the compound quite a few people I knew in uniform, in the former KP Dom

3 guard uniforms. And also there were some in military uniforms and they

4 started shuffling about. So this was between the prison building and the

5 kitchen, actually, that area.

6 Q. Whom did you recognise walking there in this space?

7 A. Am I supposed to mention names?

8 Q. Yes.

9 A. I recognised people I knew from before, Milenko Cancar, inter

10 alia, then Milivoj Maric, then Rasevic. Then I saw that Mila Krnojelac.

11 That's what they called him, Mila, Milorad. That's the first time I found

12 out what his name was. I can't remember right now. Oh, yes, Slavko

13 Koroman. Give me some more time and I'll remember more people.

14 Q. Let us first speak about the people that you just mentioned. Mr.

15 Cancar, Milenko Cancar, you said. Was he a guard in the KP Dom?

16 A. All these people I saw, 90 per cent of them were guards. I knew

17 them from before. Milenko was a guard before the war. Milenko is his

18 name for sure. I'm not sure whether it's his surname, though, Cancar, but

19 I think it is. He was sort of a biggish man. Then also there was Slavko

20 Koroman.

21 MS. UERTZ-RETZLAFF: Your Honour, Milenko Cancar is number 26 on

22 P -- on this list of employees, P-3, Slavko Koroman is number 32, and a

23 Maric, Milivoj, is under -- listed under --

24 A. No.

25 Q. You mentioned Mara?

1 A. Yes, Maric, Mara, right.

2 MS. UERTZ-RETZLAFF: Your Honour, it's number 102.

3 Q. Mara, is this a nickname? It doesn't sound like a proper name.

4 A. Yes, Mara is a nickname. That's what I called him, Mara.

5 JUDGE HUNT: Are you then asserting that it was the one that you

6 referred to, the number?

7 MS. UERTZ-RETZLAFF: Yes, Your Honour, because there's no other

8 possibility, at least not according to the list.

9 JUDGE HUNT: Thank you very much.

10 MS. UERTZ-RETZLAFF:

11 Q. You mentioned Mr. Rasevic. What was he wearing, and did you know

12 him from before?

13 A. Yes, I did know him from before. It's not that I talked to him

14 very much, but I knew him. He also had a KP Dom uniform on.

15 Q. Did you see Mr. Todovic, Savo Todovic?

16 A. Yes, I did, but right at that moment I didn't know it was Savo

17 Todovic. But I saw him. I knew him by sight, but I didn't know that Savo

18 Todovic was his name. That I found out later.

19 Q. And what was he wearing? Do you know that?

20 A. It seems to be coming back to my mind that he was a civilian, but

21 I really don't know, actually. I simply can't remember.

22 Q. And you mentioned that you saw Mr. Krnojelac, and you said that

23 you didn't know his first name at that time, Milorad Krnojelac; is that

24 right?

25 A. Yes. Yes, right. I knew that man, because I worked with his son

1 for a long time. I knew him and I came to that cafe restaurant when it

2 was being built, so I knew him.

3 Q. And you said that you knew his sons. How many sons does he have

4 and which of the sons do you know from before?

5 A. Well, maybe I'll make a mistake. He had either three or four

6 sons. He had to have had three sons, but he might have had four too. I

7 knew one called Dubravko, Dubravko or Jadranko. That's the one who worked

8 with me, and I think that was his oldest son. He worked with me in Ozren

9 for at least ten years.

10 Q. And you said you came to that cafe restaurant. What cafe

11 restaurant do you mean? To which restaurant or cafe did you go related to

12 the Krnojelac?

13 A. That's in the house. His brother or both of them together. I

14 don't know. When they were building that cafe, they needed my services,

15 because I'm a welder, for their boiler or something like that. He asked

16 me to fix some of their pipes, and I went over there to see how I could

17 have those pipes made.

18 Q. And who ran this cafe in the Krnojelac house? Do you know that?

19 A. One of the sons. One of the sons was an owner, probably. I mean,

20 I never really asked. I just went there to help, to help Jadranko or,

21 rather, Dubravko.

22 Q. Mr. Krnojelac, was he involved in politics? Do you know? Before

23 the war, I mean.

24 A. I have no idea whatsoever about that.

25 Q. Do you know if Mr. Krnojelac had a function in the reserve army?

1 A. I think he had to be somewhere, either in the civil defence or in

2 the reserve force, like I was, but I don't know about this related to the

3 war.

4 Q. When you saw him on that first day in the KP Dom, how was he

5 dressed?

6 A. Well, when I saw him, he had his back turned to me, so I didn't

7 know it was him. But then he turned around, and then I realised that I

8 recognised him, and I thought I knew this man. This was Dubravko's

9 father. He was wearing military uniform, winter uniform. We who did

10 our military service knew what winter uniforms were and what summer

11 uniforms were.

12 Q. What does a winter uniform look like? What colour does it have

13 and what distinguishes it from the summer uniform?

14 A. Well, it's like looking at a civilian winter coat and a summer

15 coat. I don't know how to explain this. I don't know how to explain it,

16 but when I see it, I know.

17 Q. What kind of colour does the uniform have?

18 A. Olive-green/grey.

19 Q. Is it the old SMB uniform that the JNA had?

20 A. Now you've really got me confused. What do you mean, "old"? It

21 is a military uniform of the Yugoslav People's Army, the JNA. Yes, you

22 could put it that way.

23 Q. And did you see any insignia on his uniform?

24 A. As far as I could see then, I saw that he had some kind of a belt

25 with shoulder straps. We, as soldiers, knew that this would be an officer

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1 or an NCO wearing that. I also saw that he had a pistol on his belt, just

2 like other soldiers did. It was closed in something. How should I put

3 this?

4 Q. This kind of belt with shoulder straps, what colour does it have

5 and what does it look like? Can you explain it a little bit more

6 detailed?

7 A. Well, I could a bit. It's a belt. It's made nicely, and the

8 colour could be, well, mauve. Well, there's nothing else I can really

9 say. Take the picture of any officer, take a look at it; that's it.

10 Q. How is this belt worn? Is it on the waist or is it over the ...

11 How do you wear this? Can you explain?

12 A. Soldiers wore it with two straps, while the officers wore a big

13 strap that goes from left to right or from right to left. I don't know.

14 It goes from the shoulder to the opposite hip, so it either goes from the

15 right shoulder to the left hip or from the left shoulder to the right hip.

16 Q. And did Mr. Krnojelac have this officer-style belt that you just

17 explained, going from the shoulder to the hip?

18 A. Precisely.

19 Q. You said that he had a pistol. Did he have anything else on his

20 body, on the belt?

21 A. I think that there was a bag on the other side.

22 Q. What kind of bag? Is that something very typical?

23 A. Leather. Leather bag. An ordinary leather bag, I think, military

24 bag, though.

25 Q. Is it a bag that all soldiers wear or is that related to officers

1 only?

2 A. Well, both could wear it in our situation; however, it is usually

3 squad leaders who wore it, corporals.

4 Q. Did you know at that time when you saw him for the first time what

5 position he had in the KP Dom?

6 A. Nobody knew that. They walked about there. The Serbs from Serbia

7 said that our people would be coming in, and then we looked through the

8 window to see who would recognise who, but I didn't really know anyone.

9 Q. When you saw Mr. Krnojelac and the other people, when you saw them

10 in the yard, where were you?

11 A. Room 11, the one that faces the corridor and the kitchen. If you

12 have a picture, I can show it to you.

13 MS. UERTZ-RETZLAFF: Yes. With the help of the usher, I would

14 like to show the witness the photo 7479.

15 A. It's this part here where they were moving about, this part,

16 approximately. This is mainly the area where they were, over here. And

17 now here is Room 11. You could see from there. So this is the view from

18 Room 11, I think.

19 MS. UERTZ-RETZLAFF: The witness was --

20 JUDGE HUNT: I didn't see what he was pointing to. It may

21 have been on the other photograph.

22 MS. UERTZ-RETZLAFF: No. The witness was pointing at the yard,

23 the main yard in front of the staircase on the photo, right in the middle.

24 JUDGE HUNT: Yes. Yes, I agree with that.

25 MS. UERTZ-RETZLAFF: He was actually pointing to something that is

1 not on the photo.

2 Q. That is, where you were. That is actually the view. What you see

3 here, is that the view that you had from your Room 11?

4 A. Yes. Yes, it is. Yes. But I showed Room 11 to be here, behind

5 this, and from that room I could see this, precisely this. This is what

6 I could see from Room 11. This is what I could see.

7 MS. UERTZ-RETZLAFF: Yes. The witness was actually pointing at

8 Room 11, which is not on the photo.

9 JUDGE HUNT: Thank you.

10 MS. UERTZ-RETZLAFF: Yes. Thank you.

11 Q. Did any of these people that you saw in the yard come to the room

12 on that day?

13 A. Yes, they did, after I don't know how much time. I think one of

14 the guards came to the room, Savo Todovic came, Rasevic, and Krnojelac.

15 Q. Did they all come together?

16 A. Yes, they did; at least, that's the way I remember it.

17 Q. And did they talk to the detainees, that is, to you?

18 A. Not to me personally, but to other inmates. I think, as far as I

19 can remember, that Krnojelac did not make a speech. Rasevic made a

20 speech. He told us that we were citizens, isolated citizens, without any

21 rights, something to that effect. That was the definition, roughly.

22 Q. Did you or any of the other detainees, did you respond to this,

23 that you were there without rights? Did anybody say something?

24 A. Yes. There was a polemic, a bit of a quarrel. It was said that

25 we were civilians, that we weren't to be blamed for everything. I

1 remember well, but I don't remember who said it, whether it was Savo

2 Todovic, Rasevic, or Krnojelac who said this, that those were orders

3 issued by some kind of command, that these were orders and that they could

4 not make any further comments with regard to that, that we were isolated.

5 Q. When this discussion took place, did anybody mention what kind of

6 command it was?

7 A. We all knew, all of us inmates. When the command was mentioned,

8 what the command was. If they were leading Serb personalities, then that

9 was the command. Nobody asked who the commander was, because we all knew

10 who the commander was, the group of people commanding a state.

11 Q. How did you know that? You said that everybody knew. How did you

12 learn that there was a command?

13 A. Well, okay. I find this question to be a bit strange, but ...

14 Everybody did their military service in the Yugoslav People's Army, in the

15 JNA, and the command is a group of people that commands the people. We

16 know that. Before the war, we knew about the SDA and the SDS and we knew

17 that the people of the SDS were leaders who were commanding the Serbs and

18 then on the other side there were these other commanders. And we knew the

19 names. I knew Velibor Ostojic, Vojo Maksimovic. Before the war they were

20 the leading personalities there and they were the ones who were commanding

21 then. We knew. We all knew that. I mean, how should I put that to you?

22 Q. When the KP Dom staff took over, how many detainees were you in

23 Room 11 and all together? Do you know that?

24 A. According to information which is only approximate, perhaps it's

25 not accurate, in my Room 11 there was between 100 and 110 persons, and

1 then also, according to the information we had, which was a bit scarce, it

2 was about 300, 350 people all together, something like that.

3 Q. When the time passed, the following weeks, did the number of

4 detainees increase? Were more detainees coming in?

5 A. Yes. Yes, it increased.

6 Q. What is your estimate of the highest numbers of detainees at

7 any point in time?

8 A. Well, according to our Sunday counts from the window, when people

9 were going out for breakfast or lunch, the count seems to range between

10 600 and 615.

11 Q. Those detainees in your room, what ethnicity did they have?

12 A. Muslims. There was one Croat too, or rather a Catholic. I don't

13 know whether he's a Croat too.

14 Q. Were there Serb prisoners in the KP Dom as well?

15 A. I don't understand your question.

16 Q. Were Serbs detained in the KP Dom as well at a later stage or at

17 that time already?

18 A. There were about four or five detainees who had remained from

19 before the war. They were convicts, though. But I mean, I was not a

20 detainee; I was an inmate. So you have to distinguish between the camp

21 and the prison. That's what I'm trying to say.

22 Q. Were there Serbs? You said there were a few convicts in the

23 prison. Where were they kept? Were they in the same room as the Muslims

24 or separate?

25 A. They were separate. Muslims were not allowed access to them, nor

1 were they allowed access to us.

2 Q. Where were they kept? Where in the prison compound?

3 A. There were four of them left, I think. They worked in the kitchen

4 then. They had been convicted. When you enter the KP Dom, they were on

5 the right-hand side, the building we mentioned, precisely in that area,

6 22, 23. And then they were either up in 22 or a bit lower, but they were

7 there. And I think that they were on the first floor of this building on

8 the right-hand side.

9 Q. Did at a later point in time during your detention, did more

10 Serbs -- did Serb prisoners arrive?

11 A. Some kind of politicians arrived and they told us that they were

12 from Banja Luka and Trebinje, and there were Serbs from Foca. Yes, they

13 were coming in. Some were leaving after a while, others were staying

14 longer. Yes, they were coming in.

15 Q. The Serb prisoners, were they soldiers or were they civilians?

16 A. I think -- I mean, I saw quite a few of them in civilian -- in

17 military uniforms, but also in civilian uniforms. But then what they

18 were, I didn't really ask them.

19 Q. Do you recall that reporters once entered the KP Dom?

20 A. Yes. Yes, in my room.

21 Q. When did they come?

22 A. I think it was June, July. I do not remember dates. I didn't

23 really want to know them either, so you have to appreciate that.

24 Q. What year was it?

25 A. 1992.

1 Q. Did you talk with these journalists?

2 A. Yes, I did, with a journalist. I think he was from Serbia, from

3 Belgrade, I think, judging by his accent. I also talked to some

4 Frenchman.

5 Q. What did they ask you?

6 A. You want the shorter version of that as well?

7 Q. Yes.

8 A. They asked me why I was here in prison, or rather, here in camp.

9 Then I said that I didn't know, just because I was a Muslim. And that's

10 what the Frenchman asked me. I told them all of that in the French

11 language because Slavko Koroman allowed me to do that.

12 Q. Did they ask you if -- did any of them ask you if you were

13 caught -- captured during battle?

14 A. Yes. The gentleman asked me where I had been captured, and I told

15 him that I had not been captured at all and that he cannot put it that

16 way. That's a mistake. I was brought in. It's not that I was running

17 away or something like that. And I distinguish between the two, to be

18 captured and to be brought in.

19 Q. You said that Slavko Koroman was present. Was anyone else present

20 from the prison staff when you had this discussion?

21 A. I don't think so. I don't know exactly. However, these French

22 journalists were there and those journalists from Serbia too. I think

23 they introduced themselves as being from the Borba newspaper, but I don't

24 know.

25 Q. I asked you -- actually, I asked you about the prison staff

1 members present. Was someone there besides Mr. Koroman?

2 A. Slavko Koroman is this guard, officer, whatever you call him, and

3 then there were the journalists and then probably over there there must

4 have been somebody else, but I was in the room.

5 Q. Okay.

6 MS. UERTZ-RETZLAFF: Your Honour, it's time.

7 JUDGE HUNT: Thank you. Those Exhibits P448 and 448/A will be

8 under seal. They do reveal the man's address.

9 Right. We'll resume at 11.30.

10 --- Recess taken at 11.00 a.m.

11 --- On resuming at 11.30 a.m.

12 JUDGE HUNT: Ms. Uertz-Retzlaff.

13 MS. UERTZ-RETZLAFF: Thank you, Your Honour.

14 Q. Witness, you mentioned already that in this short period when the

15 Serbian soldiers were in the camp that you worked for them. Did you work

16 when the regular prison staff ran the camp?

17 A. I arrived on the 18th of April. I think I started working in end

18 April or early May, I believe. I cannot tell you the exact date.

19 Q. How did this come about that you started to work? Who told you

20 that you should work?

21 A. I don't know who told me, but I was called by a guard to come

22 downstairs, so I did, and I met directly with Rasevic.

23 Q. Where did you meet Mr. Rasevic?

24 A. Right in the hallway. When you are about to leave the KP Dom,

25 through that iron door, there is the reception area nearby and the door.

1 It's a small hallway. You could go to the left or to the right from it.

2 MS. UERTZ-RETZLAFF: With the help of the usher I would like to

3 show the witness Exhibit 6/1.

4 Q. Witness, can you orient yourself with this floor plan and point

5 out where you were taken to Mr. Rasevic, where you met him.

6 A. This area here, where I'm pointing right now. At least, that's

7 what I think, according to this picture. If this is the gate, the

8 entrance door from the outside, and this is the iron door, then this is

9 the area.

10 MS. UERTZ-RETZLAFF: The witness was pointing at this passageway

11 after the entrance to the KP Dom from the street side, the reception.

12 Yes, thank you.

13 Q. What did Mr. Rasevic tell you?

14 A. He told me that I should work for him, that I should start working

15 there. I don't know whether I had mentioned it in my statement earlier,

16 but he asked whether I had any quarrel with a certain Serb, and with

17 regard to any of the Serbs I knew, I had no quarrel whatsoever.

18 Q. Did he explain why he wanted to know if you had quarrels with

19 Serbs?

20 A. He didn't explain really, but I could understand in a way. I

21 could deduce why he told me that.

22 Q. What do you mean?

23 A. Because I was supposed to work outside the KP Dom, and it was out

24 of concern for my protection, safety.

25 Q. When you had this conversation with Mr. Rasevic, did anyone else

1 join you or was anyone else present?

2 A. Mr. Krnojelac came up in the meantime. He came along in this

3 hallway. There were more senior officers in the hallway. He said I would

4 be working for the KP Dom, that is, Rasevic said that to Krnojelac.

5 Krnojelac, I believe, nodded his head and he didn't say anything. He made

6 no comments. I don't think I heard him say anything. But he did stop

7 there for a while, as if he were thinking whether that would be all right.

8 Q. On this occasion, did you already know that Mr. Krnojelac -- what

9 position Mr. Krnojelac had in the KP Dom?

10 A. No. No. I didn't even know what he was.

11 Q. How did Mr. Rasevic address Mr. Krnojelac? Do you remember that?

12 A. I think he called him Krnojelac. That's at least what I remember.

13 Q. When did you learn about the position of Mr. Krnojelac, if ever?

14 A. Well, about Krnojelac's position, there are several versions.

15 I'll tell you about one of them. After a brief period spent in the KP

16 Dom, I asked Savo Todovic whether I could write an application, a sort of

17 request, something to the effect why I was here and could I get out. And

18 he said yes. And since I could only write in Latinic script, I didn't

19 know the Cyrillic, he allowed me to do so and I said I'd bring my request

20 the next day. A certain man, I believe his name was Jasarevic wrote out

21 this request for me in Cyrillic and I handed it to Savo and Savo said,

22 "I'll hand it over to the warden to take it to the command for review,

23 and then we'll see what will happen." Then he mentioned the warden,

24 but he didn't say the Warden Krnojelac or anything; he just said "the

25 warden." So I knew there was a warden at the KP Dom.

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1 Q. Why would you have to write it in Cyrillic? Who told you that?

2 A. That's a funny question. Nobody told me that. It's just that

3 when I arrived at the KP Dom, and even before the war started, the Serbs

4 used the Cyrillic. It's their script. And since they started calling it

5 the Serbian Republic, it was something that I decided for myself that I

6 wanted to write it in Cyrillic.

7 Q. What did you write, or rather this other person who helped you?

8 What did you write? What kind of a request?

9 A. Well, I cannot explain it verbatim, but I can tell you what the

10 essence was. "I kindly request the command," and then in brackets, "the

11 competent authorities," or something, "to release me, because I do not

12 feel guilty and I believe I am locked up here, although innocent, and I am

13 requesting to be released from the camp."

14 Q. You said that Mr. Todovic told you that you could write something

15 to this effect. Why did you address it to the command and not to the

16 warden?

17 A. Because, as I have said once already, when they first came to our

18 room, they told us that we were isolated citizens there who have no rights

19 whatsoever and that they were executing orders given them by the command.

20 That's why I understood that we were in the hands of some command, and

21 that's the picture that we had. Even before, when I was talking to

22 Savo, Savo told me that all they were doing -- it's actually the people

23 from outside who were doing it, and they were mentioning this command all

24 the time, the Crisis Staff.

25 Q. Did Mr. Todovic tell you what he would do with this letter, with

1 this written request?

2 A. I've just said it. He said he would hand it over to the command.

3 Q. Did you ever get a reaction, an answer to your request?

4 A. Yes, I did.

5 Q. In what format was it? Was it a written answer or how was it

6 answered?

7 A. On one occasion when I was working at the metalwork shop, Savo

8 Todovic came along with an ugly grin, and he motioned me to approach him,

9 and he said, "Your request was thrown into the waste bin." And he

10 mentioned some man Damjanovic, who had run away from Foca to Pljevlje. In

11 any case, he told me my request was basketed.

12 Q. When did you write this request, and when did Mr. Todovic inform

13 you that it was in the wastepaper bin?

14 A. I think I wrote my request at the beginning, when I started

15 working, so it could have been May. And it was denied sometime in end

16 June or early July. I couldn't say exactly.

17 Q. Did other detainees start to work with you in end of

18 April/beginning May?

19 A. Yes, they did.

20 Q. Was there actually a working group of people that continuously

21 worked?

22 A. I think right at the beginning this metal workers' group was

23 formed, and it always numbered between 7 and 15 people.

24 Q. Were there other groups of workers who did something different

25 from you, you 15?

1 A. There were not perhaps groups exactly, but they took out people

2 occasionally to sweep the yard, to work at the kitchen and do odd jobs

3 around Foca, like transporting flour. They would go occasionally, right

4 at the outset, and later a separate group was formed to work at the farm,

5 and so on.

6 Q. How many detainees worked all together, if you would put a number

7 to the people who would work? Could you do that?

8 A. From day to day, that would change. Groups would increase or be

9 reduced. But the maximum number of people who were working at the camp

10 was between 50 and 60.

11 Q. Was work voluntary?

12 A. Well, perhaps you could call it voluntary in a sense, but I would

13 like to define that sense.

14 Q. Yes, please do so.

15 A. I'll give you an example. If you're locked up in an area out of

16 which you cannot get at all, and if somebody offers you work, then it's

17 always better for you to get outside and work, because you can expect to

18 get some things like food, cigarettes, even contacts with Serbs and find

19 out something. It's better than staying in the room. So in a way you can

20 call it voluntary, although in another sense it is quite ridiculous.

21 Q. Were you paid for your work?

22 A. Sometimes in cigarettes.

23 Q. What does it mean, sometimes in cigarettes? How many cigarettes

24 did you get for your work?

25 A. Depending on the day, depending on the month, and depending on the

1 goodwill of those who gave us cigarettes, we would get five or ten. The

2 factory which produced them had some sort of refuse cigarettes which were

3 substandard or non-standard. They were not a standard length, for

4 instance. And they were going to waste anyway, so they gave them to us.

5 Q. Who gave these cigarettes to you? The prison staff or people from

6 outside?

7 A. I personally got them from my so-called superior, who was in

8 charge there. That was Relja Golijanin. And sometimes the superior

9 officers who guarded us.

10 MS. UERTZ-RETZLAFF: Your Honour, Mr. Golijanin is listed under

11 number 40 in P-3.

12 JUDGE HUNT: Thank you.

13 MS. UERTZ-RETZLAFF:

14 Q. The work, did this have other advantages besides getting

15 cigarettes?

16 A. You mean me personally or the group which worked with me?

17 Q. Yes. All of you. Did you get additional food?

18 A. Yes. We all got extra food. We called it snacks. That was

19 between lunch and supper.

20 Q. What did it include?

21 A. It varied. I think it was a piece of bread with butter or

22 margarine on it.

23 Q. You mentioned already that it was favourable to get out of the

24 room and to work. Did working help you survive the conditions in the KP

25 Dom?

1 A. It helped me personally very much because I could get more food

2 and better food than what we officially got in our rations. I could get

3 more cigarettes. It was good for me personally. I liked working, at

4 least, better than staying inside the building.

5 Q. You have already mentioned that Mr. Rasevic personally talked to

6 you about starting to work. How did the other detainees that later worked

7 start to work? Do you know that? How did they get into the working

8 group?

9 A. I have no proof, but I can assume. In fact, that's how it should

10 be, because it can't be any other way, considering that before that, up

11 until June, I believe, everyone had already gone through those

12 interrogations by interrogators who came from outside, who didn't work at

13 the KP Dom, but came from Foca. Based on those statements and on the

14 statements of Serbs who knew these people personally, they decided who

15 would work and who wouldn't. They decided whom they could believe and

16 whom they couldn't. This is at least what I thought, and I believe it is

17 right.

18 Q. Did you have a conversation with a Mr. Slavko Ivanovic to this

19 effect?

20 A. Now, who is Slavo Ivanovic? Oh, yes, yes. Yes, of course I know

21 him. Yes. On one occasion I did talk to him, when I was going to the

22 hotel. There was the Serbian national cuisine there and I was making a

23 platform and awning for that kitchen. Slavko Ivanovic approached me. He

24 was holding an automatic gun in his hands. He had a parting in his hair.

25 He dismissed the guard, saying, "I know this man, and there's nothing

1 wrong with him." He said that, "You got a positive assessment also from

2 the company where you worked, and all of you who are working are

3 protected." That's approximately what he said.

4 Q. When did you have this conversation with him?

5 A. That could have been June, maybe mid-June, roughly.

6 Q. Did you know Mr. Slavko Ivanovic from before the war, and who was

7 he?

8 A. I could spend hours talking about him. I knew him and his entire

9 family, all of them, but I don't think you want to hear that. I will just

10 say that for a while he and his family were my neighbours.

11 Q. This conversation that you had with him, how did it start,

12 actually? What was the reason to talk about this? How did it start?

13 A. Slavko Ivanovic just happened to be going towards the hotel by

14 chance, and he saw me there. That's probably how it happened.

15 Q. And try to remember: What did he say to you?

16 A. You mean in addition? Yes, I think I can remember. He said,

17 "Listen, Lija, there will be no problems. I think when Gorazde falls,

18 all of you will be released." That's what I remember him saying. There

19 may be something else, but I cannot recall now.

20 Q. You said that he actually said that you who are working are

21 protected. Did he say why you were protected and by whom?

22 A. I gave you the brief version just now, but he said there was a

23 meeting in Cohodar Mahala where the names of prisoners, or rather,

24 inmates, were read out, those who were up there. I just said that I got a

25 positive assessment from Ozren, and I meant that I got a reply to the

1 effect that I'm a good, honest man. And I got the same kind of positive

2 assessment or reply from Cohodar Mahala, which means that it was written

3 somewhere that in view of the existing Serbian state, it could be

4 considered that I was not against it, that state.

5 Q. Did he tell you when this meeting in Cohodar Mahala had taken

6 place and who took part in it?

7 A. He said a few days ago there was this meeting. I don't remember

8 him mentioning who had been present. I cannot recall now. Maybe it's in

9 one of my statements.

10 Q. You said that he mentioned that they discussed on this meeting the

11 inmates or prisoners. Which prisoners? You mean those in the KP Dom in

12 general? Did he say something?

13 A. I have just remembered. He said they had a meeting and that they

14 discussed Muslims. They investigated who was who. I don't know how to

15 explain it.

16 Q. Let's discuss the proceedings involved with the work. What

17 happened when you were taken out for work for the first time? If you can

18 explain to us the steps that were taken.

19 A. I worked for three years, and I don't know what you want me to

20 explain, about a particular day or what?

21 Q. Your first day, were you called out from your room to go to work

22 or how did this start?

23 A. I had one pair of trousers and one military shirt, which I put on,

24 and I left with a man called Jovo. I can't remember his last name now.

25 He used to work as an electrician at the KP Dom before, with a man named

1 Susnjevic. We were going to dismantle a door from a house and install it

2 elsewhere in a house in Donje Polje. That was earlier in the day, in the

3 morning, before lunch. Then I went to the metalwork shop, where I broke

4 padlocks, because before that there had been workers in the workshop who

5 had their own tools and they had locked them up, and there were no keys

6 available. So I was supposed to take off the padlocks in order to enable

7 them to take out the tools and sort them.

8 Q. Did Jovo actually call you out from Room 11, or anyone else?

9 A. Nobody ever knew who had called them out, because there was one

10 guard inside and one older guard outside. So the one inside would tell

11 you to go to the iron door, and you would go there, ring a bell, and then

12 another guard would take you over; and then a third man would take you

13 wherever you were supposed to go. So it was like that when I was called

14 out to go with Jovo and dismantle that door.

15 Q. When you reached -- when you passed the metal door that you just

16 mentioned, did anyone put your particulars down and made a note that you

17 were leaving, or what happened?

18 A. I saw what had happened to me. Usually the one who was at the

19 reception room, the one on duty, would record my name, because I know that

20 this Jovo said, "Lija is coming with me." So he wrote it down and I went

21 with him. So he did record my name.

22 Q. Where did he write it down? What kind of paper was it?

23 A. This is a little window opening, and then through it he says he's

24 coming with me. I did not go in through that little window opening to see

25 what he was writing down, whatever. In fact, I was registered. Then this

1 man at the reception office knew that I had gone there to work. Now, how?

2 Well, you know, I was in a camp, so I can't really make comments to that

3 effect. I mean, I didn't dare to.

4 Q. When you returned, was another note taken? Was this registered as

5 well when you returned after work?

6 A. When I came back -- I mean, usually Jovo would -- actually, at the

7 reception gate, the guards would usually change, and then Jovo would

8 say -- I mean, I'm just giving you an example. He would say, "I'm taking

9 Lisica back. He's going to the compound." He would search me and then I

10 would go into the compound.

11 Q. You mentioned Jovo, an electrician. Was he a staff member, was he

12 a guard?

13 A. You know what? At the KP Dom, when they established that KP Dom,

14 actually, before he had worked as an electrician, and after that they were

15 all actually guards; whereas, those who were electricians did both jobs,

16 both one and the other.

17 Q. Does that mean this Jovo was already working in the KP Dom as an

18 electrician before the war?

19 A. Yes.

20 Q. Do you know his last name?

21 A. I can't really remember. Why don't you ask Krnojelac? Maybe he

22 remembers. I can't remember exactly. Actually, if I thought about it

23 more, maybe I could remember, but I can't remember right now.

24 MS. UERTZ-RETZLAFF: Your Honour, we have too many Jovos on the

25 list. We can't say.

1 JUDGE HUNT: Thank you.

2 MS. UERTZ-RETZLAFF:

3 Q. How many days a week did you have to work? Did you have a

4 five-days week, six-days week?

5 A. It was not always the same. Sometimes five, sometimes six,

6 sometimes seven, sometimes three. Well, if we were to make an

7 approximation, it could have been five days a week. There would be less

8 and there would be more.

9 Q. So you occasionally had to work on weekends as well?

10 A. Yes.

11 Q. Did you have regular working hours?

12 A. The working hours for the metal shop were from 7.00 until 3.30, or

13 until 3.00. However, since I worked all over Foca, sometimes in the

14 hospital too, sometimes I'd stay until 5.00. It depended on the job that

15 had to be done, actually.

16 Q. Did you also have to work during night-time?

17 A. Once.

18 Q. Only once?

19 A. Once I went to work during the night.

20 Q. What about the breaks? Did you have regular breaks during your

21 work?

22 A. We had some regular breaks, and then it would really depend on the

23 guards. If the guards were nasty, then we would have regular breaks; but

24 if it was a good guard, then we would have more than the regular breaks.

25 Q. What were the regular breaks? How many breaks did you have during

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1 a working day?

2 A. Between 7.00 and 12.00 we had one break for the snack. It could

3 have been around 10.00, about half an hour. That was half an hour. And

4 then I think we had an hour for lunch. And since we went home, I mean,

5 back to the camp, at 3.00, that was it.

6 Q. This one-hour lunch break, when did you have this?

7 A. Well, listen. First when I just started working, it wasn't an

8 established working group of the metal shop. They would call people out

9 from rooms and then people would go from the metal shop. We would be the

10 first or sometimes the last to have our meals, so we would go at 12.00 to

11 the compound and then we would go back and then we would go back home at

12 3.00. But then, after that, when we established -- when the working group

13 was established, then after this break at 10.00 we would have yet another

14 break just before the end of working hours. We would go and have a meal

15 and that would mean that our work would be over.

16 Q. You said that you actually worked all through your time in the KP

17 Dom. Were there times that you were not able to go out and work?

18 A. You mean was I sick or something?

19 Q. No. That nobody went out. Were there times that nobody would go

20 out for work?

21 A. Yes, there were such periods. I think there was one, two, or

22 three, or perhaps even more than that. I can't remember. We would

23 usually know when there was mobilisation, a state of alert, or something,

24 probably when there was fighting around Gorazde, outside Foca. When there

25 were bigger wars going on, then they would lock us up and wouldn't let us

1 go out and work.

2 Q. Do you know who made this decision that you couldn't go out for

3 work?

4 A. I have no written proof, but I have proof from the guards, when I

5 asked the guards what's going on, and they said there's a big offensive

6 against Gorazde and the command issued orders that nobody could go out and

7 work. Guards told me about this. I was somehow on good terms with them

8 and they made statements to that effect to me. Whether they were true or

9 not, that I can't say.

10 Q. During such an alert situation when nobody worked, did you work

11 nevertheless, on one occasion? Do you recall?

12 A. Yes. It so happened, I don't know exactly, but I saw those

13 corpses. Probably the Muslims carried out to slaughter, massacre,

14 somewhere in Ustikolina, and they brought them to hospital. And I had not

15 finished some kind of water pipes for the heating between the two

16 buildings. Then there was a state of alert and they called me to finish

17 that, and when I came down to the hall, the same Rasevic said to me -- no.

18 I think it was Relja Golijanin and not Rasevic. I'm sorry. That they

19 should call the command to ask whether they should give me permission to

20 go and finish that. I came back to the iron gate and I waited there, and

21 after I don't know how much time, Golijanin came back and said that they

22 got permission, and he went up to Mr. Krnojelac's to see. And I went to

23 work.

24 Q. You said that he went up to Mr. Krnojelac's to see. What do you

25 mean? What did he say to you, Mr. Golijanin?

1 A. He said to me? He said to me, as far as I can remember, "I'm

2 going to the warden to see because the command has forbidden people to go

3 out and work. I'm going to see with him whether you can go and finish

4 this part of the hospital," the one I was supposed to do, that is.

5 Q. When he returned, did Mr. Golijanin -- when he returned, did he

6 say anything to you?

7 A. Well, he did. He called me and, and some Davidovic came from the

8 hospital, one who would drive me to the hospital. He said that he had

9 received permission from the command that I could go out and work, that he

10 got permission, right.

11 Q. Yes. Relja Golijanin, you mentioned that he was your supervisor?

12 A. Golijanin.

13 Q. Golijanin. Sorry. You mentioned that he was your supervisor.

14 Did you get all your tasks from him?

15 A. Throughout my stay he was my supervisor, and I got it from him.

16 From time to time he would tell me -- well, I had a special job. I mean,

17 I was a welder and I had these oxygen bottles and they were very scarce,

18 so they had to be taken care of. And sometimes these wardens --

19 THE INTERPRETER: Interpreter's mistake.

20 A. -- guards would come and they would ask for me to do something for

21 them using these oxygen bottles. Then he said to me, "I cannot turn

22 anyone down, you know." When he would be away for two or three days, he

23 would say, "You are not allowed to weld anything without me. Only the

24 warden and I can give you orders, nobody else."

25 Q. Did the warden give you orders in relation to welding?

1 A. I remember once that I was supposed to do something, I don't know

2 what, and I said that to the guard. I said that I wouldn't do that. I

3 mean, it's not that I would not do it, but I don't dare do it, because I

4 would suffer consequences, that that is what Golijanin told me. And he

5 went to the warden's. That's what I called him. And then the warden once

6 came to the metalwork shop. He said, "Lija, you can do that."

7 Q. When did this happen that the warden came to you and said, "Lija,

8 you can do that"? Can you place it in a time?

9 A. Well, it could be 1993 or perhaps the end of 1992. Sometime

10 during that period.

11 Q. Who was the warden?

12 A. I knew that the warden was Krnojelac, but I did not read that

13 anywhere, nor did I see it written anywhere. I personally addressed him

14 that way sometimes, because I would see him and I would usually say,

15 "Warden, what do I do about this? What do I do about that?" And he

16 would say to me, "Ask Relja," or I don't know, "Do what you want," or he

17 would tell me do this or do that.

18 Q. Did anyone from the prison staff ever tell you that Mr. Krnojelac

19 was the warden?

20 A. Well, the guards, when there was something -- well, they'd say

21 warden, but they wouldn't say warden Krnojelac. They would say, "We're

22 going to see the warden," or if they were to have meetings, they would

23 say, "We're going to the warden's." And this same Relja said to me, the

24 warden this, the warden that. As for Mr. Krnojelac, I saw him there often

25 and I was in contact with him. I was certain that he was the warden.

1 Q. You mentioned that you actually worked in various places about the

2 town, and you already mentioned that you worked in the Hotel Zelengora.

3 A. Yes.

4 Q. While you worked in the Hotel Zelengora, did you ever see

5 Mr. Krnojelac there?

6 A. Yes.

7 Q. What was he doing there? Could you see?

8 A. What was he doing? I don't know. But I do know, when I was

9 working on this cauldron that was to be used for cooking, that he came by

10 once. He did not talk much, it seemed, but he nodded and then went to the

11 building, the hotel. But what he was doing there, I can't say.

12 Q. When you worked at the Hotel Zelengora or at other places all over

13 the town, were you guarded?

14 A. 99 per cent. Yes, 99 per cent.

15 Q. Who guarded you?

16 A. Usually I was guarded by guards from the KP Dom. Sometimes -- I

17 mean, once I worked for the military police, and then the military police

18 came. Rasevic was there then, and he asked me whether I knew the

19 policeman and I said I did and then I went to work with this policeman and

20 then the same policeman drove me there and drove me back.

21 Q. You mentioned that you worked for the military police. Where did

22 you work for the military police?

23 A. Well, maybe I didn't express myself right when I said for the

24 military police. In the hotel there was this police. I call them the

25 military police because they were the police. I went there to stack up

1 some sacks for them. I went together with Mr. Ekrem Zekovic. We went

2 there to unload some things. I think it had something to do with food and

3 hygiene. We were unloading this from a truck.

4 Q. Does that mean the military police or police was in the Hotel

5 Zelengora, stationed there?

6 A. I cannot guarantee, but while I was there there were several of

7 them who told me where I should leave these things, where I should unload

8 them. Now, whether they were stationed there or not, I don't know.

9 Q. Were you ever taken to the Velecevo women's prison for work?

10 A. Yes, I went there too.

11 Q. What kind of work did you have to do there?

12 A. Frames for a kiosk, something that had to do with a kiosk.

13 Q. The Velecevo women's prison, for what was it used during the war?

14 A. I don't know what its function was, but I saw quite a few soldiers

15 when I was there. I think it was -- I mean, this is my opinion. This was

16 some kind of a technical platoon or something. I think the military was

17 there. I don't know.

18 Q. Did you have to repair military vehicles when you went to

19 Velecevo?

20 A. Yes, once. I had to fix some kind of screws on a military

21 vehicle. Spica was there, that was his nickname, Radovic. We went to

22 school together. And yes, I think I cut off two or three screws.

23 Q. Was that the only military vehicle that you worked on, or did you

24 work on several?

25 A. Yes. I worked on another occasion, but that was at the KP Dom.

1 Q. When you worked at Velecevo, did you ever see high-ranking

2 military leaders there?

3 A. I think so. I think that's the way it was. While I was up there

4 at the kiosk -- I mean, I knew this Velibor Ostojic, so I think I

5 saw him and Vojo Maksimovic, and Miro Stanic, because I knew this Miro

6 Stanic through the hosiery factory, through the man who was his driver.

7 Actually, he wasn't his driver. He drove a Deutz. I think I saw them

8 together. I mean that's as far as I could know him. I knew Velibor

9 Ostojic. He was a plumpish man. I think I saw him and I think that's the

10 way it was.

11 Q. I had actually asked you if you saw high-ranking military leaders,

12 and you gave their names. Were they military leaders at that time?

13 A. Well, that's a good question, you know, but I was not in the Serb

14 command. But I saw them because I knew them. I knew who these people

15 were. I don't know them. I mean, I was not a commander, a Serb

16 commander. I was not a member of this military command, but we all knew

17 that Velibor Ostojic, Miro Stanic, that they were the top people. Whether

18 they were the real people, that I don't know, but you know, I was in a

19 camp.

20 Q. Did you see Mr. Boro Ivanovic at Velecevo?

21 A. Yes, I think I did.

22 Q. Do you know what position he had in the military, and did you know

23 him from before?

24 A. I knew him from before just like that, just by sight, and

25 sometimes we had contacts perhaps in relation to Godijevno where he was

1 from. I heard, though, and I don't know whether my information was

2 correct, that he had something to do with our exchange. I don't know what

3 his function was, whether he was some kind of a commander or something. I

4 don't know. But I would often see him coming to the KP Dom. Why he came,

5 I don't know.

6 Q. Was he a teacher?

7 A. I think he was. He had something to do with the school. He did

8 teach at the school, but what kind of teacher he was exactly, primary

9 school, secondary school, or something, whether he was a professor, I

10 really don't know.

11 Q. When you saw him at Velecevo or in the KP Dom, what was he

12 wearing? Was he in a uniform?

13 A. He had a camouflage uniform. It was a bit sloppy. It wasn't very

14 tidy.

15 Q. Where else in the town did you work? You have already mentioned

16 now a few locations. Where else did you work? Did you ever work in a

17 grocery store?

18 A. In a shop. Yes, I worked in two shops.

19 Q. What two shops were they?

20 A. I worked in a shop where the glass had been broken. This shop was

21 supposed to be opened. I don't think it had been opened before that, and

22 it was supposed to sell food.

23 Q. Was it a shop related to the KP Dom?

24 A. Well, yes. Before the war this shop was the KP Dom's in part, or

25 I don't know exactly. But before the war the KP Dom farm sold milk,

1 cheese, and then they distributed that. The KP Dom continued delivering

2 milk and such products in shops in Foca.

3 Q. Did you see these shops actually start functioning as a shop later

4 on?

5 A. Well, this is the way it was: I would go to Velecevo for five or

6 six days and I would take the little TAM truck and then we would get milk

7 or rather empty milk bottles from these shops. Since we collected these

8 empty bottles every morning, they probably worked.

9 Q. You mentioned another shop that you worked in. What kind of shop

10 was this? Who was the owner?

11 A. You mean who was the owner during the war or before the war?

12 Q. Both, if you know.

13 A. Well, before the war I think it was Perucica, and after the war I

14 guess the Serb Republic, or perhaps the KP Dom also rented it out. I

15 don't know.

16 Q. Why do you think the KP Dom rented it out? Was there any

17 connection with the KP Dom that you saw?

18 A. Yes, because the KP Dom was involved in agriculture up there at

19 the farm they made their own produce, dairy products, pig and chicken

20 products. We tried to make some kind of shelves and things there so that

21 people could sell this produce and they could make money. How should I

22 know?

23 Q. When did you work in the two shops that you mentioned? Do you

24 recall that?

25 A. Well, that was also June, July.

1 Q. 1992?

2 A. Yes. I think that Aladza was in 1993 and the other one was 1992.

3 Quite a bit of time went by between the two shops in terms of when I was

4 there.

5 Q. You have already mentioned that you worked in the Foca hospital.

6 In which time periods did you work in the Foca hospital? Do you recall

7 that?

8 A. I remember, yes, from 1992 to 1994.

9 Q. Does that mean throughout you went there quite often, then, or

10 what?

11 A. Quite frequently. Maybe if I look at the time I spent there, then

12 it was perhaps four months running, but it was in the period between 1992

13 and 1994, with intervals. It was rather frequent.

14 Q. What kind of work did you do there?

15 A. I mentioned that I was a welder by occupation, so I welded and did

16 all the jobs related to metalwork, everything that had to do with metal

17 jobs.

18 Q. When you went to the hospital for work, did you sometimes take

19 medications from the hospital back to the KP Dom for detainees?

20 A. I had quite a few offers from our inmates, because I used to go

21 down there and they would ask me, "Please bring this or that medicine."

22 And I even carried letters.

23 Q. Were you ever caught while doing that?

24 A. Yes.

25 Q. When was it?

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1 A. Once, I don't know why. Maybe I was stupid or I was under great

2 tension - I didn't want to work any more. I just stopped and said, "I'm

3 not going to work any more, and kill me if you want." And then Relja

4 Golijanin told me to return all the tools or whatever I was issued with,

5 and I said, "I have nothing." And they searched me and they found a

6 letter I was supposed to take to some doctor, a relative of one of the

7 Muslims, [redacted], and the doctor's name was Cele.

8 Q. Were you punished for carrying this letter on you or for refusing

9 to work in any way?

10 A. At the moment when I accepted, I regretted it, that very moment,

11 but it was all done already and I had no choice.

12 Q. I do not really understand your answer. My question was: Were

13 you punished for carrying this letter or for refusing to work in any way,

14 and it says in the English transcript: "At the moment when I accepted it,

15 I regretted it." Can you explain that?

16 A. Had I refused that order, I knew straight away that I was in

17 trouble, and I regretted it because I knew there would be very hard

18 consequences. And this letter Cancar found on me, he took it to Mitar

19 Rasevic or someone else, and I was taken to solitary confinement. And

20 after a while I got out from this solitary confinement, and in this

21 hallway Savo Todovic met me and he said he was aware of what I had said

22 and what I had done.

23 Q. Were you punished afterwards, and if so, through what means? What

24 happened to you?

25 A. From that moment on, I was trying to apologise, and he said,

1 "Lija, do you know that Muslims are foes? Do you know what you're

2 doing?" And he showed that letter to me. Behind me there was [redacted]

3 [redacted] standing - I don't know which one of them - and he asked the

4 question, the same question of this man, and he asked me, did I know what

5 was written in that letter. Then he punished me. He said, "I think 20

6 days of solitary confinement." But I was going to work anyway. I think I

7 actually spent three or four days in solitary confinement and then they

8 released me back to my room and I started working again.

9 Q. Did you ever work on the house of Mr. Krnojelac during your

10 confinement?

11 A. Yes.

12 Q. When?

13 A. Well, do you mean the date while I was at the camp?

14 Q. Approximately. I thought you were thinking about it. How often

15 were you --

16 A. You want me to think about it?

17 Q. No. I thought you were thinking. How often did you work on the

18 house? Do you know how many days all together?

19 A. I think, if I could add it up, it was perhaps 15 to 20 working

20 days, roughly, I would say.

21 Q. Do you know which year it was? Was it in 1992 or later, 1993?

22 A. I worked in 1992, but I also remember that I did some work in 1993

23 as well.

24 Q. In 1992 when you worked there, was it in the summer, autumn, or

25 was it even winter?

1 A. It was in autumn, the end of autumn/the beginning of winter. It

2 was not the fiercest frost, but it wasn't warm either.

3 Q. When you worked on the house, who took you there?

4 A. The guards.

5 Q. Were you the only one working on the house or were other detainees

6 working there together with you?

7 A. I did only metal jobs, which means I made the staircase and the

8 metal railing, the metal jobs involved there. But I saw other people

9 working there as well, doing construction work. However, I worked mostly

10 indoors, because I was making the staircase going from the ground floor

11 upstairs.

12 Q. And do you recall which other detainees worked there? And please

13 use the list in front of you for those who are protected witnesses. Do

14 you recall -- can you tell us the names or the numbers of other detainees

15 who worked there on the same house?

16 A. Together with me, 144 worked with me, and he was tied to me, 163

17 [as interpreted], Telo Mustafa, Telo Aziz, some other people as well. One

18 [redacted] Those were the people who worked.

19 Q. Let me just clarify something. In the transcript it says that 163

20 worked with you. There is no 163 on the list. Is that a mistake?

21 A. There is 162. I cannot see 163 written anywhere. I don't know

22 Q. Yes. It's not. Is it is a mistake in the transcript? Did you

23 say, or did you want to say 162?

24 A. He didn't work with me. Only 144 and 73 worked with me.

25 Q. Okay. Thank you.

1 A. No other people from this list. Maybe he did work, but I didn't

2 see him. I have to explain it a little about this house. I worked

3 indoors. I worked on the interior. On the outside there were other

4 people whom I couldn't see.

5 Q. Yes. Did Mr. Zekovic work with you on the house?

6 A. Yes. Yes. I had forgotten about him. Yes, he did.

7 Q. Who told you what you have to do in the house? Who gave you your

8 jobs?

9 A. When I was supposed to do a job, or this guy under the code-name,

10 who was a locksmith - he had more work to do, because I was a

11 welder - this man under number 144. I would approach Relja Golijanin or

12 Krnojelac's son. And on several occasions I stood there with Krnojelac

13 and discussed with him directly things that were supposed to be done, what

14 should be done and how, because he didn't know much about construction and

15 the frames. But that was usually Relja's job.

16 Q. And when you started to work there for the first time, did you

17 have a discussion about what would have to be done, before you even went

18 there?

19 A. What?

20 Q. Before you started to actually work in the house, did you discuss

21 your job or the job of the other detainees? Was there a kind of a

22 discussion, a broader discussion with the people involved in this?

23 A. I don't understand the question.

24 Q. When you went to the house for the first time, did you already

25 know what you were supposed to do?

1 A. Oh, yes, yes. Because before I would go to Krnojelac's house, I

2 had to prepare my material, and the gentleman under number 144 went,

3 because we worked with iron and pipes. We had to prepare this material,

4 load it onto a car, and take it there.

5 Q. And you said that you got your tasks from Mr. Relja, and you also

6 mentioned that you approached also Mr. Krnojelac's son. When did you

7 approach them, and for what?

8 A. That happened during that time I was working. When you are making

9 a railing or a fence for somebody, it can happen easily that you do the

10 job differently than the client wanted it, and then they say you have to

11 change it. If you see that Krnojelac is around, you can say, "I have to

12 change this. May I do it this way?" Or if Relja was there, I would talk

13 to him. So in any case, you have to talk to an authorised person. If I

14 was working on Krnojelac's house, then I thought his son was a person I

15 could speak to, authorised, because there might be obstacles later.

16 Q. How often was Mr. Krnojelac's son at the work site?

17 A. During my stay, I know about this Dubravko or Jadranko. I keep

18 confusing this. I talked to this man often, because we were friends, and

19 I was glad to see him. He was often there. He was a policeman. He would

20 take a walk around and then come by.

21 Q. And was there another son as well on the work site that you could

22 approach?

23 A. Yes. I saw another one. I don't know whether he was the second

24 or third son. I hadn't known him before, but he was pointed out to me and

25 I was told that this was one of the warden's sons. Yes, he was there.

1 Q. And did you also approach him when something had to be clarified?

2 A. [redacted]approached him instead, but I was present and I

3 had a discussion with him.

4 Q. How often did Mr. Krnojelac come to the work site?

5 A. He would come by together with Rasevic during the day. He and

6 Rasevic would take off somewhere and then they would pass by the house,

7 take a tour. Several days would pass without my seeing him and then he

8 would come several times during one day. There was no rule.

9 Q. And did you approach him also and talk with him about how to do

10 the work?

11 A. I think I've just said that we had talked before we started. We

12 discussed this work and we were giving him some suggestion, because

13 Mr. Krnojelac had no clue about this metal staircase and about the

14 construction, and he was asking us why things should be done in the way we

15 were suggesting, et cetera, and then he would often come by to see how we

16 were doing. And there was his wife as well. She would come by too.

17 Q. When you worked on the house of Mr. Krnojelac, did you go back to

18 the KP Dom for the meals, especially this snack?

19 A. No, we didn't. We would take our breakfast usually in the morning

20 and we received our food directly from the cook [as interpreted]. I once

21 asked whether he had cooked it or whether it had been brought from

22 somewhere. In any case, I know it was not KP Dom food.

23 Q. You said you received -- "We received our food directly from the

24 cook." What cook? What cook do you mean?

25 A. What do you mean, "cook"?

1 Q. I can only read what is in the English -- what I heard. It says

2 in the transcript: "We would take our breakfast usually in the morning

3 and we received our food directly from the cook."

4 THE INTERPRETER: Interpreter's mistake. It seems to be a hot

5 meal. I misheard.

6 A. It must be a mistake of some sort. We received food, meals, from

7 his sons. They brought us food directly to this house, and it was not

8 food from the KP Dom. Other people, not me, would sometimes even have a

9 brandy with them. I don't want to defend anyone, but at that moment food

10 was much, much better than at the KP Dom. I don't know why was that, but

11 in any case, we were pleased, and we preferred eating there at that house

12 than at the KP Dom, because the food at the KP Dom was bland, completely.

13 Maybe somebody misheard me. Maybe I meant the cook who had prepared the

14 meal or something.

15 Q. Yes. Thank you. That clarifies the matter. Thank you.

16 Did you have to work for Mr. Krnojelac or his son in any other

17 place than the house?

18 A. Yes. I was making some sort of shelves in the metalwork shop for

19 this son who had an accident. He was supposed to open a shop where the

20 Planika shop used to be, and I was making these shelves so that this man,

21 this other man, would take them there to install them. I was doing my job

22 down at the metalwork shop and I was told that it was for his son. I

23 don't know whether that's correct or not.

24 Q. Did you work on another work site related to the son who had the

25 accident?

1 A. I didn't work, but once I went there to collect some paint, I

2 think it was. It was Fehim Dedovic who did the paint job, and he

3 personally told me that this work was being done for his son, who was

4 disabled, that this apartment had been allocated to his son. And it had

5 belonged to some Fadila, I believe he was a gynaecologist who had worked

6 at the hospital. Sorry. It's not Fadila. It's Tafro.

7 Q. The former owner of the apartment, was he a Muslim?

8 A. I think he was.

9 Q. Did you actually see the handicapped son in this apartment

10 when you went there to pick up paint?

11 A. Yes, I did see him up there, but when you ask me those things, you

12 should understand: It's not that I really saw him. It was just a quick

13 glance in passing. I was not interested. I was going about my business.

14 But I did see him very quickly. I entered a corridor. There was a door

15 open there. I saw him and I continued on my way. If somebody told me

16 now that I was supposed to confirm an oath that it was him, I could hardly

17 do it. It was just a passing glance. I can hardly claim with 100 per

18 cent certainty that it was him.

19 Q. What kind of handicap did he have?

20 A. I heard on one occasion, I believe it was Krnojelac himself who

21 told me, that he had lost both his legs when he stepped on a mine.

22 Q. Do you know when Mr. Krnojelac told you this?

23 A. Well, Krnojelac must remember. He was supposed to make some sort

24 of device for his child, for this son to exercise his arms, and he was at

25 the metalwork shop. That's probably where we met. I was doing some job.

1 And there was another man, Muhamed, who was speaking to him, and I was

2 just present there. That was some kind of device for exercise. I think

3 it was in 1993. You know, it's very hard when you're asking me about

4 dates. I got things sorted out between 1992 and 1993, and I can

5 distinguish between the years which were hardest for me and those which

6 were less hard. Otherwise I cannot be much more precise than that.

7 Q. You mentioned that Mr. Krnojelac made this remark probably in the

8 metalwork shop when this exercise machine was made. Did he come often to

9 the -- no? Did he come often to the metalwork shop? Did you see Mr.

10 Krnojelac often in the workshop?

11 A. Well, I'm telling you: I saw him almost every day. Perhaps not

12 every day, but at least two or three times a week because there were cars

13 about. In any case, I saw him often.

14 Q. When you saw him either in the metal shop or on the work sites

15 where you met him, how did he behave towards you? How did he treat you?

16 A. Well, as regards some guards, they could get a passing grade. As

17 for others, he was decent towards me, but I didn't notice how he treated

18 others. But for instance, when he was walking about, his face was not

19 very -- was not very kind, so to speak. He didn't exactly invite people

20 to address him. And people -- he came across as angry, sort of. People

21 tried to avoid him.

22 Q. You have already mentioned that you had several talks with

23 Mr. Krnojelac and you addressed him as warden when you did so. Did you

24 ever speak with him about the beatings and the disappearances in the KP

25 Dom?

1 A. Yes. On one occasion I asked him why I wasn't being exchanged,

2 and I was telling him that the people who were locked up there were

3 innocent. I said something like, "None of the people who are locked up

4 here had been on the front line or in combat." He said, "I don't decide

5 about such things." He said, tongue in cheek, "Lija, it's not me who

6 locked you up." He said, "There were other people who decided such

7 things," or he would say on a different occasion, "It's the command who is

8 deciding." He said on one occasion, "Lija, I didn't lock you up," and

9 something like, "I'm not the one to blame for this." I think he said,

10 "There are other people," or maybe he said, "There is the command."

11 Q. It's difficult, but how often did you have such a conversation

12 with him, and where and when? Was it only once?

13 A. There was another occasion, and that ties in with my previous

14 story. Krnojelac came by with Savo Todovic and I believe Rasevic was

15 there as well, and they were going up there to the garage where Hamdo was

16 working. And I approached them. I said I couldn't work any more. I

17 was ravenous, I was going to faint. I told them how hard the work was on

18 unloading. He turned away angrily and he brought me two slices of bread

19 and he proffered them to me, saying, "I'm giving you this one and the

20 commander is giving you the other one. That's all I can do to help you."

21 I don't know what else happened, but that's approximately how it

22 was that time. I don't think we made any further comments or that we

23 discussed it any more.

24 MS. UERTZ-RETZLAFF: Your Honour, the time has come.

25 JUDGE HUNT: We'll resume at 2.30.

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1 --- On resuming at 2.30 p.m.

2 JUDGE HUNT: Ms. Uertz-Retzlaff.

3 MS. UERTZ-RETZLAFF: Thank you, Your Honour.

4 Q. Mr. Lisica, before the break you described to us two conversations

5 that you had with Mr. Krnojelac, and you mentioned the first conversation

6 where you asked him if you could be exchanged, and where he mentioned that

7 he was not the one to make this decision. Do you know when this

8 conversation took place?

9 A. The end of 1992/beginning of 1993. Three, yes.

10 Q. Where did it take place? Where were you?

11 A. I think it could have been at the mechanic's shop, the metalwork

12 shop, as it was called. Or it could have been at the farm. Wait a

13 second. Wait a second. Let me think now. Wait. I think it was at the

14 metalwork shop, after all.

15 Q. This other conversation where he gave you two slices of bread, you

16 said that he was, he and Mr. Rasevic and Mr. Todovic were going up there

17 to the garage where number 249 worked. Do you mean within this compound

18 where the metal shop was? Do you mean this garage, or where?

19 A. Yes. Yes. Yes. I mean if you have a drawing here, the metalwork

20 shop was like right in front of the KP Dom, whereas the mechanic's garage

21 was a bit further off. And all of that belongs to the same compound.

22 Now, that could have been between the garage and the metalwork shop, but

23 that is all one entity. I tried to be a bit more precise. That's why I'm

24 putting it this way.

25 MS. UERTZ-RETZLAFF: With the help of the usher, I would like to

1 show the witness Exhibit 6, the entire plan of the KP Dom compound.

2 Q. Mr. Lisica, can you point out the metalwork shop where you usually

3 worked and the garage that you spoke about?

4 A. I worked here. The heating room, the metalwork shop, and then all

5 of this is sort of the metal complex. And the car mechanic's shop here

6 belongs to that too. I'm pointing it out to you right now with this

7 pointer. The story I told you might have taken place here where this

8 little sign is. I don't know what this little sign means, but it could

9 have been in this area. I don't know what this is. Is it something

10 crossed out or something? It's probably a toilet. I think the toilet was

11 there. The toilet was somewhere around here, so it could have happened

12 here, in this area.

13 MS. UERTZ-RETZLAFF: Your Honour, the witness was indicating first

14 showing his workplace and he was showing the boiler room, which is

15 indicated as the boiler room in the plan, the metal shop in the middle

16 and the metal shop next to the river. And he was referring to the garage

17 he mentioned. He pointed to the auto mechanic's shop at the end of the

18 compound, at the left end of the compound. For the place of the

19 conversation, he pointed at this little square spot between the metalwork

20 shop and the auto mechanic's shop. And I can't really read it on this

21 small plan that I have if there is a toilet indicated in there, but it

22 should be visible from the huge version. I can't read it.

23 JUDGE HUNT: We can agree that it's the cross -- it's the square

24 with the cross in it.

25 MS. UERTZ-RETZLAFF: Yes. Yes, Your Honour. Thank you.

1 Q. You mentioned --

2 MS. UERTZ-RETZLAFF: Thank you. It's enough with this map.

3 Q. You mentioned that you -- when you had this second

4 conversation. When was it? Was it after the first one or earlier?

5 A. This other conversation I had, I don't know whether I told you

6 about it. There were several conversations. But then I had this one

7 conversation by way of a joke, at the farm. And the other conversation

8 was after this, when I talked about the exchange. When I talked about the

9 exchange, that was -- I mean, we talked about this first thing and then

10 this second one could have been a month, a month and a half later, 30 or

11 40 days later.

12 Q. The first one, was it the discussion about the exchange or this

13 incident where he gave you two pieces of bread? What was first?

14 A. The first conversation had to do with bread and hunger. The other

15 conversation had to do with the exchange. And the third conversation, I

16 don't know whether it was a conversation -- well, it wasn't that I joked

17 with him. It was just like that. I was sort of relaxed. I really wonder

18 why.

19 Q. You said this first conversation was about hunger, and you told us

20 already in relation to this conversation that you told Mr. Krnojelac that

21 were you going to faint. Did you actually speak about being hungry?

22 A. Well, okay. I wasn't fainting. I mean, I was just pretending

23 because of him. But I was hungry. In all fairness, I was hungry. But

24 it's not that I fainted or anything. I just pretended that I would faint

25 so that I would get more food. I wasn't getting much food, no I was not.

1 Nobody was.

2 Q. What exactly did you tell him? Did you complain about the small

3 rations you got?

4 A. I said specifically Zeka was there and others, I think. I also

5 think Mr. 144 was there too. I was cutting some boards for Maglic. And

6 then I stopped him. I was doing this outdoors. I was doing it outdoors.

7 And as I was working I saw them coming from up there, and then I turned

8 off the tool and I said that I was hungry and that I wasn't getting enough

9 food and that I couldn't do this and that also these gases were harmful

10 and that welders would get milk and things like that, something in that

11 sense. Do you want me to repeat everything I talked about?

12 Q. Oh, yes. Sorry. Yes, please. What else did you tell him? Yes.

13 A. I just said that. I asked for meals to be increased, that he

14 should give me more to eat, and that was it, more or less.

15 Q. As a result -- as his answer, in addition to what you have already

16 told us, do you recall anything else?

17 A. Well, wait a second. I don't know what he answered me. Maybe he

18 remembers. I know that he turned around and that he brought two slices of

19 bread. One was thicker and the other one was thinner. And it was also

20 mentioned how many slices of bread were cut, that the command ordered 15

21 slices to be cut from one loaf of bread, and he was cutting 12 slices.

22 And he was a bit upset. He was a bit angry. He said, "What more can I

23 do?" And at that time when I would talk to him, I wouldn't dare say all

24 the things I wanted to say. Because I tried to say everything but without

25 any expense to me, so to speak. So that was the content of it, more or

1 less.

2 MR. BAKRAC: [Interpretation] Your Honour --

3 JUDGE HUNT: Yes.

4 MR. BAKRAC: [Interpretation] It seems to me that this has not been

5 interpreted properly. The witness said, "I cannot help you with that."

6 And in line 18 it says, "What can I do about it? What more can I do?

7 What more can I do?" And the witness said, "I can't help you any."

8 A. Yes. Yes. I said something like that.

9 JUDGE HUNT: Well, you've got it recorded now.

10 MS. UERTZ-RETZLAFF: Yes.

11 Q. You mentioned that you also had a third conversation with

12 Mr. Krnojelac or a joke. You said on the Brioni farm. Did you have to

13 work on the farm?

14 A. We already said that once, whether I had to work. Of course I had

15 to work, because I was in a camp. You asked me whether I volunteered.

16 Yes, I had to work.

17 Q. Wait. Wait. I wanted to know what kind of work did you have to

18 do at the farm and how often did you work there?

19 A. Excellent. Excellent. I went quite often. My task was to make

20 these boxes for pigs, where pigs were kept. Pigs tend to break these up

21 when they walk about. Then also chicken coops. When chicken coops would

22 break, then I was supposed to weld them together. Everything that was

23 made of metal at the farm, like fences, gates, things like that.

24 Q. How often did you see Mr. Krnojelac at the farm when you worked

25 there? Only one time or more often?

1 A. I saw him several times.

2 Q. What was he doing there?

3 A. I don't know what he did. Sometimes he came with civilians. I

4 did not know. He would walk around with them. Then sometimes he would

5 come with Rasevic, sometimes he came with Savo, sometimes he came on his

6 own. What he did, he walked around toward the place. I don't know. I

7 didn't ask him what he did there.

8 Q. Did you see him with soldiers there or officers even?

9 A. Well, during my stay, while I was there, I actually did not see

10 any big officers coming there anyway. They probably didn't come there at

11 all. I don't know. I didn't see any. There were soldiers; that's true.

12 But that there were some big and important people, no, I didn't see

13 anybody like that.

14 I don't know about these civilians, when they were

15 walking around with him in civilian clothes. I didn't really pay that

16 much attention. While I'm working, while I'm doing my job, I would look

17 up and I would see him walking with someone. And it wasn't that you could

18 dare stop all together and look and see what they were doing. You could

19 just barely glance.

20 Q. You said on one occasion you spoke with him at the farm. What was

21 it?

22 A. The farm is an area where the pig area was down, much lower. The

23 Serbs at the time did not have enough food for pigs. They gave them

24 apples. That means that it was autumn time. So they mixed these apples

25 with bran and I was standing there. I don't know whether it was break

1 time or whatever, so I was eating apples or rather looking at them because

2 I wanted to get some of the better apples to take them with me. I said

3 that, "There were pigs that weren't even touched by Muslims for a year and

4 what do they do here? They feed apples to the pigs." I think he just

5 laughed at that and that's the way it was

6 Q. When you worked in the metalwork shop, did you have to service

7 cars and vehicles of the KP Dom?

8 A. Yes. Yes. What do you mean, service.

9 Q. That is what I want to ask you. What did you do with the cars or

10 with the vehicles? What were the tasks you had in relation to cars and

11 other vehicles?

12 A. I worked as a welder before at the service shop, and I serviced

13 trucks and vehicles in general. I was the one who helped mechanics and

14 locksmiths. When a car would have a crash, an accident, when the exhaust

15 pipe would break down, to cut screws, and then sometimes I would work a

16 bit as a mechanic if I didn't have enough work as a welder. So even at

17 that garage I worked a bit as a mechanic.

18 Q. Did the KP Dom have a small delivery truck, a Kedi?

19 A. Yes. At first, as far as I know, because there was a warehouse

20 underneath number 11, it was used for this food produce.

21 Q. What kind of a car was it? Can you tell us which brand it was?

22 A. It was a Zastava 101. Instead of a back seat, it had sort of a

23 big trunk.

24 Q. Did this car have a particular noisy exhaust pipe?

25 A. It didn't have anything special. It didn't have anything special,

1 if you are referring to something special. However, it just had an

2 exhaust pipe that wasn't good. It had a hole on it, so then the exhaust

3 fumes were not regulated properly, so the sound was very loud.

4 Q. Did you ever see bloodstains in this particular Kedi?

5 A. Yes, once, in the back, Zeka and I were there. I saw stains on

6 the bottom, on the floor, and on the sides.

7 Q. When was -- when did you see that?

8 A. You mean which month, year?

9 Q. Yes. Which month, year, and what time of the day?

10 A. It could have been approximately the month of July or August,

11 mid-July/beginning of August. I'm not sure. And it was approximately in

12 the morning, say around 9.00 or 10.00.

13 Q. Where was it parked when you saw it? Would you be able to point

14 it out on the map that you just had in front of you?

15 A. Yes.

16 MS. UERTZ-RETZLAFF: With the help of the usher, could the same

17 plan be shown.

18 A. [Indicates]

19 MS. UERTZ-RETZLAFF: The witness is pointing at a space in front

20 of the metalwork shop, close to the Drina River, and he is pointing in the

21 middle, approximately in the middle of this metalwork shop.

22 Yes. Thank you.

23 Q. Did you actually have to clean this car on that same day?

24 A. When I finished the partitions that I was doing in the isolation

25 cells, I had to take my tools there, so as I was taking the tools I had to

1 see that. And then I came back. Zeka was taken back to the room and I

2 returned to the metalwork shop by myself because I had to leave my tools

3 because we had finished our work. Then somebody said to me there, I don't

4 know who it was, a guard, and he said, "Lija, why don't you wash this,

5 and then there's a toilet nearby, perhaps I can show it to you. I think

6 it should be around here, right around here, the toilet." And then I took

7 a hose and I washed this and then I went inside to the KP Dom, to the

8 rooms there.

9 MS. UERTZ-RETZLAFF: Your Honour, actually, I couldn't see where

10 the witness was pointing at because I had to switch and I was too slow.

11 Q. Can you please point out where you got the water from?

12 A. [Indicates]

13 Q. You mentioned that you got a hose.

14 A. Here, where the toilet is. This is actually the metalwork shop,

15 and behind it was a toilet, and there was water there too. I don't know

16 whether this has been drawn precisely, but at any rate, it's in this

17 area. It's in this area. I often used this water, and there was a hose

18 there too.

19 MS. UERTZ-RETZLAFF: Yes. Your Honour, the witness was pointing

20 at the left end of the building that is marked as the metal shop close to

21 the Drina River.

22 JUDGE HUNT: Thank you.

23 MS. UERTZ-RETZLAFF:

24 Q. Can you describe to us the sights of the bloodstains you saw and

25 where they were within the car

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1 A. It was a stain roughly in the middle of this Kedi, of the trunk

2 there, perhaps between 10 and 12 centimetres. That was the diameter. It

3 wasn't round, actually. It wasn't -- it was sort of like this. And then

4 it's on the left side or on the right side, if you look at it from the

5 back, then on the right side. Yes, on the right side. The stain was

6 there. It was like light red. I'm not saying anything. Well, that's the

7 way it was. Well, like this big.

8 MS. UERTZ-RETZLAFF: The witness was pointing in front of him in a

9 circle, which was about 20 centimetres.

10 Q. Can you show it again?

11 A. Yes, okay. Perhaps this big. This big. I mean, you know,

13 Q. And how much inches? I have difficulty to say how many inches?

14 A. Okay. Seven or 8 inches. Perhaps 7 or 8 inches. I don't know.

15 You can measure it.

16 JUDGE HUNT: Some of us are still impaired by imperial

17 measurements, I'm afraid.

18 MS. UERTZ-RETZLAFF:

19 Q. Was it just this one bloodstain or was it -- did you see blood in

20 other parts of this Kedi?

21 A. I told you, on the side, on the side, on the left and right side.

22 But these are not such stains. They are smaller stains.

23 Q. Did you see anything else in the Kedi had you cleaned it? Was

24 there something else besides the bloodstains?

25 A. Yes. Up in the corner there was a wire that had been on fire.

1 And nothing else, I think. Oh, yes. There was a basket too, I think, and

2 also this burned wire.

3 Q. This burned wire, is it a particular sort of wire or was the wire

4 burnt, burnt by fire? I'm just -- I don't really understand what you

5 mean. Burnt wire, is that something particular, technical?

6 A. In our language, burned wire means that it's a flexible wire, that

7 you can't break it. It was used to tie things up in construction. It was

8 good for that, for tying things up in construction, and we call it burned

9 wire.

10 Q. Did the guard who told you to wash the car, did he say anything

11 about the bloodstains?

12 A. No, he didn't. How should I put this? When I took care of all

13 this, he came up, he saw it, and he thought of telling me that, and I

14 washed it and that was it.

15 Q. Did you also have to service the warden's car?

16 A. Yes, I did. Several times I cleaned his vehicle. I think it was

17 a Yugo 45 or 55. It was red. Not exactly red, reddish. The colour is a

18 bit strange. Yes, it was there often, and sometimes I'd bring it to the

19 metalwork shop and wash it there. And then there was a Serb who I called

20 Glavonja and he brought it. And once I think the warden himself brought

21 it and left it there.

22 Q. The Yugo car, what kind of a car is it? Does it have a particular

23 brand?

24 A. It's actually a Zastava vehicle. One was called a Yugo 45,

25 another one was called a Yugo 55 and then there was a Zastava 101. But at

1 any rate, it was Zastava made.

2 Q. How do you know that it was the warden's car?

3 A. I don't know how come I know, but I know that I saw him driving it

4 often and I know that this Glavonja who brought me the car, he told

5 "Lija, clean the warden's car now." I don't know whether it was his

6 car. I mean, that was the impression I had. It's not that I have any

7 documentation. He personally, Glavonja said to me -- once I also think

8 that the warden, Krnojelac, came there and left it there, because I saw

9 him in it often.

10 Q. This Serb, Glavonja, was he a staff member?

11 A. Yes. He was a worker at the KP Dom. He issued fuel to drivers

12 for trucks of the KP Dom. So I would go and help him pour the fuel also

13 into this Yugo with a pump. Glavonja was my nickname for him, but I never

14 knew in my life what his name and surname were.

15 Q. How often did you actually service the warden's car?

16 A. Well, it would happen that for some reason, on some days, when no

17 one worked, they would take me out and give me this car and I would clean

18 it for a long, long time, because it was nicer for me than to sit up in

19 the room. I could pinch something, steal something, you know.

20 Q. What would you steal?

21 A. It had to do with tobacco, tobacco, cigarettes. Sorry. I didn't

22 mean steal. I mean, they would leave me on my own, so I would have the

23 chance of looking around and taking some tobacco from some room. I mean,

24 it all had to do with tobacco.

25 Q. Did you continue to see this car or service this car after

1 Mr. Krnojelac was replaced by a new warden?

2 A. Well, I think I didn't.

3 Q. Besides the workshop, did you work in other areas within the KP

4 Dom? You have already mentioned that you had some work to do in the

5 isolation cell. Where else did you work within the KP Dom compound?

6 A. I worked all over the KP Dom, in all the rooms at the KP Dom where

7 there were any pipes or water pipes. I worked everywhere, in all of those

8 places. From the roof down, including entrance doors, offices. I think I

9 worked in 95 per cent of all the premises of the KP Dom.

10 Q. Did you ever work in the warden's office?

11 A. Yes, I did. Two or three times.

12 Q. Where was it within the building? On which floor was it?

13 A. What do you mean, in the building?

14 Q. In the administration building, on which floor was the warden's

15 office?

16 A. Yes. Yes. Well, let me see how many floors there were. I think

17 it was the second floor. It was along the corridor. You go straight,

18 then you go upstairs, then you go through the back door into that

19 building. I think there are no more offices or doors after that.

20 MS. UERTZ-RETZLAFF: With the help of the usher I would like to

21 show the witness Exhibit 6/3. It's a plan of the second floor of the

22 administration building.

23 Q. Can you point -- yes.

24 MS. UERTZ-RETZLAFF: The witness is pointing at the warden's

25 office, the room that --

1 A. This is the corridor.

2 Q. The room next to the entrance to the KP Dom, right-hand side.

3 Yes. Thank you.

4 In which period -- thank you. In which period did you work in

5 this room? Do you recall?

6 A. Due to that wartime system, the KP Dom building was heated through

7 the steam aggregate, steam pipeline, and they provided heating for

8 themselves in the winter. It was end 1992, beginning of 1993 I had to

9 clean the chimneys because they were dirty, and I had to install a furnace

10 into that room.

11 Q. The KP Dom, did it not have a central heating system? You had

12 pointed out to us previously the boiler room.

13 A. I think you didn't quite understand me. I said that when the

14 boiler room stopped working, because it was broken, and in 1992 it wasn't

15 operational. It used to work before. And the chimneys, which I cleaned,

16 hadn't been cleaned for 20 years, because the steam pipe hadn't worked for

17 the previous 20 years. It wasn't working at the moment, in December, and

18 before that it was in operation; it was being used.

19 Q. And how, then, was the administration building kept warm at that

20 time when you worked there? What did they use? I didn't really

21 understand the system. Did they have stoves in each room or how was it

22 kept warm?

23 A. Maybe I can make it clearer like this: In 1990, 1991, and 1992,

24 there was a central heating. In end 1992, there was no central heating,

25 because the system, the heating system, was broken, because the boiler

1 room was not operational; it was broken. So they used firewood and coal.

2 And I had to clean out the chimneys, which hadn't worked for ages, and

3 they put furnaces into their offices to keep warm.

4 Q. What about the prisoners' rooms? Did you have to prepare them as

5 well? Did you put stoves in there and clean the chimneys?

6 A. Let me see. I think in 1993 and 1994 we had heating, while in

7 1992, December 1992, and then January 1993, we didn't have any heating, so

8 we had heating after October 1993.

9 Q. In 1992, when you made these furnaces for the administration

10 building, could you have as well made furnaces for the prisoners' rooms?

11 A. I don't think we could.

12 Q. Why not?

13 A. How do I know? I don't know.

14 Q. Was material available? Could you have done that if you were

15 ordered to do so?

16 A. I did that in 1993.

17 Q. Could you have done that in 1992 as well if someone had

18 ordered you to do so?

19 A. Well, if I did it in 1993, why couldn't I have done it in 1992?

20 Q. You said that you worked in Mr. Krnojelac's office. Was he ever

21 in the office when you worked there?

22 A. He stood there once. He was looking for something in his -- on

23 his shelf. And then I was working in the room next to his. He was there

24 in the room, but not all the time. He would leave occasionally. And

25 while we were doing our jobs in those offices, not only the warden's

1 office, but also the ones next door, they moved around. They would come

2 and go. He stood there for a while, then he went elsewhere.

3 Q. Did you ever see lists related to detainees on his desk?

4 A. I didn't see any about prisoners, but I once saw a paper with my

5 name on it on the desk. I couldn't see much really. While I was standing

6 there I just peeked at it. I could see my name. It was the fourth from

7 the top on a list. It was just lying on the table like this sheet is now

8 lying here. That's all I know.

9 Q. How many names were on this sheet of paper? Do you recall? You

10 said yours was the fourth name.

11 A. Well, it's difficult to make any conclusions now. I didn't count

12 then. I didn't read much, because I didn't dare. I just glanced at it.

13 And in my estimate, there were about ten, a dozen names, judging by the

14 number of lines.

15 Q. Were you present when this sheet of paper with the names on it was

16 actually given to Mr. Krnojelac?

17 A. You mean that paper specifically?

18 Q. Yes.

19 A. I think once, and I think it was on that occasion precisely, Savo

20 Todovic and Krnojelac were both there sitting in adjacent offices, and

21 they were moving around, coming and going. They were handing those

22 papers, and it's difficult it say definitively whether it was this paper

23 or not. I can hardly say with any certainty. I came here to tell the

24 truth and I'm afraid to tale lie if I venture a guess. Maybe it was that

25 paper, maybe it wasn't. Because he had lots of those on his desk. They

1 were just lying around.

2 Q. Did you hear any conversation between Mr. Todovic and

3 Mr. Krnojelac in relation to papers on the desk or that Mr. Todovic had?

4 A. I cannot recall at the moment that I had any conversation related

5 to that. Maybe I did hear it, but I cannot recall now. I don't think I

6 did, though.

7 Q. While you worked outside the KP Dom compound, did you ever see

8 bodies in the Drina River in front of the KP Dom-? Do you recall

9 anything?

10 A. Yes, once. I went there with this Arso, Krnojelac's brother. He

11 was with me. I was pushing this machine. I think Zeka and I were

12 together. That is outside the KP Dom, on the road towards the hospital.

13 There were some old vehicles and trailers there on that lot we were

14 supposed to take some parts of for our purposes. And while we were going

15 there, there is like an island or something, and I saw some clothes

16 floating. And Zeko told me just before, "Look at those corpses over

17 there." And I looked and I saw a body indeed.

18 Q. But you did not recognise who it was; is that right?

19 A. No way. I couldn't know. I didn't come close. It was at a

20 distance of about 10, 15 metres from the place where I was standing and

21 where I was doing my job. You could see it was a corpse, but you couldn't

22 recognise it.

23 Q. When did you see that? Which year was it, and which month, if you

24 can say?

25 A. All of that was somewhere in the period from early July to the

1 15th of August, or perhaps the beginning of July, the beginning of

2 August. I think it was in July. I want you to know when you're asking

3 questions like this, I've told you this already: Years 1992 and 1993

4 blended in my mind into one year, and I cannot say, otherwise very

5 roughly, when things happened. It could have been June, it could have

6 been July, but it's certainly not May and it's not September either.

7 Q. When you say "June," "July," is that 1992 or 1993?

8 A. 1992.

9 Q. I just want to read something. Do you recall that you gave a

10 statement to the Prosecutor's office in 1999? Do you recall?

11 A. Yes, please. Go ahead. I hope I'll remember.

12 MS. UERTZ-RETZLAFF: Your Honour, I will now read from page 9,

13 paragraph 3 of the document number 318/A of the trial binders, and in the

14 B/C/S version it's also page 9 and it is paragraph 4 -- no, not 4. This

15 one. Five. It's paragraph 5. Sorry.

16 JUDGE HUNT: Thank you.

17 MS. UERTZ-RETZLAFF:

18 Q. "On one occasion in either October or November, 1992, I had to

19 clean the steam heating in Krnojelac's office. Ekrem Zekovic or

20 Maljanovic or the worker Berberkic were working with me. I'm not sure who

21 of the three were working with me on this occasion. While we were working

22 in Krnojelac's office, Todovic came in with a list. He presented the list

23 to Krnojelac and said that the detainees on this list should be taken out.

24 Krnojelac looked at the list, obviously checking and considering. Because

25 we left the room immediately after this, we could not hear if Krnojelac

1 approved the taking."

2 Do you recall this?

3 A. Could you repeat this, please, once again?

4 Q. "On one occasion in either October or November" -- would it

5 help you to read it yourself? I can also put the document in front of you

6 so that you can read this paragraph yourself. Would it help you more?

7 A. You can read it to me. I'll listen.

8 Q. "On one occasion in either October or November 1992, I had to

9 clean the steam heating in Krnojelac's office. Ekrem Zekovic or

10 Maljanovic or the worker Berberkic were working with me. I'm not sure who

11 of the three were working with me on this occasion. While we were working

12 in Krnojelac's office, Todovic came in with a list. He presented the list

13 to Krnojelac and said that the detainees on this list should be taken out.

14 Krnojelac looked at the list, obviously checking and considering. Because

15 we left immediately after this, we could not hear if Krnojelac approved

16 the taking."

17 A. I'd like to have it in front of me and read it.

18 MS. UERTZ-RETZLAFF: The witness has been given page 9 in the

19 B/C/S version, and the paragraph is indicated to him by just a little

20 mark.

21 A. What's written here, on one occasion in either October or November

22 1992, I had to clean the steam heating in Krnojelac's office," that's not

23 true, because I was cleaning the chimneys.

24 Well, it says here, "Berberkic," I'm not sure who of the three

25 were working with me on this occasion. I would correct this. I think I

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1 don't know that I ever gave this statement. I know that Savo Todovic had

2 papers all the time and that he was handing them over to Krnojelac, but I

3 don't know about this for prisoners, that prisoners should be taken out.

4 Maybe I did say this, but I would like to correct this part. Maybe it was

5 a misunderstanding due to interpretation or I used a different expression,

6 I put it differently. I don't know. It's true that he had a look at the

7 list, because Savo Todovic carried his bag like this, under his arm, and

8 he contacted with Krnojelac all the time and he would hand him papers.

9 That much is true. But I don't know about what's written here. "He

10 presented the list to Krnojelac and said that the detainees on the list

11 should be taken ..." First of all, I would never use the word "detainee."

12 I would have said Muslims or inmates.

13 Q. Yes. Okay.

14 A. I cannot tell you about this, but I don't think this is my

15 statement. Maybe it was a misunderstanding. I think it was a

16 misunderstanding.

17 Q. Yes. Okay. It's clarified now. Thank you.

18 In relation to the work that you did, was it hard work, physically

19 hard work?

20 A. The work that I did was my job even before the war. It was

21 metalworking. It's a difficult job, for a myriad of reasons.

22 Q. When you -- after work, when you returned to your room, were you

23 exhausted?

24 A. That depends. Sometimes. I was always exhausted. All of us

25 were. I was exhausted all the time, but sometimes more, sometimes less.

1 If, for instance, I would go to the hospital and get more food, I was less

2 exhausted.

3 Q. Did other detainees have to work on the front lines? Do you know

4 that?

5 A. I personally didn't see them, but some people told me that they

6 had been close to the front lines, that they gathered hay for the farm,

7 that they drove trucks. But I personally didn't see them doing that,

8 because I hadn't been there.

9 Q. Do you know a Mujo Hodzic?

10 A. I knew him.

11 Q. Do you know whether he had to work? Do you know if he had to work

12 on the front line?

13 A. Well, listen. I don't want to get this mixed up. There is one

14 Mujo Hodzic and there is another Hodzic as well. One of them worked

15 with the people who gathered hay and the other one was a house painter,

16 and he worked with me in the same shop. The one who gathered hay, Mujo

17 Hodzic -- the Mujo Hodzic that I knew didn't work. I don't know. Maybe

18 you can look it up in my statement. There are also people with the last

19 name of Hadzic.

20 Q. Do you know if any detainees had to work on the front lines

21 digging trenches?

22 A. Oh, good. Good. I know what you're asking now. About this Mujo

23 Hodzic, precisely. I've just remembered. This man was taken away, and it

24 was not only him; it was a group of about 15 or 20. They were taken away,

25 I don't know where, but it was approximately in the autumn. I think two

1 months later, the same people were returned to the KP Dom and we were very

2 surprised to see them back. I spoke personally to that Mujo Hodzic. What

3 they told me was that they had been somewhere at the front line digging

4 some trenches, sleeping in barracks with Serbs, with soldiers, and then

5 they were returned to the KP Dom. If that is what you mean, I know about

6 it, but that's all I know.

7 Q. You said in autumn. Is that 1992 or 1993?

8 A. I think it was autumn 1992.

9 MS. UERTZ-RETZLAFF: With the help of the usher, I would like to

10 discuss schedule E with the witness. It should be in front of him.

11 Q. Witness, we do not need to talk about all these people that you

12 see on schedule E. Just the ones that I will refer you to. The person

13 number 1, Uzeir Aganovic, did he work in the metalwork shop together with

14 you?

15 A. Sometimes.

16 Q. When? Do you recall at what period he worked?

17 A. He worked there in 1992 and in 1993. He was there all the time.

18 If that is the Aganovic, Uzeir I have in mind.

19 Q. The person listed under number 5, Muharem Bacvic, Bacvic, yes, did

20 he work in the KP Dom, and in which field of work did he work?

21 A. I know one Bacvic who didn't work at all. But wait a minute.

22 This Bacvic, Muharem, I can't remember now. Bacvic, Muharem. Bacvic,

23 Muharem, Bacvic, Muharem. I think he worked at the carpentry shop.

24 Q. And number 10, the worker Berberkic?

25 A. Berberkic was a tin Smith. He worked together with me.

1 Q. And number 13, Izet Causevic [sic], where did he work, if he

2 worked?

3 A. Izet Cosovic or Causevic?

4 Q. Cosovic. Sorry.

5 A. Well, I don't know according to name -- oh, I know. Here. Fine.

6 Great. It says so. He worked -- he was a jack of all trades. He did not

7 have a specific job.

8 Q. Number 16 on the next page, number 16, Enver Cemo, where did he

9 work, if he worked?

10 A. He was also a jack of all trades. He worked at the farm and in

11 the compound, different things.

12 Q. Number 17, Mujo Dudic?

13 A. For some time, that was the main cleaning lady of the

14 administration building, for one period of time. And then after that he

15 worked up at the farm. But I think he spent most of the time around the

16 administration building.

17 Q. And number 18?

18 A. He was there briefly. He was taken somewhere later. Actually, I

19 have his brother in mind. His brother. He also worked a bit around the

20 compound.

21 Q. And number 20?

22 A. Well, there were two Gogalijas there. Gogalija, Asim and another

23 Gogalija. One of the Gogalijas work at the carpentry and then he was

24 taken somewhere, and the other one was released. Now, I don't know who is

25 Asim and who is Kasim. I don't know which is the one referred to here.

1 One of them worked at the carpentry, at any rate.

2 Q. Number 25, Munib Hadzic, did he work, and if so, where?

3 A. He worked with me, together with me at the metalwork shop. He was

4 one of the first people in the metalwork shop where I was. He went

5 somewhere after that. I said goodbye to him on the bus. The bus was

6 parked. And he went somewhere.

7 Q. What does that mean, he went somewhere? Does that mean he

8 disappeared or was he released?

9 A. He went for an exchange. That was a successful exchange, because

10 I know that he's alive.

11 Q. And number 28, Murid Islambasic, did he work?

12 A. Murid Islambasic? If I'm referring to the baker/driver, he went

13 somewhere in the morning and then they would return him in the evening. I

14 don't know where he went, whether he went for an interrogation or to work

15 somewhere. I don't know.

16 Q. Was he kept separate from other detainees or ...

17 A. Well, was he isolated then? At that time there were perhaps 500

18 or 600 detainees, and I was out there. I went to work and then I came

19 back in the afternoon. I mean, well, possibly he was separate. Perhaps

20 he was in one of the rooms. I think perhaps he was separate. I have no

21 idea. At any rate, he was not present in any one of the rooms that I

22 knew, that I knew about. And then, you know, there were lots of rooms

23 there, from 11 to Room 20. There are 10 or 15 rooms.

24 Q. Thank you. Number 29, did this person, Suad Islambasic, did he

25 have to work?

1 A. When Munib and Suad Islambasic worked -- actually, this Munib

2 Hodzic worked with me and Suad Islambasic. He worked -- actually, he

3 worked before Mr. -- Mr. -- Mr. -- Mr. -- Mr. -- the one who has a

4 code-name 249.

5 Q. Yes. So he worked in the metalwork shop, this Mr. Suad --

6 A. Yes. At the mechanic's department. He was a mechanic.

7 Q. And number 30, Atif Jasarevic, did he have to work, and where?

8 A. He also did all sorts of things. He went out with the grass

9 cutters and he did work related to the farm. When I'm talking about the

10 farm, I'm referring to the farm that had to do with agriculture, so I'm

11 talking about agriculture, cutting grass, collecting hay, things like

12 that.

13 Q. Number 31, Karahasanovic, do you know this person, and did he have

14 to work, and what?

15 A. At the same time, if you mean Karahasanovic, the forwarder,

16 because there were lots of them at the camp, if you mean the one nickname

17 Karasi, then he worked with me together. I think it was him. I don't

18 think it was someone else. He worked with me and sometimes he would help

19 me and sometimes he would help the mechanics. Then You keep asking me

20 whether we had to all the time. I think we've taken care of that, whether

21 we had to or not.

22 Q. Number 33, did he work, Saban Karup?

23 A. Saban Karup, yes. He used to drive an FAP truck that belonged to

24 the KP Dom, a yellow one. He also worked together with Jasarevic up

25 there. So they were actually collecting the crops for cattle feed.

1 Q. 35?

2 A. Krkalic, Rasim. Rasim Krkalic. I'm a bit confused right now. I

3 simply do not have his image before my eyes now. I know him well, but

4 right now I just can't.

5 Q. Okay. We can move on. 38, Goran Kukavica, what did he do?

6 A. I think he never did anything while he was here at the KP Dom

7 Foca. I saw him once in Sarajevo. Perhaps that's not important. I don't

8 think he did anything in Foca.

9 Q. And number 42, Maljanovic?

10 A. 42, Maljanovic, you mean?

11 Q. Yes.

12 A. Fine. There were two Maljanovics. One worked with me all the

13 time and the other one from time to time, so I don't know which one you're

14 referring to. These are actually two half brothers.

15 Q. If you look at 43, you see Ramiz or Asim. Would that be the first

16 names of the brothers?

17 A. Great. Yes. Yes. Asim. Asim is the one who worked with me all

18 the time, and Maljanovic worked from time to time.

19 Q. And number 44, Sacir Muratovic?

20 A. A tailor. A tailor at the carpentry shop. He cut fabrics for

21 upholstery.

22 Q. And number 49?

23 A. Reko Taib. He was with the grass cutters. He had to do with the

24 farm and with cutting grass and collecting hay.

25 Q. And number 50?

1 A. Sahovic, Ifet. Right now I've lost his image too. I can't say

2 anything.

3 Q. And 51?

4 A. Saraka Ramiz. Well, he was not in Foca for a long time. He

5 worked in the compound. I think he left early. I don't know when he

6 left.

7 Q. When you say he worked in the compound, do you mean within the

8 yard of the main prison or where?

9 A. Yes. I'm referring to the main yard. Because they had to clean

10 the yard itself.

11 Q. And number 52, Dzevad Sosevic?

12 A. Yes. Sosevic, Dzevad. He worked for a while with the hay

13 cutters, the grass cutters, and those who were collecting hay. This had

14 to do with the farm, Brioni. And he also went before others did; at

15 least, that is what I know.

16 Q. And at last, 57 and 58, the two tailors, did they work, and if so,

17 what?

18 A. Telo, Aziz and Telo, Mustafa. Yes. I think they were the main

19 people there, from the beginning to the end. They worked at Brioni, at

20 the farm there, and they had to do with cutting grass and collecting hay

21 for the cattle.

22 Q. When you say they worked there from the beginning to the end, does

23 that mean they worked there as long as you did, that is, until October

24 1994?

25 A. Yes.

1 Q. Yes. Thank you. We are finished with this part.

2 Witness, while you were at the KP Dom, were you beaten?

3 A. Yes.

4 Q. When were you beaten?

5 A. When Zeka escaped.

6 Q. At that time when this happened, was Mr. Krnojelac still the

7 warden, do you know?

8 A. I don't know, but at any rate he was in the building. You know

9 what, when you say "warden," I don't know who appointed who where, but

10 he was there. He was there, he was in the building. And when Zeka

11 escaped, he was in the building, as he was in 1992. He was there then

12 too. Now, whether he was the warden, whether he was the director, what he

13 was, I don't know. He was some kind of an important person, I think.

14 Q. Did you know that Mr. Zekovic actually wanted to escape before he

15 did it actually?

16 A. Yes, because I was preparing an escape together with him.

17 Q. Why did you and he -- and Mr. Zekovic, why did you want to escape

18 at that time?

19 A. Why? Why I wanted to escape? Well, everybody who is in prison

20 tries to escape if he has a chance. So I was in a camp. I mean, it was

21 my wish to escape, because of the pressure, because of the conditions, the

22 living conditions I had there. It's hard to explain this directly right

23 now. Ask anybody who was in a camp, in a prison, whether he wanted to

24 escape if he had a chance.

25 Q. When was it noticed that Mr. Zekovic was missing, and who actually

1 noticed that?

2 A. I noticed it because I knew that he would escape, but I didn't

3 know when. Because I had given up. And then I thought that he might too,

4 but as soon as I saw that he was missing I realised that he had escaped.

5 We noticed it some time around 2.00 or 3.00 in the afternoon.

6 Q. When did the guards notice?

7 A. Some of us -- I mean, there were 7 or 10 of us there at that

8 moment - while we were having dinner, or no, rather, lunch, I said to one

9 of them, "Did you know that Zeka is missing?" And then one of them got

10 really scared and he went directly to one of the guards and told him that.

11 Q. To whom did you say, "Did you know that Zeka is missing?" Did you

12 say that to a detainee or to a guard?

13 A. Detainee. A Muslim.

14 Q. What happened after the guard was informed?

15 A. What happened? A state of alert, emergency. They returned us to

16 the other place, to the metalwork shop, where he worked. We didn't go

17 back to the rooms. And of course, all these provocations started: "Where

18 is Zeka?" They pressured me most of all: "You were friends with him.

19 Where is he? Where? Where? Tell us, where is he?" So these

20 provocations. I don't know what you are really interested in.

21 Q. I want you to tell us what happened on that day after he left,

22 Mr. Zekovic escaped. You said you were taken to the metal shop. Who from

23 the prison staff was present in the metal shop?

24 A. Everybody was present, everybody, all of those who worked at the

25 KP Dom. I can't say with 100 per cent certainty, but those who were on

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1 the shift and those who were not on the shift were present. I would say

2 that it was some kind of mobilisation. I mean, everybody was there.

3 Q. Was Mr. Krnojelac present?

4 A. I saw him there too.

5 Q. Were you beaten while you were in the -- while you were questioned

6 in the metal shop?

7 A. Yes. Pljevaljcic slapped me in the face and he dragged me out

8 there to walk. I always said that perhaps the man fell asleep and did not

9 hear the time He slapped me in the face and then this mistreatment

10 started. And then I was walking through this metal shop from one room to

11 another. We were allegedly looking for him. Not allegedly. I was

12 looking for him.

13 Q. From the metalwork shop, where were you taken next?

14 A. They returned us to this hall that I explained a few minutes ago,

15 where that reception room is and that hall that enters the KP Dom, and

16 also this hall that links up the administration building and the KP Dom.

17 How should I call it?

18 MS. UERTZ-RETZLAFF: With the help of the usher, I would like to

19 show the photo 7446, this one, and 7470, this one, to the witness.

20 Q. When you look at this photo, is that part of the hall that you

21 mentioned?

22 A. Yes, that's right. This part here. There should be another

23 photograph here, because there is another hall here. Yes, this area.

24 MS. UERTZ-RETZLAFF: The witness is pointing on the floor in front

25 of this kind of reception desk.

1 And can we have the other photo, usher, please.

2 A. Yes, that's right. It's this part here, precisely this part here,

3 because this part has to do with the first part that I showed you. Yes,

4 that's right.

5 Q. You mean these two parts are connected?

6 A. I don't think; I know. The door was always open.

7 MS. UERTZ-RETZLAFF: Yes. The witness has pointed at the room

8 shown in 7470.

9 Q. Yes. And when you were there, what happened in this hall? First

10 of all, who was in the hall? Who of the detainees and who of the staff?

11 A. All of us who were at the metalwork shop were there, and there

12 were also lots of guards who were going left and right, up and down, all

13 over the place. They were milling about. And then beating started, and a

14 lot of them were yelling and saying, "Tell us, where is Zeka? We're going

15 to kill you." So they threatened us and they beat us. That moment they

16 took me to this reception office - you haven't got that picture

17 here - and Savo Todovic took me there directly, and Boro Ivanovic.

18 Q. Witness, we do not have a photo of this room that you just

19 mentioned, but I would like to show you the floor plan. It's the floor

20 plan, the Exhibit 6/1.

21 Can you point out the room where you were taken?

22 A. This is the hall, this is the reception desk, then this is the

23 room here, here, where there is this interrupted thing.

24 MS. UERTZ-RETZLAFF: The witness was pointing at the room -- the

25 next room left to the entrance.

1 Q. Yes. And you said that -- you said that Mr. Todovic and - let me

2 just see - Mr. Todovic and Mr. Ivanovic, Boro Ivanovic, took you there,

3 and what did they do there when you were there with him? What did they

4 do?

5 A. Well, I'll be repeating things again. At the same time, the same

6 questions - where is Zeka? Where did he go? In which directions? What

7 are his intentions? - that I should tell them about all of that because I

8 knew about it. They threatened me. They walked up real close to me.

9 Boro walked up to me to hit me on the head with a pistol. He did not hit

10 me, though. That kind of thing. So all the time the same story was being

11 repeated: Where was he, and also these provocative questions, whatever.

12 Q. Did they beat you? You said that Mr. Boro Ivanovic threatened you

13 and he even tried as if he wanted to hit you. Were you actually beaten by

14 the two of them?

15 A. No. Boro approached me with a pistol. Savo was standing on the

16 side, and then he said - I have to tell you this literally - that he would

17 hang me by the balls and that he would skin me like a goat. And then he

18 came forward with a gun, but he did not hit me.

19 Q. And before, when you were still together with the other members of

20 the workshop, of the work group, in this main hall, did you see who was

21 beaten by whom? Did you notice?

22 A. Well, listen. They took me out of that room a hundred times and

23 then they returned me to the isolation cell and then to that hall, and

24 then we went to the building where these isolation cells were. They were

25 beating people. They were beating people. Now, who beat whom,

1 personally -- I mean, I was beaten by Pljevaljcic and another one. I

2 can't remember his name. Who else was there? I know that Maric slapped

3 someone in the face there, but, you know, I was looking ahead and there

4 was lots of panic, and you could not really look around and see who was

5 beating whom. Everybody was beaten, at any rate.

6 Q. Did you see Mr Rasevic beat anyone?

7 A. I did not see.

8 Q. Did you see what Mr. Krnojelac did?

9 A. I saw him moving around there. He was there. He would dart in,

10 dart out. How can I put this to you? He looked as if the KP Dom was on

11 fire and that now the fire was being extinguished, and the Muslims were

12 the victims. Something like that. I didn't see him personally beating

13 anyone. Maybe he did beat someone, but I don't know.

14 MS. UERTZ-RETZLAFF: Your Honour, it's 4.00.

15 JUDGE HUNT: Thank you. We will resume again at 9.30 tomorrow.

16 We will now adjourn.

17 --- Whereupon the hearing adjourned at 4.00

18 p.m., to be reconvened on Tuesday, the 3^rd day of

19 April, 2001, at 9.30 a.m.

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