Tribunal Criminal Tribunal for the Former Yugoslavia

Page 1613

1 Tuesday, 4 April 2000

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

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

6 JUDGE MUMBA: Would the registrar please call

7 the case.

8 THE REGISTRAR: [Interpretation] Case number

9 IT-96-23-T and IT-96-23/1, the Prosecutor versus

10 Dragoljub Kunarac, Radomir Kovac, and Zoran Vukovic.

11 JUDGE MUMBA: Good morning, Witness. You are

12 still under solemn declaration. We are continuing with

13 cross-examination by Mr. Kolesar.

14 Mr. Kolesar, yesterday I gave you 15

15 minutes. This morning I'm giving you 10 minutes.

16 Mr. Kolesar, please.

17 MR. KOLESAR: [Interpretation] Your Honour,

18 and Honourable Judges, before I go on to my questions,

19 I have an observation to make which can be counted in

20 my 10-minute time. I wish to inform you that we have a

21 technical problem linked to the preparations of the

22 Defence.

23 At the Pre-Trial Conference on the 2nd of

24 March, it was agreed that we would get the transcript

25 by the end of the working day. However, that has not

Page 1614

1 proven to be the case in practice. We have informed

2 the Registrar, Ms. de Sampayo, of this, and I take

3 advantage of this opportunity to inform the Trial

4 Chamber of the same.

5 A second point: You have reduced my time by

6 another five minutes. Of course, that is your right

7 and I will respect your decision, but the practice so

8 far has been to make sure that the trial should be fair

9 and equitable, that the Defence should be entitled to

10 the same amount of time for the cross-examination as

11 the Prosecution has for its direct examination. We

12 have not up till now abused the time of the Court. On

13 the contrary; we have done our best to share the

14 questions that we, as the Defence, have for the

15 witnesses, and thereby to shorten the time we need and

16 avoid any repetition. That is what I wish to say for

17 the transcript, and if I may, I shall now go on with

18 the cross-examination.

19 JUDGE MUMBA: Before you go on, Mr. Kolesar,

20 let me clear the transcript problem. I would like to

21 find out from the Prosecution whether they are getting

22 the transcripts for each day at the end of the day.

23 MS. UERTZ-RETZLAFF: No, Your Honour. We

24 have the same problem; we don't get it at all. So I,

25 for instance, when I proceeded with 75 yesterday, I

Page 1615

1 didn't have the transcript from Thursday, so I have

2 that same problem.

3 JUDGE MUMBA: Yes. The Judges have the same

4 problem. We are also wondering why we were not getting

5 transcripts at the end of the day, particularly that we

6 are rising at 1600 hours. So I don't know whether the

7 Registry's representative can assist us.

8 THE REGISTRAR: [Interpretation] Indeed, for

9 the moment, it is impossible to provide the Chamber,

10 the Prosecution, or the Defence with a complete

11 transcript of the hearings on the same day, for

12 technical reasons. The Registrar wishes to produce the

13 best possible result, and therefore it needs to compare

14 the French transcript with the English transcript to

15 have the same numbering of pages, and I'm sure that the

16 Chamber is fully conscious of the importance of these

17 numbers during the judgement stage. Therefore, we are

18 unable to provide a copy of the transcript of the same

19 day in paper form, but it is always possible for the

20 parties to transfer the transcript, with the help of a

21 laptop computer, on a diskette. We can only provide

22 the transcript the next day, especially as the French

23 transcript comes from Canada and cannot be produced in

24 a speedier form, and we have to compare the two before

25 distributing them.

Page 1616

1 JUDGE MUMBA: The technicalities have been

2 explained. It is easy to get -- every counsel has

3 access to a laptop, I take it, and the Registry's

4 assistant has explained how you can get the transcript,

5 the English one, because that's the one we are

6 getting. And you must understand that it is not

7 edited. So you can get what is there, what is written

8 there, unedited. You can get copies for each day

9 through your laptop.

10 [Trial Chamber deliberates]

11 JUDGE MUMBA: And coming to the time,

12 Mr. Kolesar, yes, it is understood that the Defence

13 must be given equal time to the Prosecution, but that

14 does not mean asking questions unnecessarily long; and

15 when I told you that I'm limiting my time to 10 minutes

16 this morning, I just want you to understand that you

17 have to ask your questions within a limited time. So

18 I'm not counting 10 minutes from the time that you

19 stood on your feet, because we've discussed other

20 things, and I'm now giving you time to cross-examine

21 and finish your cross-examination, no time limit.

22 MR. KOLESAR: [Interpretation] Thank you, Your

23 Honour, but I will abide by your decision of 10

24 minutes.

25 WITNESS: WITNESS 75 [Resumed]

Page 1617

1 [Witness answered through interpreter]

2 Cross-examined by Mr. Kolesar: [Cont'd]

3 Q. Witness, yesterday we adjourned when we were

4 trying to count up how much time you spent in Kovac's

5 apartment in the building close to the Zelengora Hotel

6 and in the building near Masala, and we agreed that

7 that was 55 days.

8 A. We did not agree. I said that I didn't know

9 for sure. What I said was approximate.

10 Q. Yes, but you confirmed that what you stated

11 in your statements was the truth.

12 A. I'm saying again that I'm not quite sure. I

13 didn't count the days, and that is what I said then and

14 what I'm saying again now.

15 Q. Could it be 55 days?

16 A. I don't know.

17 Q. On the assumption that it was 55 days, that

18 would end with the 25th of December. Would that be

19 so?

20 A. I don't remember.

21 Q. That would be the 25th of December. Can you

22 agree with that?

23 A. I said I don't remember. I can't tell you

24 when I don't remember. I simply can't say when it

25 was. I can't remember and that's it.

Page 1618

1 Q. In the second half of December, you were

2 still in Foca; is that correct?

3 A. Yes.

4 Q. Do you know that in the second half of

5 December, around St. Nicholas' Day, which I think is an

6 Orthodox holiday, but I think you know when that is,

7 that Foca was attacked?

8 A. I don't remember.

9 Q. You don't remember that the alarms went off

10 and that the fighting started in Foca?

11 A. I don't know. I didn't hear it. In the

12 studio in which I was detained, there was no radio or

13 television, nor could I hear anything.

14 Q. But the shooting could have been heard

15 regardless of the radio or the television.

16 A. I didn't hear it. I just heard them shooting

17 when they were celebrating something like the New Year

18 or Christmas. That is when I heard the shooting in

19 town. I heard nothing other than that.

20 Q. Do you know where Klanfa was then? Was he on

21 the front?

22 A. I don't know.

23 Q. Do you know that he was wounded around about

24 then?

25 A. I don't know.

Page 1619

1 MR. KOLESAR: [Interpretation] If the witness

2 continues in this way, I won't even need the ten

3 minutes allotted me.

4 Q. You have stated here in court, in connection

5 with your expulsion from the apartment and forcing

6 towards the Drina, that Kovac forced you naked to the

7 Drina, and when you got there, Jagos Kostic arrived,

8 took you back to the apartment, and then he threw you

9 out again to the confluence of the Cehotina and the

10 Drina. Is that correct?

11 A. I don't think you read it properly, nor

12 understood it properly. As far as I can recollect,

13 when he evicted us from Tuta's flat and forced us

14 towards Masala, he stripped us there and forced us in

15 front of the building. Then he took us back into the

16 apartment, forced us to get dressed, and then he chased

17 us out by the municipality building towards the

18 Cehotina and Drina River, threatening to slit our

19 throats. You should have read that more carefully.

20 Q. Will you please be more polite, as I am

21 trying my best to treat you with politeness.

22 A. I think I'm treating you sufficiently well.

23 Q. Will you look at page 14 of your statement to

24 the investigators of the Tribunal. Page 14. Second

25 paragraph, about the middle. Will you read the

Page 1620












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Page 1621

1 sentence, the one but last, beginning with: "He forced

2 us to ..."

3 A. "He forced us to go to the Cehotina and Drina

4 confluence. At that time, Jagos arrived, exchanged a

5 few words with Klanfa, and took us back to the flat."

6 Q. Thank you. Now, will you find the statement

7 that you gave to the authorities of Bosnia-Herzegovina,

8 page 9, 15 rows from the top.

9 A. I don't have it here in front of me.

10 Q. You had it yesterday.

11 A. But I don't have it now.

12 JUDGE HUNT: May I just suggest that you read

13 it to her yourself.

14 MR. KOLESAR: [Interpretation] Yes, Your

15 Honour.

16 Q. "He forced us naked out of the building. In

17 front of the building he met Jagos Kostic, had a short

18 conversation with him, and then he took us back to the

19 apartment to get dressed. After we got dressed, he

20 took us out again and led us past the municipality

21 building, past the bridge on the Drina, holding an

22 automatic rifle and a knife in his hands, saying that

23 he would slit our throats. We couldn't approach the

24 Drina, so he took us to the place where Cehotina and

25 the Drina meet, the locality called Sastovci. Jagos

Page 1622

1 Kostic ran after us, with whom he had a short

2 conversation again. Then he slapped us and said that

3 we should go back to his apartment in the Lepa Brena

4 building to clean up the flat and later he would see

5 what he would do with us."

6 Is that what you said?

7 A. Yes.

8 Q. Explain to me, in view of these two

9 statements that you made and what you said here in

10 court, when you were beaten and mistreated on this

11 occasion.

12 A. When we were forced towards Masala and when

13 we were brought back from the Drina to the apartment.

14 Q. Did you pass by the municipality?

15 A. Yes, we did.

16 Q. Did you pass by the SUP?

17 A. We did.

18 Q. Didn't anyone try to protect you?

19 A. Oh, really. They were ridiculing us, the

20 people who were watching. Who do you think would

21 protect us?

22 Q. Let us go back once again to page 13 of your

23 statement to the investigators of the Tribunal. You

24 said, the one but last paragraph, you say: "For the

25 first two or three days Klanfa raped all of us, and

Page 1623

1 then he took AB and AS, whereas they left 87 alone and

2 nothing happened to her. Then one night Klanfa

3 brought ..." and so on and so forth.

4 A. As far as I can see, the difference is in the

5 translation only. There's no major difference.

6 Q. Here in court you gave a completely different

7 description of the events regarding your arrival in the

8 Brena building and the apartment used by Kovac and the

9 sequence of the rapes was described by you

10 differently.

11 A. I said, and I say again, that I cannot

12 recollect all the incidents and all the details today.

13 Q. To the authorities of Bosnia and Herzegovina,

14 you said you were there for some 20 days and that all

15 three of you were raped constantly: "That Jagos first

16 slept with AS, some 20 days later Klanfa took for

17 himself 87, whereas he told me and AB that we should go

18 to some people from Serbia."

19 So you have three different statements on

20 important incidents.

21 A. The first one is the most correct, the one

22 that I gave to the investigators of the Tribunal. That

23 is the most correct one. I cannot remember each and

24 every detail as to what I said now and what I am saying

25 now.

Page 1624

1 Q. At one point in the course of your testimony,

2 during the cross-examination yesterday, you stated that

3 you came here to judge. I'm sorry we don't have the

4 transcript so we can check on this. Is that what you

5 said?

6 A. Possibly.

7 Q. Who do you need to judge and are you the

8 person to judge?

9 A. I am not the person who should judge anyone.

10 I am the person who should testify.

11 Q. Will you agree with me that jealousy is a

12 psychological state, when a person imbued by is ready

13 to do certain things which people which are not imbued

14 by jealousy would not consider doing?

15 A. I'm afraid I don't understand that question

16 at all. What are you talking about? What do you mean

17 by jealousy?

18 Q. I'm referring to the fact that you said that

19 after four or five days, Klanfa rejected you. I said

20 yesterday that in my understanding, when a man rejects

21 a woman, it is usually a person he loves and not a

22 person who has been raped.

23 A. How could I possibly be Klanfa's beloved?

24 JUDGE MUMBA: [Previous translation

25 continues] ... after listening to the evidence of this

Page 1625













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14 French transcripts












Page 1626

1 witness and her explanation yesterday and what she

2 meant by the term "reject," I don't think we should

3 waste time on that. Please proceed with other

4 questions.

5 A. Only dead, not even dead, could I be Klanfa's

6 beloved, or any one of theirs. That's all I could say.

7 JUDGE MUMBA: Don't bother, Witness. Don't

8 waste your energy.

9 Mr. Kolesar, please.

10 MR. KOLESAR: [Interpretation] Your Honour, I

11 have some more questions, but my 10-minute time limit

12 has expired, and I will break off my cross-examination.

13 JUDGE MUMBA: Mr. Kolesar, you know that your

14 client is facing serious offences.

15 MR. KOLESAR: [Interpretation] Yes, Your

16 Honour.

17 JUDGE MUMBA: Go ahead and finish your

18 cross-examination.

19 MR. KOLESAR: [Interpretation] Your Honour, I

20 have finished my cross-examination.

21 JUDGE MUMBA: Are you sure?

22 MR. KOLESAR: [Interpretation] Absolutely.

23 JUDGE MUMBA: Your client is looking at you.

24 You understand that?

25 MR. KOLESAR: [Interpretation] I do

Page 1627

1 understand, Your Honour. I have a note from him. It's

2 a question that has been already discussed, and I don't

3 want to repeat myself. But of course you can ask my

4 client.

5 JUDGE MUMBA: Thank you.

6 Mr. Jovanovic, any questions?

7 MR. JOVANOVIC: [Interpretation] Yes, Your

8 Honour. With your permission, I would have several

9 questions. Thank you.

10 Cross-examined by Mr. Jovanovic:

11 Q. Good morning. I shall try and be as

12 expeditious as possible. Madam, do you still claim

13 that you didn't know Zoran Vukovic before the war?

14 A. Yes.

15 Q. Did you know any members of his family?

16 A. No.

17 Q. Did you perhaps give information about Zoran

18 Vukovic and members of his family to other witnesses

19 regarding information such as where they work, what

20 kind of activity they engage in, and so on?

21 A. No.

22 Q. Was a photo album ever shown to you when you

23 were asked to identify Zoran Vukovic?

24 A. I don't know.

25 Q. Did you manage to identify Zoran Vukovic on

Page 1628

1 that occasion?

2 A. I did not.

3 MR. JOVANOVIC: [Interpretation] I would like

4 to ask the usher for his assistance, to help us.

5 JUDGE MUMBA: And Counsel, be slow. The

6 interpreters, please.

7 MR. JOVANOVIC: [Interpretation] Your Honours,

8 this is a document that we received from the

9 Prosecution, and it is linked to a photo spread shown

10 to this witness, and another witness, whose name I will

11 not mention, for the purpose of identification of Zoran

12 Vukovic. Unfortunately, I have no additional copies.

13 I didn't have a chance of copying them, because the

14 machine wasn't working until two minutes prior to the

15 beginning of the hearing. So I'm just asking the

16 witness whether she can identify this photo spread.

17 THE REGISTRAR: [Interpretation] Is it

18 document 60 of the Prosecution, Prosecution Exhibit

19 number 60?

20 JUDGE MUMBA: She's asking you, Counsel.

21 Maybe the Prosecution can help us.

22 MS. UERTZ-RETZLAFF: The Prosecution Exhibit

23 number 60, which was not used, actually, entered into

24 evidence, is a photo spread referring to a photo spread

25 ID procedure related to Dragoljub Kunarac. The

Page 1629

1 Prosecution never showed any photo spread to this

2 witness of Zoran Vukovic.

3 JUDGE MUMBA: Thank you.

4 MR. JOVANOVIC: [Interpretation] Your Honours,

5 I didn't say that the Prosecution had shown this

6 document, but that an attempt had been made at

7 identification by other bodies. I just said that we

8 were given this document by the Prosecution. I didn't

9 say that the Prosecution showed it to the witness.

10 JUDGE MUMBA: Yes. That is clear. So you go

11 ahead with your cross-examination. Yes.

12 MS. UERTZ-RETZLAFF: Your Honour, the

13 Prosecution also wants to see it.

14 JUDGE MUMBA: Oh, yes. Before it is shown to

15 the witness, can the Prosecution see it? Actually, if

16 we had enough copies, that's what we like; also the

17 Bench also sees it before the questions are put.

18 MS. UERTZ-RETZLAFF: But this is still the

19 Prosecution Exhibit number 60. That's not what you are

20 referring to.

21 JUDGE MUMBA: Can the usher get that and show

22 it to the Prosecution first? Let them see whether they

23 have a similar document. Now, tell us what it is.

24 MS. UERTZ-RETZLAFF: The Prosecution has that

25 same document, and it is -- we received it recently

Page 1630

1 from the Bosnian government. When the witness was

2 there in Sarajevo doing a photo ID on a certain other

3 person, she was also shown several other photos

4 related -- and one of them was related to the accused

5 Zoran Vukovic.

6 JUDGE MUMBA: So what is that?

7 MS. UERTZ-RETZLAFF: It's a document without

8 any report. It's a document from the Bosnian

9 government, referring to a photo ID proceeding they

10 conducted with the witness.

11 JUDGE MUMBA: Yes. Not the Prosecution with

12 the witness.

13 MS. UERTZ-RETZLAFF: With the witness.

14 JUDGE MUMBA: Yes. That's what I wanted to

15 clarify. Yes. So now it can be shown to the witness.

16 Yes, you can go ahead, Counsel.

17 MR. JOVANOVIC: [Interpretation]

18 Q. Were you able to recognise and identify Zoran

19 Vukovic on that occasion?

20 A. Roughly, but I wasn't sure.

21 Q. Thank you.

22 JUDGE MUMBA: Can we have it numbered for

23 identification purposes?

24 THE REGISTRAR: [Interpretation] This document

25 will be D28, Defence Exhibit D28.

Page 1631

1 JUDGE MUMBA: It is not yet admitted into

2 evidence; right?

3 MR. JOVANOVIC: [Interpretation] Yes, Your

4 Honour; I understand that.

5 Q. Would you please assist me now, madam, in

6 clarifying the appearance and disappearance of Zoran

7 Vukovic in your statements. The exhibit admitted as

8 D24, a statement given between the 15th and 18th of

9 November, 1995, in that statement you mention the

10 accused Zoran Vukovic only in one sentence; is that

11 correct?

12 A. Possibly.

13 Q. The statement admitted as Exhibit D25, a

14 statement given by you to the Investigation and

15 Documentation Agency, in that statement you make no

16 mention at all of Zoran Vukovic, not a single word; is

17 that correct?

18 A. I don't know. I don't remember.

19 Q. Did you make that statement?

20 A. Perhaps I did, but maybe I didn't remember at

21 the time.

22 Q. Let me refresh your memory that in that

23 statement you mentioned more than 80 names and

24 nicknames of various people.

25 A. Correct.

Page 1632

1 Q. But only Zoran Vukovic is missing.

2 A. Possibly.

3 Q. Thank you. The statement admitted as Exhibit

4 D23, in that statement Zoran Vukovic is not mentioned

5 either. It's a statement given to the Prosecution.

6 Will you agree with that?

7 A. I don't really know what it says. I don't

8 remember.

9 Q. Let me remind you that you made those

10 statements between November 1995 and March 1998, those

11 that I have just referred to. So we come to a rather

12 interesting point. As the trial approaches, Zoran

13 Vukovic appears more and more often. On the 24th of

14 September, 1999, did you tell the investigator, Robert

15 Kempf that Radomir Kovac brought Vukovic for the

16 purpose of rape and that this occurred when you were

17 taken to the 4th floor of the Zelengora Hotel, and all

18 this happened during your detention in the apartment in

19 Foca?

20 A. I was already in the apartment when Klanfa

21 brought Vukovic. I didn't say --

22 Q. There seems to be a misunderstanding. My

23 question is: Is that what you told the investigator,

24 Robert Kempf on the 24th of September, 1999? Will you

25 answer that question?

Page 1633

1 A. I don't remember when I said what.

2 MR. JOVANOVIC: [Interpretation] Your Honours,

3 could I ask the usher for his assistance in

4 distributing these documents? This is for the witness,

5 in Serbo-Croatian, and this is the English version for

6 the Trial Chamber and the Prosecution. This is the

7 English version, and the first document is the

8 Serbo-Croat version.

9 JUDGE MUMBA: Which statement?

10 MR. JOVANOVIC: [Interpretation] Your Honour,

11 these are parts of a memorandum that we received from

12 the Prosecution immediately prior to the trial and in

13 the course of the trial regarding contact that the

14 Prosecution had with the witness. I'm trying to

15 establish whether those citations are truthful, and

16 that is why I am asking these questions. So I should

17 like the witness to see them first, and then we can

18 proceed with the questions.

19 THE REGISTRAR: [Interpretation] The document

20 will be D29, Defence Exhibit D29.

21 MR. JOVANOVIC: [Interpretation]

22 Q. Do you remember the event now?

23 A. Yes, I do, but not like this. It must be an

24 error in translation.

25 Q. Thank you.

Page 1634

1 MR. JOVANOVIC: [Interpretation] Your Honours,

2 I should like to tender this and have it admitted into

3 evidence.

4 A. Because I was already on the 4th floor when

5 he brought him to the apartment. He did not take me to

6 the 4th floor.

7 Q. Let us clarify something. I did not give any

8 of those statements, I have only read those statements,

9 and that is why I'm asking the questions.

10 JUDGE MUMBA: There is no objection, I take

11 it, so it's admitted into evidence. It retains the

12 same number.

13 MR. JOVANOVIC: [Interpretation]

14 Q. On the 17th of March, 2000, three days before

15 the start of this trial, did you tell the people

16 working in the Prosecution that Zoran Vukovic

17 identified himself to you as the individual who had

18 killed your uncle?

19 THE INTERPRETER: A little slower, please,

20 counsel.

21 MR. JOVANOVIC: [Interpretation] Thank you for

22 warning me. Let me repeat.

23 Q. On the 17th of March, 2000, three days prior

24 to the commencement of trial, did you tell individuals

25 working in the OTP that Zoran Vukovic himself

Page 1635

1 identified himself as the individual who killed your

2 uncle, without mentioning on that same occasion any

3 sexual abuse and that all this took place in the

4 co-accused's apartment, Kovac? Is that true?

5 A. Yes, it is.

6 Q. Thank you.

7 MR. JOVANOVIC: [Interpretation] Your Honours,

8 I should now like to show a document. It is a

9 memorandum, once again, which we received from the

10 Prosecution. I have sufficient copies of it, both in

11 English and in the Serbian version. So with your

12 permission, I should like to show this to my learned

13 colleagues and to tender it into evidence.

14 THE REGISTRAR: [Interpretation] This document

15 dated 17 March 2000 will be D30, Defence Exhibit D30.

16 JUDGE MUMBA: I take it there's no objection

17 to it being admitted. Okay.

18 MR. JOVANOVIC: [Interpretation]

19 Q. In your testimony before this Tribunal on the

20 30th of March, 2000, these two events -- you seem to

21 say that these two events were taking place at the same

22 place at the same time. Can you tell us which of these

23 three things that I have put to you now is true? I

24 can't hear you, Witness.

25 A. This is true.

Page 1636

1 Q. Which?

2 A. This one.

3 Q. Which one? I can't see from here.

4 A. On the 17th of March, 2000.

5 Q. If I understand you correctly, that is the

6 truth. The rest is not the truth. Is that right?

7 A. Well, it's all more or less the same, but it

8 depends how it was translated, and I can't go into

9 that.

10 Q. So we have an error in the translation, do

11 we? Very well. Let's continue.

12 Let us now go back for a moment to the time

13 you were brought to Buk Bijela. I should like to

14 clarify the following, but let me ask you a question

15 before that. Was that the first time that you saw

16 Zoran Vukovic, in Buk Bijela, in fact?

17 A. Yes.

18 Q. Thank you. Having ascertained that, let us

19 clear up where you saw Zoran Vukovic for the first time

20 in your life, and I'm going to offer you two variants.

21 The first is Exhibit 24, page 5, on the road to the

22 huts when you were being taken off, or the testimony

23 before the Court on the 30th of March, 2000, and it is

24 transcript page 1387, line 25 and page 1388, line 1.

25 That is the second variant where you say that this

Page 1637

1 occurred within the same hut when you were taken from

2 one premises to the other. So as one of the premises

3 was closed, a closed space and the other an open space,

4 which of these two proposals, variants are correct?

5 A. It is correct that they took me out of one

6 hut, and when I was taken out of this one hut, Zoran

7 Vukovic passed right by me with my uncle.

8 Q. Does that mean that the testimony you gave

9 before this Trial Chamber is not the truth?

10 A. Yes, it is. Everything I said is correct.

11 And taking me off to the second entrance of the same

12 hut.

13 MR. JOVANOVIC: [Interpretation] Your Honours,

14 I think that it would be helpful to us all if the

15 witness would answer -- stick to answering my questions

16 alone. This would speed up matters considerably.

17 Thank you.

18 Q. There are two quite different things. One

19 thing that the event take place outside in the open,

20 and the second that it takes place indoors.

21 A. As far as I remember, it was an open space.

22 When they took me out of one premises, outside, that is

23 when I encountered Zoran Vukovic with my uncle. From

24 there they took us to another entrance.

25 Q. Let me remind you --

Page 1638

1 JUDGE MUMBA: Counsel, always wait until the

2 witness finishes the answer.

3 MR. JOVANOVIC: [Interpretation] Thank you,

4 Your Honours.

5 Q. If I understand what you're saying, the

6 following is true: "Then a soldier took me to another

7 hut. On the way there, I passed by Zoran Vukovic and

8 my uncle." We're not going to mention his name. That

9 is correct, is it? Why then did you testify

10 differently here?

11 A. I don't remember having said anything

12 different.

13 Q. Thank you. Did you recount this occurrence

14 to anybody?

15 A. Possibly.

16 MR. JOVANOVIC: [Interpretation] So I need

17 your assistance once again, the usher, please. With

18 the help of the usher, I'm going as though you know the

19 name of a witness. Please tell me if you know that

20 individual or not.

21 JUDGE MUMBA: Can you repeat the question,

22 counsel? Can you repeat the question?

23 MR. JOVANOVIC: [Interpretation]

24 Q. Does the witness know this individual?

25 A. Yes.

Page 1639

1 Q. Is that the wife of the individual who was

2 killed at Buk Bijela?

3 A. That is correct.

4 Q. Did you tell that person, whose name you've

5 just read, what happened in Buk Bijela?

6 A. Correct.

7 Q. Did you state the following: "Zoran Vukovic

8 and Zoran Vilota were still with him, but my husband's

9 face was covered in blood. She saw that his ears had

10 been cut off. She told me that they had taken my

11 husband off to the River Drina and had thrown him into

12 the river. She saw Zoran Vukovic shooting at him when

13 he had fallen into the river. She asked him why he had

14 done that, and he answered that it was only an old

15 man." Did you, in fact, say that or not?

16 A. Yes.

17 THE INTERPRETER: Counsel, slow down,

18 please.

19 MR. JOVANOVIC: [Interpretation] Yes.

20 Q. And you saw all this and this actually

21 happened as you recounted it?

22 A. No, I didn't see it. I saw what my uncle

23 looked like. But Vukovic later on himself told me,

24 because he thought we'd never leave the place alive, so

25 nobody would get to know that. So that's why he could

Page 1640













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14 English and French transcripts












Page 1641

1 say all these things.

2 Q. If I understand you correctly, you know

3 something. From that you make up -- compose the

4 situation as to how you think it occurred and then you

5 recount that; is that right?

6 A. Well, when I saw what my uncle looked like --

7 Q. Just one moment, please. Did you see Zoran

8 Vukovic shoot fire at your --

9 A. No, I didn't. But he told me that he got him

10 in the middle of the Drina because he was trying,

11 allegedly, to escape and then he shot at him.

12 Q. I read you a passage and asked you whether it

13 is correct. From this here, we can assume that you

14 have direct knowledge as to how the event took place.

15 So that is what I'm asking you. Do you or do you not?

16 As to what Zoran Vukovic asked you or told you, we'll

17 come to that later on. All I'm asking you is this

18 particular fact now.

19 A. Yes.

20 Q. You said that. Thank you.

21 JUDGE MUMBA: Can we have the number for

22 that?

23 THE REGISTRAR: [Interpretation] This document

24 will be D31, Defence Exhibit.

25 JUDGE MUMBA: Thank you. It is admitted, so

Page 1642

1 that the record is clear, under seal.

2 MR. JOVANOVIC: [Interpretation] Your Honour,

3 I omitted to say that this document has already been

4 admitted into evidence as D14. If you take a look, you

5 will find that D14 has already been admitted. So I do

6 apologise to the Trial Chamber and the Registry. It

7 has already been admitted as D14.

8 JUDGE MUMBA: Yes. Let the Registry

9 confirm.

10 THE REGISTRAR: [Interpretation] The document

11 D14 was a statement by a protected witness, dated the

12 8th and 11th of September. So it is a different

13 document from what has just been given to us. The

14 document is the piece of paper with the name of that

15 protected witness, and it will bear the number 31.

16 MR. JOVANOVIC: [Interpretation] Yes. That

17 was a misunderstanding. I was thinking of a different

18 document.

19 Q. Could you tell me, please: That particular

20 moment when you saw your relative, how long did that

21 last?

22 A. Well, it didn't last more than a couple of

23 seconds. We just passed each other by.

24 Q. How many people were there around your

25 relative at that particular point?

Page 1643

1 A. I don't know. I don't remember.

2 Q. What position was Zoran Vukovic standing in

3 relation to you and your uncle?

4 A. Correct.

5 Q. I didn't understand your answer.

6 A. I said correct, he was standing. He was

7 walking with him, because we were not able to stop and

8 talk.

9 Q. I asked you: What was Zoran Vukovic's

10 position in relation to you and your relative?

11 A. I don't know. I don't remember.

12 JUDGE MUMBA: Counsel, sometimes it is

13 important to explain what you mean by your question,

14 because the witness may not understand. Sometimes it

15 is important to explain.

16 MR. JOVANOVIC: [Interpretation] Yes, Your

17 Honour. It was my intention, by asking this question,

18 to ascertain the possibility of identification; that is

19 to say, the witness's identification with respect to

20 the accused. I wanted to have the witness answer how

21 long this moment of contact lasted, what the

22 circumstances of it were, what other individuals were

23 in the vicinity, to see if in the normal run of events

24 it was possible, in these few seconds, which is the

25 time that the witness says this lasted, that there

Page 1644

1 should be a positive identification, especially as that

2 individual, as the witness has told us, saw her for the

3 first time -- she saw him for the first time on that

4 occasion in her lifetime, as she herself has said.

5 JUDGE MUMBA: All right.

6 MR. JOVANOVIC: [Interpretation]

7 Q. Immediately prior to seeing Zoran Vukovic and

8 your relative, what happened to you?

9 A. I've already said that.

10 Q. Is it correct to say that you were being

11 taken away after questioning to another premises?

12 A. Yes.

13 Q. After that interview which you had, how did

14 you feel?

15 A. I think that I said that as well.

16 Q. Could you please repeat and tell me again,

17 because I can't remember everything.

18 A. How could I have felt? I felt terrible. I

19 felt half dead.

20 Q. So you were half dead, and for several

21 seconds you see your relative in a group of other

22 individuals and you happen to recognise Zoran Vukovic.

23 A. I apologise. There was no rape there. This

24 was a meeting before. It was before I was raped. And

25 I think that that is what I say quite clearly in my

Page 1645

1 statement.

2 Q. Well, if we can look at the transcript, I say

3 "interview" or "examination," and not "rape."

4 A. Well, I thought you meant how I felt -- I was

5 saying how I felt after the rape, not after the

6 interrogation.

7 Q. I would appreciate it if you would pay

8 attention to what I'm actually asking you. I asked you

9 the following question: How did you feel,

10 psychologically speaking, after the interrogation that

11 took place in order to determine whether there were any

12 weapons, where the men were, and things like that,

13 things you were asked during that interview?

14 A. I was shocked.

15 Q. Thank you. I just have two or three brief

16 questions connected to an event which took place during

17 the night when the Aladza mosque was destroyed, and my

18 questions are the following: On that particular night

19 you were taken off in a car to an apartment near

20 Aladza; is that correct?

21 A. Yes, it is.

22 Q. Was Zoran Vukovic in that car?

23 A. I don't know. I don't remember.

24 Q. Do you remember who was in the car?

25 A. Zaga and Gaga. I remember that.

Page 1646

1 Q. And how many of you from Partizan?

2 A. Four.

3 Q. That makes six in all, six people?

4 A. Yes. I don't know exactly. I'm not quite

5 sure.

6 Q. What car was it?

7 A. I think it was the one -- what's it called?

8 Pezeac. It was referred to as Pezeac. It had no

9 exhaust pipe.

10 MR. JOVANOVIC: [Interpretation] As the Trial

11 Chamber and my colleagues from the Prosecution do not

12 know the type of cars and the type referred to as

13 Pezeac --

14 A. Zaga drove it.

15 Q. Well, would you say it was a large car?

16 A. No.

17 Q. A small car?

18 A. I forget the make.

19 Q. Thank you.

20 A. I know that they just called it the Pezeac.

21 Q. Thank you. Was that the first time that you

22 went to Aladza?

23 A. No, it was not.

24 Q. Thank you. I have just a few more questions,

25 if you agree, in respect to the apartment where, as you

Page 1647

1 say, you were detained. The term you used, "brought,"

2 when you say, "Radomir Kovac brought Zoran Vukovic," do

3 you imply that the two of them came together?

4 A. Well, I don't know. I don't remember.

5 Q. You don't remember whether they came together

6 at that particular moment to the apartment?

7 A. I don't remember.

8 Q. Very well. Why were you in the kitchen?

9 Were you ordered to be there; and if so, who ordered

10 you? How did you come to be in the kitchen?

11 A. Well, quite certainly it wasn't of my own

12 free will. Ask Klanfa. He knows it full well.

13 Q. Well, from that I conclude that it was he who

14 ordered you to go to the kitchen.

15 A. That's right.

16 Q. So he ordered you to go to the kitchen with

17 Zoran Vukovic?

18 A. That's right.

19 Q. Do you recall, perhaps, the words that he

20 used on that occasion?

21 A. No, I don't.

22 MR. JOVANOVIC: [Interpretation] Your Honour,

23 I'm asking this question because in her portion of the

24 statement, where the witness describes the situation

25 and says how she came -- that Zoran Vukovic identified

Page 1648

1 himself as the individual who had killed her uncle, the

2 witness says, "I think after he had heard my name."

3 And it is precisely for that reason that I'm asking

4 these questions: to learn at what particular moment

5 and how it was that Zoran Vukovic came to learn that he

6 had in front of him such-and-such a person, who was the

7 relative of such-and-such.


9 MR. JOVANOVIC: [Interpretation]

10 Q. As far as I have understood, you do not

11 recall that Radomir Kovac said that, and I'll

12 paraphrase, that "XY, you're now going to the kitchen

13 with Zoran Vukovic." He didn't name you. He did not

14 use your full name and surname so that you can be

15 identified in that fashion.

16 A. I don't know. I don't remember.

17 Q. When you went into the kitchen, did you

18 introduce yourself to Zoran Vukovic?

19 A. I don't remember that either.

20 MR. JOVANOVIC: [Interpretation] Very well.

21 In the transcript, page 1450, lines 24 and 25, Your

22 Honours, we have a description of a conversation

23 between the witness and the accused.

24 Q. If I understood you correctly, Witness, you

25 were talking about the living and the dead.

Page 1649

1 A. That's right, yes.

2 Q. After that, the conversation turned to a more

3 concrete detail, that is to say, the killing of your

4 relative.

5 A. Correct.

6 Q. Zoran Vukovic identified himself as being the

7 person to have killed your relative by shooting at

8 him.

9 A. That is correct. All the details of how this

10 happened, I cannot remember, but I only remember the

11 detail when he said that he came to the middle of the

12 Drina River and that he shot at him then, when he

13 started fleeing across the River Drina. But I don't

14 remember all the details.

15 Q. But you know that he did not kill him by

16 shooting at him?

17 A. Well, no, he didn't, and I suppose he's still

18 alive. Is that what you mean? If he was alive, he

19 would have contacted me.

20 Q. I didn't mean that your relative was alive or

21 not, but do you know that the death of your relative

22 did not occur through a gun wound but in another way?

23 A. I don't know.

24 Q. Well, let me remind you. The same page of

25 the transcript, the same lines, you said that you know

Page 1650

1 that your uncle was -- that his throat was slit. That

2 is an extremely brutal act.

3 A. I didn't state that. I assumed that.

4 Because when I heard him scream in Buk Bijela, and the

5 amount of beating he got, all his screams, I was able

6 to hear, and so I presumed that his throat had been

7 slit, because those up there, our people up there who

8 were killed, the seven or eight of them, were

9 slaughtered as well, so I assumed that.

10 MR. JOVANOVIC: [Interpretation] Your Honours,

11 these seem to be very strange situations, and may I

12 tell you the point of my questioning and the point of

13 asking the witness how her relative lost his life? I

14 won't take up too much of your valuable time, Your

15 Honours.

16 JUDGE MUMBA: Go ahead.

17 MR. JOVANOVIC: [Interpretation] Thank you.

18 The point of my questions is the following: The

19 witness, in all manner of ways, regardless of what

20 actually happened, is endeavouring and is telling us

21 about extreme brutalities that happen generally, so

22 that all of us listening to her here can gain an

23 impression as to the things that took place there. My

24 question was asked precisely for that reason. And let

25 me remind the witness of a statement she made and which

Page 1651

1 she maintains to be correct, and that is Exhibit 24, I

2 believe. It is the statement taken in 1995.

3 Q. At the end of your statement you say, "While

4 I was raped, I heard my uncle shouting outside. First

5 I heard a shot and then silence. At that moment I knew

6 that he had been killed." At that moment you know that

7 he was killed by a firearm, and then later on you know

8 that his throat was slit.

9 A. I didn't say I knew; I said that I assumed

10 after the cries I heard. Because they were shooting

11 all the time. It wasn't just then; they were shooting

12 all the time.

13 Q. Thank you. You will agree with me that it is

14 rather painful to discuss the dead and the living and

15 the way in which somebody was killed, in this

16 particular case, your relative, whom you assume was

17 killed in an extremely brutal way. I assume that you

18 didn't feel very well when talking about it.

19 A. How could I feel? Perhaps I should have been

20 singing.

21 Q. From your statement, I also see that Zoran

22 Vukovic wasn't feeling too well after this talk with

23 you, so he needed your assistance in order to be able

24 to rape you.

25 A. Yes, correct.

Page 1652

1 Q. Would you describe Zoran Vukovic as an

2 emotional killer, slaughterer, and rapist?

3 A. Yes.

4 Q. Several times so far you have said, and

5 confirmed, that your memory was better earlier on than

6 it is today, which is quite normal, isn't it?

7 A. Yes.

8 Q. Explain to us, then, how, in the case of

9 Zoran Vukovic, and only in his case, your memory

10 becomes better as time passes; the more time passes,

11 the more you recollect.

12 A. I don't believe so. As time passes, I try to

13 forget and to delete from my memory these things.

14 Q. Yes, but until 1999, Zoran Vukovic doesn't

15 exist in your statements at all, only in one sentence;

16 and then later on he is said to have raped you, that he

17 identified himself as a killer, and so on.

18 A. That is correct. Perhaps I couldn't remember

19 all the details at the time when I was speaking to

20 whoever, because there are many of them that I

21 recollect, though I didn't mention them at the time.

22 Q. The name "Zoran Vukovic," does it arouse any

23 special emotional response when you hear the word

24 "Zoran Vukovic"?

25 A. Not just Zoran Vukovic, but each and every

Page 1653












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13 the English and French transcripts













Page 1654

1 one of them.

2 Q. My question is Zoran Vukovic.

3 A. Yes. The very thought of him makes me sick.

4 Q. Let me make a digression before I ask my last

5 question, and that is: In addition to Zoran Vukovic,

6 who has been accused here, the witness has mentioned

7 another Zoran Vukovic, whose nicknamed is Kifla, if I'm

8 not mistaken.

9 THE INTERPRETER: Witness says, "Correct."

10 MR. JOVANOVIC: [Interpretation] My question

11 is directed as follows: Zoran Vukovic, nicknamed

12 Kifla, before the day his name was announced here, in

13 all the witnesses' statements, the name appears only

14 once, and she identified him as the person she saw

15 breaking into a Muslim house for the sake of looting.

16 Then at the hearing here, the witness said

17 that that same Zoran Vukovic, Kifla, had broken down

18 the door in which she was living, raped her, took her

19 to his mother's apartment and raped her, brought her

20 back the next day to the same apartment and raped her.

21 Q. So my question is whether this name "Zoran

22 Vukovic" and the very mention of that name, does

23 something inexplicable occur as the result of the

24 mention of that name? That Zoran Vukovic, Kifla, you

25 never mentioned either until two days ago.

Page 1655

1 A. I think I did.

2 MR. JOVANOVIC: [Interpretation] Your Honour,

3 I have no more questions. Thank you.

4 JUDGE MUMBA: Thank you. Any re-examination

5 by the Prosecution?

6 MS. UERTZ-RETZLAFF: Yes, Your Honour. I

7 have a few additional questions.

8 JUDGE MUMBA: Please go ahead

9 Re-examined by Ms. Uertz-Retzlaff:

10 Q. The first question relates to Defence Exhibit

11 29. Witness, do you recall that before Zoran Vukovic

12 was arrested, you were called by an investigator of the

13 Tribunal?

14 A. I think I do remember, yes.

15 Q. Were you questioned about what you know about

16 Zoran Vukovic?

17 A. I think so, yes.

18 Q. Did you ever see or discuss the notes that

19 the investigator made about this conversation with

20 you? Did you, for instance, sign it?

21 A. I don't know. I don't remember. I think I

22 spoke on the phone with someone, but I don't remember.

23 Q. The next question refers to the Defence

24 Exhibit number 30. Witness, do you recall that you, in

25 March 2000, met with investigators of the Tribunal in

Page 1656

1 Sarajevo, in the Office of the Prosecution?

2 A. Yes.

3 Q. Do you recall what the purpose of this

4 meeting was?

5 A. I don't know exactly.

6 Q. Could it have been administrative matters as

7 to your way of travelling and if you want a support

8 person and those things?

9 A. Yes. Yes.

10 Q. Who was present? Who else, except for the

11 investigators, who else was present during this

12 meeting?

13 A. Who was there? I don't know. You're asking

14 me --

15 Q. Do you recall that your husband-to-be was

16 present?

17 A. Yes. Yes.

18 Q. While your husband-to-be was present, did we

19 discuss about sexual assault et al.?

20 A. I think it was discussed.

21 Q. Please try to remember what happened on that

22 occasion. Do you recall that we spoke about this

23 Kifla, Zoran Vukovic?

24 A. Yes. Yes, I do remember.

25 Q. And did we speak about the accused Zoran

Page 1657

1 Vukovic?

2 A. I think we did, yes.

3 Q. Were you asked to describe any rapes

4 committed by these two men at all on that one occasion

5 when your husband-to-be was present?

6 A. I think not.

7 MS. UERTZ-RETZLAFF: Your Honour, just for

8 clarification, when you look into the document D30,

9 there is no mention at all about any sexual assault at

10 that time.

11 Q. When the cross-examination started, Defence

12 counsel Prodanovic referred to two statements you gave

13 to the Prosecution, and he referred to your statement

14 given to the Bosnian authorities. Were these

15 statements, besides the days when you made them and you

16 signed them, were they ever given to you and read out

17 to you for review?

18 A. No, never.

19 Q. When you spoke about Partizan during the

20 cross-examination, you said that women would sneak out

21 to buy some bread. Did they sneak out secretly or did

22 they talk to the guards before that?

23 A. They talked to the guards, asking them

24 whether they could go or not to the shop to buy bread

25 for the children.

Page 1658

1 Q. Did all guards allow it or only those who you

2 mentioned as friendly and protecting?

3 A. Only the two that I described, those that

4 protected us.

5 Q. Those women who sneaked out, were they young

6 girls?

7 A. Yes. Actually, only one woman really went,

8 and she had two children, and then she'd bring five or

9 six loaves of bread for all of us.

10 Q. Is this one of the women who are listed on

11 this list?

12 A. Yes.

13 Q. Which one?

14 A. Number 95.

15 Q. With Defence counsel Mr. Kolesar, you

16 discussed your stay in Klanfa's apartment in detail,

17 and there was a mention of so-called sleeping

18 arrangements. I want to ask you: Were you or any

19 other of the girls voluntarily together with Radomir

20 Kovac?

21 A. I think that is impossible. My heart and

22 soul could never do anything like that with a Chetnik

23 who killed my own brother who was 20. For me to go to

24 bed with him voluntarily, not even if I were dead.

25 Q. Did any of you girls make decisions on how to

Page 1659













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14 the English and French pagination.












Page 1660

1 sleep, how long, with whom whatsoever, or to move to

2 other places?

3 A. No.

4 Q. Who then made the decisions?

5 A. They. Who else? Klanfa and his colleague

6 Jagos.

7 Q. You mention that at a certain point in time,

8 Klanfa was in the KP Dom. Do you know when that was

9 and why he was in the KP Dom?

10 A. Why, I don't know exactly. I just know that

11 he was imprisoned, and it was certainly not because he

12 did something good. And when this old woman broke into

13 our apartment to chase us out of there, then Gojko

14 Jankovic came to throw her out. He said that Klanfa

15 was in detention, and he yelled at her, saying, "Do you

16 think that Klanfa will never come out of prison?" And

17 that is how I knew that he was in the KP Dom in Foca.

18 Q. And when he returned, did he ever tell you

19 why he was there, what he did?

20 A. No. I don't remember.

21 MS. UERTZ-RETZLAFF: No further questions,

22 Your Honours.

23 JUDGE MUMBA: Thank you. Thank you very

24 much, Witness, for giving evidence to the Tribunal.

25 You are now free and you can leave.

Page 1661

1 [The witness withdrew]


3 MS. UERTZ-RETZLAFF: Your Honours, as there

4 is now a new witness coming, we need a break to arrange

5 the technical things, and we also want to switch

6 places. Maybe it's a possibility to make our break

7 now.

8 JUDGE MUMBA: Yes. For the arrangements that

9 have to be made, we will break now. I'm looking at the

10 clock in the courtroom, so we shall resume at 11.20.

11 We shall resume the proceedings at 11.20 sharp.

12 --- Recess taken at 10.50 a.m.

13 --- On resuming at 11.20 a.m.

14 [The witness entered court]

15 JUDGE MUMBA: Good morning, Witness. Please

16 make your solemn declaration.

17 THE WITNESS: [Interpretation] I solemnly

18 declare that I will speak the truth, the whole truth,

19 and nothing but the truth.


21 [Witness answered through interpreter]

22 JUDGE MUMBA: Thank you.

23 MS. KUO: Good morning, Witness.

24 With the assistance of the usher, I would

25 like to have this witness shown Exhibit 192, which has

Page 1662

1 been given to Defence as well as provided to Chambers.

2 Examined by Ms. Kuo:

3 Q. Witness, on Exhibit 192, do you see your

4 name?

5 A. Yes.

6 Q. Next to your name, do you see a number?

7 A. Yes.

8 Q. Is that number 87?

9 A. Yes.

10 Q. Throughout these proceedings you will be

11 referred to by that number. Do you understand?

12 A. Yes.

13 THE INTERPRETER: May the witness approach

14 the microphone, please.

15 MS. KUO:

16 Q. Witness, underneath your name, do you see

17 your birth date?

18 A. Yes.

19 Q. Underneath that, do you see the name of your

20 father?

21 A. Yes.

22 Q. Underneath that, the name of your mother?

23 A. Yes.

24 Q. Finally, the name of your sister?

25 A. Yes.

Page 1663

1 Q. Could you tell us what initials appear beside

2 the name of your sister?

3 A. DB.

4 Q. Thank you. Now, Witness, how old are you?

5 A. Twenty-three and a half.

6 Q. In April of 1992, how old were you?

7 A. About 15 1/2.

8 Q. Where were you born?

9 A. In Foca.

10 Q. Where did you live?

11 A. In Trosanj.

12 Q. Did you live in a particular part of Trosanj?

13 A. No. Yes. Just Trosanj.

14 Q. Were there both Serbs and Muslims living

15 there?

16 A. Trosanj was inhabited only by Muslims, the

17 part up to the road, and a place called Mjesaja was

18 inhabited by both Serbs and Muslims.

19 Q. What ethnicity are you?

20 A. Muslim.

21 Q. In 1992 whom did you live with?

22 A. With my mother, father, sister, and brother.

23 Q. How old was your brother?

24 A. He was 10.

25 Q. How old was your sister?

Page 1664

1 A. I will have to calculate it.

2 Q. Was she older or younger than you?

3 A. She was four years my senior.

4 Q. In 1992 were you still in school?

5 A. Yes.

6 Q. What grade were you in?

7 A. Second grade of secondary school.

8 Q. Where did you go to school?

9 A. The Nikola Tesla Secondary School centre in

10 Foca.

11 Q. Is that the same school that's located in the

12 Aladza neighbourhood of Foca?

13 A. Yes.

14 Q. Do you know when the war in Foca started?

15 A. I think it was on the 8th of April, though

16 I'm not quite sure.

17 Q. At that time could you hear or see anything?

18 A. Yes. We could hear shooting, explosions,

19 sometimes houses set on fire, and things like that.

20 Q. Did you see soldiers?

21 A. I didn't see soldiers until roughly the 3rd

22 of July.

23 Q. Before the 3rd of July, how did the war

24 affect your life? Did you continue to go to school?

25 A. No. The school work was suspended, I think

Page 1665

1 it was at the beginning of April.

2 Q. Were you able to continue living in your

3 house?

4 A. For a very short time. Afterwards we had to

5 hide in the woods.

6 Q. Why did you have to hide in the woods?

7 A. Out of fear that we would be killed or

8 something like that.

9 Q. Did you feel that you were targeted because

10 you were Muslims?

11 A. Yes.

12 Q. Who else was in the woods with you?

13 A. My family and two other families. That was

14 at the beginning. Later, a short while before we were

15 attacked, there were several families in one group.

16 Q. What ethnicity were all these people in the

17 woods with you?

18 A. They were all Muslim.

19 Q. When was your village attacked?

20 A. On the 3rd of July, 1992.

21 Q. Do you recall what time of day it was?

22 A. I couldn't tell the exact time, but it was

23 about 6.00 in the morning. It was very early.

24 Q. Where were you when the village was

25 attacked?

Page 1666

1 A. We were sleeping in a tent in the woods.

2 Q. What did you hear?

3 A. We heard shots.

4 Q. What did you do?

5 A. When we heard the shots there was panic, and

6 the people started fleeing. Nobody knew where to go,

7 in which direction. When the first man was hit or,

8 rather, wounded, then we were swept by real panic.

9 Q. Could you see who was shooting?

10 A. At first we couldn't, but after a short while

11 we could see.

12 Q. Who was shooting?

13 A. They were soldiers in camouflage uniforms. I

14 knew they were Serbs.

15 Q. Did you recognise any of them?

16 A. At that moment I did not, I wasn't even

17 looking, but a little later, yes.

18 Q. Do you recall now who those soldiers were?

19 A. I now remember only one of them from that

20 attack that morning. I can't remember the others.

21 Q. Whose name do you remember?

22 A. May I say the name?

23 Q. The name of the soldier, yes.

24 A. It was Jagos Kostic.

25 Q. You mentioned that a man was shot. Did you

Page 1667












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Page 1668

1 see anyone else get shot?

2 A. Yes. I saw three persons who were shot. One

3 was a man and two women.

4 Q. Do you know approximately how old the man

5 was?

6 A. I don't know exactly. About 50 maybe.

7 Q. What else did you see the soldiers do?

8 A. When they started shooting at us, we were

9 fleeing, and they ran after us. Then they surrounded a

10 group of us, and they beat the men, demanding that they

11 tell them where the weapons were, where they had hidden

12 the weapons and things like that.

13 Q. Were there any weapons with you in the

14 woods?

15 A. No.

16 Q. Was your father one of the men being beaten?

17 A. Yes.

18 Q. What did the soldiers do then?

19 A. You mean after that?

20 Q. Yes.

21 A. They separated the men from the women and the

22 children. They took us out of the woods to a meadow.

23 It wasn't far. Then they lined us up, and then they

24 asked whether we had gold, money, and the like. Then

25 in our tents they found quite a number of old

Page 1669

1 photographs and documents, and then they showed us

2 those photographs, asking us who they were, where they

3 were, and the like.

4 Q. In the meadow, was it women and children or

5 men?

6 A. In the meadow were the women and the

7 children. Though I don't remember very well, the men

8 were not right next to us. They were separated from

9 us, as far as I can recollect. They were not lined up

10 in the same row, in any event.

11 Q. Could you hear what happened to the men?

12 A. After that, they told us that they were

13 taking us somewhere, the women and children, and we

14 hadn't moved far from the meadow when we heard shots,

15 and I think -- it is my opinion that those men up there

16 were killed at the time.

17 Q. Did you ever see your father again?

18 A. No.

19 Q. Where were you women and children taken after

20 that?

21 A. To Buk Bijela.

22 Q. When you say "Buk Bijela," are you speaking

23 of someplace in particular?

24 A. Buk Bijela has another name and it's Mjesaja,

25 though Buk Bijela is better known. I can't really

Page 1670

1 explain whether it was a hotel, a boarding house, or

2 something like that. I just know that before the war,

3 military training took place there or something like

4 that. What Buk Bijela really was was a motel or a

5 hotel. I really couldn't say.

6 MS. KUO: With the assistance of the usher,

7 I'd like to have the witness shown Exhibit 11,

8 photographs 7415 and 7416.

9 Q. Witness, do you recognise photograph 7415?

10 A. I can't be sure.

11 Q. Would you look at 7416?

12 A. I can't be sure.

13 Q. Thank you. Witness, what were you told to do

14 when you arrived at Buk Bijela?

15 A. First they lined us up against a wall, and

16 they told us to wait. I don't know why. But anyway,

17 they came occasionally and took people off for some

18 sort of questioning.

19 Q. When you say "they," who do you refer to?

20 A. I'm referring to the Serb army.

21 Q. How did they take people out?

22 A. They would simply come and call out the names

23 and take them off.

24 Q. Were you taken off at that time?

25 A. I was taken, but not for interrogation.

Page 1671

1 Q. Who took you?

2 A. I didn't know that man before, but his name

3 was Pero. I don't know his surname. He took me away

4 to a room. Well, it was a sort of room. But he didn't

5 call out my name; he just came and took me by the hand

6 and took me off.

7 Q. Did he tell you why he was taking you?

8 A. No.

9 Q. What did he do when he took you to this room?

10 A. When he took me to the room, he first of all

11 ordered me to take my clothes off, and I didn't

12 directly refuse, but I didn't take my clothes off.

13 Then he did so. After that he raped me.

14 Q. Are you able to describe exactly what he did?

15 A. It's a little difficult for me. Well, what I

16 mean is he had sexual relations; forcibly, against my

17 will, he had sexual relations with me.

18 Q. Did he put his penis in your vagina?

19 A. Yes.

20 Q. What did he do after that?

21 A. I don't remember the exact details. I think

22 somebody else came, who was in front of the door, who

23 had been in front of the door, and who took me off

24 again to where the others were, lined up to where the

25 others were.

Page 1672

1 Q. What happened when you were returned to that

2 group?

3 A. I don't think anything happened; that is to

4 say, it was as if I wasn't present, conscious of it

5 all, what was happening to me. Although not much time

6 went by before two men turned up, who called me out by

7 name, and the name of another individual, and we were

8 asked to go to this so-called interrogation.

9 Q. That other individual, was it your sister?

10 A. Yes.

11 Q. What happened to you when you were taken out

12 again?

13 A. They took me into a sort of room, not a big

14 one; a small one, where there was a bed, a table, and a

15 couple of chairs, and I think there were four soldiers

16 in there, although people would be coming in and going

17 out all the time.

18 Q. Do you know who those four soldiers were, or

19 do you remember who they were?

20 A. I know two of them; that is to say, I didn't

21 know one of them before, but I knew his name. I know

22 the other one's name, because I knew him from before.

23 Actually, I didn't know him, but I knew who he was. As

24 for the other two, I didn't know their names.

25 Q. Can you tell us the names of the soldiers

Page 1673












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Page 1674

1 that you did know?

2 A. Dragan Zelenovic, nicknamed Zelja, and the

3 other one was Veso Miletic.

4 Q. What did they do when you were brought to the

5 room?

6 A. First of all they asked me questions.

7 Q. What kind of questions?

8 A. First of all they asked me about the other

9 inhabitants of Trosanj, where they were, and where the

10 inhabitants had hidden their weapons; do we know any of

11 the places where the other inhabitants of Trosanj could

12 have escaped to and hidden. Then they asked me how old

13 I was, my age, and whether I went to school or not.

14 Q. Did you answer those questions?

15 A. The first questions they asked me, I wasn't

16 able to answer, because I didn't know. But I only

17 answered the question -- the last questions; that is to

18 say, how old I was and whether I went to school.

19 Q. Did they ask you anything else about

20 yourself?

21 A. They asked me whether I was a virgin, and I

22 answered that I was a virgin until a few moments ago,

23 or words to that effect.

24 Q. What was their reaction when you told them

25 that?

Page 1675

1 A. I don't remember.

2 Q. What did they do?

3 A. After that Zelenovic told me to take my

4 clothes off, and when I didn't do so, he did it. And

5 then he raped me. And Miletic did the same, and the

6 other two whose names I don't know.

7 Q. What happened after they raped you?

8 A. I don't remember exactly who it was, who took

9 me out of that room, outside, to a bus where the other

10 people were already sitting, except my mother, who was

11 still outside, because she didn't want to leave without

12 me. When I arrived, I got into the bus and then they

13 took us off to the secondary school centre.

14 Q. Did you tell your mother what had just

15 happened to you?

16 A. No.

17 Q. Why not?

18 A. I think that at that time I didn't have the

19 strength to, to even look her in the eyes. Not only

20 her, but anybody, to look anybody in the eyes.

21 Q. How did you feel at that time?

22 A. It's very difficult to describe that. I know

23 that I was terribly frightened, I felt ashamed in a

24 way, and in a way I felt very, very dirty, soiled.

25 Q. Where were you all taken?

Page 1676

1 A. To the secondary school centre named Nikola

2 Tesla in Aladza.

3 Q. Is that the same school that you were

4 attending at that time?

5 A. Yes.

6 MS. KUO: With the assistance of the usher, I

7 would like to have this witness shown Exhibit 11,

8 photographs 7418 and 7419.

9 Q. Do you recognise 7418?

10 A. Yes. That's the Nikola Tesla Secondary

11 School centre in Aladza.

12 Q. And 4719 as well?

13 A. Yes, that's the same thing. It's the Nikola

14 Tesla Secondary School centre in Aladza.

15 Q. Thank you. Where were you taken when you

16 arrived by bus?

17 A. When we got to the secondary school centre,

18 they took us inside. We stood for a time, for a

19 moment, in the hall, although I don't remember

20 exactly. But I know that after that we were taken into

21 a classroom which was on the first floor, in which

22 there were no desks and chairs. There were just

23 sleeping mattresses lined up.

24 Q. When you say "they" took you, who do you

25 mean?

Page 1677

1 A. I'm thinking of the same people, the Serb

2 soldiers, although at the time there were about --

3 well, let's say about four or five of them.

4 Q. Did soldiers come to the school on other

5 occasions while you were there?

6 A. Yes.

7 Q. What did these soldiers do when they came to

8 the school?

9 A. Every time one of them would turn up, they

10 would call out the girls by their names, or the women,

11 and then they would take them off with them.

12 Q. How often did this occur?

13 A. Well, I couldn't say that it happened every

14 night. Perhaps every other night, approximately.

15 Q. Were you ever taken out by any soldiers?

16 A. Yes.

17 Q. Can you describe what happened to you?

18 A. Usually some of them would come, call out the

19 names, and take me away from the secondary school

20 centre to another house, another apartment, although on

21 one occasion I was taken just from that classroom into

22 another classroom.

23 Q. Could you describe what happened on that

24 occasion when you were taken to the other classroom?

25 Let's start with who took you out.

Page 1678

1 A. I remember that on that occasion, I think

2 there were five of them who came into the room, five

3 soldiers, and that they called out the names of five

4 girls. I think there was one woman among them -- I'm

5 not sure -- although one of the girls was returned and

6 another one taken out. I don't know for what reason.

7 Then they took us out to the other classroom,

8 all five of us. One of the soldiers took the girl

9 straight out in front of the classroom, whereas we

10 stayed in the classroom with the four soldiers.

11 Q. If I could interrupt you here and ask the

12 usher to show you Exhibit 193.

13 MS. KUO: This has already been provided to

14 Defence counsel and Chambers.

15 Q. You mentioned that there were five of you who

16 were picked out. Do you see the names of the other

17 girls on this paper, and, if so, could you give us

18 their numbers, the numbers next to their names?

19 A. Yes. They were number 75, number 50,

20 number 88, and DB. Then DB was returned and number 95

21 was taken out.

22 MS. KUO: Your Honour, I would like to make

23 sure that Exhibit 192, which was previously shown to

24 this witness, and now Exhibit 193, are entered into

25 evidence.

Page 1679

1 JUDGE MUMBA: Yes. Can we have just the

2 numbers formally, please.

3 THE REGISTRAR: [Interpretation] The document

4 will be 192, and this is confidential, as well as

5 Exhibit 193, which will also be confidential.

6 MS. KUO:

7 Q. Witness, you mentioned that one of the girls

8 was taken to the front of the classroom. Which one was

9 that? What is her number?

10 A. I don't understand your question. You mean

11 brought back?

12 Q. I'm sorry. Earlier you said that when you

13 were all brought into the separate classroom, one of

14 the girls among you was taken out to a different

15 classroom. Who was that?

16 A. It was number 50.

17 Q. Do you recall who the soldiers were who took

18 you girls out?

19 A. I remember some of them. I don't remember

20 all of them.

21 Q. Could you tell us the names or nicknames of

22 those you remember?

23 A. The first was Dragan Zelenovic, nicknamed

24 Zelja; the second was Zoran Vukovic; and the third was

25 Tuta. I think he was Janko Janjic, but I'm quite

Page 1680













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Page 1681

1 certain of his nickname. I'm not quite certain of the

2 name "Janko." I'm not absolutely certain it was

3 Janko.

4 Q. Did you know Zoran Vukovic from before the

5 war or did you know of him?

6 A. No, I didn't know him before the war,

7 although he was an individual -- there were some

8 individuals in the group of us who knew him from

9 before, and that is how I learnt his name.

10 Q. When you say "individuals among you," do you

11 mean the girls and the women?

12 A. I'm not thinking of anybody specific. The

13 group of people that was there. There were elderly

14 people, younger people. I don't remember exactly who

15 of them said they knew him.

16 Q. Do you remember how it is you learned his

17 name?

18 A. On that occasion when he came there and when

19 he went, left, I don't remember who exactly, but I know

20 that somebody -- that they said they knew him, that

21 they knew who he was, and that they knew his name and

22 surname.

23 Q. Someone who saw him that day?

24 A. That day they came into the classroom, and

25 then all the people who were in the classroom had seen

Page 1682

1 him.

2 Q. Do you recall giving a statement to

3 investigators from the Tribunal in January 1996, in

4 which you stated that you did know Zoran Vukovic by

5 sight from before the war?

6 A. Yes, I remember.

7 Q. Do you know what you meant by that or why you

8 said that?

9 A. I couldn't say. I think -- well, a lot of

10 time's gone by since then. I don't know what I meant

11 to say by saying that, because I didn't know Zoran

12 Vukovic before. Possibly I might have seen him at one

13 time in Foca, but I'm not sure of that.

14 Q. When you girls were brought into that other

15 classroom, what happened?

16 A. Zelenovic, he sort of ordered each girl where

17 to go, so that he ordered me to go into a corner where

18 Zoran Vukovic was already sitting. He ordered another

19 girl to go to another corner where Janjic Tuta was

20 already, and he, Zelenovic, and another one whose name

21 I don't know, stayed with the other two, the remaining

22 two girls.

23 Q. What happened when you went in the corner

24 where Zoran Vukovic was sitting?

25 A. I don't know who turned the light off, but

Page 1683

1 the light went off. Vukovic told me to lie down on the

2 mattress. Then he took my clothes off and then raped

3 me.

4 Q. I'm sorry to have to ask you this again, but

5 could you tell the Court specifically what he did?

6 A. He forcibly put his penis in my vagina.

7 Q. Could you hear what was happening to the

8 other girls in that room?

9 A. The only thing that I could hear was in the

10 corner, where Janjic "Tuta" was, and number 95, with

11 number 95, blows were heard, or something like that.

12 And I think Janjic swore. That's the only thing I

13 heard.

14 Q. Do you mean by "blows," that somebody was

15 hitting somebody else?

16 A. Yes.

17 Q. Did Zoran Vukovic say anything to you while

18 he was raping you?

19 A. No.

20 Q. Do you recall if he was armed? Did he have a

21 weapon?

22 A. I do not remember that, though they were

23 never without arms.

24 Q. What happened after Zoran Vukovic raped you

25 in that classroom?

Page 1684

1 A. Then they simply took us back to the

2 classroom.

3 Q. The one where the other women and children

4 were?

5 A. Yes.

6 Q. Did you tell your mother what had happened to

7 you?

8 A. No.

9 Q. Was there anything about the way you looked

10 that might have led her to conclude what happened to

11 you?

12 A. I think so, yes. She never asked me, nor did

13 I ever tell her, but I think she knew, with some

14 certainty.

15 Q. How did you feel?

16 A. As I did every time.

17 Q. Did you ever see Zoran Vukovic again?

18 A. I think I saw him maybe two or three times,

19 but I don't remember the exact occasions or dates. I

20 just remember one occasion when I was in the apartment

21 in the Brena building in Foca, but that was for a very

22 brief encounter.

23 Q. Is that when you were in Klanfa's apartment?

24 A. Yes.

25 Q. Could you describe how it is you saw Zoran

Page 1685

1 Vukovic at that time? What was he doing?

2 A. The time he came to Klanfa's apartment, I

3 think he came wearing Klanfa's clothes, which were

4 bloodstained, and he said that Klanfa had been wounded

5 in battle, or something to that effect, that he had

6 been shot in the leg and wounded.

7 Q. Did he give you anything at that time?

8 A. I don't understand.

9 Q. Did Zoran Vukovic say anything else to you

10 when you saw him in that apartment?

11 A. What I can remember is that he explained that

12 Klanfa had been wounded and that he would be in the

13 hospital for a time, and that Klanfa's clothes needed

14 to be washed. I don't remember anything else.

15 Q. Are you able to recognise Zoran Vukovic

16 today?

17 A. Perhaps.

18 Q. Would you please look around the courtroom,

19 take your time, and tell us if you recognise Zoran

20 Vukovic.

21 A. I think I do.

22 Q. Can you please describe what he's wearing and

23 where he's seated?

24 A. He's the second in the last row, from that

25 side [indicates].

Page 1686












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Page 1687

1 Q. Do you mean from the right? You appear to be

2 indicating from the right.

3 A. Yes, from the right, if I look at them this

4 way; facing them, from the right.

5 Q. Can you describe what he's wearing, please.

6 A. A white shirt, I think it's a dark blue

7 blazer, and a dark blue tie with a pattern on it.

8 MS. KUO: May the record reflect that the

9 witness has identified the accused Zoran Vukovic.


11 MS. KUO:

12 Q. Were you ever taken out of that classroom in

13 the high school again?

14 A. Yes. I don't remember everything too well,

15 but I remember once when Zelenovic took us to an

16 apartment in the Brena building, and the other

17 occasions I can't remember, though I know that that was

18 not the only time when I was taken out of the secondary

19 school centre.

20 Q. And each time that you were taken out of the

21 secondary school centre, what happened to you?

22 A. Each time when I was taken out of the

23 secondary school centre, I was always raped.

24 Q. Did you see other girls being taken out of

25 the secondary school centre?

Page 1688

1 A. Yes. They never took me out alone; there was

2 always someone with me, another girl.

3 Q. How long did you stay at the high school?

4 A. I don't remember that too well. I don't

5 think it was for a long time. Maybe two weeks, but I'm

6 not sure of that.

7 Q. During that time did you feel free to just

8 leave?

9 A. No.

10 Q. Can you describe why not?

11 A. You mean the secondary school centre?

12 Q. Yes.

13 A. In the first place, there were soldiers there

14 always, and at the entrance there were soldiers on

15 guard, guarding the entrance, though there weren't too

16 many Muslims left at the time, so it wasn't safe to go

17 out into the street.

18 Q. Were you all Muslims who were detained inside

19 the secondary school?

20 A. Yes.

21 Q. Where were you taken when you were taken from

22 the secondary school after those two weeks?

23 A. They took us to the sports hall, Partizan.

24 First they took us there to clean up the hall, and then

25 they transferred us there to stay.

Page 1689

1 Q. Did they take everybody who was detained with

2 you at the high school?

3 A. Yes.

4 Q. Approximately how many people were with you

5 at Partizan Sports Hall?

6 A. At the time, at first, there were only people

7 from Trosanj. I really couldn't say how many. Not

8 many, because all of us could sleep in a single

9 classroom in the high school. But later, some more

10 people were brought in, people I didn't know, who were

11 from the villages surrounding Foca.

12 Q. Were there any men among you?

13 A. I think there were some older men, but I

14 remember only two of them. One was very old, and the

15 other one was sick.

16 Q. While you were at Partizan, did you feel free

17 to leave?

18 A. No. The same applies as to the high school,

19 the guards were always there, and to go into the street

20 or anywhere else was unsafe.

21 MS. KUO: With the assistance of the usher, I

22 would like to have this witness shown Exhibit 11,

23 photograph 7302.

24 Q. Do you recognise that photograph?

25 A. Yes. That is the Partizan Sports Hall.

Page 1690

1 Q. Thank you. Did soldiers also come to

2 Partizan and take girls out?

3 A. Yes.

4 Q. How often did they do that?

5 A. Sometimes it was every night, sometimes every

6 other night. I can't remember exactly.

7 Q. What would they do when they came to the hall

8 to take girls out?

9 A. They would come inside looking for particular

10 persons, girls. They would select them, as many as

11 they wanted, and then they would take them with them.

12 Q. Do you know the names or nicknames of the

13 soldiers who did this?

14 A. I remember Gojko Jankovic. I remember a man

15 called Zaga; his surname is Kunarac. I'm not sure of

16 his first name. I think it's Dragan or something like

17 that. Then also Janjic Tuta would come there. I think

18 Gagovic was there twice also. I can't remember any

19 others.

20 Q. The person you identified as Zaga, surname

21 Kunarac, did you know him before the war?

22 A. No.

23 Q. Are you able to describe him?

24 A. It's rather hard. I know he wasn't very

25 tall. He wasn't too skinny or too fat. I think he had

Page 1691

1 dark brown hair. I can't remember any other specific

2 trait.

3 Q. How often did he come to Partizan?

4 A. He wouldn't come every night. Maybe every

5 third night, though I'm not sure of that.

6 Q. When Zaga came, did he come alone or with

7 other soldiers?

8 A. With other soldiers.

9 Q. And what would he do when he came to

10 Partizan?

11 A. Usually he would pick up a couple of girls or

12 three of them. He would select them and take them with

13 him.

14 Q. Did Zaga, surname Kunarac, ever take you out

15 of Partizan?

16 A. Yes.

17 Q. Do you recall where he took you?

18 A. I just remember two occasions. I remember

19 precisely those two occasions, not the others. One of

20 those occasions was in a house in Aladza, and a second

21 time he took me to a house near the bus station.

22 Q. Could you describe for us the first time when

23 he took you to the house in Aladza? First, where was

24 the house?

25 A. The house was not far from the high school

Page 1692













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Page 1693

1 and not far from the Aladza mosque. The house is to

2 the right when you're going in the direction of the

3 high school, and to the right there is a small street,

4 and it is the first house on the corner, the house he

5 took me to. The windows were facing the street.

6 Q. Could you tell who used to live in that

7 house?

8 A. I'm not sure of that, though in the yard of

9 the house or, rather, on the ground floor there was a

10 kind of workshop. I think it had to do with sewing

11 clothes or footwear or something like that, although

12 I'm not sure.

13 Q. When Zaga Kunarac took you to this house,

14 what did he do?

15 A. Zaga Kunarac was never alone, and I was never

16 alone. There were always several girls with me.

17 Usually there would be several soldiers there. Then,

18 of course, I should say, they would rape each one of

19 us.

20 Q. On this particular incident, do you remember

21 what girls were taken with you?

22 A. Yes. It was number 75, 50, DB, and myself.

23 Q. Do you remember when this was?

24 A. I don't remember that any longer, but I do

25 remember that I think it was the day before they took

Page 1694

1 us to Miljevina.

2 Q. Was that the first time that you were taken

3 to that house in Aladza, the day before you were taken

4 to Miljevina?

5 A. No. That was the last time when I was in the

6 house in Aladza, but the previous occasions that I went

7 to that house, I cannot remember exactly with whom and

8 when and how.

9 Q. Could you tell what soldiers were in that

10 house in Aladza, where they came from?

11 A. I think they were from Montenegro. They had

12 a different accent from ours, though they also said

13 where they came from. I think most of them were from

14 Niksic, yes.

15 Q. When you were taken -- on the occasions when

16 you were taken to the house in Aladza, who took you?

17 A. It was usually Zaga Kunarac. We would be

18 taken back, but I don't know by whom.

19 Q. Before the last time that you were taken to

20 the house in Aladza and the other times, did Zaga ever

21 rape you?

22 A. Yes.

23 Q. You mentioned that Zaga also took you to an

24 old house by the bus station. Do you remember when

25 that was?

Page 1695

1 A. I don't remember exactly when that was, but

2 this was before we were taken to this house in Aladza,

3 that time I have described, but I don't remember when

4 this was.

5 Q. Were you taken alone or with other girls to

6 the house by the bus station?

7 A. I was there with two other girls. They were

8 number 50 and DB.

9 Q. What happened to you in that house?

10 A. I was raped by two soldiers, one of whose

11 name I don't know, and the other was Zaga Kunarac.

12 Q. Do you know what happened to the other girls

13 when they were taken with you to that house?

14 A. I don't know about DB, but number 50 told me

15 that she was also raped by Zaga Kunarac.

16 Q. You mentioned being taken to other places by

17 Zaga Kunarac that you no longer recall. Is that right?

18 A. Yes.

19 Q. Did he rape you those times as well?

20 A. I don't remember that.

21 Q. But you do remember that he took you out of

22 Partizan; is that right?

23 A. Yes. I do remember that he came and took me

24 out several times, but I remember two occasions with

25 precision.

Page 1696

1 Q. Do you recall a time when a female journalist

2 came to Partizan?

3 A. Yes, I remember that.

4 Q. Do you remember what she looked like?

5 A. She was very slim, blonde. She wore very

6 tight clothing, tight-fitting clothing. She was

7 heavily made up. That was it more or less.

8 Q. Was Zaga Kunarac with her when she came to

9 the Partizan?

10 A. I don't remember that, although I know that

11 she asked questions about him.

12 Q. What questions did she ask about him?

13 A. The first thing she asked was whether -- how

14 we were in Partizan, whether we were being mistreated

15 by anybody, whether soldiers came to mistreat us. I

16 don't remember exactly how she came to mention Zaga's

17 name on that particular occasion, but I do remember

18 that someone out of this group of people said that he

19 would come and take girls out with him.

20 Q. Do you recall who spoke with that journalist?

21 A. I don't remember that, no.

22 Q. Did you talk with her?

23 A. No.

24 Q. Did you ever see her again?

25 A. Yes, I saw her once again in Miljevina.

Page 1697

1 Q. Where in Miljevina?

2 A. In Karaman's House, where we were taken to

3 after that night in the house in Aladza.

4 Q. What was she doing in Karaman's House?

5 A. I don't remember that she was doing anything

6 special; she was just sitting there. I don't think she

7 talked much, but I don't remember really anything much

8 about that, any details.

9 Q. When you saw her again, was she acting like

10 she was a journalist?

11 A. No. She looked like an ordinary woman, not

12 like a journalist. There was nothing specific, but she

13 didn't behave in that way. She said that she was --

14 she didn't say that she was there because of her work

15 or anything like that.

16 Q. Now, you mentioned the last time you were

17 taken to this house in Aladza as being the day before

18 you were taken to Miljevina. Do you recall that?

19 A. I can't be certain, but I think it was the

20 day after we were taken to the house in Aladza for the

21 last time.

22 Q. And by that day, what do you mean happened?

23 A. I'm afraid I didn't understand you.

24 Q. I'm afraid I didn't phrase it correctly. The

25 last time you were taken to Aladza, the house in

Page 1698

1 Aladza, was the night before you were taken to

2 Miljevina; is that what you're saying?

3 A. Yes.

4 Q. Did anything happen to the mosque that night

5 that makes you remember that night in particular?

6 A. I know that on one occasion the mosque was

7 blown up or something like that, although I can't say

8 that it occurred exactly on that particular night.

9 Although I do remember that night, because -- I don't

10 know how exactly, but I think that that night when we

11 were in the house at Aladza, and the next day in

12 Miljevina, I think -- I don't know -- in some strange

13 way I think they might be connected.

14 Q. All right, then. Let's talk about that last

15 time you were in the house before being taken to

16 Miljevina. Who took you to the house?

17 A. Kunarac.

18 Q. Were you taken alone or with other girls?

19 A. With others.

20 Q. Could you tell us their numbers, please?

21 A. 75, 50, DB, and myself.

22 Q. Were you arrived at the house, did you see

23 any other girls?

24 A. I just remember one girl -- she was already

25 there when we arrived -- and that was number 190.

Page 1699

1 Q. Were there also soldiers at the house?

2 A. Yes.

3 Q. Were you raped that night at the house?

4 A. Yes.

5 Q. Who raped you?

6 A. I remember Kunarac; I remember an older man,

7 whose name I don't know; and I remember a younger man

8 whose surname was Toljic, I think, and he was nicknamed

9 Tolja. And those are those three, the three who I

10 remember raped me.

11 Q. In what room did Kunarac rape you?

12 A. When you go into the apartment, on the

13 left-hand side is the kitchen and on the right-hand

14 side is the room, and it was in this room that Kunarac

15 raped me.

16 Q. Could you tell if Kunarac was in charge of

17 the other soldiers, or what his relationship with them

18 was?

19 A. It was my impression that when Zaga would

20 come to Partizan, or when he took us away to the house

21 in Aladza, that he was the one issuing the orders, and

22 I felt -- I had the feeling that the other soldiers who

23 were there listened to him.

24 Q. How long were you kept in the house in Aladza

25 that night?

Page 1700

1 A. I think it was until morning. I think the

2 next morning we were taken away to Miljevina, but I

3 can't be certain.

4 Q. You can't be certain of exactly when you were

5 taken to Miljevina, or that you were taken at some

6 point?

7 A. No. I can't be certain when.

8 Q. Do you recall who took you to Miljevina?

9 A. I remember Pero Elez, and I remember that

10 there were two other men too. I think there were two

11 other men, but I can't remember who they were.

12 Q. Do you remember being told why you were being

13 taken to Miljevina?

14 A. No. They didn't tell us. They didn't tell

15 us where we were going or why we were going.

16 Q. Who was taken there with you?

17 A. Taken with me was number 75, DB, and number

18 190.

19 Q. Where in Miljevina were you taken?

20 A. We were taken to a house. I don't know how

21 it came to be known as Karaman's House, but I think

22 that Karaman was the surname of the man who owned the

23 house, or who was the owner of the house before the

24 war.

25 MS. KUO: With the assistance of the usher, I

Page 1701












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13 the English and French pagination.













Page 1702

1 would like to have this witness shown Exhibit 11,

2 photograph 7355.

3 Q. Do you recognise what is in that photograph?

4 A. Yes. That's Karaman's House in Miljevina.

5 Q. Thank you. Was there anyone at Karaman's

6 House when you were taken there, when you arrived?

7 A. Yes. There was another girl there, although

8 I don't remember her name anymore. And I don't think I

9 see her here.

10 Q. Were there also soldiers there?

11 A. Yes. I don't know exactly how many. I think

12 there were about two or three of them when we arrived.

13 Q. What were they doing, the soldiers?

14 A. I don't understand your question.

15 Q. Did anyone live at Karaman's House?

16 A. It looked as if they did, yes. Two or three

17 of them lived in that house. Yes, that's how it

18 appeared.

19 Q. Do you recall who those two or three soldiers

20 were who lived there?

21 A. One of them was Radovan Stankovic, nicknamed

22 Raso. The other was Nedzo Samardzic, I think. And the

23 third was Nikola. I think his surname was Brcic,

24 although I'm not sure.

25 Q. Did other soldiers come to this house?

Page 1703

1 A. Yes.

2 Q. What did the soldiers do when they came to

3 this house?

4 A. Usually they would select one the girls and

5 take her off to the second floor.

6 Q. How long were you kept at Karaman's House?

7 A. I can't remember that exactly. A month and a

8 half, two months perhaps, although I'm not quite sure.

9 Q. During that time, what happened to you

10 there?

11 A. I, like all the other girls in Karaman's

12 House, was raped by the Serb soldiers. I think that

13 after a certain amount of time, that two other girls

14 were brought in, or three, but at any rate, all of them

15 were raped either every night or every other night;

16 often.

17 Q. Are you able to count how many times you were

18 raped in Karaman's House?

19 A. I don't think that is possible.

20 Q. Did Zaga Kunarac ever come to Karaman's

21 House?

22 A. I remember only one time when he was there.

23 I remember that he was wounded or injured and that he

24 had a cast on a part of his body. He had something

25 bandaged up somewhere, although I don't remember very

Page 1704

1 well. I remember that one time. As for the others,

2 whether he came or not, I couldn't say.

3 Q. What did he do that time when he came, that

4 you remember?

5 A. I don't remember exactly why he came and what

6 he was doing in that house exactly. All I remember is

7 that he took me into a room on the upper floor and that

8 he raped me there.

9 Q. Was there anything in particular about that

10 incident that made an impression on you?

11 A. Well, I think I thought about how an

12 individual who was -- I wondered how an individual who

13 had been wounded or injured could do something like

14 that.

15 Q. Would you be able to recognise Zaga Kunarac

16 today?

17 A. Perhaps.

18 Q. Could you please look around the courtroom

19 and tell us if you see him?

20 A. Yes.

21 Q. Could you please describe where he's seated

22 and what he's wearing?

23 A. He's sitting on the left-hand side, and the

24 second man there. I think he's got a dark blue blazer

25 on, a white shirt. He's got a tie with a pattern on

Page 1705

1 it, something reddish, something like that.

2 MS. KUO: Let the record reflect that the

3 witness has identified the accused Dragoljub Kunarac.


5 MS. KUO:

6 Q. During the time that you were kept at

7 Karaman's House, were there other girls there as well,

8 and if so, could you give us their names or initials on

9 the paper before you?

10 A. Yes, there were other girls there as well. I

11 knew the ones who had come with me, number 75, DB, and

12 190, although 190 was returned from the house after a

13 short while. And afterwards, after some time, others

14 were brought; that is to say, AB, AS, and one other one

15 whose name I don't see here. Yes. And number 132, and

16 another girl whose name I can't see on the list.

17 MS. KUO: With the assistance of the usher,

18 perhaps this witness could be given a blank piece of

19 paper, and that paper can be marked as Exhibit 194. I

20 would ask the witness to write down the name of this

21 girl whose name she does not see on the exhibit before

22 her.

23 THE REGISTRAR: [Interpretation] This piece of

24 paper will be 194, and it will be under seal.

25 MS. KUO:

Page 1706

1 Q. Witness, you mentioned someone identified as

2 AB. Do you know how old she was at that time?

3 A. I couldn't say how old she was exactly, but I

4 think she was either 12 or 13.

5 Q. Could you tell who was in charge of Karaman's

6 House?

7 A. I think it was Pero. That's what he said, in

8 fact. He said that special people had the right to

9 enter that house or that only those people that he

10 allowed could enter.

11 Q. Were you given instructions what to do if

12 other people tried to enter?

13 A. I think Pero gave us the telephone number of

14 the hotel in Miljevina -- I think that's where they

15 lived or something like that, I don't know exactly --

16 in case somebody came. He told us that if anybody

17 came, we should phone him up and tell him.

18 Q. The soldiers who came and raped you, did they

19 appear to be among those that you described as being

20 allowed to be there?

21 A. Yes.

22 Q. Was the door at Karaman's House locked?

23 A. The door wasn't locked. I think it was the

24 kind of door that you could open from the inside but

25 not from the outside. Only if you had a key could you

Page 1707

1 open if from the outside.

2 At first we weren't allowed to go out of the

3 house, although later on we were able to go out into

4 the garden or onto the terrace.

5 Q. Why didn't you just leave the house, go away

6 from there?

7 A. Once again, for the same reasons. You didn't

8 know where to go or where this would lead you, this

9 attempt to escape. Nothing was safe. You wouldn't

10 know where it would lead to.

11 Q. Did you also have to do housework in

12 Karaman's House?

13 A. Yes, cooking, washing, laundering, cleaning

14 up generally, things like that.

15 Q. When were you taken away from Karaman's

16 House?

17 A. I can't remember the exact time of that

18 either, but I think it was perhaps the end of September

19 or the beginning of October, but I'm not quite sure.

20 Q. Where were you taken?

21 A. To Foca. First of all they took us to an

22 apartment in a settlement called Ribarsko, and the next

23 day we were taken to Klanfa's apartment, which is

24 located in the Brena building.

25 Q. Who took you out of Karaman's House, if you

Page 1708

1 remember?

2 A. Yes, I remember Zelenovic. I think that

3 Gojko Jankovic was also there, and Tuta, but I can't be

4 quite certain of that.

5 Q. Were you taken alone or with other girls?

6 A. With other girls. They took me, number 75,

7 AB, and AS.

8 MS. KUO: Your Honour, I see that we've come

9 to our lunch break, and perhaps this would be a good

10 time to pause.

11 JUDGE MUMBA: Yes. We're going to have our

12 lunch break and resume in the afternoon at 1430 hours.

13 --- Luncheon recess taken at 12.59 p.m.













Page 1709

1 --- On resuming at 2.29 p.m.

2 JUDGE MUMBA: Good afternoon, Witness. We

3 are proceeding with the Prosecution

4 examination-in-chief.

5 MS. KUO: Thank you, Your Honour.

6 Q. Witness, before the lunch break you described

7 a number of incidents in which Kunarac raped you when

8 he took you from Partizan. Could you tell the Court

9 specifically what he did, or what you meant by "rape"?

10 A. What I mean by "rape" is that he forced his

11 penis into my vagina by force.

12 Q. And when Kunarac raped you at Karaman's

13 House, was it the same thing?

14 A. Yes.

15 Q. While you were detained at the high school,

16 was there ever a time when Zelenovic took you and 75

17 out alone, and Zelenovic and Zoran Vukovic raped you?

18 A. Could you repeat the question, please.

19 Q. While you were detained at the high school,

20 do you remember if there was ever a time when Zelenovic

21 took you and 75 out alone, and Zelenovic and Zoran

22 Vukovic raped you?

23 A. I remember that once Zelenovic took me and

24 75, and that we were raped then, but I don't remember

25 whether Vukovic was present.

Page 1710

1 Q. While you were detained at Partizan, do you

2 remember being raped by four men, taken out and being

3 raped by four men at the same time, including Zelenovic

4 and Zoran Vukovic?

5 A. No, I don't remember.

6 Q. Witness, before the break you were describing

7 to us that you were taken away from Karaman's House and

8 brought to a flat in Foca, in the area known as

9 Ribarsko; is that right?

10 A. Yes.

11 Q. What happened to you at that flat?

12 A. I don't remember Zelenovic. I think Gojko

13 Milanovic and Tuta were there. I was raped by

14 Zelenovic. I can't remember about Jankovic and Janjic.

15 Q. Do you know if the other girls were also

16 raped there?

17 A. Yes, the other girls were also raped.

18 Q. Were you taken away from that flat?

19 A. Yes. The next day we were taken from that

20 flat to another one.

21 Q. Who took you from that flat to another one?

22 A. Radomir Kovac and Jagos Kostic.

23 Q. Where did they take you?

24 A. They took us to the Brena building, to an

25 apartment on the 4th floor.

Page 1711

1 Q. Did they take all four of you?

2 A. I think so, yes.

3 MS. KUO: With the assistance of the usher,

4 I'd like to show this witness Exhibit 11, photograph

5 7401.

6 Q. Do you recognise what's in that photograph?

7 A. I think it is the Brena building.

8 Q. Are you able to see the apartment that you

9 were brought to, or at least the balcony of that

10 apartment, in this photograph?

11 A. I'm sure that this is the Brena building, but

12 I cannot be sure whether that is the right entrance to

13 that building, I mean the entrance to that apartment.

14 Because there were several entrances to that building.

15 Q. Do you recall what floor the apartment was

16 on?

17 A. On the 4th floor.

18 Q. That's the 4th floor above the ground floor;

19 is that right?

20 A. Yes, the 4th floor above the ground floor,

21 yes.

22 Q. Thank you very much.

23 MS. KUO: May I just make a request that the

24 light on the ELMO be turned off so there's no glare on

25 the witness. Thank you.

Page 1712

1 Q. When you were taken to this apartment in the

2 Lepa Brena, what did Kovac do to you there?

3 A. Kovac and Kostic, when they brought us to

4 that apartment, I remember being raped by Kovac. I

5 also know that number 75 was raped by him. As for the

6 other two, I know that AS was raped by Kostic, and for

7 the fourth, I'm unable to say.

8 Q. How long were you kept at that apartment?

9 A. I'm not quite sure, but roughly about four

10 months.

11 Q. During those four months, how often did

12 Radomir Kovac rape you?

13 A. That depended. Sometimes every night.

14 Sometimes Kovac was absent, he would be away from the

15 flat for a couple of days, but if he was in the flat,

16 then it would usually happen every night.

17 Q. I apologise for having to ask you this again,

18 but when you use the word "rape," could you tell the

19 Court specifically what you mean?

20 A. I think he forced his penis into my vagina

21 against my will.

22 Q. Did he also force his penis into your mouth?

23 A. Yes.

24 Q. In addition to these rapes, did Klanfa do

25 anything else to you girls?

Page 1713

1 A. I remember Klanfa and Kostic on one occasion

2 forcing us girls to strip, and on one occasion, Kovac

3 forced me alone to strip, to climb on the table, and to

4 dance.

5 Q. The incident that you described when Kovac

6 and Kostic forced all of you girls to strip, could you

7 tell the Court in more detail what they forced you to

8 do?

9 A. He forced us to take our clothes off, all our

10 clothes, to stand one next to another. I can't

11 remember whether we had to stand on the bed or on the

12 floor. I can't remember that exactly, but I do

13 remember that he forced us to take all our clothes off

14 and to stand there naked.

15 Q. Did he also turn on music?

16 A. That time I can't remember whether he did or

17 not.

18 Q. And what did he do after he forced you all to

19 take your clothes off?

20 A. I think they just sat there and watched,

21 though I'm not -- I didn't really see that. I didn't

22 watch what they were doing.

23 Q. Did Kovac or Kostic have a weapon with them

24 at that time?

25 A. They always had weapons with them.

Page 1714












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Page 1715

1 Q. What kind of weapons?

2 A. I think they had rifles and pistols and

3 knives.

4 Q. Was there another time when Kovac forced all

5 of you to take your clothes off?

6 A. Yes. This was in another apartment. I think

7 it was somewhere in Gornje Polje, although I'm not

8 quite sure about that. I think he forced us to strip

9 and to stand on the table, and when he said that he

10 would take us through the town naked and take us to the

11 river where he would kill us.

12 Q. When you say "he," who are you referring to?

13 A. I'm referring to Kovac.

14 Q. And you said that he would take you through

15 the town to the river. Did he, in fact, do that?

16 A. Yes, he did that, though when he said that he

17 would do that, I can't remember whether it was him or

18 Kostic who said that we should put our clothes on and

19 then we did. After we put our clothes on, he took us

20 to the river.

21 Q. What happened at the river?

22 A. I don't remember that, actually, very well.

23 I just know I was terribly frightened, and I just kept

24 thinking how they were going to do that, in what way.

25 I know that shortly after that, he took us back to his

Page 1716

1 apartment.

2 Q. And by "he" you mean Kovac as well; right?

3 A. Yes.

4 Q. You mentioned one other incident when Kovac

5 alone forced you to take your clothes off. Can you

6 describe for the Court what happened at that time?

7 A. Yes. I was alone at the time in the room.

8 He forced me to take my clothes off, to climb on the

9 table, and to dance to music. He was sitting on the

10 bed with a pistol pointed at me.

11 Q. What kind of music was it, do you remember?

12 A. I think it was typical -- our music. Our

13 typical music. Folk music.

14 Q. When you say "our," what do you mean by

15 "our"?

16 A. I mean music from Bosnia.

17 Q. When you were forced to do this, how did you

18 feel?

19 A. It is again difficult to describe. I was

20 frightened. I was ashamed. I don't know what to say.

21 Q. Did you feel like you could control what was

22 happening to you in any way?

23 A. No.

24 Q. Did you feel like Kovac owned you?

25 A. Yes.

Page 1717

1 Q. Can you describe why you felt that way?

2 A. That too is rather difficult to explain,

3 since in the apartment there were only Kovac and Kostic

4 and only me and AS. We couldn't go out anywhere; the

5 doors were locked. We knew that Kovac would take me to

6 one room and Kostic would take AS to the other room.

7 That was how it was until the very end.

8 Q. You mentioned earlier that when you were

9 first brought to the apartment there was, in addition

10 to you and AS, also 75 and AB. Is that right?

11 A. Yes.

12 Q. When were 75 and AB taken away?

13 A. I cannot remember the exact time, but I think

14 it was shortly after we came to Klanfa's apartment. I

15 don't remember for how many days they stayed there

16 exactly.

17 Q. Do you remember the circumstances under which

18 they were taken away, how they were taken away?

19 A. I don't remember that too well. I think they

20 simply came, picked the two of them up and took them

21 away. I don't remember anything in particular.

22 Q. In addition to the time that you've described

23 to us when you were taken down to the river, were you

24 or any of the other girls also taken outside the

25 apartment?

Page 1718

1 A. At the time when I and AS were alone in that

2 apartment, I remember that we left the apartment

3 several times. And while the other two girls were with

4 us, I think we were taken out perhaps two or three

5 times. I don't remember exactly.

6 Q. You said it was just you and AS, and you left

7 the apartment. Did you leave alone or were you taken

8 out?

9 A. I think they took us out. We couldn't leave

10 the apartment alone because we were locked in.

11 Q. On those occasions, where were you taken?

12 A. I remember once they took us to an apartment

13 in Donje Polje; once they took us to another apartment,

14 which I can't really remember; and several times they

15 took us out to cafes and pubs and the like.

16 Q. What would they do when they took you to the

17 cafes and pubs?

18 A. They would simply tell us to get dressed.

19 Usually they would force us to put on some hats or

20 something with the signs of their army or something

21 like that, and then they would simply take us there to

22 a cafe, a coffee bar. Nothing special. We would

23 simply go there and sit there and then come back.

24 Q. When you say "they," was it Kovac and

25 Kostic?

Page 1719












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Page 1720

1 A. Yes.

2 Q. While you were kept in that apartment, did

3 Kovac or Kostic ever hit or beat you?

4 A. Kostic hit me, I remember, once. Once he

5 threatened with a knife, that he would cut up my face.

6 I remember that time. Kovac, I don't remember that

7 Kovac ever hit me.

8 Q. Did Kostic or Kovac ever threaten you in

9 other ways?

10 A. There were a couple of times when they

11 threatened that they would kill us, slit our throats.

12 Q. And before AB and 75 were taken away, could

13 you see what effect all this was happening [sic] on AB?

14 A. I don't understand the question.

15 Q. Did you see, or do you know what kind of

16 physical or mental state AB was in by the time she

17 left, was taken away?

18 A. I couldn't really tell you about her physical

19 state. There were no visible things that she could

20 say. As for her mental state, it was quite evident on

21 her that she wasn't all right. She didn't talk much.

22 Sometimes she behaved strangely. And in Karaman's

23 House she couldn't sleep, and when she did sleep, she

24 had nightmares.

25 Q. Are you able to recognise Kovac today?

Page 1721

1 A. Yes.

2 Q. Would you please look around the courtroom

3 and tell us if you recognise him.

4 A. Yes.

5 Q. Would you please describe what he's wearing.

6 A. A dark grey suit, I think it's a white

7 shirt -- I think it's white. I'm not sure -- and a

8 grey tie with a dark grey and light grey pattern on it.

9 MS. KUO: Would the record reflect that this

10 witness has identified the accused Radomir Kovac.


12 MS. KUO:

13 Q. When were you finally taken away from Kovac's

14 apartment?

15 A. Again, I don't remember the exact date. I

16 think it was sometime in February, perhaps mid-February

17 or end of February. I don't remember.

18 Q. Do you know what the circumstances were or

19 how you came to be taken away?

20 A. I remember that there were two of them, two

21 soldiers from Montenegro, who spoke to Kovac and

22 Kostic, and that they wanted to take us, though Kovac

23 and Kostic wanted money in exchange. I think in the

24 end AS was sold by Kovac and Kostic to these

25 Montenegrins for 500 German marks, for one.

Page 1722

1 Q. And what happened to you?

2 A. You mean me and AS?

3 Q. Yes.

4 A. I don't know whether that was the next day

5 exactly, but not long after that we were taken to

6 another apartment -- I think it was also in the Brena

7 building -- and those Montenegrins were staying in that

8 apartment. I think we spent the night there, one

9 night, and that they then took us to another apartment

10 at Brod, and I think we had to wait there for those

11 Montenegrins to take us across the border to

12 Montenegro.

13 Q. Now, you mentioned that you knew AS was sold

14 for 500 German marks. Do you know if you were sold as

15 well?

16 A. Yes. Both of us were sold for that sum.

17 Q. Did you actually hear the negotiations

18 between the two Montenegrins and Kostic and Kovac?

19 A. Yes. I heard the negotiations, though not

20 all of them, because we were not in the same room. AS

21 and me were not in the same room in which they were

22 negotiating, but we heard a part of the conversation.

23 Q. Were you taken over the border into

24 Montenegro?

25 A. Yes. I don't remember exactly for how long

Page 1723












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Page 1724

1 we waited in the apartment at Brod, but finally those

2 Montenegrins escorted me and AS across the border, or,

3 to be more precise, to Niksic.

4 Q. When you say "escorted," how did they take

5 you over the border?

6 A. We went by car. And there was another

7 Montenegrin there with us, also from Niksic. I think

8 that they were purchasing weapons on that occasion as

9 well, because they were hiding the weapons in the car,

10 under the seat, in the boot, and so on. And they told

11 us that when we reached the border of Bosnia and

12 Montenegro, that we should say that we were Serb, and

13 they gave us names that we should use, and that we

14 should say we had no ID documents, that they had been

15 destroyed, or something to that effect.

16 When we reached the border, there weren't too

17 many problems over this. We spent maybe 15 minutes

18 there and then they took us to Niksic.

19 Q. What happened to you in Niksic?

20 A. In Niksic we lived in the apartment of one of

21 these Montenegrins, and a few days after that we

22 started working as waitresses in a coffee bar. We did

23 that the whole time, until we were taken to Podgorica.

24 Q. When you say you started working as

25 waitresses, were you forced to or did you do that

Page 1725

1 voluntarily?

2 A. No, it wasn't voluntarily; it was forcibly.

3 Q. Were you ever paid for that work?

4 A. No. They never paid us for that work, but me

5 and AS could earn a small sum of money from tips left

6 by customers.

7 Q. What happened to you when you were taken to

8 Podgorica?

9 A. We were taken to an apartment in Podgorica,

10 in a building. I don't remember the exact floor the

11 apartment was on. I remember that there was another

12 man there, a Montenegrin. But he was working and -- he

13 worked, and he was only in the apartment for three or

14 four hours during the afternoon.

15 Q. Were you finally able to escape?

16 A. Yes. We didn't spend long in Podgorica. I

17 don't know exactly how long, but not a long time. The

18 Montenegrins who brought us there, brought us to Niksic

19 and to Podgorica, weren't there at the time. They only

20 came perhaps once. And as there was nobody there,

21 nobody in the apartment at about 3.00 in the afternoon,

22 and the apartment wasn't locked, I and AS were able to

23 go outside. And I remember that we were very scared at

24 first. We wondered who we would meet in the street.

25 But the second time was easier. Podgorica,

Page 1726













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Page 1727

1 at that time, was not in a state of war. The people

2 behaved normally. So that we felt relieved in a way.

3 On one of the subsequent occasions, we tried

4 to find a way of getting out of there somehow, and I

5 remember that we found the bus stop, the bus station,

6 and we looked at the timetable and how much the tickets

7 cost, and we decided to leave one day, quite simply, to

8 leave there.

9 Q. And did you do that?

10 A. Yes, that's what we did. I think it was

11 sometime around the 5th of April when we left Podgorica

12 for Rozaje.

13 Q. Now, the two Montenegrins who bought you from

14 Kostic and Kovac, did they ever sexually assault you?

15 A. Yes, both of us, both myself and AS. They

16 raped us. All three of those Montenegrins raped us,

17 even the fourth one who lived in Podgorica.

18 Q. As a result of all the rapes that you

19 suffered during these many months, did you continue to

20 suffer?

21 A. In a way, yes. I think that I'm once again

22 at a point where I find it difficult to explain. I

23 think that I have decided to try and leave many of

24 those things behind me somewhere, although within me, I

25 still have and there will always be traces of

Page 1728

1 everything that happened to me. I think that for the

2 whole of my life, all my life I will have thoughts of

3 that and feel the pain that I felt then and still

4 feel. That will never go away.

5 MS. KUO: Those are all the questions from

6 the Prosecution, Your Honours.

7 JUDGE MUMBA: Cross-examination by Defence

8 counsel. Who will begin?

9 Cross-examined by Ms. Pilipovic:

10 Q. Good afternoon, Witness.

11 MS. PILIPOVIC: [Interpretation] Your Honours,

12 I would like to ask the witness to approach the

13 microphone, because I found it difficult to hear her.

14 She speaks quietly. So with all due respect, could she

15 just come closer to the microphone, please. Thank

16 you.

17 Q. Thank you, Witness. According to the

18 information you gave to the Prosecution and the

19 investigators of the Tribunal -- you gave two

20 statements, in fact. Do you remember whether they were

21 two or --

22 A. Yes. I remember that there were two

23 statements.

24 Q. Did you give any statements to anybody else?

25 A. No.

Page 1729

1 Q. Apart from those two?

2 MS. PILIPOVIC: [Interpretation] I should now

3 like to ask the usher to show the witness ...

4 THE REGISTRAR: [Interpretation] We need to

5 know whether these are the witness statements from 19th

6 and 20th of January, 1996, and 4th and 5th of May,

7 1998.

8 MS. PILIPOVIC: [Interpretation] Yes.

9 THE REGISTRAR: [Interpretation] Therefore,

10 the witness statement dated 19th and 20th of January,

11 1996 will be marked D32, Defence Exhibit D32; and the

12 witness statement dated 4th and 5th of May, 1998 will

13 be marked D33, Defence Exhibit D33, and these are

14 documents that are confidential documents.

15 JUDGE MUMBA: Thank you. Counsel, please

16 proceed.

17 MS. PILIPOVIC: [Interpretation]

18 Q. In your statement which you gave to the

19 investigators of the Tribunal in 1996, you said that

20 you and your family lived in Buk Bijela.

21 A. Yes.

22 Q. With your mother, father, brother, and

23 sister.

24 A. Yes.

25 Q. Did you live in an apartment or in a house?

Page 1730

1 A. In a house.

2 Q. In your family house?

3 A. Yes.

4 Q. Today during your testimony, you said that

5 you lived in Trosanj. Could you explain that to me,

6 please?

7 A. What.

8 Q. Did you live in Trosanj or Buk Bijela? Or

9 perhaps I don't understand where Buk Bijela is in

10 respect to Trosanj or the other way around, or did you

11 go to Trosanj?

12 A. No. I lived in Trosanj. There is a motorway

13 down below, and Trosanj is up in the mountains.

14 Mjesaja and Buk Bijela are near the road. If you write

15 an address, for example, your address, then you would

16 write Trosanj, and then you say Buk Bijela to

17 determine.

18 Q. Thank you. What is your father by way of

19 profession and where did he work?

20 A. (redacted)

21 (redacted).

22 Q. And what about your mother?

23 A. My mother was a housewife.

24 Q. What were the relationships in your family

25 like; that is to say, who were you closest to in your

Page 1731

1 family, most intimate with?

2 A. I think it was my sister.

3 Q. Thank you. Did you tell your sister about

4 your problems until the conflict broke out in the Foca

5 area?

6 A. Not always. Sometimes, yes.

7 Q. What was your sister's attitude? Did she

8 ever try to advise you, give you any advice in

9 situations like that when you sought it?

10 A. Yes, she would.

11 Q. Did your sister ever ask you for advice and

12 what you thought about the problems that she had, the

13 daily type of problems and the talks that sisters have

14 in the age that you were?

15 A. Well, not very often. She was older than me,

16 and I don't think she asked me for my advice at all

17 ever.

18 Q. You said that in the Foca municipality,

19 something unusual was going on before April 1992.

20 Could you explain that to me a little bit; that is,

21 explain to this Trial Chamber and to me what you

22 thought was unusual?

23 A. Well, I went to school at the time, and we

24 usually had shorter classes than usual, especially

25 before the 8th of April, before the shooting actually

Page 1732

1 began. We would have shorter classes and were allowed

2 to go home earlier sometimes. Barricades were set up

3 at some points and sometimes I wasn't able to go home

4 because of the checkpoints. And I remember that

5 several days before the shooting started, that there

6 was a rally of some kind in front of the municipal

7 building or something of that sort.

8 Q. That rally in front of the municipality

9 building, when did that take place and do you know

10 anything about it?

11 A. Well, I don't know exactly when the rally

12 took place. Perhaps it was only a few days before the

13 shooting actually started, but why the rally was held

14 and what it was all about, I really couldn't say.

15 Q. In that period or in your house, was anything

16 spoken about the Focatrans affair, or did you come to

17 hear of that affair in any other way, that incident?

18 A. Well, I don't know what the Focatrans affair

19 is.

20 Q. How did you usually go to school up until

21 then? While you still went to school, how did you go?

22 A. Well, I'd always go by bus.

23 Q. Which bus?

24 A. How do you mean which bus?

25 Q. Were there any characteristic features on the

Page 1733

1 bus?

2 A. No. They were the usual type of bus that

3 always runs that way. I couldn't say whether it had

4 any characteristic features or not.

5 Q. I know that you're young, but did you know or

6 was it talked about in your home about the fact that

7 some parties were being founded and that relations had

8 changed after the establishment of those parties?

9 A. No. I knew nothing about that at the time.

10 I knew nothing about that.

11 Q. You have now told me that there were some

12 barricades. Where were those barricades set up?

13 A. I don't remember that. I don't remember

14 where the barricades were exactly.

15 Q. And do you know who set them up?

16 A. I couldn't say that either. I don't know.

17 Q. In the place in which you lived, can you tell

18 us how many Serbs there were as opposed to Muslims?

19 A. Well, I couldn't tell you.

20 Q. What about your neighbours? Were they Serbs,

21 and if so, what were your relations with your

22 neighbours?

23 A. My next-door neighbours were Muslims; that

24 is, when I'm talking about Trosanj. Then this was a

25 Muslim population. Although in Mjesaja, for example,

Page 1734

1 it was a mixed population, a mixed Serb/Muslim

2 population, as was the case in the surrounding areas.

3 I think the surrounding areas had a Serb population. I

4 don't know what to say about the relationships between

5 the two ethnicities. I never noticed there was any

6 difference in them than what was the case previously.

7 Q. You said that you and your family had taken

8 to the woods.

9 A. Yes.

10 Q. Could you tell me when that occurred?

11 A. I don't know the exact date. I couldn't tell

12 you the exact date.

13 Q. May I help you with respect to the event that

14 happened on the 3rd of July in your village? How far

15 off was it from that 3rd of July?

16 A. I don't quite understand your question.

17 Q. How long before that did you go to the woods?

18 A. Well, I'm not quite sure about that either,

19 but I think for a time -- we spent some time in the

20 woods, and we slept with two other families there. And

21 for a time, we came back home, we were in our house for

22 a little while, and then we went to the woods again.

23 How many days that was before the attack, I couldn't

24 exactly say.

25 Q. Could you tell me: While you were in the

Page 1735

1 woods, were you there all day and all night, or was the

2 arrangement different?

3 A. Well, usually we would spend the whole day

4 and the whole night in the woods, although my mother

5 and my father would go back home to see to their daily

6 duties.

7 Q. During the time you spent in the woods and

8 then came back, was anything going on? Did anything

9 happen around your village and in the woods while you

10 were there?

11 A. Around our village, or rather in our village,

12 I don't think that anything special was going on, apart

13 from the fact that we didn't dare leave the village, go

14 beyond the village anywhere. But nothing special

15 happened before the 3rd of July.

16 Q. Will you tell me why you didn't dare move

17 around freely? Were there any threats or did anybody

18 say that you should hide?

19 A. I don't remember that exactly, because I was

20 15 1/2, and you usually listen to what people tell

21 you. But I think that there was a sort of general

22 fear. I think that everybody knew, or had heard on the

23 news or something like that, what had happened in some

24 other village, in some other place, things like that.

25 Q. In your statement you say that there was no

Page 1736












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Page 1737

1 electricity in your village, so how did you get -- come

2 by that information?

3 A. Well, the radio, for example. You don't need

4 electricity to listen to a radio. There are

5 battery-operated radios, or otherwise. I don't really

6 know.

7 Q. You said that you were in tents in the woods;

8 that is to say, you, your family, and another family.

9 A. Two other families.

10 Q. Two other families. In view of the fact that

11 we would like to protect these people, could you write

12 down on a piece of paper who the other two families

13 were, their names, please.

14 [Witness complies]

15 THE REGISTRAR: [Interpretation] This document

16 will be marked Defence Exhibit D34.

17 JUDGE MUMBA: Yes, Counsel.

18 MS. PILIPOVIC: [Interpretation] Thank you.

19 Q. You mentioned these two families. Where did

20 they come from?

21 A. They were our next-door neighbours.

22 Q. How many members were there in one family and

23 how many in the other family?

24 A. The first family had four members, and so did

25 the second.

Page 1738

1 Q. How many men were there in all who were your

2 father's age?

3 A. Well, I don't know the exact age, but the

4 older men, I'd say -- I think -- yes, three.

5 Q. How many people were there of your own age?

6 A. Well, there was nobody of my own age. There

7 was nobody my own age.

8 Q. Except for you and your sister. That's what

9 I'm referring to, the younger girls. All the others

10 were younger, were they?

11 A. Well, one of the families had two younger

12 children. I think the eldest child was perhaps 10 or

13 12. And the second family had two grown-up men, young

14 men, who were 25 years old, perhaps.

15 Q. You said you spent the night in the woods.

16 Did anybody guard you during the night, and did any of

17 those people have any weapons in case you were

18 attacked?

19 A. None of us had any weapons, and I think that

20 the older people who were with us would stay awake all

21 night.

22 Q. You said that you spent -- that is to say,

23 how long did you spend there before the 3rd of July? A

24 month, two months, 15 days? How long?

25 A. Well, I couldn't really say.

Page 1739

1 Q. You can't say. Thank you. I would now like

2 to ask you a few questions related to your arrival in

3 Partizan.

4 A. Yes?

5 Q. Could you tell me, please, when you arrived

6 in Partizan.

7 A. Once again, as to the exact date and time, I

8 don't really remember very well, but it could have been

9 two weeks after the 3rd of July, perhaps. We were at

10 the secondary school centre for about two weeks before

11 we were taken to Partizan. Perhaps two weeks, although

12 I'm not quite sure.

13 Q. Do you agree with me that this would make it

14 sometime around the 17th or 18th of July?

15 A. Yes, approximately, about that, although I'm

16 not quite sure.

17 Q. Tell me, please: On that particular date,

18 17th and 18th of July, when you arrived, what was going

19 on at the Partizan Sports Hall?

20 A. You mean --

21 Q. I mean the conditions there, what

22 relationships existed between you.

23 A. Before we arrived in the Partizan, we had to

24 clean -- that is, when we arrived, we had to clean

25 everything up. We slept on the gym mats. The living

Page 1740

1 conditions were very difficult. There was absolutely

2 no -- there were absolutely no hygienic conditions.

3 The food was very bad, hygiene was poor. I don't know

4 what to say exactly.

5 Q. In your statement, the statement you gave to

6 the investigators of the Tribunal, which is Exhibit

7 D32, on page 9 of that statement -- would you take a

8 look at page 9 of your statement, please, and look at

9 paragraph 3, which starts, "The Partizan Sports

10 Hall ..."

11 A. Yes.

12 Q. Could you read that first line out, please.

13 A. You mean, "We were the first prisoners in the

14 Partizan"?

15 Q. No. It is the third sentence.

16 A. "There was electricity in the Partizan

17 sometimes, sometimes not."

18 Q. That would be the fourth. Read the third

19 paragraph.

20 A. "I was detained at Partizan for a month. The

21 first three or four days they would leave us alone.

22 However --"

23 Q. Thank you. "I was kept at Partizan for about

24 a month. The first three or four days we were left

25 alone." That is how the sentences read. You know what

Page 1741

1 you read out?

2 A. Yes.

3 Q. Tell us, please, how long did you spend at

4 Partizan?

5 A. I'm not quite sure about that either. I

6 don't know how long it was. I'm not sure.

7 Q. Was it a month or was it less than a month,

8 or more than a month?

9 A. Well, I would say that it was about a month.

10 Whether it was more or less, I couldn't be sure about

11 that.

12 Q. Could you explain to me this second

13 sentence: "The first three or four days we were left

14 alone."

15 A. Well, I don't really understand what this

16 refers to, so I can't really explain it.

17 Q. Is it your statement?

18 A. Yes. Of course it is, yes. But I don't

19 know -- I said that I don't understand what this

20 actually referred to. When I say we were left alone, I

21 don't really know what it means.

22 Q. Were you able to go outside the sports hall

23 at all, move around outside? Were you able to?

24 A. Well, we could go out into the courtyard

25 around Partizan, but not further than that.

Page 1742

1 Q. As far as I was able to understand you, you

2 were able to go outside into the yard.

3 A. Well, for example, in front of the entrance,

4 that sort of thing.

5 Q. What about in front of the Partizan Sports

6 Hall? Were there guards positioned at the entrance?

7 A. Yes. Yes, there were guards.

8 Q. Were they during the day and during the

9 night?

10 A. I think they were there during the day and

11 during the night, yes.

12 Q. Do you know or did you meet a woman there who

13 was a Serb, an ethnic Serb? Did you talk to her?

14 A. I don't remember that.

15 Q. Does the name Vida mean anything to you?

16 A. No.

17 Q. Could you tell me, please, how many guards

18 did a shift?

19 A. Well, I can't quite remember, but there might

20 have been two perhaps, although I'm not sure.

21 Q. What were your relationships with the guards;

22 that is to say, how did they behave towards you?

23 A. Well, I never talked to them. I never

24 actually noticed. I didn't have -- I don't know.

25 Q. Could you tell me, please, how many times you

Page 1743

1 were taken out of Partizan?

2 A. I couldn't tell you. I don't know the exact

3 number of times.

4 Q. Could I help you and try to refresh your

5 memory and tell you the places you were taken to

6 according to your statement? Can I help to jog your

7 memory in that way perhaps?

8 A. Well, a lot of time has gone by since that.

9 Sometimes -- I remember some of the times I was taken

10 out of Partizan but not others, but what I do know is

11 that it was many times.

12 Q. Let me remind you that you gave a statement

13 in 1996 and another one in 1998. Could you tell me

14 when your memory was better with respect to the things

15 you're talking about here? Did you remember better

16 then, or do you remember better now?

17 JUDGE MUMBA: This witness was fifteen and a

18 half, so that type of question she can't answer.

19 Whether her memory was better when, no, it's not fair

20 to ask her that question.

21 MS. PILIPOVIC: [Interpretation] Your Honour,

22 I apologise, but the witness made a statement in 1996,

23 a very detailed statement about those events, and I

24 just wanted to check whether what she said then was

25 correct.

Page 1744

1 JUDGE MUMBA: Yes. What you do is you put

2 whatever she said there to her, not asking her the

3 state of her memory at any time, no.

4 MS. PILIPOVIC: [Interpretation] Thank you,

5 Your Honour.

6 Q. I should now like to ask the witness to turn

7 to page 9 of her statement from 1996. It is the last

8 paragraph on that page. "Most frequently, from

9 Partizan" -- could you read it, please?

10 A. "From Partizan we were taken mostly to

11 apartments and houses around Foca. Most of the time I

12 was taken with --"

13 Q. Seventy-five. Let me help you. Number 75.

14 Read another two lines, please.

15 A. "We were taken to different places like

16 Brena, Donje Polje, Gornje Polje, Trnovace, near the

17 primary school in Foca, to the Aladza area."

18 Q. Can you remember how many times you were

19 taken to the Brena building?

20 A. From Partizan?

21 Q. Yes.

22 A. I couldn't tell you the exact number of

23 times.

24 Q. And were you taken from Partizan to Brena?

25 A. I'm afraid I couldn't say about that either.

Page 1745

1 Q. You said Donji Polje here. And where were

2 you taken in Donje Polje. Was it an apartment or a

3 house there? If you can describe it to us.

4 A. I don't remember that.

5 Q. In Donje Polje? Do you remember who took you

6 to Donje Polje?

7 A. No.

8 Q. Could you please explain to me: In relation

9 to Partizan, where is Donje Polje? What is it?

10 A. It's a part of the town called Donje Polje.

11 Q. Is it an inhabited part of the town of Foca?

12 A. Yes.

13 Q. Are there apartment buildings there or

14 houses?

15 A. I think there were both, both houses and

16 apartment buildings.

17 Q. And Gornje Polje?

18 A. I couldn't tell you.

19 Q. And where is Gornje Polje in relation to

20 Partizan?

21 A. I'm not quite sure.

22 Q. Is it a part of the town of Foca?

23 A. Yes. Both Donje Polje and Gornje Polje are

24 parts of Foca.

25 Q. What about Trnovace?

Page 1746

1 A. Trnovace could be a village or a district,

2 I'm not sure, but it is a bit further away from Foca.

3 Q. Were you taken there too from Partizan?

4 A. Yes.

5 Q. Could you please tell me how many times you

6 were taken to Aladza?

7 A. I remember being taken there once, but I

8 think I was taken there several times. I can only

9 remember one time.

10 Q. When you say "several times," can you tell me

11 how many times that is, one, two, or three times?

12 A. No, I can't.

13 Q. Can you remember who took you several times

14 there?

15 A. To Aladza?

16 Q. Yes.

17 A. I think it was always Kunarac, if you mean to

18 the house in Aladza.

19 Q. Yes. This house in Aladza, in relation to

20 Partizan, where is it located? How far is it from

21 Partizan? Can you go there on foot or do you need to

22 take a car?

23 A. One can go on foot, of course. Aladza is a

24 part of the town of Foca. I couldn't tell you how far

25 away it is.

Page 1747

1 Q. But you just said that one could go on foot

2 or by car. But how did you go mostly to that house?

3 A. Mostly by car.

4 Q. When were you taken to Aladza for the first

5 time?

6 A. I don't remember that. I remember just that

7 one time, the day before we were taken to Miljevina.

8 Q. I see. You remember that day. If I ask you

9 to look again at your statement, it is page 9 of the

10 statement, when you said: "For the first three or four

11 days we were left alone." So I understand that to mean

12 that you were free and no one came to Partizan.

13 A. I don't know what to say about that.

14 Q. And after those three or four days, when were

15 you taken out for the first time and where?

16 A. I don't know exactly how many days after I

17 came to Partizan, and I don't remember exactly where I

18 was taken that first time I was taken out of Partizan.

19 Q. Do you remember, in relation to the time you

20 arrived in Partizan and then those first three or four

21 days until you were taken to Miljevina, do you remember

22 whether you left Partizan at all in the interim?

23 A. What do you mean?

24 Q. I mean, in an organised manner were you taken

25 to some other location?

Page 1748

1 A. You mean myself or several people?

2 Q. I don't know how many people. Could you tell

3 us how many of you did go out of Partizan to some other

4 place?

5 A. I don't know of anyone leaving and going

6 elsewhere unless they were taken there.

7 Q. I should like to remind you that an exchange

8 was organised in that period and departure to Cajnice.

9 A. Yes.

10 Q. Do you remember when that was?

11 A. No, I can't remember.

12 Q. Do you remember -- you said several people --

13 who those people were that went with you and who left?

14 A. I don't remember who they were.

15 Q. Could you use the list that you have and

16 write down on a piece of paper the persons who left

17 with you, went out with you?

18 A. I couldn't write a list, because I think

19 there were quite a number of people, and I couldn't

20 remember exactly who they were.

21 Q. But those that you remember from your list,

22 as you have the list before you.

23 JUDGE MUMBA: Why can't she use the numbers?

24 Is this the list you are talking about, the

25 Exhibit 193?

Page 1749













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Page 1750

1 MS. PILIPOVIC: [Interpretation] The witness

2 may use the list, of course. That's what I told her to

3 do, if she could tell us the numbers from that list.


5 A. Again, I cannot be sure. I only remember

6 exactly number 75, and I think number 50 also. As for

7 the others, I cannot tell with any certainty.

8 MS. PILIPOVIC: [Interpretation]

9 Q. You said 75 and 50.

10 A. Yes.

11 Q. You cannot give us a time when this

12 happened. Was it before the 2nd of August, 1992?

13 A. I couldn't tell you.

14 Q. Can you tell us how many nights you spent

15 outside?

16 A. I don't remember that well either, but we

17 didn't spend a lot of time.

18 Q. Was it one night, two or three?

19 A. I don't know.

20 Q. Today you said that you remember an event

21 when you were taken to Aladza.

22 A. Yes.

23 Q. When was that?

24 A. Well, if you're asking me about a date again,

25 then I have to say once again that I don't know. On

Page 1751

1 that particular occasion when we were taken to Aladza,

2 all I remember is that it was one day before we were

3 taken off to Miljevina, but I can't tell you the exact

4 date.

5 Q. And when was that? At what time of day was

6 it, day or night?

7 A. I think it was in the afternoon sometime, but

8 I'm not quite sure.

9 Q. That afternoon, can you tell us roughly was

10 it 5.00, 6.00, 7.00, or 8.00?

11 A. Well, perhaps about that time, but as I say,

12 once again I'm not quite sure. What I want to say is

13 that I don't think it was dark yet, but on the other

14 hand, it wasn't early either.

15 Q. And who came to Partizan?

16 A. I only remember Kunarac. I don't remember

17 the others.

18 Q. Were there other soldiers with him and how

19 many?

20 A. I don't remember that.

21 Q. How did he come to Partizan?

22 A. I think he came by car.

23 Q. Do you remember what kind of car it was?

24 A. No.

25 Q. Do you remember the colour of the car?

Page 1752

1 A. No, I don't.

2 Q. When he arrived, how was he dressed on that

3 occasion?

4 A. Well, I don't know. I think that he always

5 wore a camouflage uniform, camouflage clothing,

6 although I'm not quite sure of that either. That is to

7 say, I'm not quite sure what he was wearing on that

8 particular occasion.

9 Q. Did that camouflage uniform have any insignia

10 on it?

11 A. I don't remember.

12 Q. And what about the other persons who

13 accompanied him? Do you remember what they looked

14 like?

15 A. No, I don't.

16 Q. Were they wearing military uniforms too?

17 A. I don't remember that.

18 Q. When he came, and when you said that he came

19 by car -- you don't remember who was with him, you

20 don't remember what he looked like -- which of you

21 girls or women went with him?

22 A. Number 75, number 50, DB, and myself.

23 Q. When you reached the house in Aladza, who did

24 you find there in the house?

25 A. I remember that there were some soldiers

Page 1753

1 there and that there was another person, number 190.

2 Q. When you arrived at that house, there were

3 soldiers there. Can you remember the names of any of

4 the soldiers; names, nicknames, or anything specific

5 about them when you arrived? And where did you sit?

6 A. As far as the soldiers are concerned, I

7 remember just one of them, and his name was Goran. And

8 I remember another one whose nickname was Tolja, and I

9 think his surname was Toljic. But I can't remember any

10 of the other names. Where I was sitting? Hmm, well, I

11 can't tell you exactly.

12 Q. Would you please describe Goran, what he

13 looked like?

14 A. I saw him just once on that occasion, and all

15 I remember is that he was tall, and I think he was --

16 had sort of dark blond hair, but I'm not quite sure.

17 Q. Did you talk to him?

18 A. I think I did, but what we talked about, I

19 really cannot remember.

20 Q. Did he tell you that he had been wounded?

21 A. I don't remember.

22 Q. How long did you sit together in the house?

23 And could you describe the house to me a little bit,

24 the layout of the rooms?

25 A. How do you mean, how long we sat there?

Page 1754

1 Q. When you entered the house, you said that you

2 spoke to Goran. Did you speak to anyone else? How

3 much time did you spend sitting there together?

4 A. When we came there, we were there the whole

5 night, and then the next day we were taken to

6 Miljevina. And as far as the layout of the house is

7 concerned, on the lower floor -- and I don't really

8 remember whether it was the lower floor or a separate

9 building perhaps, or like a garage, something like a

10 garage, perhaps. It was in the yard, and it looked

11 like a workshop of some kind. And you would go up the

12 stairs into the house, and then when you come up to the

13 above floor, on the left-hand side there was a kitchen,

14 if I remember correctly; on the right-hand side there

15 was a room; straight on was the bathroom; to the left

16 of the bathroom there was another room.

17 Q. And where were all of you sitting; in which

18 of those rooms?

19 A. I don't remember that, but I think that I

20 spent most of the time in the room to the left of the

21 bathroom. And the windows of that particular room

22 looked out onto the street.

23 Q. Was there light in the house?

24 A. I don't remember.

25 Q. You said that you were in the room to the

Page 1755

1 left.

2 A. Yes. I think it was to the left of the

3 bathroom.

4 Q. When did you go to that room?

5 A. I couldn't say.

6 Q. From the moment you arrived?

7 A. No. I don't know exactly what room I was in,

8 for how long, and when.

9 Q. Where were the other girls that came with

10 you?

11 A. I don't remember that either.

12 Q. Do you remember number 75, where she was?

13 A. No.

14 Q. And DB, your sister?

15 A. No.

16 Q. Number 50?

17 A. I think 50 was taken away from the house when

18 we arrived there. I think that somebody else took her

19 off somewhere.

20 Q. From the moment you arrived, until she was

21 taken away, how much time went by? Was it before you

22 went to the room upstairs?

23 A. Well, I think so, yes.

24 Q. Do you remember who took her away?

25 A. No.

Page 1756

1 Q. In the course of that evening, did she come

2 back to that house?

3 A. Not as far as I remember, no.

4 Q. Who took you to the room to the left? As far

5 as I understand, that is on the top floor of the

6 house.

7 A. Well, all those rooms -- the kitchen, that

8 room, and the room to the left of the bathroom --

9 they're all on the storey above.

10 Q. So they were all upstairs. Who took you to

11 that room upstairs?

12 A. I don't remember.

13 Q. And how much time did you spend in that room?

14 A. I couldn't tell you that either. I don't

15 know.

16 Q. Do you remember that something unusual

17 happened that night?

18 A. No. No, I don't remember.

19 Q. Did anything at all happen to you that night

20 in that house?

21 A. I don't know what you mean. Do you mean --

22 what do you mean, what happened to me?

23 Q. I was asking you, when you went upstairs into

24 the room, and I asked you how much time you spent in

25 that room.

Page 1757

1 A. I don't know how long I was in the room for.

2 Q. Who were you with in that room?

3 A. I can't remember that either. All I remember

4 is that while I was in the house, I was in one room, in

5 the other room, and in the workshop, which is in the

6 yard.

7 Q. Who were you with in the first room?

8 A. In the first room to the right-hand side, I

9 was with Kunarac.

10 Q. When was this in relation to the time when

11 you arrived?

12 A. I don't remember that. I don't remember

13 time.

14 Q. Who were you with in the second room after

15 that?

16 A. I think I was in the workshop with Toljic,

17 although I'm not sure. I'm not sure of the order in

18 which things happened.

19 Q. In the course of that night, were you taken

20 out of that house?

21 A. No, not further than the yard.

22 Q. Were you in a car that night?

23 A. I don't remember.

24 Q. Does the name Bane ring a bell?

25 A. I don't remember.

Page 1758

1 Q. Could you please describe the room to the

2 left in that house. What did it look like and what was

3 inside?

4 A. I don't know what was inside. I can't

5 remember. But I think there was a big display cabinet,

6 or cupboard, and that there were two beds or sofas,

7 whatever, and -- well, that's it. I don't remember any

8 more.

9 Q. And where did the window of that room face?

10 A. Out onto the street.

11 Q. Was there any lighting in the room when you

12 entered?

13 A. I don't remember.

14 Q. You said that you were in that room. How did

15 you get into that room; alone or with someone else?

16 A. I don't remember.

17 Q. You said you were in that room with Kunarac.

18 And did he enter the room?

19 A. I don't remember.

20 Q. What did he look like that night?

21 A. How do you mean, what did he look like?

22 Q. When he entered the room, what did he look

23 like?

24 A. I don't remember.

25 Q. I know that this is very painful for you, and

Page 1759

1 all these things that happened as you have described

2 them. Could you tell me in somewhat greater detail how

3 this contact between you and Mr. Kunarac occurred?

4 A. Well, I don't think there was any contact.

5 Quite simply, he came, took me, and took me into the

6 other room.

7 Q. How much time did you spend with him in that

8 room?

9 A. I don't remember.

10 Q. Did anyone come in?

11 A. I don't remember that either.

12 Q. You left that room, and when did you go to

13 the other room?

14 A. I don't remember.

15 Q. Let me again ask you whether anything special

16 happened that night. Did you hear a sound, an

17 explosion, some destruction?

18 A. Well, I remember that there was an explosion,

19 and I thought it was the Aladza mosque, although I

20 personally can't remember whether it occurred on that

21 particular night or some other night before that. I

22 don't actually remember.

23 Q. Could you please tell me whether Kunarac took

24 his clothes off when he entered the room?

25 A. Well, I don't know what you mean by "took his

Page 1760













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Page 1761

1 clothes off." I've already told you that he raped me.

2 He must have.

3 Q. In which statement did you say that he had

4 raped you?

5 A. During my testimony today.

6 Q. I should now like to ask you to look at your

7 statement to the investigators of the Tribunal in

8 1996.

9 A. Yes.

10 Q. Look at page 9, please.

11 A. Yes.

12 Q. It begins with, the sixth line in the last

13 paragraph, "In it there was a sewing machine."

14 A. Yes, the sewing machines. I think that the

15 owner was a tailor; I don't know who exactly.

16 Q. Go on, please.

17 A. "I was always taken there by Dragan Kunarac

18 to the house there. The first two times there were

19 only two soldiers in the house, and both of them were

20 Montenegrins. I know that one of them was Dragan

21 Toljic, called Tolja, from Niksic. The other one was

22 older, but I don't know his name. Both these men raped

23 me. On the third occasion, which I will describe in

24 more detail later, this house was again filled with

25 Montenegrins. I never saw members of Cosa's Guard

Page 1762

1 inside the house. Kunarac never took me to another

2 house than this one. He did not rape me on the first

3 two occasions; only on the third time."

4 Q. Could you tell me now, taking into account

5 this statement of yours, how many times did Kunarac

6 bring you to the house?

7 A. I don't know. I don't remember that.

8 Q. Let me now remind you of your statement in

9 1998. Page 4, the last paragraph. If you could read

10 it, please.

11 A. Yes. "I do not remember whether Zaga raped

12 me that last time when I was taken to the house in

13 Aladza. Now I clearly remember that on that occasion I

14 was raped by a man whose name was Goran. On that

15 occasion, there were several more soldiers in the house

16 than usual. They were drinking in the kitchen. Zaga

17 was not always present. He would keep going in and

18 out."

19 Q. Please tell me which is correct, either of

20 these two statements or your testimony today? Because

21 in 1998, you said that Goran raped you.

22 A. What do you mean which is the truth?

23 Q. Which is the truth?

24 A. What do you mean "which is the truth"?

25 Q. What happened that night? Who raped you?

Page 1763

1 A. My first statement was taken in 1996, the

2 second one two years later, and today I'm talking here

3 today and saying what happened eight years ago, so that

4 I don't remember many of those things any more.

5 Although, I do remember that on that particular night,

6 Goran and Zaga were both there in that house.

7 MS. PILIPOVIC: [Interpretation] Your Honours,

8 I am looking at the time.

9 JUDGE MUMBA: Yes. It's time for us to rise,

10 and we shall continue tomorrow at 0930 hours.

11 --- Whereupon the hearing adjourned

12 at 4.02 p.m., to be reconvened on

13 Wednesday, the 5th day of April, 2000,

14 at 9.30 a.m.