1. 1 Wednesday, 26th May, 1999

    2 (Open session)

    3 (The accused entered court)

    4 (The witness entered court)

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

    6 THE REGISTRAR: Case IT-95-16-PT, the

    7 Prosecutor versus Zoran Kupreskic, Mirjan Kupreskic,

    8 Vlatko Kupreskic, Drago Josipovic, Dragan Papic, and

    9 Vladimir Santic.

    10 JUDGE CASSESE: Thank you.

    11 Counsel Par.

    12 MR. PAR: Good morning, Your Honours.

    13 Before I begin with the examination of the

    14 witness, would you please allow me to address a

    15 question to the Trial Chamber, and could the witness

    16 leave the courtroom for a moment while I address that

    17 question to the Court?

    18 JUDGE CASSESE: Yes.

    19 (The witness withdrew)

    20 MR. PAR: Mr. President, my question has to

    21 do with the documents which the Prosecutor intends to

    22 use in today's cross-examination. Actually, yesterday

    23 we received two documents from the Prosecutor which he

    24 intends to use in his cross-examination.

    25 The first document was given to us prior to

  2. 1the beginning of the hearing and before the witness was

    2 brought into the courtroom, and we consider that quite

    3 appropriate.

    4 However, as regards the second document, the

    5 Prosecutor gave it to us immediately after the end of

    6 the hearing, that is, after the witness had started

    7 testifying and had taken the solemn declaration.

    8 Clearly, the document was given at that very point in

    9 time so as not to enable the Defence counsel to ask the

    10 witness anything about that document before the

    11 Prosecutor.

    12 As the Defence counsel, I have had enough

    13 time to study the document, but I was not in a position

    14 to confront the witness with it.

    15 My question to the Trial Chamber is as

    16 follows: Is such a disclosure of documents on behalf

    17 of the Prosecutor in accordance with the Rules of

    18 Procedure or, rather, is it permissible for the

    19 Prosecutor to prevent the Defence from asking the

    20 witness about documents in the possession of the

    21 Prosecutor, the aim being to surprise the witness with

    22 a document which he was not in a position to see

    23 before?

    24 If Your Honours consider such a procedure to

    25 be in accordance with the Rules, I apologise if this is

  3. 1due to any misunderstanding on my part. If not, would

    2 I be allowed to discuss this document with the witness

    3 for ten minutes, at least, prior to the examination?

    4 JUDGE CASSESE: Thank you. Before I give the

    5 floor to Mr. Terrier, may I ask whether we could also

    6 be given these two documents? Before making a ruling,

    7 we have to read those documents.

    8 MR. TERRIER: Of course, Your Honour.

    9 JUDGE CASSESE: So we will concentrate on the

    10 documents to which Counsel Par has just made an

    11 objection. He said "the second document", which,

    12 Counsel Par, could you please specify which one is the

    13 second document, the one --

    14 MR. PAR: The first document is a letter to

    15 the International Tribunal, and we have no dispute over

    16 that, and the second document with the signature

    17 regarding the confiscation of weapons and so on, a

    18 report on inventory taken by the inventory commission,

    19 with the annexes.

    20 JUDGE CASSESE: No, this is the first one.

    21 So the first document is a letter by Ljubica Kupreskic

    22 to the International Criminal Tribunal, the first one?

    23 MR. PAR: Yes, and we're not disputing that.

    24 JUDGE CASSESE: The one we are disputing is

    25 the report on inventory taken by the inventory

  4. 1commission. Thank you.

    2 MR. PAR: That is correct.

    3 JUDGE CASSESE: Good. Could I ask

    4 Mr. Terrier to comment?

    5 MR. TERRIER: Thank you, Your Honour.

    6 First of all, I would like to say that by

    7 serving the document prior to the beginning of the

    8 cross-examination and even before the end of the

    9 examination-in-chief, and by giving Mr. Par one night

    10 to think it over, I think that we perfectly complied

    11 with the directives edicted by this Tribunal.

    12 Secondly, when it comes to the letter written

    13 by the witness to the Prosecutor in The Hague, that

    14 shouldn't raise any problem whatsoever.

    15 Thirdly, with regard to the report by the

    16 inventory commission, I do not have much information as

    17 to the nature and the purpose of such a commission, but

    18 by serving this document to the Defence, my primary

    19 concern was to ask the witness whether she recognised

    20 the signature at the end of this document and the name

    21 of Vlatko Kupreskic. I didn't intend to ask the

    22 witness, because I don't think she would know that,

    23 whether she knew anything special as to the purpose of

    24 the commission, as to the results obtained by the

    25 commission.

  5. 1The main purpose of serving the document to

    2 the Defence was for the witness to recognise or for

    3 failing to recognise the signature of her husband.

    4 Besides, Mr. Par has not completed

    5 examination-in-chief. He is therefore perfectly able

    6 to ask all questions he deems useful on this report or

    7 on anything else.

    8 This is what I had to say. Thank you.

    9 JUDGE CASSESE: Counsel Par?

    10 MR. PAR: Fully appreciating the observations

    11 by my learned friend, Mr. Terrier, if the question has

    12 to do with the signature alone, then I have no

    13 objection. At the same time, however, my question was

    14 of a principle nature so we should know in the future

    15 what exactly is the position of the Trial Chamber

    16 regarding the disclosure of documents. But I would

    17 stress, once again, that if it is a question of

    18 recognising the signature, I withdraw my complaint.

    19 (Trial Chamber deliberates)

    20 JUDGE CASSESE: All right. Now, our ruling,

    21 of course, is of a general nature, because you raised

    22 the question of principle. I understand that you

    23 accept, in light of what the Prosecutor just said, his

    24 explanation. He will confine himself to asking

    25 questions about the signature of the witness's husband,

  6. 1so therefore you are not raising any question.

    2 As a matter of principle, however, we agree

    3 with your position. We feel that the Prosecutor should

    4 disclose these documents as soon as possible, not at

    5 the very last minute, because this may delay our

    6 proceedings. In any case, if the Prosecution is unable

    7 to disclose such documents as soon as possible, it is

    8 only fair for the Defence counsel to have some time to

    9 discuss a new document with the witness in private.

    10 So in future, if the same occurrence arises,

    11 then we will allow the Defence counsel to take some

    12 time to discuss any matter relating to a particular

    13 document which has just been disclosed, or has been

    14 disclosed a short time before the testimony, to discuss

    15 it with the witness. So we will proceed this way in

    16 the future.

    17 For the time being, we can resume our

    18 proceedings, and I would like to ask the registrar to

    19 bring in the witness.

    20 (The witness entered court)


    22 Examined by Mr. Par:

    23 Q. Good morning, Mrs. Kupreskic. May we begin?

    24 During today's examination, we will mainly be

    25 dealing with a certain number of documents. Yesterday,

  7. 1in the course of your examination, you said that during

    2 the conflict, Vlatko Kupreskic did not have a rifle.

    3 My question is: When he was arrested, was a rifle

    4 seized from him?

    5 A. Yes, when he was arrested, it was.

    6 Q. Could you tell the Court where that rifle

    7 came from, when and how he gained possession of it, and

    8 why he needed it?

    9 A. That rifle was purchased upon my initiative

    10 because of frequent burglaries in our house and our

    11 shop, and I was the one who initiated the purchase of

    12 such a rifle because I was often left alone with the

    13 children. After the cease-fire was signed in May, a

    14 burglary occurred into my house. I was alone with the

    15 children. Vlatko was away on business at the time, and

    16 when he returned, I told him about it, and I said that

    17 he should get a weapon, because I was afraid to stay

    18 alone, as our house is rather isolated. Everything

    19 around it had been burned. However, Vlatko did not

    20 follow my advice on that occasion, but after another

    21 burglary in our shop, when a large amount of goods were

    22 stolen, in January '95, he went to the military and

    23 asked them to give us a weapon.

    24 MR. PAR: With the usher's assistance, could

    25 I show the witness this document, and I have copies for

  8. 1Their Honours, the Prosecution, and the registry. The

    2 original for the Trial Chamber, please.

    3 THE REGISTRAR: This exhibit will be Defence

    4 Exhibit 35/3.

    5 MR. PAR:

    6 Q. Mrs. Kupreskic, you are familiar with this

    7 receipt, so could you tell us what it certifies and

    8 where it comes from?

    9 A. This is a card on the basis of which weapons

    10 were issued. We can see here that the name is Vlatko

    11 Kupreskic, the date is 17th of January, 1995, when he

    12 was issued this rifle. The rifle was issued by

    13 Mr. Smiljko Cevozic, and this card was deposited in the

    14 registry in our shop on the same day that the rifle was

    15 issued. This is evident from the document itself.

    16 Q. Does this mean, when a rifle is issued, that

    17 such a document is issued at the same time?

    18 A. Yes.

    19 Q. Can we see what kind of weapon it is?

    20 A. I don't know much about weapons, but I can

    21 read what it says: AP 2223. It probably means an

    22 automatic rifle.

    23 Q. And what else was issued?

    24 A. Three magazines of ammunition.

    25 Q. Very well. Thank you. So we are finished

  9. 1with that certificate.

    2 You mentioned that there were some burglaries

    3 in your shop and home, so I'll show you another

    4 certificate for you to look at and tell us what the

    5 origins of that document are, with the help of the

    6 usher, please.

    7 THE REGISTRAR: This is Exhibit D36/3.

    8 MR. PAR:

    9 Q. Mrs. Kupreskic, this, too, is a familiar

    10 document for you, so could you briefly tell the Court

    11 what kind of certificate it is, who issued it, and what

    12 does it certify?

    13 A. At my personal request, this certificate was

    14 issued by the police administration of Vitez, and the

    15 burglaries that took place were registered. The first

    16 one occurred on the 17th of May.

    17 Q. Which year?

    18 A. 1994, in our family house. The second one

    19 occurred in September 1994, and the third in February

    20 1997.

    21 Q. Let us refresh our memory: When was the

    22 rifle issued?

    23 A. In January 1995.

    24 Q. So the reasons were these burglaries, as you

    25 have told us?

  10. 1A. Yes.

    2 MR. PAR: Could I ask the registry to show

    3 the witness Prosecution Exhibit P329, P329, a

    4 certificate on mobilisation.

    5 Q. Until we find that document, let me tell you

    6 that it is a document which says that Vlatko Kupreskic,

    7 from the 16th of April, 1993, was assistant commander

    8 for health in the Vitez Brigade. So could you look at

    9 this certificate and comment on the accuracy of the

    10 statements it contains.

    11 Have you received a copy?

    12 A. My husband never had a certificate of this

    13 kind, nor have I seen it before I was shown it by

    14 counsel. It is not correct, what it says here, that he

    15 was assistant commander for health from the 16th of

    16 April, 1993.

    17 Q. What is not right? The title that he held,

    18 or the date?

    19 A. He was not even mobilised then.

    20 Q. Thank you. And when was he mobilised?

    21 A. Around the beginning of September.

    22 Q. And to what post was he assigned?

    23 A. He was assigned to the position of driver in

    24 the medical corps, because an order arrived to

    25 confiscate Vlatko's white Mercedes which he owned at

  11. 1the time. During the general mobilisation, Vlatko was

    2 mobilised by force, and he used that vehicle as a

    3 driver working for the medical corps.

    4 Q. Do you know whether Vlatko asked to be issued

    5 such a certificate for some particular purpose?

    6 A. No. If he had asked for it, I would have

    7 probably seen it. I've never seen it before, nor did

    8 he request such a certificate to be issued to him, and

    9 I really don't know where it comes from.

    10 Q. Very well. Let's go on. Did any member of

    11 your family, or acquaintance, on the basis of

    12 erroneously-entered data on participation in the war,

    13 acquire the right to certain shares?

    14 A. Yes.

    15 Q. Let me show you a few documents that I

    16 received from you, but we would like to show them to

    17 Their Honours.

    18 You know that I have three so-called certificates

    19 on the salary for members of the armed forces. I

    20 should like to ask you to tell me briefly, with regard

    21 to each of those certificates, to whom they apply, when

    22 the person mentioned was born, to what extent she

    23 participated in the war, and whether you personally

    24 know that person and can confirm whether the data

    25 indicated are correct. Do you have the certificate

  12. 1before you?

    2 A. This certificate applies to Ana Topic, born

    3 in 1928, which can be seen from her personal

    4 registration number. According to this certificate,

    5 she was a member of the armed forces for 49 months,

    6 which is not correct.

    7 Q. For 49 months; a person born in 1928 would

    8 hardly have been a member of the armed forces. Do you

    9 know her in person?

    10 A. Yes, I do. I know that she's not very well

    11 physically, and she is my brother's mother-in-law.

    12 Q. Let us go through two more certificates that

    13 I have here of a similar nature.

    14 THE REGISTRAR: This exhibit will be D37/3.

    15 MR. PAR:

    16 Q. Mrs. Kupreskic, very briefly, to whom does

    17 this certificate apply?

    18 A. It applies to Ljubica Frljic, born in 1928,

    19 and it says here that she too was a member of the armed

    20 forces for 45 months, which is not true. This is

    21 actually my mother. She has been sick for 30 years.

    22 She's under medication. She can hardly walk. So this

    23 is really not true.

    24 Q. And how can you tell the age from the

    25 registration number of the person?

  13. 1MR. PAR: We have one further certificate of

    2 this kind.

    3 THE REGISTRAR: This is Exhibit D39/3.

    4 MR. PAR:

    5 Q. Can you comment in the same way on this

    6 certificate?

    7 A. It applies to Miroslava Jonjic. She is a

    8 refugee from Zenica. She's the mother of a worker that

    9 I employed. It says here she participated for 45

    10 months and acquired a salary on that basis.

    11 She was born in 1937, which can be seen from

    12 her personal registration number. This lady died a

    13 couple of months ago. She was of poor health.

    14 Q. A few more words about her. How can you see

    15 that it is not correct that she was in the armed

    16 forces? How do you know that? That she was sick, you

    17 mean?

    18 A. No.

    19 Q. That she participated in the armed forces for

    20 45 months, how can it be true?

    21 A. I know her personally. She was really sick.

    22 She was immobile. She couldn't move. She was

    23 bedridden.

    24 Q. Very well. Thank you. Let us go on to the

    25 next document.

  14. 1You said, Mrs. Kupreskic, that on the 15th of

    2 April, on the eve of the conflict in Ahmici, you took

    3 your driving test. Now I shall show you another

    4 certificate confirming this. In view of the fact that

    5 what you are going to see is also a certificate that

    6 you obtained and gave to me, let us not dwell on it too

    7 long. Just tell Their Honours what the certificate

    8 says or, rather, who issued it and how.

    9 THE REGISTRAR: This is Exhibit D40/3.

    10 A. This certificate certifies that I, Ljubica

    11 Kupreskic, took my driving test on the 15th of April,

    12 1993, at 16.00 in Vitez in the auto motoring club in

    13 Vitez. This certificate was registered in the

    14 registry.

    15 MR. PAR: I would now like to ask the

    16 Registry to give us Defence Exhibit D12/3, which is the

    17 minutes on damage to the house or report on damage to

    18 the house of Vlatko Kupreskic. D12/3.

    19 Q. Yesterday you said that on the 16th of April,

    20 '93, certain damage was inflicted on your house and

    21 that some things were stolen from your house. Did you

    22 apply for compensation for this damage or, rather, are

    23 you familiar with this record that you have?

    24 A. Yes, I know what it is.

    25 Q. Was this record drawn when you applied for

  15. 1damages?

    2 A. Yes.

    3 Q. Briefly, what kind of damage is indicated

    4 here?

    5 A. This record was drawn on the 15th -- no, the

    6 5th of April, 1995, and at that time the things taken

    7 away and damaged or, rather, the merchandise taken

    8 away, so I did notice. So in 1995, we already said

    9 that the entrance door was damaged, as you can see from

    10 here, that a large part of merchandise was damaged.

    11 All the bills and receipts were stolen. Then there was

    12 valuables, jewellery or, more specifically, a necklace,

    13 a golden necklace, which was a wedding present to me

    14 from Vlatko's parents.

    15 So the commission came out and wrote it all

    16 down. So windows were damaged, the heating system was

    17 damaged, roof tiles.

    18 Q. All right. Let us then proceed to the next

    19 document, or two more.

    20 The next document is a certificate of the

    21 Centre for Social Work in Vitez. You were also the one

    22 who gave it to me. So will you tell us, what is this

    23 certificate? Who issued it, and what does it satisfy

    24 about?

    25 A. It was issued by the Centre for Social Work

  16. 1to certify that our family, as of the -- on the 1st of

    2 May, 1993, we were refugees in Vitez.

    3 Q. That was the period of time when you came

    4 from Rovna to Vitez. When you came there, did you

    5 immediately report to the centre? What was the

    6 procedure at the time about registering refugees?

    7 A. Well, I don't know exactly. Someone from

    8 door to door and making the -- compiling the list of

    9 refugees, and thus then putting us on the record in the

    10 centre.

    11 MR. PAR: Right. We have more or less

    12 finished with these documents. Only two or three short

    13 questions more.

    14 THE REGISTRAR: Excuse me. This document was

    15 Exhibit D41/3.

    16 MR. PAR: Only a few brief questions related

    17 to some character statements which we already gave the

    18 Prosecution. Let us see how they came about.

    19 Q. Could you tell us, please, on what terms was

    20 Vlatko with the Muslims after the war, after the

    21 conflicts? Did the Muslims that you had contact with

    22 accuse him of some infamous role in the war?

    23 A. Vlatko, with all people and in particular

    24 with the Muslims, Vlatko was on the same terms as

    25 before the war. And with all the people that I had to

  17. 1do something with, and I had to deal with a number of

    2 people, I had contact with a number of people, Serbs

    3 including, nobody said anything against Vlatko.

    4 Everybody was surprised when Vlatko was indicted. They

    5 knew him well. They knew he was a good businessman,

    6 and he always helped people.

    7 Q. Where did you talk to them, where did you

    8 meet them?

    9 A. Well, I mostly talked to them in Ahmici, in

    10 front of my house, in the shop in Vitez.

    11 Q. Tell us, please, did you ask them something

    12 specific from them? Did you ask them to come to the

    13 Tribunal or write some statements? What was their

    14 response? What did those conversations look like?

    15 A. Yes. When you told me that the Tribunal

    16 permitted us to take down some character statements, I

    17 went to see my neighbours, asking them to write down a

    18 statement or come here to the Tribunal. Some of them

    19 did write it down, except that people want to be

    20 protected. They have all some problems. Some of them

    21 would be ready to come to testify as to the character

    22 of Vlatko Kupreskic, but they are afraid to do so.

    23 Q. Right. It is clear now.

    24 I have here a list of people who wrote down

    25 these character statements. We submitted them to the

  18. 1Prosecutor's office in time, and I should now like to

    2 show you the list of these people. I don't want you to

    3 read out all these names, because this is a public

    4 session. I only want to ask you which one of these

    5 persons is a Croat and which one is a Muslim? We have

    6 numbers here, so will you please tell us just that

    7 number so and so is a Muslim and number so and so is a

    8 Croat?

    9 MR. PAR: Mr. Usher, will you please help?

    10 This document is a certificate of the municipal

    11 department that these persons were contacted to, and we

    12 shall attempt to enter it into evidence subsequently.

    13 A. I don't want to take too much of your time,

    14 so number 1, this is a person of Muslim ethnicity.

    15 Number 2, also Muslim ethnicity. Number 3, Muslim

    16 ethnicity. Number 4, Muslim ethnicity. Number 5,

    17 Serb. Number 6, Serb; 7, a Muslim woman. Number 8, a

    18 Muslim woman. Number 9, a Serb. Number 10, a Muslim;

    19 11, a Muslim; 12, Muslim; 13, Muslim; 14, Muslim; 15,

    20 Muslim. Number 16, Muslim. Number 16 (sic), Muslim.

    21 MR. PAR: Thank you, Mrs. Kupreskic.

    22 I have no further questions, and I should

    23 like that these D31/3 to number D41/3 be admitted into

    24 evidence as Defence exhibits.

    25 THE REGISTRAR: The last document will be

  19. 1marked D42/3.

    2 MR. PAR: Yes, that is correct, D42/3.

    3 JUDGE CASSESE: Any objection?

    4 MR. TERRIER: [No translation]

    5 THE INTERPRETER: Sorry, sorry, the

    6 interpreter apologises.

    7 MR. TERRIER: Yes. As to the last document,

    8 D42/3, I'm wondering whether this document can be

    9 tendered into evidence today. There is only one list

    10 of names, whilst there is no indication as to the

    11 relevance of this document, given the facts the accused

    12 is accused of in this trial or when you think of the

    13 testimony of Mrs. Kupreskic today. I would like to

    14 have this document together with statements which are

    15 apparently announced but have not been provided yet.

    16 I do not think that the last document, D42/3,

    17 could be usefully tendered into evidence. I do not

    18 have any objections as to the other documents which

    19 were provided today.

    20 MR. PAR: I agree. I withdraw my suggestion

    21 for 42/3, and we'll submit it in the end with a list of

    22 witnesses.

    23 JUDGE CASSESE: Thank you. So therefore all

    24 the other documents are admitted into evidence except

    25 for D42/3, which will probably be submitted into

  20. 1evidence later on with the other accompanying

    2 documents.

    3 Yes, Counsel Pavkovic.

    4 MR. PAVKOVIC: Your Honours, I should merely

    5 like to inform you that Mrs. Slokovic-Glumac will also

    6 ask some questions of this witness.

    7 JUDGE CASSESE: Yes. This is for

    8 cross-examination. All right, Counsel

    9 Slokovic-Glumac.

    10 MS. SLOKOVIC-GLUMAC: Thank you, Your

    11 Honours.

    12 Cross-examined by Ms. Slokovic-Glumac:

    13 Q. Mrs. Kupreskic, I understand that you work

    14 for the Sutre company.

    15 A. Yes.

    16 Q. When was that?

    17 A. I was there between '92, end of '92, until

    18 the war. And then after the war, I went back to work

    19 there and became even more active there.

    20 Q. Will you tell us if at that time Mirjan

    21 Kupreskic was also there?

    22 A. Mirjan Kupreskic was also there at the time.

    23 Q. Where did he work before the war?

    24 A. Before the war, he worked at the outlet in

    25 Pirici, and then some 15 days before it, he moved to

  21. 1Vitez. So for a while before the war in '93, he moved

    2 to Vitez.

    3 Q. Who worked with him at the warehouse at the

    4 time?

    5 A. Ivica Covic was with him at the warehouse in

    6 Covici, so Mirjan moved from that warehouse to Vitez

    7 because we opened there another business outlet there.

    8 Q. Did Ivica Covic go on working in the

    9 warehouse until the war broke out?

    10 A. Yes.

    11 Q. And after the war -- that is, in 1994, when

    12 the cease-fire was signed -- in 1994, did Mirjan

    13 Kupreskic continue to work there?

    14 A. Yes, Mirjan Kupreskic continued to work

    15 there, and I saw him every day there because I did

    16 paperwork there, and he was downstairs in the sales

    17 department.

    18 Q. And where was that?

    19 A. In Vitez.

    20 MS. SLOKOVIC-GLUMAC: Thank you. I have no

    21 further questions.

    22 JUDGE CASSESE: Thank you, Counsel

    23 Slokovic-Glumac.

    24 Mr. Terrier?

    25 MR. TERRIER: Thank you, Your Honour.

  22. 1Cross-examined by Mr. Terrier:

    2 Q. Good morning, Ms. Witness. I am Franck

    3 Terrier. I'm one of the prosecutors, as you know, and

    4 you know that I'm going to ask you a series of

    5 questions following the examination-in-chief.

    6 First of all, could you tell us about

    7 professional activities of your husband, and about

    8 yours as well, prior to the war, in 1992 up to April

    9 1993. Could you also tell us how the business evolved

    10 after the war, you know, I'm talking about the business

    11 run by your husband. How did that develop?

    12 A. May I ask you to speak slower? You asked

    13 very many questions. I do apologise, really.

    14 Q. I am going to attempt to comply with your

    15 wish.

    16 On several occasions you mentioned the store,

    17 the Sutre store, that company that you had; could you

    18 tell us how the company was organised? Who was the

    19 owner of it, and what was the exact part played by your

    20 husband in that company?

    21 A. Ivica Kupreskic was the owner of the Sutre

    22 company, both the manager and the owner, and my husband

    23 worked together with Ivica Kupreskic as a professional,

    24 as an expert, because he had graduated from the faculty

    25 of economics.

  23. 1Q. What was your husband supposed to do within

    2 that company? What was his role?

    3 A. He was responsible for commercial affairs.

    4 Q. Could you be more specific as to the purpose

    5 of that company? What were you trading in? What was

    6 the company trading in? I'm having in mind the months

    7 if not the years prior to the war, so before April '93.

    8 A. At that time the company was trading in

    9 wholesale and retail trade in foodstuffs, and textiles

    10 to a certain extent.

    11 Q. On several occasions before this Tribunal a

    12 shop in Vitez was mentioned. Who was the owner of that

    13 shop?

    14 A. Ivica Kupreskic. It was one company with two

    15 units, with two outlets. One of them was in Pirici and

    16 the other one was in Vitez. So it is one company.

    17 Q. So let's be quite clear: The Sutre company,

    18 whose owner and director was Ivica Kupreskic, had its

    19 seat in Ahmici and Pirici, but also had an outlet in

    20 Vitez? Is that so? Was your husband working more in

    21 the Vitez outlet? Would he work more frequently in

    22 Vitez than in Pirici?

    23 A. Well, I don't know. He spent just as much

    24 time over there as over here, because sometimes he

    25 worked until midnight putting papers in order and so on

  24. 1and so forth. I have an office at home, even. It just

    2 depends on the kind of transaction, on business

    3 partners. They would come, perhaps we would meet in

    4 Vitez, conduct negotiations, and then he would go to

    5 fetch the merchandise, or ...

    6 Q. What became of that company during the war?

    7 As of April 1993, what happened to the company?

    8 A. In April 1993, there was merchandise in this

    9 company. All that we had, at that time, we had

    10 invested in merchandise. That company, when the

    11 conflict broke out, was closed down until the cease-fire

    12 was signed.

    13 Q. You mentioned investment you made. Do you

    14 think of yourself making such investment, you and your

    15 husband, or was it the company that was investing? Did

    16 your husband invest his own money into the Sutre

    17 company?

    18 A. These funds came from the company.

    19 Q. In the period following the cease-fire, what

    20 happened then? As of then, how did the business

    21 evolve? How did your husband's relations with Ivica

    22 Kupreskic evolve?

    23 A. Let me see, sometime in May, in early May,

    24 the company reopened. It was very difficult. It was

    25 very dangerous to go and bring the merchandise in. I

  25. 1mean, the roads were dangerous. It was difficult to

    2 set the company in motion again and start developing

    3 it, but somehow we all joined in, and we were managing

    4 somehow to do it, and Vlatko and Ivica Kupreskic were

    5 on correct terms.

    6 Q. Isn't it true to say that at some point in

    7 time, your husband -- and probably you, yourself, as

    8 well -- became independent in relation to Ivica

    9 Kupreskic?

    10 A. Yes, in August 1994, we founded a private

    11 company called Modus, and I'm its manager.

    12 Q. So you created this new company called

    13 Modus. Was it a company with the same purpose as the

    14 former one, which was managed by Ivica Kupreskic?

    15 A. Yes, it was the same branch of activity, and

    16 it is to this day.

    17 Q. What happened to the company run by Ivica

    18 Kupreskic?

    19 A. Well, they continued in business. They still

    20 do the same thing.

    21 Q. So you're basically competitors, aren't you?

    22 A. This is irrelevant. I take this question --

    23 right, I'll give you an answer. Ivica Kupreskic has a

    24 shop, and he still sells foodstuffs, but he has

    25 expanded his activity, and he also engages in trade in

  26. 1other types of merchandise.

    2 Q. Is it true to say that your company -- and

    3 I'm now speaking of the Modus company -- as of August

    4 1994 up till today imports into Bosnia goods which it

    5 then sells to other intermediaries? So basically you

    6 have an import business, and then you have wholesale

    7 trading? Isn't it so?

    8 A. Yes.

    9 Q. And how do you go about it? How do you

    10 import goods? How do you manage contacts with sellers

    11 abroad?

    12 A. We do not import anything from foreign

    13 countries. Our merchandise -- our supplies come mostly

    14 from Herzegovina, so we are second-hand in delivery of

    15 it. Sometimes we order it by telephone. Sometimes our

    16 representatives go there directly to our suppliers,

    17 conclude the contract, orders. So the merchandise will

    18 have a driver. He goes, ships it in, we store it

    19 there. Then, when we sell it, then we go and purchase

    20 a new lot. That's how it goes on and on.

    21 Q. How many employees does the Modus company

    22 have today?

    23 A. Modus employs ten people at present.

    24 Q. Do you run the business yourself, personally?

    25 A. As much as I can, since I'm all by myself,

  27. 1that I'm both guardian and mother, and wife of an

    2 unjustly accused person. He has no father, no brother;

    3 I'm all alone. But I do have an accountant, and he

    4 keeps books, on a day-to-day basis. I have two

    5 brothers who also work with me, so that -- but it's

    6 hard.

    7 Q. Could you give us some information as to the

    8 yearly turnover of the Modus company? Approximately

    9 so -- I'm not the, you know, Inland Revenue. Just to

    10 have an idea.

    11 A. The amount of money that passes through the

    12 company? Well, don't you think it's a business

    13 secret?

    14 Q. Keep your professional secret for yourself,

    15 then. Let's talk about the shippers, or people who

    16 would transport goods. Do you employ Fadil Sipcic?

    17 A. No. Tomo Simic, who is a Serb, works for me,

    18 and Fadil Sipcic never worked there.

    19 Q. I'm now going to mention your husband's

    20 activities prior to April 1993. It looks as though the

    21 Sutre company then mainly imported goods from Croatia

    22 and sold such goods in Central Bosnia. Is that so?

    23 A. Yes.

    24 Q. In order to buy goods in Croatia, it would

    25 happen that Ivica Kupreskic and your husband would go

  28. 1to Croatia; is that so?

    2 A. Yes, of course. How else would they buy the

    3 goods?

    4 Q. Could you tell us how often, how regularly,

    5 your husband would go to Croatia at that time? And the

    6 period I have in mind is late 1992, early 1993.

    7 A. That depended on demand. Sometimes he would

    8 go three times a week, sometimes once a week. That

    9 depended. If we sold out the goods quickly, then he

    10 would have to go as often as three times a week.

    11 Q. Do you mean by that that your husband's trips

    12 to Croatia were then at least once a week?

    13 A. Yes. Once, sometimes two times, sometimes

    14 three times. It depended on the demand for goods.

    15 Q. Would your husband usually go to Croatia

    16 alone, or was he together with someone else?

    17 A. He usually went with Ivica Kupreskic or with

    18 me, personally, so that I travelled frequently in that

    19 period with him.

    20 Q. So if you would go with him to Croatia, what

    21 kind of contracts or agreements would he conclude?

    22 What kind of contacts would he mostly have in Croatia

    23 when he made such trips?

    24 A. When contacting larger firms, Ivica would

    25 travel with him. However, to purchase clothing, like

  29. 1jeans, we would usually purchase them at the large

    2 market in Split. I would go there by passenger car,

    3 because we didn't have so much demand for clothing,

    4 because I mentioned that we dealt in clothing on the

    5 side, on a minor scale.

    6 Q. How long does a trip to Croatia take, madam?

    7 How many days did you have to spend away from home?

    8 A. Usually two days.

    9 Q. Where did your husband use to spend the

    10 night, the night away from home, since the journey

    11 would take two days?

    12 A. Most frequently we would spend the night with

    13 Radislav Simovic. Sometimes, in Split, with an old

    14 lady who was renting rooms. I personally spent the

    15 night there with this old lady in Split twice. And we

    16 went to stay with Radislav Simovic for our annual

    17 holidays.

    18 Q. Do you mean that as far as business trips

    19 were concerned, which were basically once or more a

    20 week, your husband would spend the night at Radislav

    21 Simovic's place?

    22 A. It depended. Sometimes in Split, sometimes

    23 at Radislav's place.

    24 Q. But you mean by that that it was very

    25 customary for your husband, very frequent for your

  30. 1husband to spend the night at Radislav Simovic's, say

    2 in the season period, or as well in the off-season

    3 period?

    4 A. Yes.

    5 Q. In September 1998, a witness testifying under

    6 the pseudonym of "WT" testified in front of this

    7 Tribunal, and the witness said that in October 1992,

    8 he'd seen your husband, Vlatko Kupreskic, he had seen

    9 yourself and a third person, a male, unloading a Yugo

    10 vehicle in front of your house, and there were weapons

    11 which they were unloading. This witness was heard on

    12 the 24th of September, 1998, and this was in front of

    13 your house. According to the witness testimony, this

    14 was happening in October 1992. What does this make you

    15 think of? What do you think of this witness testimony?

    16 A. I deny that, 100 per cent, because it is not

    17 true. We would often unload goods when we didn't have

    18 room in the warehouse, so we would unload them in the

    19 garage into the house. We are still doing that to this

    20 day. But that we unloaded weapons, that really is not

    21 true.

    22 Q. When your husband went to Croatia on business

    23 trips, which vehicle would he usually take to go?

    24 A. Usually the Yugo 45, because the road was not

    25 very good. Ivica owned a Mercedes in those days as

  31. 1well, but because the road was not in very good

    2 condition, we would use this smaller vehicle.

    3 Q. Is it possible that sometime in October 1992

    4 your husband brought back from Croatia goods or items

    5 that could be mistaken for weapons by a witness located

    6 some 50 metres away from the location where you were?

    7 A. No, it's not possible. Nobody could ever

    8 think that weapons were brought into my house, and they

    9 were not, until I insisted on this rifle for the

    10 purpose of protecting myself from burglars. You can

    11 check on the spot. In the attic there are cigarettes,

    12 in the garage there are other goods.

    13 Q. Were you ever helped by a third person, by a

    14 man, when you had to unload the Yugo, you and your

    15 husband? Did it happen that somebody helped you to

    16 carry goods inside the house?

    17 A. There are workers whose duty it is to carry

    18 the goods. Neither Vlatko nor I carried the goods.

    19 I'm a woman, after all, and Vlatko is not allowed to

    20 strain himself, because of his health.

    21 Q. During that period of late '92, early '93,

    22 given the circumstances prevailing at the time, did it

    23 happen that your husband bought military-type items?

    24 I'm having in mind not only weapons but also military

    25 uniforms, or any other equipment used by the army, that

  32. 1he got from Croatia. I also have tents in mind, for

    2 instance, or whatever equipment of that type.

    3 A. I do not remember that. I don't remember

    4 that they purchased any goods of that kind, nor did I

    5 see such goods.

    6 Q. But you don't rule that out? You don't

    7 remember it, but you don't rule that possibility out,

    8 do you?

    9 A. I really don't know. I never saw it, and if

    10 I didn't see it, it probably never was purchased.

    11 Surely I would have seen such things if they had been

    12 purchased.

    13 MR. TERRIER: I'm going to ask the usher's

    14 help for Prosecutor's Exhibit 172 to be shown to the

    15 witness in order to have all the necessary precautions,

    16 given that this relates to weapons.

    17 Q. Do you recognise the weapon?

    18 A. All guns are the same to me.

    19 Q. Earlier on, you were answering questions put

    20 by Mr. Par as to the weapon which was at your home, at

    21 least when your husband was arrested. As far as you

    22 can remember, was that a weapon that looked like this

    23 one?

    24 A. I really cannot recollect the appearance of

    25 the rifle that we had in our home.

  33. 1Q. Seeing it again doesn't arouse any memories,

    2 does it?

    3 A. (No audible response)

    4 MR. TERRIER: Thank you, usher. I think you

    5 can take the document -- the weapon, sorry.

    6 Q. Answering questions put by Mr. Par earlier

    7 on, you explained that you had insisted for your

    8 husband to get this weapon and that you needed the

    9 weapon because your husband was off and away and you

    10 had to make sure that your children were safe. Doesn't

    11 such a thing imply that when this weapon was brought

    12 home, it was up to you to be able to use this weapon?

    13 A. Yes, it was up to me. But believe me, I have

    14 no idea how to use a gun. My brother explained to me

    15 the simplest things that needed to be done; to put a

    16 bullet in and to cock the gun. I just wanted to have

    17 it in the house to be able to frighten the burglar. I

    18 really don't know anything about guns.

    19 Q. Did you ever use a gun? Did you ever shoot,

    20 just for training purposes, of course?

    21 A. Yes, I tried once.

    22 Q. Did your husband shoot with the gun?

    23 A. As far as I can recollect, no. Maybe at the

    24 time of his arrest, he shot twice. I tried, but he

    25 wouldn't let me.

  34. 1Q. So you can't remember then that he fired with

    2 the gun when he was arrested?

    3 A. I do remember I tried to shoot, and the rifle

    4 that was taken away probably has my fingerprints on

    5 it. But I really was confused. I gave the gun to

    6 Vlatko. He shot with it twice. He could have killed

    7 me and himself, because we thought that they were

    8 burglars.

    9 Q. Therefore, the night when he was arrested,

    10 your husband fired the gun?

    11 A. Yes, yes, he did fire it.

    12 Q. Who did he aim at?

    13 A. He fired it at the wall. He thought he would

    14 shoot into the air, but it was dark and it hit the

    15 wall.

    16 Q. Where was the gun in the house?

    17 A. Behind the door in the bedroom.

    18 Q. So the weapon was in the bedroom, just behind

    19 the door. Was it loaded?

    20 A. It was. I don't remember, actually, whether

    21 it was loaded, but I think it was. I can't remember

    22 exactly, because when I talk about it, I get upset.

    23 Q. Beforehand, I mean before the night of the

    24 arrest in December 1997, prior to that date had your

    25 husband used the gun to train with it?

  35. 1A. Not on that day. But when it was purchased

    2 in '95, he came home carrying the gun, and he said,

    3 "Look what a horrible gun they gave me." He didn't

    4 know anything about it, nor did I, but my brother, who

    5 works in the warehouse -- and this gun was sometimes in

    6 the shop and sometimes in the house, and he explained

    7 to us how to handle the gun.

    8 Q. Therefore, although you both didn't know how

    9 to use guns, you kept that gun in the room, in the

    10 bedroom. It was an AK-47 gun, and it was loaded?

    11 A. Yes.

    12 Q. Could this weapon be purchased freely? Was

    13 it perfectly legal to purchase such a weapon?

    14 A. We obtained it legally.

    15 Q. In other words, you didn't need to have any

    16 permit from the administration, any authorisation from

    17 any administrative service?

    18 A. You see, in those days all the institutions

    19 were not fully operational, so I really don't

    20 understand these things very well. It was only later,

    21 after the war, we were all informed that such rifles

    22 cannot be kept at home or on the premises because it

    23 was illegal. You are allowed to have a pistol, that

    24 is, a guard, a security officer may have one, or a

    25 hunting rifle is permitted.

  36. 1Q. Do you know who your husband purchased the

    2 weapon from?

    3 A. My husband did not buy the gun, but he was

    4 regularly issued this gun, which can be seen from the

    5 card which was registered and put away in our register

    6 in a regular fashion. He didn't buy it.

    7 Q. I only have a copy, so I didn't know that

    8 that card was yellow. But I'll come to this in a

    9 moment.

    10 However, could you tell us from whom, if he

    11 didn't buy the weapon, from whom he borrowed the gun?

    12 A. He didn't borrow it either. It says, clearly

    13 on the card, that it was issued by Mr. Miljko Omazic,

    14 who was working at that time as a keeper and who issued

    15 the gun.

    16 These were cards that were issued for such

    17 weapons. It is a regular document with the weapon

    18 indicated, the kind of weapon, who issued it, and to

    19 whom it was issued.

    20 Q. Please, madam, could you explain this to me?

    21 I didn't quite get it.

    22 That person who gave the weapon to your

    23 husband, what is that person supposed to do? What is

    24 her or his job?

    25 A. He was the keeper of the warehouse. We

  37. 1called them magacioner, the person who issues goods,

    2 the person who keeps the warehouse.

    3 Q. Which warehouse, madam?

    4 A. I don't know that, really.

    5 Q. Is it an official warehouse of the

    6 administration, government services?

    7 A. I don't know what kind of warehouse it was.

    8 I just know that Vlatko went to the brigade and asked

    9 whether he could be given something, as I was living

    10 alone with his parents, so I really don't know what

    11 kind of warehouse it was.

    12 Q. Therefore, at the time and probably also in

    13 January 1995, anyone was free to go to the barracks or

    14 the warehouse, ask for an AK-47 and get it; is that so?

    15 A. It depended on the reasons that the person

    16 would indicate as a reason for requesting a weapon.

    17 MR. TERRIER: I shall ask the usher to submit

    18 to the witness Defence Exhibit D35/3.

    19 Q. Would you agree with me in saying that this

    20 yellow card, it was yellow as the original card, that

    21 this card deals with the working hours performed by an

    22 employee, a staff member?

    23 A. No. No, I don't agree.

    24 Q. What is it?

    25 A. It is a card showing that Vlatko Kupreskic

  38. 1was issued a rifle in 1995, and these were cards that

    2 were issued under such occasion. It is clearly stated

    3 here who issued the weapon. No working hours are

    4 indicated here.

    5 Perhaps in those days they didn't have the

    6 appropriate forms. That is possible, I don't know, as

    7 to the typewritten headings of columns. So it is a

    8 kind of receipt card.

    9 Q. Who signed this card? A certain Cevozic, do

    10 you know this person? Who is this person?

    11 A. It should say Miljko Omazic [realtime error

    12 corrected], Miljko Omazic.

    13 Q. It might be a problem in translation, but

    14 what are you reading? "Cevozic", am I wrong in doing

    15 so?

    16 MR. PAR: There is a mistake in the English

    17 translation. I have the original. It says "Miljko

    18 Omazic". So it is an error in the English translation,

    19 so could the usher please show the Prosecutor the

    20 original card so that he can see for himself?

    21 JUDGE MAY: Let us see it first.

    22 MR. TERRIER:

    23 Q. If I understood your explanations well, this

    24 card was issued at the very time when your husband was

    25 given the weapon, wasn't it?

  39. 1A. Yes. This card was issued at the same time

    2 as the rifle.

    3 Q. Allow me to ask the question. Why was he

    4 given the card? Is it more customary, when you take a

    5 valuable item from a public warehouse, as was the case

    6 here, isn't it so that you sign a receipt which is to

    7 be filed in the archives of that public warehouse?

    8 Would it be more logical for your husband to sign the

    9 receipt and to hand it over to the person who issued

    10 the weapon to him?

    11 A. I don't know how they kept their records over

    12 there. I just know that Vlatko brought with him this

    13 card, certifying that he had been issued this weapon.

    14 Q. In this card, we see that your husband was

    15 issued three magazines of ammunition. We know where

    16 one of them is. Where are the other two, as far as you

    17 know?

    18 A. I don't know how many frames you took away,

    19 but I know that one of them was in the shop down there

    20 under the counter. Another one, I don't know where it

    21 is. And the one that was in the shop, my brother took

    22 away when the weapons were handed over, so that I don't

    23 have anything.

    24 MR. TERRIER: Your Honour, shall we have a

    25 break now?

  40. 1JUDGE CASSESE: Thirty minutes' break.

    2 --- Recess taken at 10:30 a.m.

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

    4 JUDGE CASSESE: Mr. Terrier?

    5 MR. TERRIER: Thank you, Mr. President.

    6 Q. Before the adjournment, we were talking about

    7 the rifle, AK-47, which your husband was issued in

    8 1995. Will you please tell us whether your husband

    9 had, at any time before that, in possession, did he

    10 have any rifle, any kind of weapon, before that time?

    11 A. Before? I didn't quite get you.

    12 Q. My question related to the period which

    13 preceded the moment when he was issued the AK-47.

    14 A. No, he did not.

    15 Q. I must insist on more precision. I'm

    16 interested in any kind of weapons; that is, a hunting

    17 rifle or whatever. Any kind of weapon.

    18 A. No, he never had either a hunting rifle or an

    19 airgun.

    20 Q. Mrs. Kupreskic, I should like to show you

    21 now, with the help of the usher, a document which is

    22 called the report on the inventory taken by the

    23 inventory commission of the 12th of February, 1993.

    24 THE REGISTRAR: 359.

    25 MR. TERRIER:

  41. 1Q. The first page of the Bosnian version of this

    2 document, to the right, we can see the name of Vlatko

    3 Kupreskic. Under his name we see a signature. Is this

    4 your husband's signature?

    5 A. Yes.

    6 Q. Thank you. Could we now move on to the 15th

    7 of April, 1993. Could you please tell us, what do you

    8 know about the reasons for and circumstances under

    9 which your husband travelled to Croatia on the 14th and

    10 15th of April, 1993, or so it would seem?

    11 A. The reason why they went there was to

    12 purchase some textile goods which they had ordered for

    13 a buyer -- or rather for (redacted); and the

    14 second reason was that Ankica Kupreskic, Mr. Ivica

    15 Kupreskic's wife, was coming back from Germany.

    16 Q. And what was the quantity, how big was this

    17 lot of clothes that you brought from that trip?

    18 A. Well, usually those textiles were packed in

    19 large bags and sacks, and the tennis shoes were in

    20 smaller boxes or crates, so that we had just one large

    21 bag of jeans, and there was underwear in a smaller bag,

    22 and children's sneakers were in a cardboard box. I

    23 wouldn't know exactly how many pairs, how many pairs of

    24 whatever, but it wasn't a significant quantity, because

    25 it was really very little.

  42. 1Q. And doesn't one calculate the value of

    2 merchandise in the clothing business by the number of

    3 pieces, by the number of items? Could you tell us how

    4 many items were brought by your husband on that

    5 particular occasion when he went on that business trip?

    6 A. Who could remember that, really? It was to

    7 be entered in the books on the next day, but in the

    8 morning of the next day the war broke out, so I really

    9 can't remember how many items there were.

    10 Q. All right. We do not have to talk about the

    11 number of items, but could you tell us how many parcels

    12 there were?

    13 A. There was one box, and there was this one

    14 large bag with jeans. And a slightly smaller bag, a

    15 bag smaller than this biggest bag, was the bag with

    16 underwear.

    17 Q. And how about tennis shoes, sneakers?

    18 A. Yes. Children's sneakers.

    19 Q. How many, approximately?

    20 A. I really don't know. I can't remember that.

    21 Q. And all this was in the boot of the Yugo 45?

    22 A. Well, some of it was in the boot and some of

    23 this was in the back seats. It fitted in, I mean, it

    24 practically all fitted in, in the Yugo 45, all that was

    25 brought on that occasion.

  43. 1Q. And where was your husband sitting, then?

    2 Because you say that the merchandise was in the back

    3 seats, so where was your husband sitting?

    4 A. Well, he couldn't be in the front because

    5 only two people could be in front, but I do not

    6 remember who sat in the front, whether it was Ankica or

    7 Vlatko. I really don't remember.

    8 Q. I should like to tell you that Vlatko

    9 Kupreskic -- that this -- he never saw this merchandise

    10 because it was in the boot, so it says that it was all

    11 in the boot, but nobody could see that. Another

    12 witness said that he could not see it because it was in

    13 the boot. So was it all in the boot of the car?

    14 A. I don't know.

    15 MR. TERRIER: Will Mr. Usher help me to show

    16 the Witness D26/3.

    17 Q. Are you familiar with this document?

    18 A. Yes.

    19 Q. Could you explain to us, what is it all

    20 about?

    21 A. This document says that Vlatko Kupreskic is

    22 authorised to go on a business trip to Vitez, Split,

    23 Vitez, from the 15th of April until the 24th of April,

    24 1993.

    25 Q. Who issued this document?

  44. 1A. Well, I suppose the authorities. This issue

    2 was usually obtained in the municipality, and up here

    3 it says the Croatian Defence -- Council of Defence. I

    4 don't know, because it wasn't me who went to get this.

    5 Q. Why was it issued in the name of Vlatko

    6 Kupreskic rather than the owner of the company, Ivica

    7 Kupreskic?

    8 A. Well, this authorisation was issued on an

    9 individual basis, and every person had to have his own

    10 authorisation to be able to move about freely. I guess

    11 that Ivica Kupreskic also had such an authorisation. I

    12 don't really know. I don't know whether he had such a

    13 permit.

    14 Q. Do you have the original of the document?

    15 A. I don't have the original of this document

    16 because all the documents were taken away when Vlatko

    17 was arrested, and I saw them, with my own eyes, take

    18 away all the documents from our house.

    19 Q. I'm asking you this because Mr. Ivica

    20 Kupreskic, when he testified here, said that the

    21 original of the document that you have now before you

    22 was in your possession, and he had given it to you. Of

    23 course, he didn't know what you did with it afterwards,

    24 but he said that he'd given it to you.

    25 A. I never asked Ivica to give me his permit,

  45. 1excuse me. Whether it's in the house or where, in the

    2 archives, among the records, in the files, I can't tell

    3 you. But all the documents that relate to Vlatko

    4 Kupreskic were the originals which were taken away.

    5 Q. Are you quite positive about the date of the

    6 trip your husband made to Croatia? In other words,

    7 are you quite positive that he left on the 14th of

    8 April and that he returned on the 15th?

    9 A. I'm 100 per cent certain that he left on the

    10 14th of April and returned on the 15th of April, in

    11 late afternoon.

    12 Q. Are you absolutely positive that the purpose

    13 of his trip was only to buy a few pairs of jeans and

    14 some other things on the market in Split and, secondly,

    15 to meet Mrs. Kupreskic, calling her and giving her a

    16 lift from the Split airport? Did he have any other

    17 plans for that business trip?

    18 A. No, as far as I know.

    19 Q. If he had some other business plans, for

    20 instance, to negotiate -- to conduct negotiations about

    21 a sale or something, would you have been informed about

    22 that, would you know about that?

    23 A. Well, as a rule, I always know where my

    24 husband is. He calls me either by telephone or let's

    25 me know in some way or other. Whether he was supposed

  46. 1to conduct some negotiations to strike a deal or

    2 something, I really can't remember because it was a

    3 long time ago. Whether down there they were about to

    4 conclude a business contract or something, I really

    5 can't remember now.

    6 Q. Do you remember if during that trip, when he

    7 was either in Croatia or on his way, did he call you to

    8 tell you what was going on?

    9 A. I really can't remember. He may have. I was

    10 also absent because I also was having additional

    11 driving lessons, and I really can't remember.

    12 Q. Could you tell us something about the return

    13 of your husband on the 15th of April in late afternoon

    14 or the evening?

    15 A. I can tell you all that you want to know.

    16 Q. Could you share your memories? When did he

    17 come back, how did he come back, what did he do with

    18 the merchandise, and things like that?

    19 A. So he arrived on the 15th of April, '93, late

    20 in the afternoon or early evening, around 7.00. I came

    21 out of the house, greeted Mrs. Ankica Kupreskic because

    22 I had not seen her for a year and a half. Then those

    23 clothes were taken out of the car and into the house,

    24 and it was agreed that all this had to be delivered to

    25 Travnik the next morning around 8.00. Then they left.

  47. 1We entered our house, and that's about it.

    2 Q. According to several other witnesses who

    3 testified here before the Tribunal, that indeed in the

    4 house of Ivica Kupreskic there was a kind of a party to

    5 celebrate the return of his wife. Do you remember

    6 that?

    7 A. I don't remember going there.

    8 Q. Let us now move to the night between the 15th

    9 and 16th of April.

    10 Yesterday you told us that at dawn, you

    11 received two anonymous telephone calls and a third

    12 telephone call which came from Ivica Kupreskic; is that

    13 correct?

    14 A. It is.

    15 Q. At what time did the first anonymous phone

    16 call come?

    17 A. The first anonymous telephone call, as far as

    18 I can remember, was around 3.00 in the morning, and the

    19 second one, around 5.00. So Ivica called shortly after

    20 that second anonymous call.

    21 Q. We need to be accurate about this. There may

    22 have been an error, because I heard that this first

    23 anonymous call was much later.

    24 Are you absolutely certain that this first

    25 call, which told you to move to the shelter, came

  48. 1around 3.00 in the morning?

    2 A. Yes, it was around 3.00.

    3 Q. Are you quite sure? You were looking for an

    4 explanation -- rather observation made by Mr. Par, and

    5 he was asking you about lights in the house, that you

    6 must have switched on the lights in order to answer the

    7 telephone. Is that so?

    8 A. No, I don't have any need to light the

    9 lights, because it is a custom with us in Bosnia to

    10 leave some lights on either at the entrance door or in

    11 the passage. In my house, there were two lamps on, so

    12 I don't need to. One can see. I do not have any

    13 blinds on the windows, so one can see through, and I

    14 had no reason to switch the lights on.

    15 Q. Do you remember something more about that

    16 person who called you at 3.00 in the morning? What was

    17 his exact words?

    18 A. I do remember. He said to go to the shelter

    19 because the Muslims would attack us. I asked, "Who is

    20 it," and he put down the phone. Because there had been

    21 such similar provocations, I just went back to bed and

    22 I didn't wake Vlatko up to tell him because he was

    23 tired.

    24 Q. Did you have such anonymous telephone calls

    25 before that?

  49. 1A. Yes.

    2 Q. Could you tell us more specifically when that

    3 was?

    4 A. When? Let me see. But it was sometime

    5 between '92 -- at the turn of 1993 from '92. Which

    6 month, I can't really remember.

    7 Q. The second call you told us came at 5.00 in

    8 the morning. Was it the same voice?

    9 A. I can't remember it, really, whether it was

    10 the same voice or not.

    11 Q. Did the person who called you at 5.00 in the

    12 morning say about the same thing? Was it the same

    13 reason, why he called?

    14 A. Yes.

    15 Q. These two telephone calls coming from

    16 somebody who told you the same thing twice, didn't they

    17 upset you?

    18 A. No, because they were provocations of that

    19 kind so that I wasn't upset. I again went back to

    20 bed. Were it not for Ivica Kupreskic to call us again,

    21 we would have been caught unawares in the house.

    22 Q. Did you think that it was impossible that the

    23 Muslims would attack Ahmici?

    24 A. I could never really grasp it, take it into

    25 my head, that the Muslims would attack us, our

  50. 1neighbours. It was just beyond me.

    2 Q. Yes, your Muslim neighbours. So likewise it

    3 would be impossible that the Bosnian army attacks

    4 Ahmici?

    5 A. Well, I don't know if one can imagine such a

    6 thing or not, I know nothing about those things, nor

    7 could I ever imagine that a conflict could break out.

    8 Q. Now I should like to ask you to show us on

    9 this aerial photograph, I hope you can identify things

    10 on this photograph, the road which you took in the

    11 morning of the 16th of April to go from your house to

    12 the shelter.

    13 A. This is our shop (indicating), and here

    14 (indicating), I think, should be our house. So we came

    15 down from our house by the warehouse to the road which

    16 leads to Ivica Kupreskic's house. We passed by Ivica

    17 Kupreskic's house here (indicating), towards the woods

    18 here (indicating), went through the woods and came out

    19 onto the road which passes by Santic's house. Then we

    20 proceeded down there to the shelter. Somewhere here

    21 (indicating), I think, was the playground, and one

    22 could already hear shots fired in Ahmici when we got

    23 here. Then we got to this road (indicating). There is

    24 a curve here (indicating). And we reached the house of

    25 Jelena, the house of Jozo Vrebac.

  51. 1THE INTERPRETER: We could not hear the end

    2 of the witness's sentence.

    3 MR. TERRIER: Thank you.

    4 Q. Could you please now trace that route on this

    5 map which we shall give you in a moment?

    6 THE REGISTRAR: This is Exhibit 360.

    7 MR. TERRIER:

    8 Q. Madam, the photograph that you have in front

    9 of you is the same as the one on the easel. The usher

    10 is going to give you a marker, a pen, and please trace

    11 the path that you have just shown us on the map, on the

    12 aerial photograph.

    13 A. (Witness complies)

    14 Q. Thank you. You told us, madam, that upon

    15 arriving near the playground, the sports grounds, you

    16 heard the first shots. Is that true?

    17 A. Yes.

    18 Q. Could you simply put a cross, showing us

    19 where that sports playground is that you have just

    20 mentioned?

    21 A. (Witness complies) I said that when we

    22 reached the sports grounds, we heard it, so it was at

    23 this point (indicating).

    24 Q. So when you arrived at the spot marked with a

    25 cross, on this pass, it was at that point in time that

  52. 1you heard the first shots, just to clarify?

    2 A. Yes.

    3 Q. When you left your house, you were with your

    4 husband, your two children, and according to what you

    5 said yesterday, I think, your mother-in-law?

    6 A. Yes.

    7 Q. Do you remember how your husband was dressed?

    8 A. Yes.

    9 Q. Could you please tell us, madam?

    10 A. I can. That morning, Vlatko was wearing a

    11 velvet chocolate-coloured jacket. It's a short jacket,

    12 a winter jacket. And he had corduroy pants in a dark

    13 colour, and a shirt, as far as I remember, a chequered

    14 shirt.

    15 Q. When you left your house, in the area in

    16 which you lived, did you see any other people around

    17 you?

    18 A. When we reached Niko Sakic's house, I saw

    19 Niko Sakic in the yard, and I saw Dragomir Samija in

    20 his yard. And then, some 500 metres away, I saw Milan

    21 and Mara Samija.

    22 Q. But before reaching those houses, did you see

    23 other people? Did you see anybody close to Ivica

    24 Kupreskic's house and the house of Zoran and Mirjan

    25 Kupreskic? Did you see people later on in the woods

  53. 1through which you passed?

    2 A. I don't remember seeing anyone.

    3 Q. Would it be correct to say that upon leaving

    4 your house to go towards Ivica Kupreskic's house, you

    5 passed by Sakib Ahmic's house?

    6 A. Well, along the path we took, you could see

    7 Sakib Ahmic's house, but it was not by the house that

    8 we passed. It doesn't mean that.

    9 Q. Do you think that Sakib Ahmic's family was

    10 warned of the need to find shelter?

    11 A. When I reached Ivica Kupreskic's house, I saw

    12 that the light was switched on in Sakib Ahmic's house,

    13 and I remember that very well. Now, whether they had

    14 been informed or not, I couldn't tell. I don't know.

    15 Q. But as you just told us a moment ago that it

    16 was customary in Bosnia to leave a light on, what you

    17 saw has no meaning?

    18 A. No, it does mean, because the light in the

    19 house was on. Not outside the house, not light bulbs

    20 in front of the door or on the balconies. That I

    21 really do remember.

    22 Q. When leaving your house, until you reached

    23 your shelter, did you meet or see any soldiers?

    24 A. I didn't meet anyone, but when I reached

    25 Ivica Kupreskic's house, I heard some steps, and it

  54. 1looked like, to me, the echo of certain steps. Now,

    2 whether they were soldiers or not, I couldn't see from

    3 Ivica Kupreskic's house, but I did hear those steps.

    4 Q. When you speak of these steps, are you

    5 thinking of a group of marching soldiers or simply

    6 people passing by? I think the distinction can quite

    7 easily be made.

    8 A. I didn't see, so I couldn't tell you what

    9 kind of group it was.

    10 Q. When was it that you decided to go to

    11 Mr. Vrebac's house, to the shelter there, and not to

    12 any other?

    13 A. Because we went to that shelter before, and

    14 when we passed by Niko Sakic's house, he said that it

    15 was full and that we should go on, though we had never

    16 used Niko's shelter before.

    17 MR. TERRIER: With the help of the usher, I

    18 should like to show the witness Exhibit D13/1.

    19 Q. Will you please look at this document, and as

    20 soon as you become familiar with it, I should like you

    21 to put it under the ELMO so that we can see what we are

    22 looking at.

    23 Do we see, in this document given to the

    24 Tribunal by the Defence, Mr. Vrebac's house where you

    25 found shelter in the course of the day of the 16th of

  55. 1April, 1993?

    2 A. Yes, that is the house of Jelena, Mr. Jozo

    3 Vrebac's daughter. This was the house where we were on

    4 the 16th of April, 1993.

    5 Q. In the same photo album we can see pictures

    6 of the basement of this house. Would you agree with

    7 me?

    8 MR. TERRIER: Mr. Usher, can you show us the

    9 other photographs on the ELMO.

    10 A. Yes.

    11 Q. Could you tell us in which part of the

    12 basement did you find refuge, by mentioning the number

    13 attached to the photograph?

    14 A. Here, in this part (indicating), which

    15 means -- there's another door behind here (indicating),

    16 to the left. The number of the picture?

    17 Q. Could you tell us which photograph you are

    18 referring to?

    19 A. Photograph number 4.

    20 Q. Very well. I apologise for interrupting

    21 you. What were you saying about what is shown on this

    22 photograph?

    23 A. Behind here, there's another door and another

    24 room. There's a room here (indicating).

    25 Q. Very well. In this album, can we see the

  56. 1room which you took shelter in when you arrived on the

    2 16th of April, 1993, in the morning?

    3 A. Here, in the corner here. You can't see it

    4 on this photograph, this photograph number 4. It's

    5 here (indicating).

    6 Q. And you can't see that room on any other

    7 photograph in the album?

    8 A. The steps, and these are parts of the

    9 staircase, but I don't see this room on any of the

    10 photographs.

    11 MR. TERRIER: Mr. Usher, could you turn the

    12 page and show the witness other photographs.

    13 Q. Looking at these photographs, 5, 6, and 7, do

    14 you recognise the room in which you took shelter?

    15 A. Yes, I do. This is the room, shown on

    16 number 6 (indicating).

    17 Q. So it is the room that is opened by the door

    18 in the middle of this photograph, number 6; could you

    19 tell us whether you spent the whole day in that room?

    20 A. I didn't spend the whole day in that room.

    21 Q. Where did you go when you left this room?

    22 A. I moved around. I was in this room, but I

    23 was also on the ground floor, here (indicating),

    24 because there was a toilet here that we all used, on

    25 the ground floor.

  57. 1Q. In the course of that day, therefore, you

    2 found refuge in the room that we see the door of on

    3 photograph number 6, and also from time to time you

    4 went up to the ground floor because the toilet was

    5 there?

    6 A. Yes.

    7 Q. Could you show us or tell us the people who

    8 were with you in the room that we see on photograph

    9 number 6? Of course, if you can remember that. Which

    10 other families found refuge in that same room?

    11 A. There were many people there. It is

    12 difficult to remember all those people, because people

    13 were going up and down, moving around. But I can

    14 remember, for instance, some of those families. There

    15 was Nevenka Marjanovic, with her children; she had a

    16 small baby in those days. Then there was Lucinka

    17 Papic; she had five children. Then Jela Vidovic, a

    18 sick woman, whom they carried in on a stretcher. Then

    19 I saw Ruza Grgic there as well.

    20 All these rooms were full, so it is hard to

    21 recollect all those names, but I shall try, if

    22 necessary, to recall some other names.

    23 Q. You told us yesterday, madam, that your

    24 husband, Vlatko Kupreskic, stayed with you in the

    25 basement, in the room that you have shown us, until

  58. 1about 10.00 in the morning. You confirmed that?

    2 A. Yes.

    3 Q. I draw your attention to the fact, madam,

    4 that two witnesses who testified here -- you wanted to

    5 say something?

    6 A. I thought you had finished your question.

    7 Q. Well, answer the question that you thought I

    8 had put to you.

    9 A. Vlatko came with us that morning, but he

    10 didn't stay for a long time in the basement because

    11 there were a lot of women and children, so he went back

    12 upstairs to the ground floor. I, too, didn't spend a

    13 long time in this room. I went upstairs often to smoke

    14 a cigarette.

    15 Q. Why, madam, did your husband leave this house

    16 about 10.00 in the morning, according to your

    17 testimony?

    18 A. He left the house because the shooting had

    19 subsided and because everyone around him was saying

    20 that he should go and check how his father was, whom we

    21 had left behind.

    22 Q. When you left your house that morning, were

    23 you disturbed about what could happen to your

    24 father-in-law, and was your husband, too, worried about

    25 what could happen to his father?

  59. 1A. When we left the house, we had no idea that

    2 anything could happen.

    3 Q. But nevertheless, madam, you left your house

    4 before 6.00 in great haste because you received

    5 warnings and advice, strong advice, to go to a

    6 shelter. You must have thought that there was a risk

    7 to stay on in that house.

    8 A. I repeat again. If Ivica Kupreskic hadn't

    9 called up, we would have stayed in our house. What was

    10 decisive for us to leave was Ivica Kupreskic's call.

    11 Q. I understand that, madam. Ivica Kupreskic

    12 called you up, and you decided to leave. But if you

    13 decided to leave, it is because you thought or, rather,

    14 Ivica Kupreskic convinced you that it was risky to stay

    15 in that house; is that correct?

    16 A. No. The very thought of the word "Mujahedin"

    17 caused fear, and we were afraid to stay in the house,

    18 because this wasn't the first time that we fled our

    19 house. But we couldn't imagine that that morning,

    20 anything could happen.

    21 Q. Madam, I would like you to be very precise in

    22 expressing your thoughts. You have just told us that

    23 the very word "Mujahedin" frightened you. You left

    24 your house with your children, your husband, your

    25 mother-in-law. Isn't it reasonable to think that if

  60. 1you left that house, it was because you thought that

    2 there was a danger in staying in that house that

    3 morning; isn't that reasonable, to conclude that?

    4 A. Well, whether it's reasonable or not, I don't

    5 know. When Ivica called up, saying that everyone had

    6 left and sought shelter, why would we stay on?

    7 Q. I'm trying to clarify why you left behind you

    8 your father-in-law. Wasn't there some way, any way, of

    9 taking him with you as far as the shelter, as Mirjan

    10 Kupreskic did for his own mother-in-law, if I remember

    11 well, who was transported in a wheelbarrow, I think?

    12 Wasn't there any way to ensure the safety of your

    13 father-in-law?

    14 A. Because Vlatko's father didn't want to leave,

    15 and he was a sick man. Even then, we thought it was a

    16 mere provocation and nothing would come of it.

    17 Q. In your opinion, could you explain why your

    18 father-in-law, Vlatko's father, did not wish to leave?

    19 A. It's not that he didn't wish to leave. He

    20 couldn't leave because he was sick. However, later

    21 when we got together, he said that if he had known what

    22 would happen, he would have crawled on all fours to

    23 leave the house. I remember that well.

    24 Q. When did you see him again, your

    25 father-in-law?

  61. 1A. I saw him that same day on the 16th of April,

    2 in the evening about 8.00.

    3 Q. Where did you see him?

    4 A. I saw him when Vlatko arrived and brought him

    5 here to this room in the ground floor. At first, he

    6 was here somewhere. Then he was in this other room

    7 where we were.

    8 Q. In your opinion, your father-in-law, Vlatko's

    9 father, as soon as he realised it was not a provocation

    10 but something very serious, that is, after 5.30,

    11 couldn't he have joined you before 8.00 in the evening

    12 in the shelter where you were?

    13 A. It was hard to bring a man who carried a

    14 stick, who had an operated hip, who breathes with

    15 difficulty. It was hard for him to reach the shelter

    16 on foot. In the meantime, there was shooting going on.

    17 Q. But he did so, nevertheless, in the evening,

    18 didn't he?

    19 A. Yes.

    20 Q. Madam, do you remember writing a letter to

    21 the Prosecutor of this Tribunal in November 1997?

    22 A. Yes.

    23 Q. I'm going to show you a copy of that letter.

    24 THE REGISTRAR: It is Exhibit 361.

    25 MR. TERRIER:

  62. 1Q. Is that the letter that you wrote to the

    2 Prosecutor of this Tribunal in November 1997?

    3 A. Yes.

    4 Q. I draw your attention, madam, to the top of

    5 the second page of the English version, I think it is

    6 the same spot in the Bosnian version, where you say

    7 that your husband, Vlatko, who was with you in the

    8 shelter, received orders to go to Niko Sakic's house,

    9 where he was detailed to help the wounded, where he had

    10 to treat the wounded. Your husband, according to what

    11 you wrote, received orders to go to Niko Sakic's house

    12 to take care of the wounded?

    13 A. That is not correct, because this is just a

    14 summary of my story, my statement before Grlimir

    15 Jonjic, who is a relative of my husband's.

    16 Q. Madam, this is a letter that you addressed to

    17 the Prosecutor of this Tribunal in The Hague in

    18 November 1997, and you wrote in that letter, which I

    19 think was written freely, unless you deny it, that your

    20 husband, who was in the shelter, received orders to go

    21 and care for the wounded?

    22 A. That is what I was told then, but that is not

    23 true because I was against Vlatko's leaving the

    24 shelter. I grew up without a father. I was an

    25 orphan. I was afraid that Vlatko would get killed, and

  63. 1I was told that he was ordered to go to Niko Sakic's

    2 house. And then I realised, afterwards only, the

    3 truth, that Vlatko had gone home to see what was

    4 happening with his father.

    5 Q. I don't understand anymore. You tell us that

    6 your husband, Vlatko, was with you all the time in the

    7 shelter next to the Vrebacs, and now you tell us that

    8 he left. But you must have learned when he left, if

    9 you were present, and if he were present, you must have

    10 known why he left.

    11 A. Yes. He was there until 10.00. He left

    12 around 10.00. I learned the real truth, that he had

    13 gone to see if his father was alive. But for that,

    14 this gentleman who typed this thing did not write

    15 that. I mean how could Vlatko extend aid to the

    16 injured when he was an economist, a graduate

    17 economist? He's not a physician. I mean it's nonsense

    18 but there.

    19 Q. Well, it may not be nonsense, because

    20 somebody else brought it to the Tribunal. Was it Sakic

    21 who --

    22 A. Well, that's what I remember being told,

    23 because I was really against Vlatko's going back home.

    24 I was afraid he would get killed, and that is why I was

    25 told what I was told. Only when Vlatko came back did I

  64. 1find out that he had gone home and that his father was

    2 alive.

    3 Q. Could you please try to be as clear as

    4 possible, because this is a very important point. So

    5 let us be very clear.

    6 You said today, and I'm listening to you now,

    7 it seems that you were not present -- that you weren't

    8 next to him at the moment when Vlatko left the shelter.

    9 A. I was present 100 per cent when Vlatko left,

    10 because who else would he have addressed if not me?

    11 Q. But at that moment as he was leaving the

    12 shelter, did he tell you then why he was going out and

    13 where he was going?

    14 A. He told me then that he had been ordered,

    15 because he saw me crying, I was afraid, and that he had

    16 been ordered to go to Niko Sakic's house. But after he

    17 found his father alive in the house and when he

    18 returned, it was then that he told me the truth, that

    19 in fact he had gone home to see his father.

    20 Q. So as your husband, Vlatko Kupreskic, leaves

    21 the shelter, he tells you that he had been issued

    22 orders to take care of the wounded?

    23 A. It was his uncle who told me that he had

    24 received those orders. It was Anto Kupreskic or,

    25 rather, Vlatko's father's brother.

  65. 1Q. I am asking about what Vlatko Kupreskic said.

    2 A. Well, Vlatko said that he would like to go

    3 home and see if his father was alive. But as I was

    4 against it, at that time Vlatko's uncle said that he

    5 should go to Niko Sakic's house and extend aid to the

    6 injured. I thought at that time that that was the

    7 reason.

    8 Q. But did you ask your husband to confirm it?

    9 A. I didn't.

    10 Q. But wasn't his feeling of duty, to go and see

    11 his father to see if he was still alive, wasn't that a

    12 sufficient reason for him to leave? Did he really need

    13 to have an order to go and attend to the wounded for

    14 you to let him go?

    15 A. Because I was crying, I was afraid that he

    16 would get killed.

    17 Q. Then why, when you wrote this letter to the

    18 Prosecutor of the Tribunal, why didn't you simply say

    19 that your husband, Vlatko Kupreskic, left the shelter

    20 at 10.00 in the morning because he wanted to go and see

    21 whether his father was still alive? Why didn't you say

    22 that quite simply in that letter?

    23 A. Well, first let me explain how this letter

    24 was written and who did it, because it wasn't me who

    25 typed it. I told the whole story, how it happened and

  66. 1what happened on the 16th of April, 1993, and this

    2 letter was typed by Grlimir Jonjic, Vlatko's relative,

    3 Vlatko's cousin, who can be called to testify if need

    4 be.

    5 So there are some changes here. There is a

    6 date which is wrong here. And I did not read that

    7 letter again after it was typed.

    8 So on the basis of my story, he wrote this

    9 letter, and all these enclosures that I gave him, he

    10 enclosed here attached to this letter.

    11 Q. Let me just comment. You seem to me quite a

    12 temperamental woman, I realise that, but let me tell

    13 you that you're running an enterprise with about a

    14 dozen persons, they seem to be properly looked after,

    15 and I simply refuse to believe that in a case of such

    16 gravity and concerning the family so much, you simply

    17 failed to read again a letter which you were sending

    18 and -- a letter to the Prosecutor of the Tribunal,

    19 which you then signed. I find it difficult to believe

    20 that you didn't go through it.

    21 A. But this is not my signature.

    22 Q. Excuse me. Just a moment ago, you identified

    23 the letter.

    24 A. Yes, I did identify the summary of the

    25 letter. I know that that is the letter. But the

  67. 1signature -- I never read this letter. It was

    2 Mr. Grlimir who called me from Sarajevo and told me

    3 that the letter had been typed and could he sign it in

    4 my name, and I told him he could because I thought that

    5 he had written -- that he had taken down our

    6 conversation and typed it there. But if this letter is

    7 at issue, we could call this gentleman to testify

    8 here. He's there and he's alive.

    9 Q. Yes, that would be highly advisable indeed.

    10 But let us understand your position just a moment ago,

    11 that as a matter of fact this was the letter that you

    12 sent to the Prosecutor. Now you said that you

    13 entrusted it to a cousin or a friend, to an individual

    14 that you entrusted the drafting of this letter which

    15 was, as a matter of fact, your personal letter to the

    16 Prosecutor. You let somebody else then write it. Now

    17 you tell us you never even read it, never even signed

    18 it, but it was signed by somebody else in your name.

    19 Is that what you're telling us?

    20 A. Quite. I did not sign this letter. I never

    21 had an opportunity to read it. All I was informed is

    22 that on the basis of my whole story and the documents

    23 here, that this letter was drafted on the basis of all

    24 that, then typed and sent to you.

    25 Q. Therefore, it is quite possible, if I am to

  68. 1believe you, it can --

    2 A. Yes, that is how it was.

    3 Q. So can one take it then that in this letter,

    4 very few things are truthful, because after what you

    5 are telling us, it is possible that this letter

    6 contains all sorts of errors and mistakes, according to

    7 your statements?

    8 A. No. Here there are a couple, only, of

    9 errors, but the rest of it is true.

    10 Q. Could you please show us your signature, a

    11 specimen of your signature?

    12 A. Yes.

    13 Q. No, no, that's not what I want. I'm asking

    14 if you have any document with your signature. I'm not

    15 asking you to sign now a new document. Do you have

    16 something which carries your signature? Do you have a

    17 contract, your identity document or something,

    18 something which bears your signature? Do you have

    19 anything with you?

    20 A. (Witness complies)

    21 Q. Well, as this is not your signature, does it

    22 mean that you are seeing this document for the first

    23 time?

    24 A. No, this is not the first time I've seen this

    25 document.

  69. 1Q. When did you first see this document?

    2 A. When it was submitted to you, to the

    3 international police in Sarajevo, I was then given a

    4 copy of the document.

    5 Q. Did you read it then? Did you look into what

    6 that document contained, the one that you were given a

    7 copy of?

    8 A. Yeah, I did.

    9 Q. Weren't you surprised by the errors that you

    10 found in it?

    11 A. Well, this letter should have been much more

    12 exhaustive.

    13 Q. What do you mean by that?

    14 A. I mean that this whole event, our departure,

    15 our stay, our return, should have -- it should have

    16 taken many more pages. This is just a summary of our

    17 conversation.

    18 Q. But why didn't you then take care that this

    19 letter be complete, be rounded off?

    20 A. Well, we thought that all these documents

    21 which were sent would show clearly enough that Vlatko

    22 Kupreskic was a war invalid, that he had a university

    23 diploma, that he was a businessman, that he had been on

    24 a business trip on the eve of the conflict, and a

    25 number of other documents.

  70. 1Q. I'd like you to tell me, what do you think

    2 about the following: We know, through different

    3 contacts which you had with some of the prosecution

    4 witnesses -- and I'm just mentioning it, but we know

    5 that there were some contacts; we know the importance

    6 that you are attaching to the defence of your husband.

    7 And I think it only natural, of course. I would not

    8 bear a grudge against you for that.

    9 What surprises me is this casual attitude

    10 that you showed with regard to this letter that was

    11 sent to the Prosecutor, and this carelessness which you

    12 permitted when you allowed somebody else to sign this

    13 letter in your name, because legally speaking, it is

    14 then a forgery.

    15 A. Well, that is not true, really. I wasn't

    16 then involved in my husband's defence so much at that

    17 time as I am today.

    18 Q. I should also like to hear your response to

    19 the following: We heard here Niko Sakic testify.

    20 Could you --

    21 JUDGE CASSESE: If you have more questions on

    22 the same --

    23 MR. TERRIER: Yes, yes, yes, I will come back

    24 to this.

    25 Q. This Court heard the testimony of Niko Sakic,

  71. 1and he knew your husband at that time, and he said that

    2 your husband was that night to take care of the

    3 wounded, but that that night -- there were no wounded

    4 that night, so it must have -- but according to this

    5 witness, your husband's duty was to take care of the

    6 wounded. That is what he told this Court. Now, what

    7 is your response to that?

    8 JUDGE CASSESE: Mr. Par?

    9 MR. PAR: I did not hear that witness say

    10 that here, and I'd like this to be checked in the

    11 transcript, but I do not remember that witness saying

    12 that. I may be wrong, and I will apologise if I am,

    13 but I do not remember that witness saying that.

    14 (Trial Chamber confers)

    15 JUDGE CASSESE: Perhaps we could make a break

    16 in order to check whether Niko Sakic did indeed say

    17 that. 15-minute break.

    18 --- Recess taken at 12.17 p.m.

    19 --- On resuming at 12.33 p.m.

    20 JUDGE CASSESE: Mr. Terrier?

    21 MR. TERRIER: Thank you, Your Honour.

    22 Q. I'm referring to page 8.298 of the

    23 transcript. This is the cross-examination of Niko

    24 Sakic, a Defence witness. I'll give you the gist of

    25 it. This is for Mr. Par: The Prosecutor is asking of

  72. 1Mr. Sakic whether the latter remembers making a

    2 statement, a written statement, in January 1998, which

    3 statement was disclosed to the Prosecution. Mr. Sakic

    4 states, in this written statement disclosed to the

    5 Prosecution by the Defence, that around 10.00 in the

    6 morning, Vlatko Kupreskic appeared in front of the

    7 witness's house because, according to what the witness

    8 understood, he was detailed to help evacuate the

    9 wounded. Vlatko allegedly stayed there for about three

    10 hours, and since there were no wounded, he then left.

    11 When faced with this written statement, the

    12 witness, testifying before the Tribunal, stated that he

    13 then thought the following: Since Vlatko Kupreskic was

    14 not fit for active military service, since he was not a

    15 member of an army or a political or social

    16 organisation, and because he had a driving license, he

    17 was bound to provide medical aid. The witness

    18 specified that these were his own thoughts. This was

    19 his own opinion.

    20 I was referring to this very statement, and

    21 I'd like the witness to tell us whether the statement

    22 which I've just mentioned and the mention we found in

    23 the letter to the Prosecutor of this Tribunal do not

    24 call for some observations from the witness.

    25 JUDGE CASSESE: Mr. Par?

  73. 1MR. PAR: Mr. President, I don't want to

    2 cause any particular problems, but we checked the notes

    3 regarding Sakic's testimony, and it emerges from our

    4 notes that in answer to the Prosecutor's question,

    5 explaining his previous statement, he said that he

    6 thought that for those reasons Vlatko Kupreskic was

    7 there, to care for the wounded; and after that, in

    8 continuation of his testimony, he said that Vlatko told

    9 him the real reason.

    10 I really do not wish to prevent the

    11 Prosecutor in any way asking this question, and to

    12 clear it up, I'm just against anyone saying explicitly

    13 that this was something that Witness Sakic had

    14 explicitly stated. So could this question be rephrased

    15 so as not to cause any debate or dispute over it?

    16 MR. TERRIER: Your Honour, I'm going to

    17 rephrase the question, but basically in the same words,

    18 because I thought that my question was perfectly in

    19 keeping with the statement made by Niko Sakic, which I

    20 tried to reproduce the most exactly and the most

    21 honestly possible.

    22 The witness said that when he saw Vlatko

    23 Kupreskic turn up at the threshold of his house, this

    24 witness thought that Vlatko Kupreskic, given the

    25 circumstances I have alluded to, was detailed to help

  74. 1the wounded. That was the witness's personal statement

    2 which he transcribed in a written statement dated

    3 January 1998, a statement taken by the Defence and

    4 disclosed by the Defence to the Prosecution.

    5 Q. So my question to the witness is as follows:

    6 Isn't it strange, is there no explanation to be

    7 provided for the fact that Niko Sakic thought what he

    8 thought when he saw Vlatko Kupreskic on the 16th of

    9 April, around 10.00 in the morning, according to the

    10 witness, and to the fact that we find in the written

    11 letter, a letter written in October 1997 to the

    12 Prosecutor, which gives us the same account, the same

    13 explanation for Vlatko's departure from the shelter.

    14 Is there no explanation to be given for this

    15 coincidence, let us say?

    16 A. Niko Sakic, why he thought that, I cannot

    17 know. Niko Sakic probably couldn't think of anything

    18 else because he didn't know that his father was at

    19 home. That is one thing.

    20 Secondly, I was told that this was the case,

    21 but when Vlatko returned, he told me that he had gone

    22 home to see how his father was doing, because I was

    23 absolutely opposed to him going.

    24 Q. Would you please explain to me why, if Vlatko

    25 Kupreskic was indeed worried about his father, why

  75. 1then, after taking his family to the Vrebacs' shelter,

    2 after making sure that all the family members were safe

    3 there, why he didn't straightaway return to see his

    4 father close to the house? Why did he wait four hours

    5 to do so, four hours, from 6.00 until 10.00?

    6 A. First of all, Vlatko is not a very healthy

    7 man. He's afraid when he hears shooting. And

    8 secondly, the father was at home, and there was less

    9 danger of him being shot or hit by a bullet than for

    10 Vlatko, who would be moving through open space.

    11 Q. Can you give me another explanation, madam?

    12 If indeed Vlatko was worried about his father, if that

    13 is the reason why he left the shelter, the Vrebac

    14 shelter at 10.00, why, according to Niko Sakic's

    15 testimony, he stayed at Niko Sakic's from 10.30 until

    16 12.30 or 1.00, so basically from 10.00 until 12.30; why

    17 did he stay there?

    18 A. I didn't understand. Where did he stay?

    19 Q. At the house of Niko Sakic.

    20 A. I don't know. I cannot know the details as

    21 to why he stayed there, but I know when he returned to

    22 the shelter.

    23 Q. Could you tell us why you are so absolutely

    24 certain of the time when Vlatko Kupreskic left the

    25 Vrebacs' shelter?

  76. 1A. I'm sure because I know, and this is what I

    2 remember in particular, my son Igor started vomiting in

    3 the basement, so I took him upstairs to the ground

    4 floor. Vlatko was there, and I took the boy to the

    5 toilet, and Vlatko took him in his lap. In the

    6 meantime, I ran across to Jozo Vrebac's house and made

    7 tea for the boy, and I know it was around 10.00,

    8 roughly.

    9 Q. Did you have a watch?

    10 A. I did have a watch on my wrist.

    11 Q. Are you sure of the time when Vlatko

    12 Kupreskic returned to the shelter?

    13 A. It was in the afternoon when he came back.

    14 He brought with him some bread and salami because it

    15 was time for lunch, and we were hungry, and there was

    16 nothing in the shelter.

    17 Q. Do you have any idea -- you possibly can't

    18 remember, but do you have any idea of the time when he

    19 came back to the shelter?

    20 A. As far as I can remember, it could have been

    21 about 4.00.

    22 Q. In other words, your husband, according to

    23 your statement, was absent from 10.00 to 4.00 in the

    24 afternoon. That is, altogether, six hours. Did he

    25 tell you what he had done during those six hours?

  77. 1A. Yes, he did.

    2 Q. What did he tell you he did?

    3 A. He said that he had stayed for a while in

    4 Niko Sakic's house, that the shooting had started

    5 again, and that he couldn't go to our house. Then he

    6 reached our house and he stayed with his father for a

    7 short time. He picked up the food for us, and he

    8 returned to Samija Kata and Niko Sakic house because

    9 they started shooting again, and he took shelter there

    10 too for a while.

    11 Q. Just an observation. Your husband, Vlatko

    12 Kupreskic, said that he spent some time in the house of

    13 Niko Sakic, didn't he?

    14 MS. SLOKOVIC-GLUMAC: Excuse me,

    15 Mr. President, but I should like to intervene on

    16 account of the transcript. The witness said that he

    17 returned to Kata and Nikola Samija's house, and in the

    18 transcript it says "Samija Kata and Niko Sakic". This

    19 is an error in the transcript. The name is Kata and

    20 Nikola Samija. This is one house owned by these two

    21 people, so this question put by the Prosecutor is also

    22 wrong.

    23 MR. TERRIER: I stand to be corrected by

    24 Ms. Slokovic-Glumac, but the witness did say that

    25 Vlatko Kupreskic said that he spent some time in Niko

  78. 1Sakic's house.

    2 Q. This is indeed what your husband told you he

    3 did?

    4 A. Yes, when he left the shelter, and not on the

    5 way back from our house.

    6 Q. So as he left the shelter. This is indeed

    7 what Niko Sakic testified before this Tribunal. I fail

    8 to understand, because when I was quoting Niko Sakic,

    9 you seemed surprise, and you affirmed and you said that

    10 you didn't know anything about it.

    11 So I'll repeat my question, because it was

    12 unanswered before. Didn't you think it was strange

    13 that your husband leaving the shelter in order to see

    14 about his father, since he was worried about him, that

    15 your husband should stay to spend some time in Niko

    16 Sakic's house?

    17 A. I'm not surprised, because there was probably

    18 shooting, so he couldn't go to our house.

    19 Q. Towards the end of the afternoon, when you

    20 saw your husband again, did he tell you that during

    21 those six hours outside the shelter, that he met, for

    22 instance, Ivica Kupreskic, Mirjan Kupreskic, Zoran

    23 Kupreskic, Mirko Sakic; did he mention those names?

    24 A. I know that he met Niko Sakic. I don't know

    25 about any of the others. He didn't tell me.

  79. 1Q. We know about Niko Sakic. I was thinking of

    2 Mirko Sakic, Ivica Kupreskic, Zoran and Mirjan

    3 Kupreskic. I could also mention Milutin Vidovic, Jozo

    4 Alilovic. Did he meet all these people? Did he

    5 mention meeting all these people?

    6 A. On that day, the 16th of April, no, he didn't

    7 mention them.

    8 Q. When he returned to the shelter in the

    9 afternoon, as you said, around 4.00 in the afternoon,

    10 was he together with his father?

    11 A. No.

    12 Q. Under which circumstances did his father

    13 arrive then?

    14 A. His father arrived towards nightfall.

    15 Actually, it was already dark. I remember that well.

    16 It was around 8.00.

    17 Q. Did the father come alone?

    18 A. He came with Vlatko. Vlatko went back to the

    19 house again.

    20 Q. I'm now moving on to the ensuing period, the

    21 period following the 16th of April. I have a few

    22 questions in this respect.

    23 You told us that following the 16th of April,

    24 you became refugees. Thereon, you showed us a

    25 certificate which is D41/3. What does the word

  80. 1"refugees" mean if it's used in this type of

    2 certificate which was issued by the social services in

    3 Vitez? What does the word "refugees" mean in this

    4 context?

    5 A. In that context, the word "refugee" means

    6 that we are not living or residing in our own home.

    7 Q. When did you see your house again in Ahmici?

    8 A. I saw my house in Ahmici again for the first

    9 time ten days later.

    10 Q. When did you occupy again that house?

    11 A. On the 1st of July, 1993.

    12 Q. When did your husband start working again?

    13 A. He started working again when we moved to

    14 Vitez, when we became refugees.

    15 Q. Do you remember the date, the approximate

    16 date if need be, on which your husband started working

    17 again in Vitez?

    18 A. When we left Donja Rovna.

    19 Q. That is how many days after the 16th of

    20 April?

    21 A. I think 10 or 15 days later.

    22 Q. So between the 26th of April and the end of

    23 the month of April; is that so? Is it then that he

    24 resumed his professional activities?

    25 A. Something like that, yes.

  81. 1Q. As far as you can remember, when did the

    2 Sutre store start working again, the one that is close

    3 to your house?

    4 A. After the 16th of April? I didn't quite

    5 understand what you meant.

    6 Q. You told us that 10 to 15 days following the

    7 16th of April, your husband started working again in

    8 Vitez. I would like you now to specify around what

    9 time after the 16th of April this store, the Sutre

    10 store, opened again.

    11 A. In Pirici, you mean?

    12 Q. Pirici.

    13 A. After the cease-fire was signed.

    14 Q. Could you be more specific as to the time?

    15 A. The beginning of May 1994.

    16 Q. So to make things clear, early May 1994, at

    17 the latest, that is when your husband's professional

    18 activities and, I suppose, also Ivica Kupreskic's

    19 professional activities resumed in Vitez and in Pirici;

    20 is that so? Do you agree with that?

    21 A. After the truce was signed at the beginning

    22 of May 1994, both Vlatko and Ivica continued their

    23 private businesses both in Vitez and in Pirici.

    24 Q. In Pirici, things were safe enough, I

    25 suppose, from a military point of view, safe enough for

  82. 1professional activities to be happening without any

    2 particular risk attached to this?

    3 A. In what period? After the truce was signed?

    4 Q. At the time when your husband's professional

    5 activities were resumed in Pirici, for instance, that

    6 is, in early May.

    7 I withdraw the question. There was confusion

    8 on my part as to the date which you had mentioned.

    9 Here's another question for you, madam: You told us

    10 that you saw your house again some ten days after the

    11 16th of April. I'm not wrong in saying that, am I?

    12 A. Yes.

    13 Q. What condition was the house in?

    14 A. In a chaotic state.

    15 Q. "Chaotic"? What do you mean by that?

    16 A. When I arrived home, when I saw the door that

    17 had been broken in by force, when I saw a lot of mud in

    18 the house and the earth from the flowerpots -- which

    19 confirms what Vlatko's father said, that they were

    20 looking for money -- when I saw my clothes and Vlatko's

    21 clothes strewn all over the place, in the house and in

    22 the rooms and in the living room, I was astonished.

    23 There were cigarettes that had been extinguished on the

    24 carpet. My handbag was in a corner, and all

    25 documents -- or rather the document that was valid for

  83. 1transportation in those days, with my photograph on it,

    2 my name and surname, I remember that very well -- had

    3 fallen out.

    4 Q. So what you are describing there is damage

    5 caused, say, by robbery; these are not materiel damage

    6 caused by explosives or bullets hitting the house? And

    7 I'm seeking confirmation from you: Your house was not

    8 hit by firearms, by war weapons?

    9 A. There was damage on the facade that can be

    10 visible to this day, and on the tiles, too, but the

    11 tiles have been changed. And the windowpanes had been

    12 broken. But we've changed all that.

    13 Q. Back at the time, were there any photographs

    14 made of the damage? Did you take stock of the damage

    15 caused to the house?

    16 A. We compiled a report. When the commission

    17 was set up for war damages I applied, and this can be

    18 seen from the document in '95.

    19 Q. Are you talking about a report, a specific

    20 document, or is this part of the documents that were

    21 handed in to the Tribunal beforehand, a document dated

    22 the 5th of April, 1995, which is damage caused to a

    23 building on the 5th of April, 1995? Is that the

    24 document you have in mind, or do you have anything

    25 else?

  84. 1A. It is the document which registers the war

    2 damage inflicted on the 16th of April, 1993. A

    3 commission went on the spot and established on site the

    4 damage done to the house and made a normal record of

    5 it.

    6 Q. During the examination-in-chief, Mr. Par

    7 submitted two documents, or mentioned two documents and

    8 submitted one of them. It is a document marked 12A/3,

    9 dated 5th of April, 1993, which very briefly mentions a

    10 certain amount of damage. There is another document,

    11 dated the 21st of January, 1999, mentioning a robbery

    12 in the family house of the Kupreskics on the 7th of

    13 May, 1994. During that robbery, damage was caused to

    14 the front door and to the balcony.

    15 Given the situation, isn't it logical to

    16 think that the damage registered in the report of the

    17 5th of April, 1995 -- I'm not challenging this fact --

    18 was caused by the robbery you were a victim of in 1994,

    19 and that the damage has nothing to do with the events

    20 of the 16th of April, 1993?

    21 A. I'm going to explain it to you. The first

    22 burglary in my house, it wasn't that the burglars came

    23 through the door; they came over the balcony, they

    24 climbed the balcony and entered the loft. They never

    25 used the entrance door, and that is 100 per cent

  85. 1certain.

    2 Q. I'm merely referring to the certificate,

    3 madam, as established by the police services in Vitez.

    4 A. There was the attempt. The thief tried to

    5 enter through the main door but failed. I don't know

    6 how to explain it to you that our entrance door, our

    7 main door, has now been so reinforced that nobody can

    8 enter it.

    9 Q. I'm not interested in knowing where the thief

    10 went through. I say that on the basis of the

    11 certificate, on the 17th of May, 1994, around 3.45,

    12 your house was burgled by an unidentified person, and

    13 during the burglary, visible damage was caused to the

    14 front door as well as to the balcony door, but during

    15 that burglary, nothing was stolen from the house.

    16 There was only damage to the front door of the house

    17 and to the door of the balcony.

    18 Hence, my question: I'm wondering whether

    19 the record of damage, as established much later, nearly

    20 a year later, does not merely refer to what had been

    21 caused during that burglary?

    22 A. I don't understand you again. Could you

    23 please help me?

    24 Q. I'm only too pleased to do so, madam. First

    25 of all, you submitted a certificate by the Vitez police

  86. 1according to which, on the 17th of May, 1994, there was

    2 an attempted burglary during which damage was caused to

    3 the front door and to the balcony door of your family

    4 house. Secondly, we also have a document entitled

    5 "Record of Damage on a Building on the 15th of April,

    6 1995," and in this document there is indeed an

    7 indication of damage caused basically to what was in

    8 stock and store in the shop.

    9 So I'm wondering as to whether what is

    10 registered, what is recorded in 1995, has anything do

    11 with what happened in April 1993. Did you not, as a

    12 matter of fact -- or do you have any evidence that

    13 there was damage caused to your house in April 1993?

    14 Have I been clear enough this time?

    15 A. You have proof. Isn't the commission which

    16 came out to establish the war damage and the

    17 commission -- and what do we call it -- the crime

    18 department, they come on behalf of the police, they

    19 come out, they conduct an on-site investigation and

    20 make a record of the burglary, they take fingerprints

    21 and then take note of all that. Isn't that so?

    22 Q. One last question before moving on to another

    23 topic. The question arising here is to find out

    24 whether you have any evidence of damage caused to your

    25 house in April '93. What is the evidence you have,

  87. 1what evidence can you tender to this Tribunal showing

    2 that there was damage made to your house on the 16th of

    3 April, 1993? This is the very question I want to put

    4 to you.

    5 A. Well, the front door is a proof, because that

    6 is how it was. Proof is Vlatko's briefcase, which you

    7 also had here, and one could see how it was damaged. I

    8 had completely forgotten about it, but one could see

    9 that it had also been forced open.

    10 Q. One very last question before moving on. You

    11 say that damage was caused to your house. What is the

    12 evidence you can bring for that?

    13 A. Well, I've just listed them. Besides, there

    14 are also bills which were filed, and we see what kind

    15 of merchandise, what kind of things were taken away.

    16 And as for evidence, well, this commission which was

    17 there, and persons who are on the witness list, they

    18 came out, and they could see the damage done to my

    19 house.

    20 Q. So you have in mind the commission which took

    21 stock on the 5th of April, 1995, but I have another

    22 question for you. A military from the British

    23 battalion testified before this Tribunal and said the

    24 following -- this is page 2.634 of the transcript. He

    25 was Corporal Skillen. Corporal Skillen said to this

  88. 1Tribunal -- and I stand to be corrected by Mr. Par if

    2 need be -- he said that in April, '93, he entered the

    3 village of Ahmici, he had left his vehicle next to the

    4 mosque, and that he then moved up to the top of the

    5 village. He walked up to the top of the village, and

    6 at a certain point in time his attention was drawn to a

    7 house, which he very precisely described, and which he

    8 indicated on the aerial photograph.

    9 It ensues from the explanation provided to

    10 the Tribunal by this witness, beyond any ambiguity,

    11 that this house which his attention was attracted to

    12 was yours. He noticed your house, he said, because,

    13 given the chaotic environment -- there were still

    14 bodies, corpses, lying around in certain houses in the

    15 village -- because in the balcony of that house he

    16 noticed a woman and a child. When he passed by again,

    17 passed by that house again, on that very balcony, there

    18 was still the woman and the child as well as two other

    19 people.

    20 Here's my question: Were you the woman that

    21 that soldier saw on that balcony?

    22 A. No.

    23 Q. Do you have any explanation why that English

    24 military saw this woman?

    25 A. I really don't understand. I know we went

  89. 1back to the house ten days later, and I was crying so

    2 much when I saw it, when I saw all the houses that had

    3 burned down. When I got to my house, when I saw what

    4 had happened to it, and when I took some few clothes

    5 for the children, then some foreign journalists came

    6 up, and they wanted to record us. And that I was on

    7 the balcony, that is simply not true. At that time we

    8 were still in Donja Rovna. That was April '93.

    9 Q. The time that I have in mind is the 22nd of

    10 April, 1993, according to the witness's statement,

    11 before the foreign journalists were there. Do you have

    12 any idea who might have been there, who that woman was

    13 and who that child was who were on the balcony?

    14 A. I can't. Afterwards, I heard that they even

    15 needed a van to take away all of the clothes stocked in

    16 our house, in the cellar. Perhaps somebody entered my

    17 house without my knowledge. I do not know that. But I

    18 claim the full responsibility that I was not there.

    19 And what would I be doing on the balcony at that time

    20 of the year? It's cold in Bosnia in April.

    21 Q. How old were your children then, in April

    22 1993?

    23 A. My son was 6 and my daughter 10.

    24 MR. TERRIER: One moment, please.

    25 I have no further questions. I thank the

  90. 1witness. I'm only asking for Exhibits 359, 360, and

    2 361 to be tendered into evidence.

    3 JUDGE CASSESE: Any objection?

    4 No objection? Thank you. So they are

    5 admitted into evidence.

    6 Counsel Par? We still have 16 minutes.

    7 MR. PAR: I have no further questions. Thank

    8 you.

    9 JUDGE CASSESE: Thank you. Well, actually, I

    10 have a question for the witness.

    11 Madam, I know that you are tired, and I

    12 apologise, but I have a very minor and brief question:

    13 In your letter to the International Tribunal for the

    14 former Yugoslavia, on page 2, you mention a book. You

    15 say, and I will slowly read it in English: "I would

    16 like to refer you," you say to the Prosecutor, "to the

    17 book 'Time of Dishonour - the genocide against the

    18 Bosniaks in the 20th century,' published by a group of

    19 authors in Zenica in 1994, and especially to its

    20 offprint, 'The Tragedy in the Lasva Valley - statements

    21 of victims, pages 153-161' by the author Ragib Hadzic,

    22 which discusses the perpetrators of the crime in

    23 Ahmici."

    24 Could you please tell us about this book, and

    25 in particular the chapter written by the author,

  91. 1Hadzic, about the crime in Ahmici? You seem to be

    2 familiar with this book, and so I was keen to know

    3 something about this particular book, because to the

    4 best of my knowledge, it has not been presented to the

    5 Court as a piece of evidence.

    6 You also say, later on, the authors of that

    7 book "know very well the situation in the Lasva

    8 Valley."

    9 A. Your Honours, thank you for your question.

    10 It is true that I did read the book at the time when

    11 the letter was written. As far as I know, it was

    12 Vlatko's aunt's book; she lives in Zenica. I believe

    13 that book was sent to the Tribunal.

    14 JUDGE CASSESE: So you, yourself, you have

    15 not read that book, so you are simply --

    16 A. Yes, I did, I did read it, but not all of it,

    17 just fragments, because it describes all of the plight

    18 of the Lasva Valley, not only in Ahmici, and events in

    19 Ahmici are not in -- there is not a single line in that

    20 book referring to what happened in Ahmici that would

    21 mention the name of my husband. That is as far as I

    22 recollect, but I did not really read the book through,

    23 because it is quite a volume, and it describes all the

    24 trials and tribulations of the people in the Lasva

    25 Valley.

  92. 1JUDGE CASSESE: Yes, but I mean, I understand

    2 from your reference to your husband that in at least

    3 one chapter of this book a description is made of what

    4 happened in Ahmici, and probably this is based on

    5 statements of victims. So I, for one, would be

    6 interested in seeing what those victims state, because

    7 I understand from your letter that they do mention

    8 names of possible perpetrators, and your point is that

    9 however, among those names, one cannot find the name of

    10 your husband. So therefore it might have some

    11 interest.

    12 Anyway, I wonder whether the parties may be

    13 of some assistance in this -- yes, Counsel Par?

    14 MR. PAR: I believe we have the book, and we

    15 shall try to send it to the Tribunal or, rather, have

    16 translated that part which refers to Ahmici and give it

    17 to the Prosecution. I believe we had a copy here in

    18 The Hague. If that is indeed so, then the Court will

    19 have it in no time at all.

    20 JUDGE CASSESE: Thank you. I don't have any

    21 further questions.

    22 All right. Mrs. Kupreskic, thank you so much

    23 for giving evidence in court. I assume all other

    24 parties do not object to your being released. You may

    25 now be released. Thank you.

  93. 1THE WITNESS: Thank you.

    2 (The witness withdrew)

    3 JUDGE CASSESE: Since it is fairly late, we

    4 will resume tomorrow at 9.00 sharp. However, tomorrow

    5 we have to stop at half past 12.00, at the request of

    6 the Registrar. The Registry needs this courtroom, so

    7 we can't but bow to her request, so therefore we have

    8 only a limited amount of hours, from 9.00 to half past

    9 12.00. Tomorrow is Thursday, but on Friday, of course,

    10 we will resume at 9.00 until 1.30.

    11 All right. So the hearing is adjourned.

    12 --- Whereupon the hearing adjourned at

    13 1.18 p.m., to be reconvened on

    14 Thursday, the 27th day of May, 1999,

    15 at 9.00 a.m.