Tribunal Criminal Tribunal for the Former Yugoslavia

Page 2004

 1                           Friday, 31 August 2012

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.31 a.m.

 5             JUDGE ORIE:  Good morning to everyone.

 6             Madam Registrar, would you please call the case.

 7             THE REGISTRAR:  Good morning, Your Honours.

 8             This is the case IT-09-92-T, The Prosecutor versus Ratko Mladic.

 9             JUDGE ORIE:  Thank you, Madam Registrar.

10             There are no preliminaries, as far as I understand, which means

11     that, in order to conclude the testimony of the present witness, we move

12     into closed session.

13             And, Mr. Stojanovic, could you give us an indication as to how

14     much time you'd still need so that the public is aware of.

15             MR. STOJANOVIC: [Interpretation] Your Honour, I believe it's

16     going to be in accordance with what I had announced; that is to say,

17     another 45 minutes, up to one hour.

18             JUDGE ORIE:  Yes.  Then we move into closed session.

19                           [Closed session]

20   (redacted)

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Page 2029

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22                           [Open session]

23             THE REGISTRAR:  We're in open session, Your Honours.

24             JUDGE ORIE:  Thank you, Madam Registrar.

25             Mr. Lukic, we take the break now, that is the sort break after

Page 2030

 1     one hour, because I have not heard of any request to return to the two

 2     breaks, each 30 minutes schedule.  So up to that moment we will follow

 3     the schedule as we usually did.

 4             Is the Prosecution ready after -- yes, I think Mr. Mladic wants

 5     to consult with you, Mr. Lukic.

 6             Mr. Groome, is the Prosecution ready to call its next witness

 7     after the --

 8             MR. GROOME:  Yes, Your Honour.

 9             JUDGE ORIE:  And that would require protective measures.  That's

10     Witness RM083.

11             MR. GROOME:  There are no protective measures for the next

12     witness.

13             JUDGE ORIE:  No protective measure and that would be

14     Witness RM083 -- 53, I apologise.

15             MR. GROOME:  Yes, Your Honour.

16             JUDGE ORIE:  Yes.  Mr. Lukic, perhaps you use the break to

17     consult with your client.

18             We take a break, and we'll resume at five minutes to 11.00.

19                           --- Recess taken at 10.35 a.m.

20                           --- On resuming at 10.58 a.m.

21             JUDGE ORIE:  Could the witness be escorted into the courtroom.

22             MR. GROOME:  Your Honours, if I could take this opportunity to

23     introduce the Chamber to a new member of staff that's appearing for the

24     first time.  That's Mr. Edward Jeremy.  He will be taking the next

25     witness, Adil Medic.

Page 2031

 1             JUDGE ORIE:  Yes, welcome into court, Mr. Jeremy.

 2             MR. JEREMY:  Thank you, Your Honours.

 3             JUDGE ORIE:  I do understand that 45 minutes are needed for the

 4     next witness.  Then I suggest -- I do not know whether in the session

 5     after that the cross-examination could be concluded?

 6             MR. LUKIC:  Yeah, we established two hours for this witness.

 7             JUDGE ORIE:  Two hours.

 8             MR. LUKIC:  So probably we should finish by the end of the day.

 9             JUDGE ORIE:  If that would be possible, then at least the witness

10     could be released and could return home again.

11             MR. LUKIC:  Thank you.

12             JUDGE ORIE:  That would be appreciated.

13             MR. JEREMY:  Your Honours, before the witness is brought in

14     perhaps I might deal with a few preliminary matters.

15             JUDGE ORIE:  Please to do so.

16             MR. JEREMY:  Firstly regarding adjudicated facts.  The

17     Prosecution will not adduce all the evidence that this witness can

18     provide in reliance on the following adjudicated facts:  460, 461, 463,

19     465, 468, 469, 470, 471, 472, 473, 476, 478, 487, and 1006.

20             JUDGE ORIE:  Thank you.  That corresponds with the list we have.

21             MR. JEREMY:  Your Honours, there might be some instances in my

22     examination where my question are aimed at eliciting evidence that

23     overlaps partly with an adjudicated fact, and on these occasions in order

24     to assist the Chamber, I will endeavour to indicate that at the

25     appropriate point in my examination.

Page 2032

 1             JUDGE ORIE:  And try to avoid it to the extent possible.

 2             MR. JEREMY:  As regards associated exhibits, there are no

 3     associated exhibits relating to this witness.  But I will tender exhibits

 4     shown to the witness at the time that they are dealt with during the

 5     examination-in-chief.

 6             JUDGE ORIE:  Thank you, Mr. Jeremy.

 7                           [The witness entered court]

 8             MR. JEREMY:  Your Honours, regarding the witness's --

 9             JUDGE ORIE:  Yes.  If there's any need, otherwise I would first

10     now address the witness.

11             MR. JEREMY:  Of course.

12             JUDGE ORIE:  Good morning, Mr. Medic.  Can you hear me in a

13     language you understand?

14             See you're nodding yes, but ...

15             THE WITNESS: [Interpretation] Yes, thank you.

16             JUDGE ORIE:  Mr. Medic --

17             THE WITNESS: [Interpretation] Yes.

18             JUDGE ORIE:  -- before you give evidence, the Rules require that

19     you make a solemn declaration of which the text will be handed out to you

20     now by the usher.

21             I would like to invite you to make that solemn declaration.

22             THE WITNESS: [Interpretation] I solemnly declare that I will

23     speak the truth, the whole truth, and nothing but the truth.

24                           WITNESS:  ADIL MEDIC

25                           [Witness answered through interpreter]

Page 2033

 1             JUDGE ORIE:  Thank you, Mr. Medic.  Please be seated.

 2             Mr. Medic, you'll first be examined by Mr. Jeremy.  Mr. Jeremy is

 3     counsel for the Prosecution.

 4             Mr. Jeremy, to the extent the preliminaries need attention, then

 5     you weave them in -- in your examination, I take it, or address the

 6     Court --

 7             MR. JEREMY:  Yes, Your Honour.

 8             JUDGE ORIE: -- at the appropriate moment.

 9             Please proceed, Mr. Jeremy.

10                           Examination by Mr. Jeremy:

11        Q.   Good morning, sir.  Can I ask you to please state your full name

12     for the record.

13        A.   Adil Medic, born in Sanica, municipality of Kljuc.

14        Q.   Mr. Medic, is it true that you have previously provided written

15     statements to the Office of the Prosecutor and testified before this

16     Tribunal in another trial?

17        A.   Yes, correct.  Both.

18             MR. JEREMY:  Your Honour, before I show the witness his

19     statement, regarding the 1996 statement this was without

20     paragraph numbering.  As with the last witness statement, as with the

21     last witness, these paragraphs have been numbered by a member of the OTP

22     staff and the numbered version uploaded into e-court.

23             JUDGE ORIE:  Yes, I think we can use the now-numbered --

24     paragraph-numbered statement, Mr. Lukic, unless you have any problems.

25             MR. LUKIC:  Since it was numbered, I numbered it myself, page by

Page 2034

 1     page.  But I will try to follow -- and I don't have that numbered version

 2     with me.

 3             JUDGE ORIE:  Well.

 4             MR. LUKIC:  I'll ask my staff to bring one to the courtroom.

 5             JUDGE ORIE:  Yes.  At the same time, you can produce it on your

 6     screen if that's the version uploaded and then take it from e-court as we

 7     usually do.

 8             MR. LUKIC:  Thanks.  Thank you, Your Honour.

 9             JUDGE ORIE:  Please proceed.

10             MR. JEREMY:  And, Your Honours, just still on the statement, at

11     various points in my examination of Mr. Medic I refer to his 1996

12     statement as well as his 2001 statement.  And for efficiency, I think

13     Mr. Medic would be assisted, if I could, with your leave, provide him

14     with a hard copy of his statement.

15             JUDGE ORIE:  Yes.  With the numbered paragraphs.

16             MR. JEREMY:  Yes.

17             JUDGE ORIE:  Yes.

18             Please provide Mr. Medic with a hard copy of his statement --

19     statements.

20             MR. JEREMY:

21        Q.   Mr. Medic, did you provide a statement to the

22     Office of the Prosecutor which you signed on 31 January 1996?

23        A.   Yes, in Sarajevo.

24        Q.   And did you also provide a statement which you signed on

25     9 November 2001 which corrected certain inaccuracies in the statement you

Page 2035

 1     signed on 31 January 1996?

 2        A.   Yes.  There were certain corrections made, more of a technical

 3     nature, not exactly substantive.  Perhaps it had to do with terms, and

 4     that's quite logical.

 5        Q.   Thank you.

 6             MR. JEREMY:  Your Honours, could I ask that 65 ter 28356 be

 7     brought up on our screens.  It is a statement of Mr. Medic dated

 8     31 January 1996.  I would like the witness to be shown the English

 9     language version of this statement.

10        Q.   Mr. Medic, once the document is on the screen before you, can I

11     ask you if the signature at the bottom of e-court page 1, is that your

12     signature?

13        A.   Yes.

14             MR. JEREMY:  And can I ask that we go to the last page of this

15     statement, e-court page 11.

16        Q.   Mr. Medic, is that your signature at the top of the page?

17        A.   Yes.

18             MR. JEREMY:  Your Honour, could I ask that 65 ter 28357 be

19     brought up on our screens.  It is a supplemental statement of Mr. Medic

20     dated 9 November 2001.  This time I would like the witness to be shown

21     the B/C/S version of his statement.

22             THE WITNESS: [Interpretation] This is my signature.

23             MR. JEREMY:

24        Q.   To confirm, Mr. Medic, the signature on page 1 of that document

25     is your signature?

Page 2036

 1        A.   Certainly.

 2             MR. JEREMY:  And can we go to e-court page 3.

 3        Q.   Mr. Medic, is that your signature?

 4        A.   Yes.

 5        Q.   Mr. Medic, have you had an opportunity to read and review both

 6     your 31 January 1996 statement and your 9 November 2001 statement in

 7     preparation for your appearances here today?

 8        A.   Yes.

 9        Q.   Taking those two statements together, did you have any additions,

10     corrections, clarifications or other changes which you wish to make to

11     either statement?

12        A.   Only with regard to the term related to the suffering of

13     Omer Filipovic.  I think the date is wrong.  All the rest is fine; these

14     corrections notwithstanding.

15        Q.   And which date did you wish to clarify, Mr. Medic, in relation to

16     Omer Filipovic?

17        A.   Omer Filipovic passed away between the 28th and the 29th of July.

18     And I think that the reference here is wrong because it's a day later.

19        Q.   Thank you, Mr. Medic.

20             If I were today to ask you questions similar to those that you

21     were asked in the taking of these statements, would you give the same

22     answers?

23        A.   Absolutely.

24        Q.   And now that you have taken the solemn declaration, do you affirm

25     the truthfulness and accuracy of these statements taken together?

Page 2037

 1        A.   Certainly, I affirm that.

 2             MR. JEREMY:  Your Honours, I now tender pursuant to Rule 92 ter

 3     Mr. Medic's statement dated 31 January 1996, 65 ter 28356, together with

 4     his statement dated 9 November 2001, 65 ter 28357 as the next public

 5     Prosecution exhibit.

 6             JUDGE ORIE:  Madam Registrar, the 1996 statement would receive

 7     number.

 8             THE REGISTRAR:  Document 28356 becomes Exhibit P154,

 9     Your Honours.

10             JUDGE ORIE:  And is admitted into evidence.

11             The 2001 supplemental statement.

12             THE REGISTRAR:  Document 28357 becomes Exhibit P155,

13     Your Honours.

14             JUDGE ORIE:  And is admitted into evidence under that number.

15             Please proceed.

16             MR. JEREMY:  Your Honours with your leave I will now read a short

17     summary of Mr. Medic's written evidence.

18             JUDGE ORIE:  Please do so.

19             MR. JEREMY:  Adil Medic was economist who volunteered for the

20     Islamic association in 1991.  This was one of a group of organisations,

21     humanitarian organisations, that combined to form the Muslim corps in

22     1992 after the war broke out in Bosnia-Herzegovina.  Mr. Medic was chosen

23     as the leader of the Muslim corps commission in charge of Manjaca camp

24     and specifically prisoner related problems there.  On the

25     18th of June, 1992, Mr. Medic visited Manjaca camp on the invitation of

Page 2038

 1     General Talic.  Mr. Medic describes the terrible living conditions in the

 2     camp which included lack of food, shortage of clothing, and wide speed

 3     disease.  Mr. Medic spoke to a prison there named Omer Filipovic who told

 4     him that the prisoners were regularly beaten.  Mr. Medic learnt that at

 5     the end of July 1992 Omer Filipovic and Esad Bender were beaten to death

 6     in Manjaca camp.

 7             On the 22nd of June, 1992, Mr. Medic attended a meeting between

 8     Muslim representatives and members of the VRS, including General Talic.

 9     At this meeting, Mr. Medic informed General Talic of the inadequate

10     conditions at Manjaca camp and that the civilians there were being ill

11     treated.  In all, Mr. Medic made approximately 25 humanitarian visits to

12     Manjaca camp.

13             Mr. Medic also assisted the survivors of the massacre at Vlasic

14     mountain where prisoners were forced to stand at the edge of a cliff and

15     shot in the back.  Lastly, Mr. Medic was arrested on the

16     1st of June, 1995.  He was transferred to Mali Logor military prison in

17     Banja Luka where he was beaten on two occasions.  He was released on the

18     29th of December, 1995.

19             Your Honours that concludes my summary.

20             JUDGE ORIE:  Then please put all the questions you still have to

21     the witness.

22             MR. JEREMY:

23        Q.   Mr. Medic, paragraphs 1 and 3 of your 1996 statement,

24     Exhibit P154, e-court page 2 in each language, summarise your

25     professional biography.  I understand that you retired in 1990 and then

Page 2039

 1     volunteered for various humanitarian organisations.  Have you been

 2     engaged in any other professional activities since you signed that

 3     statement in 1996?

 4        A.   Yes.  Afterwards in August 1996, the association of

 5     [indiscernible] of Bosnia-Herzegovina was established and registered with

 6     the appropriate authorities.  For six years I was vice-president, and

 7     after that, I was an editor at the centre for research and documentation.

 8     I was involved in research and I also edited what other persons wrote.  I

 9     spent all of nine years there.

10        Q.   In paragraph 6 of your 1996 statement, Exhibit P154, e-court

11     page 2 and 3 in each language, you describe your first visit to Manjaca

12     camp in June 1992 under a military escort.

13             MR. JEREMY:  Your Honours, adjudicated facts 460 states that:

14             "The Manjaca camp was run by Bosnian Serb military police under

15     the command of the 1st Krajina Corps and Colonel Bozidar Popovic was the

16     camp commander."

17             I therefore do not intend to lead further evidence directly on

18     this.

19        Q.   Mr. Medic, I will, however, ask a series of general questions

20     about your personal experience of Manjaca camp.

21             Firstly I'd like to show you a sketch of Manjaca camp.

22             MR. JEREMY:  Your Honours, can I please ask the Court Officer to

23     bring 65 ter 28058 to our screens.  It is a sketch of Manjaca camp.

24        Q.   Mr. Medic, do you recognise the sketch on the screen before you?

25        A.   Yes.  But the other part of this sketch is missing.  I don't know

Page 2040

 1     why.  This sketch was on a form, A3, and that's where the administrative

 2     part is as well in relation to the existing sketch.

 3             This only shows the barns where the inmates were, and also the

 4     kitchens.

 5        Q.   And for the parts of the camp that we can see, is this sketch a

 6     fair and accurate depiction of that?

 7        A.   It is an absolutely accurate depiction.  The author was very

 8     faithful.

 9        Q.   Mr. Medic, in paragraph 8 of your 1996 statement, Exhibit P154,

10     e-court page 3 in each language, you describe a number of locations that

11     you observed within Manjaca camp.  On my instruction, I will ask you to

12     attempt to mark these locations on this sketch, and I would be grateful

13     if the Court Officer could please provide Mr. Medic with a red pen for

14     this purpose.

15             Mr. Medic, without yet marking the image, can you see the kitchen

16     you visited in the camp?

17        A.   Yes.  That is the first building on the left-hand side.  That was

18     the so-called field kitchen.  That's where food was prepared, and that's

19     where they took what they were given to eat.

20        Q.   Please mark this with a number 1.

21        A.   [Marks]

22        Q.   And, again, without marking the image, can you see the three

23     stables that you indicate housed the prisoners?

24        A.   Yes.  The first three stables were full.  Prisoners or detainees

25     were there, but there weren't any in the other three, at that point in

Page 2041

 1     time; on the 18th of June, that is.

 2        Q.   Could you please mark the first stable you visited with a

 3     number 2.

 4        A.   The very entrance.

 5        Q.   And the second stable you visited with the number 3.

 6        A.   [Marks]

 7        Q.   And could you please mark the fourth stable -- excuse me.  The

 8     third stable that you did not visit with the number 4.

 9        A.   [Marks]

10        Q.   In paragraph 10 of your 1996 statement, Exhibit P154, page 3 in

11     e-court, you refer to your conversation with Manjaca camp prisoner,

12     Omer Filipovic.  Without marking the image, can you see on this sketch

13     where that conversation took place?

14        A.   It was outside this basic compound where the inmates were.

15     Roughly here, where these small buildings are.  And then opposite them,

16     in a clearing.

17        Q.   Please mark the location you have just indicated with a number 5.

18        A.   [Marks]

19        Q.   Lastly, in paragraph 21 of your 1996 statement, Exhibit P154,

20     e-court page 5, you state that in August 1992, prisoners from Omarska

21     camp were transferred to Manjaca.

22             Again, without marking the image, can you see the stables where

23     these persons from Omarska were kept?

24        A.   It's the second row, behind the one that I marked, which is

25     practically identical.  I mean, physically it is the same.  It's the same

Page 2042

 1     buildings.  It's just a different row.

 2        Q.   Please mark that location you've just indicated with a number 6.

 3        A.   All together?

 4        Q.   Yes, please.

 5             MR. JEREMY:  Your Honours, I now tender this exhibit as marked by

 6     Mr. Medic as the next public Prosecution exhibit.

 7             JUDGE ORIE:  Madam Registrar.

 8             THE REGISTRAR:  Document 28058 as marked by the witness becomes

 9     Exhibit P156, Your Honours.

10             JUDGE ORIE:  P15 is admitted into evidence.

11             MR. JEREMY:

12        Q.   Mr. Medic, in paragraph 6 of your 1996 statement, Exhibit P154,

13     e-court pages 2 and 3, you state that during that first visit to Manjaca

14     camp, you asked one of your military escorts, a Colonel Tepsic, whether

15     the camp contained exclusively Muslim and Croat prisoners.

16             In response, you state that Colonel Tepsic told you that the

17     prisoners in the camp were all prisoners of war.

18             In paragraph 21 of your statement, e-court page 5, you estimate

19     that at one point four and a half thousand prisoners were in Manjaca.  To

20     your knowledge how many of these prisoners that circulated through the

21     camp were prisoners of war?

22        A.   I visited Manjaca, and I spoke to officers headed by

23     Colonel Tepsic.  When I was given the floor, the first question was

24     whether we were at a collection centre of civilians in Manjaca.  His

25     answer was very definite:  No, we are in a camp of prisoners of war under

Page 2043

 1     the command of the 1st Krajina Corps.

 2             When we visited the mentioned-stables, one can conclude that

 3     these were civilians only.  Some of them wore flip-flops, others were

 4     bare-foot, some had only T-shirts on.  In this stable, there were about

 5     800 men, and there were no men wearing uniforms.  So the logical

 6     conclusion was that there were civilians there.

 7        Q.   During the course of your approximately 25 visits to the camp did

 8     you ever meet a prisoner who was not either Muslim or Croat?

 9        A.   No.  When speaking to the prisoners, they called them prisoners

10     of war, and prisoners of war are captured at the front line, but

11     detainees are persons who are taken from their homes or fields.  So they

12     informed me that the persons there were 85 per cent Muslim and

13     15 per cent Croat.  No one ever mentioned any Serbs, and I never saw any

14     either.

15        Q.   Before I ask you a few short questions about your access to

16     prisoners in Manjaca camp, I'd now like to show a brief video-clip of

17     footage of a visit to Manjaca camp by British politician, Paddy Ashdown,

18     in August 1992.

19             MR. JEREMY:  Your Honours, Ms. Stewart will play the video-clip

20     with 65 ter 22302B using Sanction.  For the convenience of all parties,

21     the English and B/C/S transcripts of this video are available in e-court

22     as the same number as -- under the same number as the video-clip.  The

23     booths have transcripts of the clip.

24             Unfortunately, the audio can be heard only very faintly but to

25     assist those who cannot hear it English subtitles have been added by the

Page 2044

 1     Prosecution.  The B/C/S subtitles that appear are from the original

 2     footage and were not prepared by the Prosecution.

 3             Ms. Stewart, could we now play the clip.

 4                           [Video-clip played]

 5             "Reporter:  Paddy Ashdown had broken his holiday and travelled

 6     for three days over a thousand miles to get to the Manjaca camp.  What he

 7     saw was a shed which, in better days, might have housed animals.  Now it

 8     holds more than 600 men.  Here the prisoners live, eat and sleep 24 hours

 9     a day.  Most of these men just arrived three days ago from the camp at

10     Omarska, their faces so haunted by memories they did not care to relate

11     in the presence of their guards.  For five minutes, Paddy Ashdown was

12     allowed to speak privately to the men.  However grim their conditions

13     here, they told him, they are much better than in the place they've just

14     come from.  The camp commandant had promised Mr. Ashdown total freedom to

15     see anything he wanted.  In the end, he was told that wasn't possible.

16             "Even during Mr. Ashdown's visit, time was limited to a mere half

17     hour and access was limited to only a few prisoners.  As he left, he said

18     however bleak things seem to be, this camp did appear to be properly run.

19             "Ashdown:  Clearly, I have had access to those prisoners without

20     the guards' presence.  I detest their conditions.  I find them deeply

21     moving.  They had an appalling time in Omarska where they've come from.

22     I think it's a tremendous achievement on the part of the press to have

23     exposed that, and they probably have saved many prisoners' lives.  But

24     every prisoner I spoke to here without the guards' presence has told me

25     conditions are not what you'd want them to be but that they are a hell of

Page 2045

 1     a lot better in what they lived in before.

 2             "Reporter:  With the visiting politician gone, what these men

 3     have suffered in the past remained largely unspoken.

 4             "... is a ... run camp in Serbian-held northern Bosnia.

 5     Authorities say they hold 3500 prisoners here, including about a thousand

 6     from the notorious Omarska camp.  Pictures of emaciated captives in

 7     detention centres last week outraged the international community and

 8     prompted the Serbian leaders to quickly transfer hundreds to this

 9     military facility.

10             "They are better ...

11             "Reporter:  This terrified looking prisoner mumbled that

12     conditions here are slightly better.

13             "There is, there is ...

14             "Reporter:  'We get enough food now,' says this man.

15             "We were only allowed to interview two inmates and, in each case,

16     the soldiers immediately wanted to know what we would ask.

17             "This is one of the camps that officials from the International

18     Red Cross say they'll be inspecting this week.  Indeed, the president of

19     Bosnia's Serbs has offered to hand them control of all of these detention

20     centres.  The Serb leadership is under tremendous pressure to allow

21     outsiders access to these camps.  The proposed UN resolution will

22     authorise any means necessary to implement that access, as well as

23     guarantee the supply of humanitarian aid.  Still, even though Karadzic

24     himself authorised our visit to this camp, journalists were allowed less

25     than half an hour to assess the situation.  Soldiers moved us along

Page 2046

 1     rapidly, allowing us to take very few pictures and to ask even fewer

 2     questions.  The camp commandant insists that the Geneva Conventions have

 3     been respected, but those prisoners we asked maintained they are

 4     civilians, not soldiers.  Those we saw were crammed into cattle-sheds

 5     where they spend all day and all night, huddled together like animals.

 6     They are permitted to leave these quarters only briefly, for a small

 7     ration of bread and soup.

 8             "Christiane Amanpour, CNN, Manjaca, in northern Bosnia."

 9             JUDGE ORIE:  Yes, I have noticed that we have now English and

10     French on the transcript.  The B/C/S is in the subtitles.  Only,

11     Mr. Lukic, if there are any problems with the subtitling of the B/C/S

12     then the Chamber, of course, would like to know, but that we have a

13     complete record.

14             MR. LUKIC:  I haven't noticed that there was any problem.  I was

15     able to follow both B/C/S and English.

16             JUDGE ORIE:  Okay.  That's then --

17             Yes, Mr. Jeremy.

18             MR. JEREMY:

19        Q.   Mr. Medic, was the footage in this recording from Manjaca camp?

20        A.   Yes, that is a Manjaca camp.  Of course, the inside is more

21     important.  The outside was shown in this movie.

22        Q.   Does this footage fairly and accurately depict Manjaca camp?

23        A.   This footage, which is of very poor quality, does not show the

24     real situation - but it was authentically filmed, that's true - because

25     we cannot see here all the people.  They were not all within the reach of

Page 2047

 1     the camera.  We cannot see what they looked like.  And even if this

 2     footage were of better quality, it would be very hard to recognise people

 3     because they had been largely exhausted by then, very emaciated.

 4             MR. JEREMY:  Your Honours, I'll now ask Ms. Stewart to pause the

 5     clip at 38.1 seconds.

 6                           [Video-clip played]

 7             MR. JEREMY:

 8        Q.   Mr. Medic, although the quality of the picture is poor, do you

 9     recognise the person facing the camera on the right-hand side of the

10     screen wearing the uniform?

11        A.   Indubitably, this is Lieutenant-Colonel Bozidar Popovic, the camp

12     commander, as they introduced him when we were there for talks.  I can't

13     say negotiations, because negotiations would imply an equal footing.

14     Later for his service in this camp he was promoted into colonel, although

15     he had been retired for three years.

16             MR. JEREMY:  Your Honours, I now tender this exhibit as the next

17     Prosecution Exhibit.

18             JUDGE ORIE:  Madam Registrar.

19             THE REGISTRAR:  The document becomes Exhibit P157, Your Honours.

20             JUDGE ORIE:  P157 is admitted into evidence.

21             MR. JEREMY:

22        Q.   Mr. Medic, I will now ask a few questions relating to the

23     prisoners you met in Manjaca camp.

24             In paragraph 10 of your 1996 statement, Prosecution Exhibit P154,

25     e-court page 3, you describe talking with Omer Filipovic in the month

Page 2048

 1     before his death at the time of that first visit to Manjaca camp in

 2     June 1992.  You state, I quote:

 3             "He informed me about what happened to them from the time when

 4     they were arrested.  He gave me such a good report which made me

 5     convinced that he would not survive his stay in the camp but be killed."

 6             Mr. Medic, I would like to ask you one follow-up question on the

 7     quote from the statement I just read out.  When Omer Filipovic told you

 8     about conditions in the camp, was anyone listening to him other than

 9     yourself?

10        A.   I had with me another three persons in the delegation.  I don't

11     know if I need to give you their names.  And there were those officers

12     standing there, the ones with whom we had talked and toured the barns.

13     So Omer Filipovic gave me an account in their presence about all that

14     happened between this registration hut where the prisoners are listed and

15     how they lived without water, without bathroom, how they were beaten,

16     sometimes randomly, sometimes picked individually, without any clothes,

17     without any beds.  I could see the traces of beating on Omer because

18     there were blood-stains on his shirt, and he said all that before

19     Colonel Tepsic, before Colonel Dikic , before Lieutenant-Colonel

20     Bozidar Popovic, Lieutenant-Colonel Bosko Amidzic, and there was another

21     officer whose name I cannot recall.  They listened to his account the

22     same as I.

23             The others who were subordinated to them, the policemen or

24     soldiers, whatever they were, were not present.

25        Q.   Thank you.  Mr. Medic, why did you believe that Omer Filipovic

Page 2049

 1     would be killed because of the report he gave you about Manjaca camp?

 2        A.   It was my feeling, my hunch, to put it that way, and, as I wrote

 3     in my report the next day, I felt that he would not shut up until they

 4     killed him.  He was a policeman before the war.  He was also an official

 5     of the municipality who was a teacher of history and geography.  He was

 6     the president of a small party called MBO, I think, and he was a born

 7     leader who, in my mind, felt responsibility to say on behalf of all those

 8     people what was going on with them.  He was physically and mentally

 9     healthy and strong, and his general attitude and the feeling of

10     responsibility he had towards those people made him take it upon himself

11     to say all these things.

12             But I knew that such actions carry consequences, and I knew of

13     his background before the war, and I was certain that he would not stop

14     talking, that he would go on talking, and that he would be eventually

15     killed.

16        Q.   Mr. Medic, I'd now like to ask you some final questions about

17     what you considered the purpose of Manjaca camp to be.

18             In paragraph 21 of your 1996 statement, Exhibit P154, e-court

19     page 5, you state:

20             "On the 1st of August, 1992, Vukelic told me, facing the stables,

21     that among the 2.000 prisoners in the camp, not even 200 had anything to

22     do with the armed conflict."

23             Mr. Medic, you made approximately 25 visits to Manjaca camp in

24     1992.  We've heard that you spent nine years working for an association

25     of camp inmates from that camp and you prepared a book collating their

Page 2050

 1     experiences.  If Colonel Vukelic was correct in telling you that among

 2     2.000 prisoners in the camp not even 200 had anything to do with the

 3     armed conflict, then based on your extensive experience of Manjaca camp,

 4     what conclusions were you able to draw about the purpose of imprisoning

 5     Bosnian and Croatian civilians in Manjaca camp?

 6        A.   On the morning of that day when Omer Filipovic was killed the

 7     night before, together with his friend, Bender --

 8             MR. LUKIC:  Sorry, I --

 9             JUDGE ORIE:  Mr. Lukic.

10             MR. LUKIC:  I think that this asks for conclusions, and this

11     gentleman, as I'm aware, is not an expert.  So I would object to this

12     question.

13             JUDGE ORIE:  Mr. Jeremy.

14             MR. JEREMY:  Your Honours, I'm simply asking the witness for his

15     factual observations.

16             JUDGE ORIE:  Well, that's not what you did.  But if that's what

17     you intended to do, then please rephrase your question.

18             MR. JEREMY:  I will rephrase.

19        Q.   Mr. Medic, based on your factual observations of the camp, why

20     were the Bosnian and Croatian civilians in Manjaca camp?

21        A.   The official position of some officials in the Serb authorities

22     was that no more than 5 per cent Muslims may remain.  That was publicly

23     stated.  It's not my opinion.  And for that purpose, it was necessary to

24     cleanse the area from the Muslim and, later, the Croat population.  In

25     order to cleanse them -- and you can object to my observations all you

Page 2051

 1     want.  In order to cleanse them, three things were done; namely, some

 2     were killed; some were imprisoned in camps; and yet others were driven

 3     out.  To make these things easier, it was necessary to deprive these

 4     people of its leaders, to imprison Omer Filipovic and other

 5     intellectuals, either imprison them or kill them or expel them.  It was

 6     necessary to eliminate people of renown.  In small communities there are

 7     always prominent people, and these also needed to be removed.

 8             And, third, it was necessary to remove wealthy people who

 9     represented security in these small communities.  So they were removed

10     too.  They were the first to be eliminated, either by imprisonment,

11     killing or expulsion.  The purpose, in my view, was to cleanse the area

12     to eliminate Muslims and, later, Croats from these parts.  I can look

13     back to my own native Sanica.  One in ten was killed; one in five was in

14     Manjaca; and all the rest were expelled from Sanica.

15             JUDGE ORIE:  Mr. Jeremy, perhaps it is unnecessary to remind you,

16     but you are close to your 45 minutes.

17             MR. JEREMY:  I have no further questions at this time,

18     Your Honours.

19             JUDGE ORIE:  Thank you very much, Mr. Jeremy.

20             Mr. Medic, you will now be cross-examined by Mr. Lukic.

21     Mr. Lukic is counsel for the Prosecution [sic].

22             MR. LUKIC:  Could I have a few seconds to consult with my client?

23             JUDGE ORIE:  Yes, if you could keep it to a minimum, please do

24     so.

25                           [Defence counsel confer]

Page 2052

 1                           [Trial Chamber and Registrar confer]

 2             JUDGE ORIE:  Mr. Lukic, I hope you'll forgive me that it was a

 3     slip of the tongue that you're counsel for the Prosecution.  Of course,

 4     you are counsel for the Defence, as Mr. Medic also will have understood.

 5             Mr. Medic, you will now be cross-examined by Mr. Lukic, counsel

 6     for Mr. Mladic.

 7             Please proceed.

 8             MR. LUKIC:  Thank you, Your Honour.

 9                           Cross-examination by Mr. Lukic:

10        Q.   [Interpretation] Mr. Medic, good afternoon.  I will put my

11     questions in B/C/S and you will be answering in the same language, so

12     please leave a short pause between question and answer for the

13     interpreters.

14        A.   Okay.

15        Q.   Thank you.  Do you have your statement before you?

16        A.   Yes.

17        Q.   Could we turn to paragraph 5.  You say:

18             "Talic's demand meant, to me, that the army had taken

19     responsibility for Manjaca camp."

20             Was that the only proof at that time?

21        A.   At that moment, that was the only proof.  But when I got to

22     Manjaca, when Colonel Tepsic who had been sent by General Talic along

23     with other officers there he said that it was a camp for prisoners of war

24     under the command of the 1st Krajina Corps.  And then it became quite

25     clear that the army was in charge.

Page 2053

 1             If I may add my own comment, I believe this statement of his and

 2     all that passed between us made it impossible for us to get any further

 3     to Omarska and Trnopolje.

 4        Q.   I'll ask you about Omarska and Trnopolje later.

 5             You say in paragraph 8:

 6             "The kitchen prepared food that I believe never reached the

 7     prisoners."

 8             The prisoners ate, didn't they?

 9        A.   Yes.

10        Q.   According to you, where did that food come from, if not from the

11     kitchen?

12        A.   When I made this observation I did not mean to imply that they

13     were not eating at all.  I meant to say they were not eating that food

14     because I saw, and my father was a butcher, I saw meat being carved up,

15     and I didn't think it was meant for the prisoners.

16        Q.   When I'm waiting, it's not because I'm unhappy with your answer.

17     I'm waiting for the interpretation.

18             However, you had no insight into what the prisoners were actually

19     eating.

20        A.   Operatively, no; but, later on, yes.

21        Q.   In paragraph 8 --

22             MR. LUKIC: [Interpretation] Could we just show in e-court

23     65 ter 13876.

24        Q.   This image, Mr. Medic, is related to one part of your statement.

25             You say:  Few of them had blankets.  Most lay on the bare

Page 2054

 1     concrete floor.

 2             In this picture, as far as I can see, everyone, down to the last

 3     man, has a blanket.  Did you go inside this facility?

 4        A.   Don't forget that I spent 15 days at the official inauguration of

 5     the camp, as Colonel Tepsic called it.  The camp was opened on the

 6     3rd of June, and I went there on the 18th.  The situation then was that

 7     very few people had blankets.  This picture was taken much later, I

 8     suppose.

 9             I know that one day the conditions were slightly improved, and

10     they got some more supplies, including these blankets.  I was talking

11     only about when I was there.

12        Q.   Can we just agree that this photograph is not consistent with

13     your statement in paragraph 8?

14        A.   I may agree, but this picture was taken later.

15             JUDGE MOLOTO:  May I ask a question.

16             Mr. Medic, can you point at the blankets that counsel says are

17     there?  I don't see them.

18             THE WITNESS: [Interpretation] If we are looking at the same thing

19     on the screen, you can see something of a different colour between the

20     shoes -- and now the image disappeared.

21             It's back.

22             You can see that these are covers of some sort.  I suppose that

23     it was the ICRC, when they arrived, that brought them, and they came in

24     the second half of July; that is to say, about a month after my stay at

25     this camp.

Page 2055

 1             I was inside this facility only the first time and the last time.

 2     Never again.

 3             I hope I explained it well.  You can see different colours.  This

 4     is concrete between the shoes, and this here are blankets.

 5             JUDGE ORIE:  Mr. Lukic, if you ask a witness whether something is

 6     inconsistent with his statement, wouldn't you agree with me that time can

 7     be quite relevant.  And, therefore, what you see on the picture may be

 8     different from what the witness observed on this very specific day.

 9             MR. LUKIC:  Yes, Your Honour.

10             JUDGE ORIE:  Therefore, you're using this picture -- the Chamber,

11     of course, in order to be able to follow your suggestion, there's an

12     inconsistency, the Chamber would like to know when this picture was

13     taken.

14             Do we know?

15             MR. LUKIC:  I don't, Your Honour.  The witness explained us that

16     he entered only once.  And when he entered, and it doesn't mean that the

17     conditions were the same later on.  So I think that the witness explained

18     his knowledge, and I'm satisfied with that part.

19             JUDGE ORIE:  Okay.  Please proceed.

20             MR. LUKIC:  Thank you.

21        Q.   [Interpretation] Mr. Medic, in paragraph 9 of your statement, you

22     say:

23             "The injuries I observed on them were from beatings and bullets."

24             You talk about the wounds you observed on the persons you saw at

25     Manjaca.  You have no medical training, do you?

Page 2056

 1        A.   No, I don't.

 2        Q.   You had occasion to have private conversations with these people,

 3     without the presence of the guards?

 4        A.   Those were superficial conversations, especially with

 5     Mohammed Filipovic, who lay there immobile exclusively from beatings.  He

 6     was the only one who was lying down in the entire hall.  And the other

 7     person I mentioned, I know this by heart, was standing on his crutches

 8     with his leg bandaged and that was probably from a bullet.  I talked to

 9     the other man, and his injuries were only from beatings.  I'm certain

10     about that.

11             When the guard came in, no matter his rank, you had to stand up

12     and put up your hands behind your head.  That applied to the entire

13     facility where the inmates were.

14        Q.   Thank you.  We'll soon be going on a break.

15             Let me just ask you this:  Did you have occasion to speak with

16     the prisoners privately without the presence of the guards?

17        A.   My interaction with Mohammed Filipovic was such that the officers

18     who were present there could not hear it.

19             JUDGE ORIE:  Yes.  Mr. Lukic --

20                           [Trial Chamber confers]

21             JUDGE ORIE:  Mr. Lukic, just for you to know, that the accused

22     has been waving pieces of paper in the air with clear writing on it, one

23     of it a year, a year within the time-frame of the Second World War, and

24     some other years on it as well.

25             The Chamber will consider whether and how it will respond to

Page 2057

 1     this.  Make clear to your client that this is inappropriate behaviour

 2     which may have consequences.

 3             We first ask the witness to be escorted out of the courtroom.

 4             We'll take a break, and we'll be back in approximately

 5     20 minutes.

 6                           [The witness stands down]

 7             JUDGE ORIE:  We will --

 8                           [Trial Chamber confers]

 9             JUDGE ORIE:  We take a break, and we resume at 25 minutes past

10     12.00.

11                           --- Recess taken at 12.03 p.m.

12                           --- On resuming at 12.32 p.m.

13             JUDGE ORIE:  The behaviour of Mr. Mladic I described just before

14     the break was observed by one of the Judges.  It was observed by

15     security.  It was observed by other staff as well.  When I read out the

16     behaviour before this break, Mr. Mladic nodded in the affirmative when I

17     read it.  It has happened today repeatedly.  Showing text on paper

18     readable from a distance, whether intended to be seen by Judges, by the

19     public gallery, or to be caught by the cameras, while broadcasting these

20     proceedings is inappropriate behaviour.

21             The Chamber has decided that, as a measure of order, Mr. Mladic

22     will be removed from the courtroom for the remainder of the testimony of

23     the present witness.

24             Please, curtains down.  We take a break of one minute.  And then

25     we resume to hear the testimony of the witness.

Page 2058

 1                            --- Break taken at 12.35 p.m.

 2                           --- On resuming at 12.39 p.m.

 3                           [The accused not present]

 4             JUDGE ORIE:  Can the witness be escorted into the courtroom.

 5                           [Trial Chamber confers]

 6                           [The witness takes the stand]

 7             JUDGE ORIE:  Welcome back, Mr. Medic.  The break took a bit

 8     longer.

 9             Mr. Lukic, you may proceed.

10             MR. LUKIC:  Thank you, Your Honour.

11             THE WITNESS: [Interpretation] Thank you.

12             MR. LUKIC: [Interpretation]

13        Q.   Mr. Medic, can we go on now.

14             We talked about the people that you spoke to in Manjaca.  Were

15     they dressed when they spoke so you?

16        A.   Yes.  Of course they were not naked, but they were half-dressed.

17        Q.   Sometimes we lawyers put questions that may --

18        A.   Seem strange to me.

19        Q.   All right.  In the transcript at the Brdjanin trial on page 2262,

20     26th February, 2002, you were asked whether Mohammed Filipovic told you

21     when it was that he had been beaten and your answer was no.

22             Do you stand by that answer today?

23        A.   Yes.

24        Q.   When we talked about the type of food that the prisoners ate, I'd

25     like to ask you something in relation to that, actually.

Page 2059

 1             At that time in Bosnia and Herzegovina, was there a general

 2     shortage of all vital supplies, like food, medicine, clothing?

 3        A.   That was the very beginning of the war.  In the Banja Luka

 4     region, there weren't any shortages yet, so, conditionally speaking, as

 5     far as that's concerned, life was normal from the point of view of food

 6     and clothing.  There were already shortages of medicine though.  For

 7     instance, I know that there was a problem getting medical alcohol at the

 8     time.

 9        Q.   Thank you.  At the time, were there shortages of water, gasoline,

10     electricity, gas?

11        A.   No water shortages.  Power cuts, well, sometimes they were

12     intentional.  Also, like there were these fictitious alarms.  So this was

13     part of the strategy.  As General Talic said to me, You're a civilian,

14     Adil, so you don't know about things like that.

15        Q.   All right.  We talked about paragraph 10 of your statement, and

16     in relation to that, I'd like to ask you -- you speak about

17     Omer Filipovic there as well and you corrected the date today.  And you

18     say that he was beaten to death with a baseball bat.  What is your

19     information based on?

20        A.   Talking to inmates subsequently.

21        Q.   All right.  Thank you.  In paragraph 11, you speak about finding

22     the corpse of Omer Filipovic, and you say:

23             "I was asked to be given a copy of the death certificate from the

24     doctor at Manjaca, and also from a coroner.  I was given the documents

25     that I asked for but the man who gave them to me told me that I should

Page 2060

 1     not disclose that he had given me these documents.  Dr. Sabanovic signed

 2     one of the death certificates."

 3             First, let me ask you this:  Dr. Sabanovic, he is a Muslim, isn't

 4     he?

 5        A.   Yes.  A camp inmate at Manjaca.

 6        Q.   A camp inmate at Manjaca.

 7        A.   He signed the death certificate stating that the death had

 8     occurred but he did not state the cause of death.  The pathological

 9     findings do disclose that, the ones that I got surreptitiously, if I can

10     put it that way.

11        Q.   While we're on the subject can you tell us today who it was that

12     gave you that document.  We can even go into private session.

13        A.   I think that that is totally irrelevant.  I received it at

14     pathology.  I couldn't have gotten it in the street, but as for the death

15     certificates that's what I got at the command of the 1st Krajina Corps.

16     I got it from their commission, so I got it at an official place, if you

17     will.

18        Q.   You will allow for the fact that we have to check certain things

19     through our own investigation, and that is why we need to have you

20     confirm to us who gave you these papers so that we can establish whether

21     that had actually happened.

22        A.   These pathological findings were taken out of my bag at the

23     moment when I was arrested.  I had a copy when I was arrested on the

24     1st of March, 1995.  So whoever arrested me has the findings.

25        Q.   However, we do not have these findings.

Page 2061

 1        A.   I'm sorry.

 2        Q.   That's why I'm asking you.  Can you tell us who it was that gave

 3     you this.

 4        A.   You're not going to gain anything by that because the man has

 5     been living abroad and, by the way, let me tell you that he's a Serb.

 6             JUDGE ORIE:  Mr. Medic, whether Mr. Lukic gains anything by your

 7     answers or not is not the issue.  He asked you whether he -- you could

 8     tell us who he was.  If there's any need for you, for reasons to be

 9     explained by you, why you would give that name in private session, we

10     would consider that.  But you're invited to answer the question.

11             And, again, if there's any reason why you think it should be

12     dealt with confidentially, then we'll move into private session at your

13     request.

14             THE WITNESS: [Interpretation] I personally think that it's

15     confidential because the man said to me that I shouldn't say how it was

16     that I got that.  I know the man.  The man lives abroad.  And he's been

17     living abroad for a long time.  He left as far as back at 1993.  And I

18     really think it is irrelevant who it was that gave me this, but I do

19     claim that it does exist and that's the way it was.

20             JUDGE ORIE:  Mr. Lukic, do you insist on an answer, in which case

21     I would have to consult with my colleagues.

22             MR. LUKIC:  Yes, Your Honour.

23             MR. GROOME:  Your Honour, can I just provide one piece of

24     information that might be useful to Mr. Lukic.  I think it will also

25     assist the Chamber.  Dr. Sabanovic is a witness in this case.  He is a

Page 2062

 1     92 bis witness.  If this is an issue Mr. Lukic wants to pursue, we could

 2     discuss whether that witness would be converted to 92 ter.

 3             JUDGE ORIE:  And --

 4             MR. LUKIC:  If I may --

 5             JUDGE ORIE:  Does this assist you Mr. --

 6             MR. LUKIC:  [Overlapping speakers] ... obviously not the person

 7     who --

 8             JUDGE ORIE:  [Overlapping speakers] ... could we -- could we --

 9     first of all, could we move into private session.

10             MR. LUKIC:  Private session, yes.

11                           [Private session]

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 2063











11 Page 2063 redacted. Private session.















Page 2064

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5                           [Open session]

 6             THE REGISTRAR:  We're in open session, Your Honours.

 7             JUDGE ORIE:  Thank you, Madam Registrar.

 8             Mr. Lukic, by the way, the Chamber has considered the loss of

 9     time which happened.  The short breaks were in response to Mr. Mladic's

10     request.  Having looked at when that started, we'll continue without any

11     further break until quarter past 2.00.  And that comes close to two hours

12     for you.  If you would be able to conclude your cross-examination, that

13     would be appreciated.

14             MR. LUKIC:  Thank you, Your Honour.

15        Q.   [Interpretation] Mr. Medic, did you draft a report about that;

16     and did you hand that report over at the Merhamet office?

17        A.   As an efficient person, or at least that's the way I saw myself,

18     I made notes of everything that I saw and did.  I drafted a report on

19     five typed pages, and I delivered that to the Merhamet.

20        Q.   Can the documents still be found at the Merhamet?

21        A.   Unfortunately, I don't know.  The handwritten report was also

22     taken from me.  I didn't use a typewriter or a PC, so that handwritten

23     report was taken away from me on the 1st of March, 1995, when I was

24     arrested.

25        Q.   Let me come back to Omer Filipovic.

Page 2065

 1             In paragraph 11, you said that he was arrested as the president

 2     of the Muslim Bosniak organisation in Kljuc.  We put it to you that he

 3     was arrested because he was the commander of the TO staff in Kljuc.  On

 4     the 27th of May, 1992, the TO carried out an attack against non-armed

 5     soldiers on their way back from doing their compulsory military service.

 6     Three of them were killed.  Six were seriously wounded.  And 29 were

 7     slightly wounded on that occasion.

 8             Would you agree with me when I say that?

 9        A.   I can't say that I either agree or disagree.  I don't know

10     anything about that.  I know what Omer did before the war, and I told you

11     clearly and I can repeat that he was a history and geography teacher,

12     that he was vice-president of the municipality as a volunteer, and he was

13     also the president of the party.

14        Q.   Did you ever hear about that incident?

15        A.   Subsequently I heard that there was a clash of some sort.

16     However, I was declared unfit for military service.  I did other things.

17     I was not interested in the details of any of the things that had

18     happened in the past.

19        Q.   Did you hear that on the same day, on the 27 May 1992, the unit

20     under the command of Mr. Omer Filipovic killed the deputy commander of

21     the public security station in Kljuc?  Two policemen were wounded on that

22     occasion, and all that happened in the sector of Krasulje village.

23        A.   I know that before the war, the commander of the police station

24     in Kljuc was Mr. Atif Dzafic.  I found him at Manjaca as well.

25        Q.   Thank you for your answer, but that was not an answer to my

Page 2066

 1     question.

 2        A.   I'm telling you what I know.

 3        Q.   In other words, you don't know?

 4        A.   I don't know.

 5        Q.   Thank you.  Do you know that on that same day their armed units

 6     blew up the Banja Luka television repeater in Ramici village.  Do you

 7     remember that your TV programme was cut?

 8        A.   Sir, please don't ask me anything about military matters because

 9     I really don't know anything about that.

10        Q.   Well, then you just say, I don't know, and we'll move on.  Thank

11     you.

12             Paragraph 12 in your statement, you say:

13             "On the following day I saw Vukelic at Manjaca.  He never

14     mentioned that case, although I am convinced that he had known that those

15     two persons were killed."

16             That was your assumption.  He never said anything about that,

17     Vukelic, did he?

18        A.   It is true that I already had a very acute foreboding that

19     something had happened at Manjaca.  The guards behaved differently.  They

20     were quiet.  They were subdued in their behaviour, and that's why I asked

21     whether Colonel Vukelic was anywhere around and they told me to go to the

22     barracks to see whether he was there.  The entrance to the barracks was

23     some 500 metres away from the entrance to the camp.

24        Q.   Thank you.  You told me that he didn't say anything?

25        A.   No, he didn't say anything.

Page 2067

 1        Q.   We have to move on because our time is limited.

 2        A.   However, subsequently, my impression was that he knew it.  It

 3     was impossible that he didn't know.

 4             JUDGE MOLOTO:  Could you slow down between the two of you,

 5     please.

 6             THE WITNESS: [Interpretation] Thank you.

 7             MR. LUKIC: [Interpretation]

 8        Q.   In paragraph 15, you talk about the composition of the

 9     delegation.  On behalf of the Army of Republika Srpska, you mentioned

10     Colonel Osman Selak.

11             At that time Osman Selak was a member of the VRS.  What was his

12     rank?

13        A.   He was a colonel.

14        Q.   Was he subsequently actively involved in the work of Merhamet?

15        A.   Not actively.  However, we occasionally saw each other and he did

16     come to Merhamet, but he was not an active member of -- of the

17     organisation.

18        Q.   In the same paragraph, you say that Talic was a -- very pleasant

19     in personal contacts.  He always promised hell but he never delivered on

20     those promises.

21             At the Brdjanin trial to a Judge's question, you explained that

22     you had in mind some other things, but when it came to the steps

23     undertaken at Manjaca, when it comes to the delivery of humanitarian aid,

24     all the promises and all the agreements were honoured.  That is on

25     transcript page 2277 on 26 of February 2002.

Page 2068

 1             Would you say the same thing today?

 2        A.   I confirm and -- that I would say the same thing as I did at that

 3     time.

 4        Q.   In paragraph 17, you speak about Omarska, and you say that

 5     General Talic never said that the army had anything to do with that.

 6     Since you carried out some investigations after that, could we agree

 7     today that General Talic's statement is correct, that the army had

 8     absolutely nothing to do with Omarska?

 9        A.   Since that was in the area of responsibility of the

10     1st Krajina Corps - and I'm speaking in military terms - it is my logic

11     that things could not have been done unbeknownst to the army.

12        Q.   Did the army control cities and villages or would it be the

13     police who did that, if you know?  If you don't know, never mind.

14        A.   If I just share my position with you, I would say that the police

15     was the second-ranking force with respect to the army.

16        Q.   Very well.  We're not going to discuss military issues.  You

17     said - we shouldn't anyway - I'm not going to answer.

18        A.   Thank you.

19        Q.   Now, paragraph 18 of your statement, you speak about the delivery

20     of humanitarian aid.  You organised that with the help of Merhamet.

21             As far as I could tell, you went there once, and then there were

22     48 other deliveries of humanitarian aid.  All in all, there were

23     49 deliveries of humanitarian aid by your organisation, by Merhamet to

24     Manjaca.  Am I correct?

25        A.   Yes, that's correct.  We kept a book of visits, and we registered

Page 2069

 1     very correctly what things we delivered on each of those occasions.

 2        Q.   Every time you had to have a prior permission to deliver

 3     humanitarian aid, and you did receive it; right?

 4        A.   Every time we had to receive a permission, but that doesn't mean

 5     that we received the permission on every application.  That permit, or

 6     permission, was typewritten note - I have to slow down - and the wording

 7     on it was permit to move around the area of combat activities.  The

 8     driver and all the escorts had to have their own permits issued to their

 9     names.

10             Every time we went there, we had to apply.  Every time we had to

11     be given those permits from the command of the 1st Krajina Corps.  We had

12     to go to Colonel Bogovic, who was assistant chief for security.  I

13     believe we had to apply to the Department of Security or, rather, we had

14     to go to a certain person called Dasic.  I remember his family name very

15     well because my neighbour's family name was also Dasici.  He was also a

16     junior officer.  He was the one who dealt with us when we applied for

17     those permits.  Sometimes there were glitches and delays when issuing

18     permits.  And then, as a rule, Colonel Gojko Vujinovic would come on

19     board to deal with the matter.

20        Q.   Thank you very much.

21             Your activities improved the conditions at Manjaca; right?

22        A.   Of course.  If you are in -- deep in mud, and if somebody offers

23     you a stick to hold on to, then your situation does improve.

24        Q.   Thank you.  You say in paragraph 19, which is the following

25     paragraph:

Page 2070

 1             "I conveyed the information to -- about the three men from Kljuc

 2     who were killed on the 8th of August between Sedica [as interpreted] and

 3     Manjaca.  Their names were Daut, whose family name is unknown; his

 4     brother; and Kemal, whose family name is unknown."

 5             Since then, have you learnt their full names?

 6        A.   Strangely enough, but Kemal worked in the catering company where

 7     I worked as the CEO.  He was the head waiter.  His alias was

 8     Kinanovic [phoen] but that was not his family name.  That's just the name

 9     he went by.  I don't remember his family name.  I knew Daut personally

10     and I didn't know his brother.

11             Do you want me to explain how I arrived at their names?

12        Q.   Only if you know their names.  If not, let's move on.

13        A.   There's a story to that.

14        Q.   I just need their names.  How you know them is not going to be of

15     any assistance to me.  Thank you.

16             And now let's move on to paragraph 20 where you say that all the

17     inmates under 18 and over 60 years of age were released from Manjaca, a

18     total of 105 of them.

19             In addition to that, people from Manjaca were released in

20     August 1992.  Are you aware of that?  A group of them were -- was

21     released.  The International Committee of the Red Cross took them away.

22        A.   I know that.  I did not participate in the events.  Merhamet did

23     not participate in the events either.

24             JUDGE ORIE:  Mr. Lukic, due to the fact that no pauses are made

25     between question and answer, we have -- we are at risk that the

Page 2071

 1     transcript will not be accurate as who says what.

 2             Could you please -- "are you aware of," that your question, then

 3     I think it was the witness who said:  "A group of them were released."

 4             Or was it your words?

 5             MR. LUKIC:  I said it.

 6             JUDGE ORIE:  You said it.  Yes, then I was a bit confused by

 7     putting a question and then adding some [Overlapping speakers] ...

 8             MR. LUKIC:  [Overlapping speakers] ... inartfully posed,

 9     Your Honour.

10             JUDGE ORIE:  And we only receive it, of course, by the

11     interpretation.

12             Please proceed.

13             MR. LUKIC:  Thanks.

14        Q.   Is it also correct that 500 people were transferred to Batkovic

15     in northern Bosnia.  Do you know that?

16        A.   Yes.

17        Q.   Later on they were exchanged for Serbs imprisoned in Muslim and

18     Croatian prisons; is that correct?

19        A.   The transfer of those approximately 500 people from Manjaca to

20     Batkovici was the beginning of the end of Manjaca, of the disbanding of

21     Manjaca.  I believe that started on the 14th of December.

22        Q.   Very well then.

23        A.   Just a moment.  Just a moment.

24        Q.   Yes, go on.

25        A.   A large number of those people as I learned subsequently was

Page 2072

 1     successfully exchanged.  The final exchange of 158 people from Manjaca

 2     was carried out in Travnik or a place near Travnik, in Turbe.  I was

 3     present.  I attended that exchange.  The 158 people were exchanged

 4     together with 32 other people from Tunjice or Luka, I don't know where

 5     from.  And that was on the 10th of October, 1993.  So, in other words,

 6     those people had spent a year and a half in the camp.

 7        Q.   Thank you.  Of course, you don't know how much time did the

 8     people spend in prison who were on the other side?

 9        A.   From where I was standing, I could only tell that they were

10     soldiers.

11        Q.   Where did that exchange take place, once again?

12        A.   At Turbe.  There were buses.  One would group would leave a bus

13     and would get on the other bus.

14        Q.   That was in October?

15        A.   Yes, that was on the 10th of October, 1993.

16        Q.   Thank you.  In paragraph 21, the last two sentences.  The first

17     words are:

18             "I was aware of only one professional soldier who -- who was kept

19     prisoner at Manjaca."

20             When we're talking about that, do you know that there was

21     fighting in the municipality of Prijedor?  We did say that we would not

22     discuss military matters but this is a notorious fact.  That's why I'm

23     asking you about it.

24        A.   [No interpretation]

25        Q.   We're not talking about that one individual.  When we're talking

Page 2073

 1     about the fact that there were no --

 2        A.   I had information about general suffering, but I didn't have any

 3     specific information.  The first such place was Srebrenica, so I didn't

 4     know anything about any individuals being killed or suffering.

 5        Q.   In paragraph 24, you speak about the prison in Stara Gradiska,

 6     and you say that the 1st Krajina Corps most probably used that prison as

 7     well.

 8             Do you know that the prison in Gradiska -- when you are talking

 9     about that prison, are you referring to the prison in Gradiska in Croatia

10     or Gradiska in Bosnia-Herzegovina?  Which one?

11        A.   The prison in Stara Gradiska is in Croatia.

12        Q.   Very well.  Then we will not discusses that at all.

13        A.   However, people from the territory of Kljuc before they arrived

14     at Manjaca, a certain number of them had spent time at Stara Gradiska.

15     Among them, Hilmo, who cut his own throat when he saw what he looked like

16     in the mirror.  He had spent some time in Stara Gradiska and then Manjaca

17     was opened, and then he was transferred to Manjaca.

18        Q.   He inflicted injuries on himself.  However, four days later, when

19     he left the hospital -- what hospital was that?

20        A.   The clinical hospital at Banja Luka.

21             JUDGE ORIE:  Could you read the transcript, Mr. Lukic.

22             MR. LUKIC:  Yes.

23        Q.   [Interpretation] I asked you where he was hospitalised, and

24     operated on.  Your answer was not recorded.  Could you please repeat?

25        A.   In Banja Luka.  There are two hospitals in Banja Luka.  One is

Page 2074

 1     the so-called old hospital and the other is the so-called new hospital.

 2     But both facilities belong to the Clinical Hospital Centre.  He slit his

 3     throat at the old hospital and he was surgically treated in the new

 4     hospital.

 5        Q.   Thank you.  In paragraph 28, you speak about Ljubija.  In the

 6     territory of the Ljubija local commune is it correct that the majority of

 7     the population were Croats?

 8        A.   I'm not sure.  I know that Donja Ljubija, also known as Islam, is

 9     mostly populated by Muslims.

10        Q.   When I say the local commune of Ljubija, I also imply the

11     surrounding villages.

12        A.   Of course, but I don't know.  I only know that Islam is an

13     exclusively Muslim neighbourhood.

14        Q.   Very well.  Do you know, although this is again a military issue,

15     that Croats in that area joined the ranks of the VRS en masse?

16        A.   If they did that, I'm sure they did not do that of their own will

17     because I know for a fact because I travelled with a priest who served

18     near Ljubija.  A month or so later, he was found dead.

19        Q.   What's the priest's name?

20        A.   I don't know his name, but I know that there was another priest

21     who worked in the Caritas office in Banja Luka.  His name was

22     Martanovic [phoen].  And there was another priest who was found dead

23     drowned in a well together with his parents.

24        Q.   When we are talking about the voluntarily nature of the unit that

25     comprised all Croats, those units were armed.  Can you really say that

Page 2075

 1     somebody took up arms voluntarily?  People served in their own homes.

 2             Do you know that?

 3        A.   No, I don't know that.

 4        Q.   In paragraph 33, you speak about Koricanske Stijene.

 5             Do you know with whom the perpetrators of the killing at

 6     Koricanske Stijene were affiliated?  Do you know that they were members

 7     of the police?

 8        A.   Yes, the Prijedor police.

 9        Q.   And do you know that the survivors of that killing were found by

10     members of the army and taken to the hospital?

11        A.   I know that, but I know equally well that the investigating judge

12     who had come up on the site to investigate was removed by the troops.

13     The name of the lawyer is Jankovic.  He is a now a lawyer in Banja Luka.

14        Q.   Thank you.  In paragraph 37, you speak about the arrest of

15     members of Merhamet.  This arrest, just as the investigation that

16     followed, was carried out by the police?

17        A.   Yes.  But we were turned over to the army.

18        Q.   You were at Mali Logor?

19        A.   Yes, military prison.

20        Q.   The prisoners there were mostly Serbs?

21        A.   Yes, Serb criminals and Serb murders who were under

22     investigation.  Of course, the life of Serbs in that camp was very

23     different to the lives of Muslims and the few Croats who were there.

24        Q.   Let us now turn to paragraph 49 of your statement.

25        A.   Sadika Ceric.

Page 2076

 1        Q.   So there were women there too.  She told you that if Banja Luka

 2     were to be attacked, the prison would be closed and all non-Serb

 3     prisoners shot.  Did Sadika Ceric tell you from whom she had heard that?

 4        A.   No.  But the position of the cells, the layout of the cells was

 5     such that one could often hear conversations between guards in the

 6     hallway, especially those who were in Sanica.  Sanica did not have

 7     windows.  It had a wooden door and bars, and the door would often be left

 8     ajar because there was no natural light, nor air.  She had that that way,

 9     and she told me about it.

10        Q.   So she didn't know who was speaking?

11        A.   No.

12        Q.   We are wrapping up.  I won't be straining your patience much

13     longer.

14             Do you know that the Supreme Court of Republika Srpska brought in

15     a verdict convicting, Zeljko Bulatovic, Sinisa Teodorovic, and

16     Zoran Gajic for their participation in the beatings of people at Manjaca

17     and their involvement in the killings of Omer Filipovic, and, help me,

18     who was with him?

19        A.   Esad Bender.

20        Q.   Do you know about that?

21        A.   I know there was a trial, but I don't know the outcome.  But I

22     know very well who Bulatovic is.

23        Q.   Mr. Medic, this was all I had for you today.  Thank you for

24     answering my questions.

25        A.   You're welcome.

Page 2077

 1             JUDGE ORIE:  Thank you, Mr. Lukic.  In order to avoid any

 2     problems in the future, Mr. Lukic, you referred to paragraph 49 when you

 3     mentioned that Sadika Ceric had heard that if Banja Luka was attacked,

 4     the prison would be closed and all Serb prisoners shot.

 5             Now, in the version which we have in e-court it is --

 6             MR. LUKIC:  [Overlapping speakers] ... 50.  I thought it was 50.

 7             JUDGE ORIE:  Oh -- let me see.  Yes, it is on the transcript as

 8     49, I think.  Yes.  So.

 9             MR. LUKIC:  Maybe I misspoke.

10             JUDGE ORIE:  No, no -- that's a possibility.  The only thing I

11     wanted to avoid for the future is that your private numbering is

12     different from the numbering by the Prosecution.

13             MR. LUKIC:  I tried to use their numbering.

14             JUDGE ORIE:  Yes, let's try to do that from now on.

15             Thank you, Mr. Lukic.

16             Mr. Jeremy -- I first consult with my colleagues.

17                           [Trial Chamber confers]

18             MR. GROOME:  Your Honour, your mike is on.

19             THE WITNESS: [Interpretation] Excuse me, in paragraph 50, it

20     doesn't say Serb prisoners would be killed, but non-Serb prisoners would

21     be killed.  That's an essential difference.

22             JUDGE ORIE:  If I misspoke, then apologies for that.  But that's

23     actually what paragraph 50 says.

24             The Judges have no further questions for you.

25             Mr. Jeremy, any need to re-examine the witness?

Page 2078

 1             MR. JEREMY:  Just a few questions, Your Honour.

 2             JUDGE ORIE:  Yes, please proceed.

 3                           Re-examination by Mr. Jeremy:

 4        Q.   Mr. Medic, on temporary transcript page 64, you were asked how

 5     many times you personally visited Manjaca camp.  Just so that your answer

 6     is clear, I would like to ask you again how many times you personally

 7     visit the Manjaca camp?

 8        A.   The first 15 times, I went every time, trying to introduce my

 9     associates so they can go alone, and the other times, I accompanied them

10     once in two or three times.

11             So, all in all, it was a total of 25 visits.  But the first 15

12     visit, I always went.

13        Q.   Mr. Medic, in cross-examination, you were asked about your arrest

14     on temporary transcript page 70.  You referred to your arrest on -- in

15     paragraphs 37 to 52 of your statement where you describe the arrest and

16     imprisonment in early 1995 of various of the senior leadership of

17     Merhamet, including yourself.  Very briefly, in a few words, what were

18     you charged with?

19        A.   Only the leadership of Merhamet was arrested, the top five

20     people.  I was arrested the next day because I no longer belonged to the

21     leadership by that time.  We were charged with spying.  After those

22     arrested in Sanski Most, Prijedor and Banja Luka, the youngest was 42 and

23     the oldest was 72.  In terms of gender and age, the people were mixed.

24     Those from Sanski Most and Prijedor were taken to court six times, but no

25     verdict was brought in.  We, from Banja Luka, were brought before court

Page 2079

 1     three times, but the trial never called it -- never took place.  They

 2     always found a way to postpone it, and the people in those white uniforms

 3     were there, I believe from some international organisation.  Maybe that

 4     was the reason.

 5             But, at any rate, we were charged with espionage that had never

 6     been proven.

 7        Q.   And to be clear, neither you nor any of the senior leadership of

 8     Merhamet were convicted?

 9        A.   No.  Nobody was convicted, neither us from Banja Luka, nor the

10     other people from Sanski Most and Prijedor.

11        Q.   A final question, Mr. Medic.  What impacts did the arrest and

12     imprisonment of the senior leadership of Merhamet have on the non-Serb

13     civilian population that remained in Banja Luka in 1995?

14        A.   Our arrests were consistent with what we discussed earlier, the

15     cleansing of non-Serbs from various areas; in our case, the region of

16     Banja Luka.

17             In fact, those people who remained until 1995 were left there

18     with the intention of not leaving Banja Luka ever.

19             JUDGE MOLOTO:  I'm sorry, Mr. Lukic --

20             JUDGE ORIE:  Judge Moloto would like to --

21             JUDGE MOLOTO:  Mr. Medic, if you could just listen to the

22     question by the lawyer.  The question was:  What impact did the

23     imprisonment of the senior leadership of Merhamet have on the population

24     that remained in Banja Luka in 1995.  If you can just answer to that,

25     that would be very helpful.

Page 2080

 1             THE WITNESS: [Interpretation] After our arrests, not a single

 2     convoy left Banja Luka or the Banja Luka region again to get assistance,

 3     and that was a very effective way to get the rest of the population to

 4     move out, because, as we said before, there were deficits of everything.

 5     No more supplies got in and no more letters.  We used to bring them

 6     before, of course, checked by the Serbian authorities.

 7             So the rest of the population moved out.  That was the result of

 8     our arrests.  Not a single convoy - I repeat - left again after our

 9     arrests.

10             MR. JEREMY:  I have no further questions, Your Honours.

11             JUDGE ORIE:  Thank you, Mr. Jeremy.

12             Mr. Lukic, the questions in re-examination have not triggered any

13     need for further questions?

14             MR. LUKIC:  No, Your Honour.

15             JUDGE ORIE:  Then this concludes your testimony, Mr. Medic, in

16     this court.  I would like to thank you very much for coming to The Hague

17     and for answering all the questions that were put to you by the parties

18     and by the Bench, and I wish you a safe return home again.

19             You may follow the usher.

20             THE WITNESS: [Interpretation] Thank you very much.

21                           [The witness withdrew]

22                           [Trial Chamber confers]

23             JUDGE ORIE:  Mr. Lukic.  Mr. Lukic, there is one matter

24     outstanding which the Chamber would prefer you to address, if you want to

25     address it at all, in an oral submission on Monday.  And that is the

Page 2081

 1     issue of the administrative schedule of meetings as proposed by

 2     Mr. Groome.  I do not know whether you want to at all address the matter

 3     further or whether you just agree or --

 4             MR. LUKIC:  In essence we don't oppose, of course.

 5             JUDGE ORIE:  You don't oppose.  So if you want to make any

 6     further submissions on that, then we'd like to hear from you on Monday

 7     because the Chamber would prefer to adjourn for the day.

 8             The removal of Mr. Mladic from the courtroom was during the

 9     remainder of the testimony of this witness.  That means that we expect

10     Mr. Mladic to be back on Monday morning at 9.30.

11             Mr. Groome.

12             MR. GROOME:  Nothing from the Prosecution, Your Honour.

13             JUDGE ORIE:  Nothing from the Prosecution.

14             And nothing from the Defence.

15             Then we adjourn for the day and we will resume on Monday, the

16     3rd of September, at 9.30 in the morning, I think it will be in this same

17     courtroom, I.

18             We stand adjourned.

19                            --- Whereupon the hearing adjourned at 1.39 p.m.,

20                           to be reconvened on Monday, the 3rd day of

21                           September, 2012, at 9.30 a.m.