Tribunal Criminal Tribunal for the Former Yugoslavia

Page 22218

 1                           Thursday, 5 June 2014

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.33 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.  This is case

 8     IT-09-92-T, the Prosecutor versus Ratko Mladic.

 9             JUDGE ORIE:  Thank you, Madam Registrar.

10             There are no preliminaries, therefore the witness can be escorted

11     into the courtroom.

12             I use the opportunity to deal with the following matter.  On the

13     12th of May, the Chamber asked the Defence to file a submission on when

14     its expert reports will be filed.  The Chamber notes that 24 of the

15     witnesses on the Defence's witness list are indicated as Rule 94 bis

16     witnesses.  On the 3rd of June, the Defence provided the Chamber and the

17     Prosecution with an update through an informal communication.  The

18     Defence explained that four of the expert reports will be completed and

19     filed by September 2014.  These are two ballistic reports, one military

20     report, and one demographic report.  The Defence further stated that it

21     is not in a position to predict the completion date for the report by

22     Dr. Dunjic.

23                           [The witness takes the stand]

24             JUDGE ORIE:  Finally, the Defence indicated that it is waiting

25     for the Registry to appoint the history, radio communications, and

Page 22219

 1     demolitions experts.

 2             The Chamber would be like to be kept regularly updated on the

 3     progress of the expert reports, and therefore the Defence is hereby

 4     instructed to file short updates once a month, the first one on the

 5     20th of June of this year.

 6             Good morning, Mr. Cvoro.  Again, apologies that we were still

 7     busy with other matters when you entered the courtroom.  Before we

 8     continue, I'd like to remind you again --

 9             THE WITNESS: [Interpretation] Good morning, Judge.

10             JUDGE ORIE:  I would like to remind you again that you are still

11     bound by the solemn declaration you've given at the beginning of your

12     testimony.

13             Mr. Lukic will now continue his re-examination.

14             Mr. Lukic.

15             MR. LUKIC:  Thank you, Your Honours.

16                           WITNESS:  ZDRAVKO CVORO [Resumed]

17                           [Witness answered through interpreter]

18                           Re-examination by Mr. Lukic: [Continued]

19        Q.   [Interpretation] Good morning, Mr. Cvoro.

20        A.   Good morning, Mr. Lukic.

21             MR. LUKIC: [Interpretation] We need in e-court P6562.

22        Q.   This morning I'll go through some of the documents that were

23     shown to you yesterday by the Prosecution, and please try to give us

24     answers as brief as possible so we can go through it today.

25             As we see, this is a document from the Executive Board of

Page 22220

 1     Pale municipality.

 2        A.   Yes.

 3        Q.   The Prosecutor questioned you on this document.

 4             MR. LUKIC: [Interpretation] We need page 3 in English and page 2

 5     in B/C/S.

 6        Q.   The Prosecution was the most interested in this amount of

 7     100.000 dinars for the SDS.  You started to explain yesterday that funds

 8     were returned from the city but you were interrupted and you couldn't

 9     finish the explanation.  What did you mean to say?

10        A.   Mr. Lukic, we were one of the municipalities in the city.  All

11     the contributions, all the taxes, all the fees that were collected in the

12     city of Pale were distributed across the municipalities.

13        Q.   Was that the same situation at this time or did something change?

14        A.   Beginning with the month of January, there was some obstruction

15     on the part of the city in the distribution, in the allocation of funds,

16     so we couldn't properly implement our municipal budget.

17        Q.   Which party had control of the city, which party was making

18     problems?

19        A.   I believe at the level of the city the Party of Democratic Action

20     had majority power.

21        Q.   Thank you.

22             MR. LUKIC: [Interpretation] Now I would like to see P6564 --

23             JUDGE MOLOTO:  I'm sorry, I don't understand the question and

24     answer, Mr. Lukic.  You said which party was making the most problems.

25     And then the answer is that the SDA had majority power.

Page 22221

 1             MR. LUKIC:  SDA --

 2             JUDGE MOLOTO:  Did it cause problems because of its majority

 3     power?

 4             MR. LUKIC: [Interpretation]

 5        Q.   You've heard the question posed by His Honour Judge Moloto.

 6        A.   I believe the party that controls the government dictates certain

 7     things, and in this case it concerned the budget.  I don't know if it was

 8     just the SDA or the coalition of parties at the level of the city.

 9             JUDGE MOLOTO:  Do I then understand that it is the SDA party

10     which voted that an amount of 100.000 dinars should be given to the SDS?

11             THE WITNESS: [Interpretation] No, this is something special.

12     This is the temporary financing of the municipal budget for the month of

13     May, and the reason was that we didn't have enough funds --

14             JUDGE MOLOTO:  I'm going to stop you.  Could you please try to

15     answer my question.  You say the SDA coalition parties were controlling

16     the budget.  This is a budget, whether temporary or not.  I'm asking you:

17     Is it the decision of the SDA that this 100.000 dinars be given to the

18     SDS, yes or no?

19             THE WITNESS: [Interpretation] No.

20             JUDGE MOLOTO:  Then I don't understand your question.  Thank you.

21             You may continue.

22             MR. LUKIC: [Interpretation]

23        Q.   Is it the case that in the beginning of the year the flow of cash

24     and payments in the city of Sarajevo was disrupted?

25        A.   I don't know about the city of Sarajevo, but I know there were

Page 22222

 1     problems in the financing of the municipalities in Pale which were part

 2     of the city.

 3             JUDGE ORIE:  But then still, there is a suggestion in this answer

 4     that the -- those in power in the city of Sarajevo would have caused all

 5     this.  Could you tell us in detail what caused the problems in the

 6     financing of the municipalities?  Because then we know facts rather than

 7     that we are hearing suggestions in answers.

 8             THE WITNESS: [Interpretation] Your Honours, I did not participate

 9     in politics, but I was part of the executive authority and I know that we

10     did not receive sufficient funds from the city budget.

11             JUDGE ORIE:  Tell us then what exactly caused this to happen.

12             THE WITNESS: [Interpretation] Probably obstruction by

13     politicians.

14             JUDGE ORIE:  Yes.  So if I understand you well, you do not know

15     what caused it to happen, you have some vague --

16             THE WITNESS: [Interpretation] I don't know.  All I know is we

17     didn't receive the funds.

18             JUDGE ORIE:  Well, your answers went further.  Your answers were

19     that they made -- the SDA made the problems because they were in power,

20     but I do understand that you have no detailed knowledge on what exactly

21     happened which caused you to receive less funds from the city.

22             Please proceed, Mr. Lukic.

23             MR. LUKIC:  Thank you.

24        Q.   [Interpretation] Did the inadequate return of funds from the city

25     to the municipality of Pale constitute the reason why this temporary fund

Page 22223

 1     was created?

 2        A.   Yes, precisely.

 3             JUDGE ORIE:  Could I then ask you one more thing.  Was the SDA or

 4     were other parties not affected by the lack of adequate return of funds?

 5     What was it that specifically the SDS was suffering under it?

 6             THE WITNESS: [Interpretation] Well, the SDS was the only party

 7     that was active at the time.  The SDA had withdrawn.  It did not operate

 8     any longer.  I don't know why.  I don't know why they received any funds

 9     themselves.  My assumption is that they were not active at the time.

10             JUDGE ORIE:  That's still unclear to me, but I leave it to you,

11     Mr. Lukic, whether you want to further explore that, why and how activity

12     is established, activity of political organs which would then justify to

13     pay or not to pay them, also in terms of are they still elected members

14     of the Assembly, the municipal Assembly.  I leave it to you whether you

15     want to spend time on that, but to say they were not active therefore no

16     money was given to them; SDS was active, and therefore they did receive

17     money -- it would even require the basis for establishing exactly why the

18     SDS got money, for what exactly, and whether they reported on the way in

19     which they spent that money to those who were providing that money and

20     that is - if I understand well - the local government.  But I leave it in

21     your hands whether you want to explore it or not.  Please proceed.

22             MR. LUKIC:  Thank you, Your Honour.

23        Q.   [Interpretation] Did you allocate funds on request or did

24     somebody decide independently of requests, were the SDA and the SDS

25     supposed to apply for this money or not?

Page 22224

 1        A.   Monies were allocated strictly by law.

 2        Q.   Do you remember that the SDS did not request funds?

 3        A.   If they had requested them, they would have probably received

 4     them.

 5             JUDGE ORIE:  Mr. Lukic, could you inquire also what law exactly

 6     applied on the funding of political parties.  Perhaps the witness could

 7     answer the question.

 8             MR. LUKIC: [Interpretation]

 9        Q.   You've heard the question of Judge Orie.  Can you answer?

10        A.   I still believe it was based on the statute of the city or the

11     statute of municipalities.  The city planned annual budget according to

12     its statutes and within those funds financing was also envisaged for

13     political parties.

14             JUDGE ORIE:  Witness, could I stop you there.  What I asked you

15     is whether you could tell me what statute or whatever the legal basis was

16     exactly so that we can have a look at it, because you now say, "I still

17     believe it was based ..."  Well, I'd rather look at facts, documents,

18     rather than what you believe the case was.  Can you tell us what statute

19     or what law it was that you applied in this context?

20             THE WITNESS: [Interpretation] Well, I don't know the exact law,

21     but I know that there was Article 86 of the municipal statute as referred

22     to in this decision.

23             JUDGE ORIE:  Mr. Lukic, if Article 86 would be at one time be

24     available so that we could have a look at it, that would be appreciated.

25     Please proceed.

Page 22225

 1             MR. LUKIC:  Thank you, Your Honour.

 2        Q.   [Interpretation] We'll move on from finances.

 3             MR. LUKIC: [Interpretation] We need P6564 on our screens now.

 4        Q.   While we're waiting, I'll give you a short introduction.  You've

 5     told us that you requested fuel for the transport of refugees.  This

 6     document is dated 24 May 1992.  You told us there were five to ten buses

 7     filled with refugees going to Serbia every day.  Were they Serb or Muslim

 8     refugees?

 9        A.   Serb refugees.

10             MR. LUKIC: [Interpretation] P3038 is the next document we need.

11        Q.   These are instructions on the organising and operation of the

12     organs of Serbian people in Bosnia-Herzegovina in emergency conditions.

13     This document was issued by the Serbian Democratic Party.  You told us

14     you were not a member of the SDS?

15        A.   I was not a member of any political party.

16        Q.   This document is dated 12 December 1991 -- 19 December 1991.

17             MR. LUKIC: [Interpretation] We need page 3 in both versions.

18        Q.   We see that after the bullet points in both versions in the

19     middle of the page, we read that the Crisis Staff would be headed by a

20     commander.  Did you use this title?  Were you the commander of the

21     Crisis Staff?

22        A.   No, I wasn't.  I was the president of the Executive Board.

23        Q.   Do you know, did there exist Crisis Staffs of the SDS and

24     Crisis Staffs of municipalities?

25        A.   I know about the Crisis Staffs of municipalities, not about

Page 22226

 1     Crisis Staffs of parties.

 2             MR. LUKIC: [Interpretation] P6565 is the next document I would

 3     like to call up.

 4        Q.   If you remember when you see it on the screen, it's a document to

 5     which the Defence objected because of certain shortcomings in the

 6     document.  So I'd like to ask you:  Did you ever encounter in your work

 7     documents of the State Security Service?

 8        A.   Never.

 9        Q.   In any case, you can see that this number does not have -- this

10     document does not have a registration number?

11        A.   Yes.

12        Q.   The first sentence reads:

13             "Please find attached information ..."

14             Can we see to whom this is addressed?

15        A.   No, no.

16        Q.   In fact, it says "to" below?

17        A.   That's right.

18        Q.   But at the end of the document --

19             MR. LUKIC: [Interpretation] We need the last page in both

20     versions.

21        Q.   At the end we see there is no signature, no stamp, so we don't

22     see who created this document.  But since you never worked with SDB

23     documents, I'll move to another type of document that is certainly more

24     familiar to you.  We will begin with P6566.

25             Did you have any contact with Territorial Defence documents?

Page 22227

 1        A.   No.  I only had contact with the municipal staff of the

 2     Territorial Defence until the Army of Republika Srpska was established,

 3     and that was on the 12th of May.

 4        Q.   Very well, but this is a document of the Territorial Defence --

 5     in fact, their staff.

 6        A.   I don't know if it is the city staff or the municipal staff or

 7     the zone staff.

 8        Q.   It should be the republic staff.  In the documents you've seen,

 9     many of them lack registration number, this one too?

10        A.   Right.

11        Q.   Did you see that the documents of the TO of Pale did not have a

12     registration number?

13        A.   According to the Law on State Administration, the rule was that

14     all documents must be registered in the protocol.

15        Q.   And you worked for the state administration for years

16     [as interpreted]?

17        A.   Yes.

18             MR. LUKIC:  Just not to be leading, I asked:  And you worked for

19     the state administration?  And the witness answered:  Yes, for years.

20             [Interpretation] Could we see page 5 in both versions.  Page 3 in

21     B/C/S, one before this.  [In English] Can we move one page before this in

22     B/C/S, please.  One more.  I don't know how it happened.  This document

23     has three pages.  That's it.

24        Q.   [Interpretation] This is the end of the document.  We see there's

25     no signature and no stamp?

Page 22228

 1        A.   I see the same thing.

 2        Q.   Is that normal for a document of the state administration?

 3        A.   No, it's not.

 4        Q.   Let's compare now the first and the fourth page in B/C/S, because

 5     there are two versions.

 6             MR. LUKIC: [Interpretation] We'll need page 1 of this document on

 7     the left side of the screen and page 4 on the right-hand side of the

 8     screen, both in B/C/S.

 9             JUDGE ORIE:  I don't know whether it's possible to have this --

10             MR. LUKIC:  I'm trying -- also inquire.  Is it possible to have

11     it?  Yeah.  Thank you.  Now we know that it's even possible.

12        Q.   [Interpretation] This is the handwritten version of the document

13     on the left-hand side.  On the left -- in the handwritten document, in

14     the handwritten document we see that it was sent to the chief of security

15     and then it was crossed out?

16        A.   Yes.

17        Q.   On the left-hand side, in that version of the document, there's

18     no such thing?

19        A.   Right.

20        Q.   In the typewritten text, we read that it was the

21     Territorial Defence staff of the National Defence Ministry of the

22     Republic of Bosnia-Herzegovina?

23        A.   Yes.

24        Q.   In the handwritten version, that text is missing?

25        A.   As far as I can see - and I haven't finished reading - no, no,

Page 22229

 1     there's no such thing.

 2        Q.   On the right-hand side we see "official note" at the top?

 3        A.   Yes.

 4        Q.   On the left-hand side there is no such indication?

 5        A.   No.

 6        Q.   We've seen the beginning and the end of this document.  Can we

 7     see who created it without the signature, without the typewritten name,

 8     without a stamp?

 9        A.   I don't know.  We can't know that.

10        Q.   Thank you.

11             JUDGE FLUEGGE:  One clarification, you said, Mr. Lukic:  "On the

12     right-hand side we see 'official note' at the top."  I take it you mean

13     right-hand side of the screen but left-hand side of the handwritten

14     document?

15             MR. LUKIC:  Yes, Your Honour.  Thank you.

16             JUDGE FLUEGGE:  Is that correct?

17             MR. LUKIC:  Thank you for your help.

18             JUDGE FLUEGGE:  Thank you.

19             MR. LUKIC: [Interpretation] We don't need this document.

20        Q.   You were asked something about P2001.  It hasn't even been shown

21     to you so there's no need for me to show it either.  It was marked.

22             Mandic, 22153 is our transcript page.  I'm going to read out the

23     question that was put to you.  It's line 15.  It had to do with Mandic

24     and Stanisic.

25             [In English] I quote --

Page 22230

 1        A.   I don't have that.

 2        Q.   [Interpretation] I'm going to read it out to you now and you're

 3     going to receive interpretation.

 4        A.   All right.

 5        Q.   [In English] "Now, my first focused question for you, Mr. Mandic

 6     and Mr. Stanisic were both officials in the Bosnian Serb Ministry of the

 7     Interior; correct?"

 8             And your answer was in line 18:

 9             "Yes, that's correct.  They were in the leadership."

10        A.   Yes.

11        Q.   [Interpretation] This is what I'm putting to you:  That Mandic

12     was not a member of the MUP of Republika Srpska?

13        A.   Well, possibly he wasn't.  I know that he was part of the

14     leadership; maybe he wasn't within the MUP structures.

15        Q.   Thank you.

16             MR. LUKIC: [Interpretation] Now we need P --

17             JUDGE FLUEGGE:  Now I would like to know what the witness knows

18     about Mandic, what was his duty?  What was his position?  What was his

19     rank?  Where was he situated?  At which time?  Can you help us?

20             THE WITNESS: [Interpretation] Well, I'm not sure.  Now that

21     Mr. Lukic put this question to me -- I think he was in the Ministry of

22     Justice, not in the Ministry of the MUP.

23             JUDGE FLUEGGE:  What was his position and his duties?

24             THE WITNESS: [Interpretation] I'm not sure.  I'm saying that once

25     again, but he may have been the minister, actually, because ministers

Page 22231

 1     changed.  I don't know who it was at the time.

 2             JUDGE FLUEGGE:  Thank you.

 3             JUDGE ORIE:  Mr. Traldi.

 4             MR. TRALDI:  Your Honours, just for the clarity of the record, I

 5     think it might be useful for Mr. Lukic to specify what time-period he's

 6     talking about.  Many officials held different jobs at different times

 7     during the indictment period, Mr. Mandic included.

 8             JUDGE ORIE:  At the same time, I wonder whether the parties could

 9     not agree on who was in what ministry at what point in time.  I mean,

10     these were not secret appointments; these were public functions.  So,

11     Mr. Traldi, if you would like to know whether Mr. Mandic was in what

12     position at the moment that this happened, why not seek an agreement with

13     Mr. Lukic?

14             MR. TRALDI:  We'll speak at the break, Mr. President.

15             JUDGE ORIE:  Yes.  That's better than to ask a witness who says

16     he's not certain about it.

17             Please proceed.

18             MR. LUKIC:  Thank you.

19             [Interpretation] Now we need P3972, that's the document we'd like

20     to have displayed on our screens.

21        Q.   We know -- actually, we discussed this document yesterday.  It is

22     document -- it is a document of the Municipal Assembly of Pale.  The

23     Prosecutor showed you page 4 of this document.

24             MR. LUKIC: [Interpretation] And I would kindly ask for page 4 in

25     both versions as well.

Page 22232

 1        Q.   The Judges asked yesterday also what had been done because you

 2     explained that previously there had been attempts to move people out,

 3     there was this lack of understanding, you explained to people that they

 4     didn't have to leave.  We see here in paragraph 2 ...

 5             JUDGE FLUEGGE:  Are you referring to --

 6             MR. LUKIC: [Interpretation] In English actually we'd have to go

 7     down a bit.

 8             JUDGE FLUEGGE:  Are you referring to item 2?

 9             MR. LUKIC:  Yeah, item 2, point 2.

10             JUDGE FLUEGGE:  Thank you.

11             MR. LUKIC:  Item 2 here, yes.

12        Q.   [Interpretation] What is written here is that:

13             "The president of the Assembly and the president of the

14     Executive Board" -- so you're the latter; right?

15        A.   Yes, yes.

16        Q.   And it says:

17             "... objected to the activities of the public security station in

18     this respect because it had taken part in attempts to move the Muslims

19     out, which was done without a political decision which meant that the

20     official structures of power had been bypassed."

21             And then it says, I quote:

22             "This is why the attempt had been stopped."

23             So what was stopped, these attempts to --

24        A.   Exercise or exert pressure.

25        Q.   In the English version we have the right paragraph now.  Now the

Page 22233

 1     next paragraph, this is what I'm going to read out --

 2             JUDGE ORIE:  Before we continue, Mr. Lukic.

 3             Could you tell us exactly then what you did to prevent that

 4     because I think earlier you said you had no authority over others.  What

 5     did you then do?

 6             THE WITNESS: [Interpretation] Well, our commissioner was

 7     Mrs. Biljana Plavsic for our municipality.  We intervened through her,

 8     and she, in accordance with her authority, intervened to have these

 9     occurrences prevented, or rather, stopped.

10             JUDGE ORIE:  It makes a difference whether it was prevented or

11     whether it was stopped, the difference being that if it is prevented that

12     the attempts never materialised.  If you stop it, then it has happened

13     but then you discontinued that to happen.  Now, what was it, was it

14     prevented or was it stopped?

15             THE WITNESS: [Interpretation] Stopped, as we've stated here.

16             JUDGE ORIE:  Yes, well, the translation says it was prevented,

17     but let's -- and then could you tell us exactly in what way, then, did

18     you seek the intervention of Madam Plavsic in writing or did you -- how

19     did this happen, this stopping this event?

20             THE WITNESS: [Interpretation] Well, every day we had meetings

21     with Mrs. Biljana Plavsic -- well, I cannot say every day, almost every

22     day, and we informed her about the situation on the ground.

23             JUDGE ORIE:  And what did she then do?

24             THE WITNESS: [Interpretation] She gave us certain instructions as

25     to how we should act, the executive, that is, and also she provided

Page 22234

 1     instructions how other organs should act, those that are not within the

 2     executive.

 3             JUDGE ORIE:  What did she say how you would have to act?

 4             THE WITNESS: [Interpretation] Well, what was stated was that we

 5     should do everything to stop that kind of thing.

 6             JUDGE ORIE:  What then is the -- what did you then do to stop it?

 7     I mean -- yes, please.

 8             THE WITNESS: [Interpretation] Well, we went out into the field,

 9     we went to the actual places involved, and this is one aspect of our

10     activity and our work, as far as the executive is concerned.  Again, I'm

11     speaking about the executive.

12             JUDGE ORIE:  What was done by the others?

13             THE WITNESS: [Interpretation] Well, the police probably knows how

14     and in which way they acted.

15             JUDGE ORIE:  The "probably" suggests that you do not know

16     precisely; is that well understood?

17             THE WITNESS: [Interpretation] Well, we were not satisfied with

18     their work and that is why we informed the Assembly of that.

19             JUDGE ORIE:  Did you then inform the Assembly after you had

20     sought the intervention of Madam Plavsic?

21             THE WITNESS: [Interpretation] Yes, yes, after, I mean --

22     actually, first we informed Mrs. Plavsic and then we convened the

23     Assembly.

24             JUDGE ORIE:  One second, please.  Yes, now I'm re-reading your

25     answers.  I asked you:

Page 22235

 1             "Could you tell us exactly what you did to stop it or prevent

 2     it?"

 3             And you said:

 4             "Well, our commissioner was Mrs. Biljana Plavsic for our

 5     municipality.  We intervened through her and she intervened to have these

 6     occurrences prevented, or rather, stopped."

 7             But I do understand that as far as you are concerned, what she

 8     did is tell you to do whatever was needed to stop it?

 9             THE WITNESS: [Interpretation] Yes, that we had to stop that and

10     that we had to go out into the field and speak to the Muslims so that, I

11     mean -- well, that's what we did.

12             JUDGE ORIE:  You spoke to the Muslims or you spoke to those who

13     were attempting to drive them out?

14             THE WITNESS: [Interpretation] No, we talked to the Muslims.  And

15     those who made these attempts, well, that was within the scope of work of

16     the police because it is for the police to establish the reasons --

17             JUDGE ORIE:  Yes, do you know exactly what then the police did in

18     this respect?

19             THE WITNESS: [Interpretation] I don't have any information.

20             JUDGE ORIE:  So what happened is you went to Biljana Plavsic,

21     that she told you to do everything to stop it, that you then just talked

22     to the Muslims, and that you do not know what the police did in

23     addressing those who attempted to expel the Muslims; is that a summary of

24     what you told us?

25             THE WITNESS: [Interpretation] Yes.

Page 22236

 1             JUDGE ORIE:  Thank you.

 2             Please proceed, Mr. Lukic.

 3             MR. LUKIC:  Thank you.

 4        Q.   [Interpretation] Although you don't know exactly what the police

 5     did specifically, concretely, the situation, or rather, the attempts to

 6     have people move out by force, that was stopped all together; right?

 7        A.   Yes, that is what is written in this Assembly material under

 8     number 2.

 9        Q.   Thank you.

10             JUDGE ORIE:  Is it also your recollection that it stopped

11     completely?

12             THE WITNESS: [Interpretation] I think so, that is my

13     recollection.  The police started this action to replace the commander

14     and the chief, and I know there were some problems probably in respect of

15     these questions but I'm not aware of any details and I cannot really talk

16     about this.

17             JUDGE ORIE:  Was for this reason, was the commander and the chief

18     replaced because the police had expelled them?  I'm just trying to

19     understand your answer.

20             Mr. Lukic, your microphone is still open so I do not know

21     what ...

22             THE WITNESS: [Interpretation] I don't know whether he was

23     replaced then, but I know that there was this activity concerning the

24     replacement of the chief and the commander.

25             JUDGE ORIE:  Yes, I asked you because you raised it in the

Page 22237

 1     context of the question that was put to you about what exactly the police

 2     had done.

 3             Please proceed, Mr. Lukic.

 4             MR. LUKIC: [Interpretation]

 5        Q.   I don't have much time left so we'll have to -- well, actually,

 6     I'm going to skip a few things --

 7             JUDGE ORIE:  Mr. Lukic, the time the Chamber uses for asking

 8     questions is carefully administered so it does not go from your time.

 9             MR. LUKIC:  Thank you, Your Honour.  I'm trying to finish in the

10     first session so we have enough time for the next witness, but thank you.

11        Q.   [Interpretation] Next paragraph in this document, this is what it

12     says, I quote:

13             "In order to keep the discussion focused, the Assembly proposed

14     that a Working Group formulate a draft decision on the moving out of

15     Muslims and Croats, stressing in it that the departure of these people

16     from the territory of the municipality should be done on a voluntary

17     basis and in an organised manner."

18        A.   Yes.

19        Q.   In this decision, was the principle of voluntariness and

20     departure in an organised manner emphasised?

21        A.   Yes.

22             MR. LUKIC: [Interpretation] Now we need P264.

23        Q.   This is a brief document issued by the public security station of

24     Pale on the 2nd of July, 1992, and there is this section where it says

25     "decision."  And it said that the request made by citizens of Muslim and

Page 22238

 1     Croat ethnicity is being granted, that they can move out of the

 2     municipality of Pale, unobstructed, as they wish.

 3        A.   Yes.

 4        Q.   Had it not been for these requests, would you have taken part in

 5     moving out citizens from Pale?

 6        A.   No.

 7        Q.   Did you believe that you did not have the right to stop these

 8     people from leaving?

 9        A.   Precisely.  We wouldn't have the right to do that.  I mean, had

10     they not submitted this request, that would have been different, but

11     since they had submitted this request, then it is their civic right to

12     decide where they want to live.

13        Q.   In the next paragraph, in the last paragraph, we can see that

14     police and military patrols are to enable the unobstructed passage of

15     buses.

16        A.   Yes, that can be seen.

17        Q.   These buses, at the time were they supposed to pass through

18     check-points, were they already there?

19        A.   Well, practically they were supposed to pass through the

20     separation line.

21        Q.   That's my next question.

22        A.   Within the territory there weren't any check-points.

23        Q.   All right.  So were they supposed to cross the front line?

24        A.   Yes.

25        Q.   In your view, would they have succeeded in crossing this front

Page 22239

 1     line safely without this escort?

 2        A.   No.

 3             MR. LUKIC: [Interpretation] Now we need document P3800.

 4        Q.   This document was shown to you yesterday as well.  Again, this is

 5     a report of the public security station of Pale dated the 6th of July,

 6     1992, and this provides an idea as to who left the municipality of Pale.

 7        A.   Yes.

 8        Q.   Again, it says that it was done at the requests made by these

 9     citizens and that this was enabled by the municipality of Pale.

10        A.   Yes.

11        Q.   Was this a public process?  Was it open to the public?

12        A.   Yes.

13        Q.   And as for the document itself, on the document itself we see

14     that it hasn't been marked as a state secret; right?

15        A.   It hasn't.

16        Q.   You said to us that these people who decided to move out left,

17     some took buses, others took passenger vehicles along with their personal

18     belongings?

19        A.   Yes, I know that for sure, that some left on buses and others

20     took their own motor vehicles and all the personal belongings that they

21     could take along.

22        Q.   At the time, the end of June, the beginning of July, 1992, could

23     Serbs leave Sarajevo with their cars and their movable property?

24        A.   No.

25             JUDGE ORIE:  Mr. Traldi.

Page 22240

 1             MR. TRALDI:  Your Honours, I'd just like -- I'd just tentatively

 2     object and ask that some foundation be laid for the witness's knowledge

 3     in that respect.

 4             JUDGE ORIE:  Mr. Lukic.

 5             MR. LUKIC:  Mm-hm, that's my next question.

 6             JUDGE ORIE:  Yes, okay.  Then please put that question to the

 7     witness.

 8             MR. LUKIC: [Interpretation]

 9        Q.   At the time, were people coming to Pale from Sarajevo, or up

10     until then, had refugees already arrived from Sarajevo?

11        A.   Many refugees came through a local road.  That is to say, all

12     communications with Sarajevo had been cut off, and they took military

13     vehicles and other means of transportation as they managed.  They could

14     not take their own motor vehicles.  They did not come in an organised

15     fashion.  They didn't come on buses either.

16        Q.   Actually, you're telling us about people who managed to escape?

17        A.   Yes, precisely.  That is why we had a large number of refugees in

18     Pale.

19        Q.   Just one more document and then we'll be done, at least I will be

20     done.

21             MR. LUKIC: [Interpretation] That is P6574.

22             JUDGE ORIE:  Perhaps I put one or two questions to the witness in

23     this context.

24             Why could the Serbs from Sarajevo not use their own vehicles to

25     reach Pale?

Page 22241

 1             THE WITNESS: [Interpretation] Well, all roads that went from

 2     Sarajevo to Pale were under control.  On the one hand, I mean Muslim

 3     forces; and on the other hand, Serb forces.  These roads had been closed

 4     down.  Then what was being built was, well, across hills.  I mean, roads

 5     were being built with certain machines in order for people to be able to

 6     get to Pale and that's how they got there.  Buses could not take these

 7     roads, not even vehicles could take those roads.

 8             JUDGE ORIE:  Yes.  Now, how could the Muslims from Pale then move

 9     to Sarajevo with their own cars?

10             THE WITNESS: [Interpretation] Well, it was organised, a convoy.

11             JUDGE ORIE:  Do you have similar documentation about convoys,

12     because we see on our screen -- we saw on our screen how buses were

13     organised and escorted, et cetera.  Apparently there were written

14     instructions for that.  Do you have -- do there exist similar written

15     instructions --

16             THE WITNESS: [Interpretation] Correct.

17             JUDGE ORIE:  -- for convoys of vehicles -- vehicles owned by

18     Muslims who wanted to leave with their own cars?  Do similar documents

19     exist, to your knowledge?

20             THE WITNESS: [Interpretation] Yes, unfortunately documents only

21     say that they took buses, but I know that they would also leave in

22     passenger motor vehicles too but I don't have any documents.

23             JUDGE ORIE:  That means all those in buses, did they leave any

24     motor cars privately owned behind in Pale, or were these just people who

25     were not in the possession of personal motor cars?

Page 22242

 1             THE WITNESS: [Interpretation] Well, mostly those who did not have

 2     motor vehicles were on buses, whereas those who had motor vehicles joined

 3     the buses and ...

 4             JUDGE ORIE:  Yes, my question was whether those on the buses left

 5     behind any motor cars as far as you know?

 6             THE WITNESS: [Interpretation] I don't know about that.

 7             JUDGE ORIE:  Please proceed, Mr. Lukic.

 8             MR. LUKIC:  Thank you.

 9        Q.   [Interpretation] On the screen we see a document and you

10     protested when the Prosecutor asked you about this because it concerns

11     1995.  But I'm just going to ask you to read out the introductory

12     paragraph.  The question is whether Renovica was in Serb hands or in

13     Muslim hands.  When you read the beginning of the document, do you come

14     to the conclusion that at that time Renovica was in Serb hands or in

15     Muslim hands at that time, the end of 1995 or just before that?

16        A.   Well, according to what we learned from the captured Muslim

17     fighters, they will be pulled out along three different axes and so on;

18     is that what you mean?

19        Q.   Yes.  And now point 2 --

20        A.   Point 2, well, it says, Dzimrije, Sokolovici, Stjenice, Renovica,

21     and so on, the left bank of the river Drina.

22        Q.   Please go on to number 3 -- no, below number 3.

23        A.   "All directions are mainly unpopulated and before the war they

24     were populated by Muslim inhabitants for the most part.  The most

25     probable directions of their movement and disengagements are directions

Page 22243

 1     one and three because they are closest to Gorazde ..."

 2        Q.   So can you draw a conclusion?  If not --

 3        A.   Well, I think that Renovica was -- parts of it around the

 4     barracks were under the control of the Serb forces for a while, but when

 5     the barracks withdrew, Renovica and parts of Praca were captured by the

 6     Muslim forces.

 7        Q.   Thank you, Mr. Cvoro.  This is all I had for you.  Thank you once

 8     again.

 9             JUDGE ORIE:  Before I ask you if you have any questions,

10     Judge Moloto would have one question -- one or more.

11                           Questioned by the Court:

12             JUDGE MOLOTO:  The question I'm going to ask you, you might have

13     been asked by Judge Orie but I'm not quite sure I understood the answer.

14     You've told us that Muslims left in buses and private cars from Pale to

15     Sarajevo; am I correct?

16        A.   Yes.

17             JUDGE MOLOTO:  You also told us, and I quote page 23, lines 7 to

18     10, you say:

19             "Many refugees came through a local road."  And these are Serb

20     refugees from Sarajevo.  "That is to say, all communications with

21     Sarajevo had been cut off, and they took military vehicles and other

22     means of transportation as they managed.  They could not take their own

23     motor vehicles, they did not come in an organised fashion.  They didn't

24     come on buses either."

25             My question is:  If communications had been cut and refugees from

Page 22244

 1     Sarajevo could not come in their cars, had to use military trucks, what

 2     roads were used by the Muslims who went to Sarajevo and why is it they

 3     were able to go in private cars and buses?

 4        A.   Well, the order from the commander or the chief of the public

 5     security station discusses that precisely, what roads and what

 6     communications and in what way they left for Sarajevo.

 7             JUDGE MOLOTO:  Excuse me, let me stop you.  I understand -- the

 8     order might discuss that.  I'm asking you what roads were used by the

 9     Muslim refugees to go to Sarajevo which could not be used by the Serb

10     refugees from Sarajevo to Pale, irrespective of what is discussed in the

11     order.  I'm asking you for the roads.

12        A.   I see.  Well, that's the road going from Pale to -- via Hresa,

13     Vasin Han, and of course then through the Muslim parts, Travnik and so on

14     and so forth.  That is the normal road.

15             JUDGE MOLOTO:  And why could Serbs not use the same road?

16        A.   Well, because they weren't allowed to.

17             JUDGE MOLOTO:  Allowed by who?

18        A.   Well, probably by the Muslim forces.

19             JUDGE MOLOTO:  No, no, I'm asking for facts, not probabilities.

20        A.   Well, because the roads were closed.  There was no passing

21     through them.  The roads were mined, there were barricades, there were

22     separation lines.

23             JUDGE MOLOTO:  But if the roads were mined, how did the Muslims

24     go through them?

25                           [Trial Chamber confers]

Page 22245

 1             THE WITNESS: [Interpretation] Well, probably they removed

 2     certain -- well, I'm talking about our side and our road.  In agreement

 3     with the Muslim forces that road was cleared, it was freed up.

 4             JUDGE MOLOTO:  Thank you so much.

 5             JUDGE ORIE:  Any further questions, Mr. Traldi?

 6             MR. TRALDI:  No, Your Honour.  I had one area, but Mr. Lukic and

 7     I agreed that one document would be admitted.  I can inform the Chamber

 8     the number and it will spare us from any further questioning of this

 9     witness.

10             JUDGE ORIE:  Yes.

11             And then, Mr. Cvoro, this concludes your testimony in this court.

12     I would like to thank you very much for having answered the many, many

13     questions, not only by the parties but also by the Bench, and I wish you

14     a safe return home again.  You may follow the usher.

15             THE WITNESS: [Interpretation] Thank you, sir.

16                           [The witness withdrew]

17             MR. TRALDI:  And --

18             JUDGE ORIE:  Mr. Traldi.

19             MR. TRALDI:  The document which would be admitted, Mr. President,

20     is 65 ter 30715.  It must be admitted under seal due to protective

21     measures in a different case.

22             JUDGE ORIE:  Yes.  We may have a look at it.  It cannot be --

23     well, if it is shown on our screens, then it's not to be published --

24             MR. TRALDI:  That's correct.

25             JUDGE ORIE:  -- but before we decide on admission, we usually

Page 22246

 1     would like to know what we are admitting.

 2             MR. TRALDI:  I'm happy to have it shown as long as it's not

 3     broadcast.

 4             JUDGE ORIE:  Yes.

 5             MR. TRALDI:  I can provide more detail on the relevance, in my

 6     view, Your Honours, but I'd request to do it in private session if that

 7     would assist the Bench.

 8             JUDGE ORIE:  Yes, perhaps it's better to do it now than --

 9     Mr. Lukic.

10             MR. LUKIC:  I think this is something you asked for yesterday, so

11     I think that Mr. Traldi --

12             JUDGE ORIE:  Oh, that's --

13             MR. TRALDI: [Overlapping speakers] --

14             MR. LUKIC:  And we don't object.

15             JUDGE ORIE:  Okay.  You don't object, we asked for it, then it's

16     clear.

17             Then there was one translation issue left over of yesterday.  It

18     had got something to do with the forceful or -- you remember that.

19             MR. LUKIC:  Yes, I do.

20             JUDGE ORIE:  Is there any further report on that?

21             MR. TRALDI:  I can inform the Chamber that we've contacted CLSS.

22     A new translation has been uploaded under the doc ID Y015-0027-1-ET.  We

23     received it this morning and at whatever leisure the Defence is able to

24     review it.

25             JUDGE ORIE:  Mr. Lukic, no objection against --

Page 22247

 1             MR. LUKIC:  Not yet, unfortunately, no.

 2             MR. TRALDI:  We just received it during the session.

 3             JUDGE ORIE:  The one line -- the one line is -- are you able to

 4     read that one line which caused the whole thing so that the Chamber ...

 5             MR. TRALDI:  The translation I have -- well, perhaps we could

 6     call it up by doc ID.  Has it been released?

 7                           [Trial Chamber confers]

 8             MR. TRALDI:  And for the record, this is P6572 that's at issue.

 9     That's the document that should not be broadcast.

10             JUDGE ORIE:  Okay.  Perhaps we first take the break and then --

11     but there's one thing, Madam Registrar, 65 ter number 30715 has not been

12     assigned a number yet.

13             THE REGISTRAR:  Document 30715 receives number P6575, under seal,

14     Your Honours.

15             JUDGE ORIE:  And is admitted into evidence under seal.

16             Then we take a break and we will resume at 11.00.  And during the

17     break, the necessary measures will be taken -- the protective measures

18     will be installed.

19             We resume at 11.00.

20                           --- Recess taken at 10.40 a.m.

21                           --- On resuming at 11.05 a.m.

22             JUDGE ORIE:  For the next witness to be escorted into the

23     courtroom, we need to go into closed session for a short while.

24                           [Closed session]

25   (redacted)

Page 22248

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20                           [Open session]

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

22             JUDGE ORIE:  Thank you, Madam Registrar.

23             Witness GRM311, because that's how we will call you, before you

24     give evidence, the Rules require that you make a solemn declaration.  May

25     I invite you to make that solemn declaration, the text of which is now

Page 22249

 1     handed out to you.

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

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

 4                           WITNESS:  GRM311

 5                           [Witness answered through interpreter]

 6             JUDGE ORIE:  Thank you, Witness.  Please be seated.

 7             Witness, you will testify and we'll not use your own name, you'll

 8     testify under pseudonym, your pseudonym being Witness GRM311.  No one

 9     will see your face outside this courtroom.  No one will hear your own

10     voice.

11             Please keep in mind that if any question touches upon a matter

12     which might reveal your identity, that you then ask for private session,

13     and the parties are also -- are also reminded that they should take care

14     to ask for private session whenever that would be needed in order to make

15     the protective measures effective.

16             Witness, you'll first be examined by Mr. Lukic -- no, by

17     Mr. Ivetic, although Mr. Lukic --

18             MR. LUKIC:  I have a few words before that.

19             JUDGE ORIE:  Yes.

20             MR. LUKIC:  If I may.

21             JUDGE ORIE:  Yes, please.

22             MR. LUKIC:  Before the break, Mr. Traldi offered one document,

23     actually corrected translation, under number ID Y015-0027-1-ET.  We

24     checked the translation during the break and we do not object to this

25     translation.

Page 22250

 1             JUDGE ORIE:  Yes.

 2             MR. LUKIC:  That's all I have --

 3             MR. TRALDI:  We'd request to replace it -- request leave to

 4     replace it.

 5             JUDGE ORIE:  Yes.

 6             Madam Registrar, leave is granted to replace the original English

 7     translation by the newly uploaded one.  And that was in relation to --

 8             MR. TRALDI:  P6572, Mr. President.

 9             JUDGE ORIE:  P6572.  Thank you.

10             MR. LUKIC:  And I would just --

11             JUDGE ORIE:  Yes --

12             MR. LUKIC:  -- ask for myself and Mr. Traldi to be excused, both

13     of us.

14             JUDGE ORIE:  Yes, yes, that's very kind of you, Mr. Lukic.

15             MR. TRALDI:  Thank you, sir.

16             JUDGE ORIE:  Yes, and, Witness, you'll first be examined by

17     Mr. Ivetic.  You'll find him to your left.  Mr. Ivetic is a member of the

18     Defence team of Mr. Mladic.

19             Please proceed, Mr. Ivetic.

20             MR. IVETIC:  Thank you, Your Honour.

21                           Examination by Mr. Ivetic:

22        Q.   Good day, sir.

23        A.   Good day.

24             MR. IVETIC:  I would like to call up 65 ter number 1D02794, but

25     please do not broadcast the same.

Page 22251

 1        Q.   Sir, I would draw your attention to this document, which is a

 2     pseudonym sheet, and I would ask that you confirm if your name and

 3     birth-date are set forth correctly on this document?

 4        A.   Yes.

 5             MR. IVETIC:  Your Honours, I would move to admit 1D02794 into

 6     evidence under seal.

 7             JUDGE ORIE:  Madam Registrar.

 8             THE REGISTRAR:  Document 1D2794 receives number D508,

 9     Your Honours.

10             JUDGE ORIE:  And is admitted into evidence under seal.

11             MR. IVETIC:  Thank you.

12             The next document I would like to call up also should not be

13     broadcast, it is 1D01619 in e-court.  And I have a hard copy, with the

14     assistance of the usher, for the witness after the Prosecution checks to

15     see that it's a clean copy.

16        Q.   Sir, on the screen we have a witness statement.  Can you please

17     confirm for us if that is your signature that appears on the bottom of

18     the first page in the original?

19        A.   Yes.

20        Q.   Have you had the opportunity to review the statement in the

21     Serbian language during proofing subsequent to having signed the same?

22        A.   Yes.

23             MR. IVETIC:  If we can turn to page 4 in the English, page 4 in

24     the Serbian, again not broadcasting the same, and focus on paragraph 13.

25        Q.   Sir, here in paragraph 13 where it says:

Page 22252

 1             "The mortars were in front of the Army Hospital in Sarajevo."

 2             Do you wish to correct that entry?

 3        A.   The launchers were within the perimeter of the military hospital,

 4     not outside it.

 5        Q.   Apart from this one change, do you stand by your statement and

 6     affirm that everything therein is accurate to the best of your knowledge?

 7        A.   Yes.

 8        Q.   And if I were to ask you the same questions today about the

 9     topics covered in the statement, would your answers be the same in

10     substance?

11        A.   I would answer the same.

12        Q.   And now that you have taken the solemn declaration, would those

13     answers as contained in this statement be truthful?

14        A.   Yes.

15             MR. IVETIC:  Your Honours, at this time I would move for the

16     witness statement to be admitted into evidence under seal.

17             MS. MacGREGOR:  Good morning, Your Honours.  The Prosecution does

18     not object to the admission of this witness's statement; however, we

19     maintain the position that we put in the response to the Defence

20     92 ter motion for this witness, that the majority of the evidence is

21     tu quoque.

22             JUDGE ORIE:  Yes, no objections.

23             Madam Registrar.

24             THE REGISTRAR:  Document 1D1619 receives number D509,

25     Your Honours.

Page 22253

 1             JUDGE ORIE:  And is admitted into evidence under seal.

 2             MR. IVETIC:  Thank you, Your Honours.

 3             At this time I would read the public summary of the statement,

 4     the purpose of which has been explained to the witness.

 5             JUDGE ORIE:  Please do so.

 6             MR. IVETIC:  The witness is an ethnic Serb who spent the war in

 7     Sarajevo on the territory controlled by the ABiH.  The witness was

 8     ordered to produce hand-grenades for the ABiH at a civilian factory.  The

 9     witness worked 12 hours straight at this job daily.  The witness knows

10     that Bosnian Muslim youths were going around with a list of persons to

11     throw grenades at and that the Bosnian Muslims killed their own to

12     increase the number of casualties.

13             At home the witness's utilities were cut off and a neighbour told

14     him it was because he was a Serb.  Due to that, the witness had to

15     collect firewood to take home with him.  On three occasions while

16     collecting wood, the witness found dead bodies with black bags over their

17     heads.

18             On 5 January 1993, while going home from work, the witness was

19     taken by two men wearing balaclavas who put a bag over his head and drove

20     him in a van towards Pofalici.  There they showed him a massacre of more

21     than ten bodies cut up and piled in a pit, with a decapitated child on

22     the top of the pile, its severed arms in the shape of a cross.  Next to

23     the child's body was a woman, on whose chest the head of the child had

24     been placed.  These men beat the witness and cursed his Serbian mother,

25     saying that if he did not continue making grenades for the Muslims, he

Page 22254

 1     would end up the same as the people who had been killed in the pit.

 2             The witness says the BH authorities shut down the city and kept

 3     it that way.  He had to pay money to various Bosnian Muslim and Croat

 4     officials in order to get members of his family out of Sarajevo.  The

 5     witness recalls that the Bosnian Muslim side positioned weapons at public

 6     institutions, like schools, health centres, and hospitals.  The witness

 7     saw the ABiH firing mortars from the army hospital and a machine-gun nest

 8     near the health centre by Kumrovec.

 9             The witness was forced out of Sarajevo in 1996.  A Bosnian Muslim

10     was given his apartment to keep that man quiet because he knew that his

11     wife had been killed by the ABiH side and not the Serb side.

12             And that ends the summary of the statement for this witness.  I

13     would ask to go briefly into private session for some follow-up

14     questions.

15             JUDGE ORIE:  We move into private session.

16                           [Private session]

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 22255











11  Pages 22255-22256 redacted.  Private session.















Page 22257

 1   (redacted)

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 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23                           [Open session]

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

25             JUDGE ORIE:  Thank you, Madam Registrar.

Page 22258

 1             MR. IVETIC:  If we could please turn to page 3 in both languages

 2     of D509 under seal and focus on paragraph 7 of the same.

 3        Q.   Sir, in this paragraph you describe an incident in January of

 4     1993 when you were taken away and beaten, and you mentioned 11 prior

 5     occasions.  Can you please explain for us what you meant by reference to

 6     11 prior occasions?

 7        A.   On my way to work, on the way back from work, usually on the way

 8     back, people I didn't know stopped me on 11 different occasions.  They

 9     took me to show me the crimes that they had committed in order, I

10     suppose, to kill me mentally.  Every time I was beaten and every time I

11     was threatened and told that I shouldn't meet anyone, and they would ask

12     me, as I've already said in my earlier answer, who I had met and what I

13     was doing there and what I was looking for, which was all made up.

14        Q.   Did those individuals also make reference to your work?

15             MS. MacGREGOR:  Your Honours, I object.  That's leading.

16             JUDGE ORIE:  Well, Mr. Ivetic, could you phrase the question in

17     such a way that you do not find objections.

18             MR. IVETIC:

19        Q.   Did the individuals who took you away appear to know who you

20     were?  Did they make any reference to your identity?

21        A.   Yes, they knew exactly who I was, where I was working, and what I

22     was doing.

23        Q.   Now, you mention in your statement that you needed to make

24     grenades.  What was the requirement of you and the other two coworkers

25     for the daily output for each of you for these grenades?

Page 22259

 1        A.   In a 12-hour shift I needed to make 120 grenades.  And if we

 2     stayed until 10.00 p.m., then we needed to make 150 grenades each.

 3        Q.   And in paragraph 7 of your written statement you identify that on

 4     this occasion when these men took you out, they told you that you needed

 5     to keep -- continue making bombs for the Muslims.  Is that all that they

 6     referenced in relation to your work or did these men who took you away

 7     make any additional comments about your work?

 8        A.   While they were taking me away they kept asking the same

 9     questions:  With whom I was collaborating, to whom I was reporting, and

10     to whom I had reported that one of the Muslims needed to be killed, and

11     they called me an accomplice in all these things, which wasn't true.

12        Q.   I would now like to take a look at page 4 in English and page 5

13     in Serbian at paragraph 16 of your statement, which goes on to the next

14     page in the English.  Sir, in this paragraph you state that you found at

15     the Marin Dvor school Muslims killed their own people.  Could you please

16     explain what you meant by that comment?

17        A.   Towards the end of 1992, as I was leaving the workshop where I

18     was working, I ran into three boys who carried in their school bags

19     hand-grenades made by me.  They were standing by a man who was also

20     working in the factory who knew them, and he pointed to me and said:

21     Here is the man who knows all about these things.  So they were

22     introduced to me.  The boys were 15 or 16 years of age, and they said

23     that in the secondary mechanical engineering school at Marin Dvor they

24     had undergone training in what I would call sabotage.  They had shells in

25     their school bags, each could hold 12 grenades so that they wouldn't move

Page 22260

 1     around.  (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9             JUDGE ORIE:  We briefly move into private session.

10                           [Private session]

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

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25   (redacted)

Page 22261











11  Pages 22261-22262 redacted.  Private session.















Page 22263

 1   (redacted)

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 3   (redacted)

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 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14                           [Open session]

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

16             JUDGE ORIE:  Thank you, Madam Registrar.

17             MR. IVETIC:  Thank you.

18             If I can please ask to have called up Exhibit P0003, page 20 in

19     e-court.  And again, if we can have the assistance of the usher to assist

20     the witness.

21        Q.   Sir, I would like to have you mark with an X any buildings that

22     are visible in this photograph where ABiH soldiers were situated.

23   (redacted)

24   (redacted)

25        Q.   Are there any other buildings where there were ABiH soldiers

Page 22264

 1     situated that are visible in this photograph?

 2             JUDGE ORIE:  Ms. MacGregor --

 3             MS. MacGREGOR:  I'm sorry --

 4             THE WITNESS: [Interpretation] Yes.

 5             MS. MacGREGOR:  I'm sorry to interrupt, Your Honours.  I'm

 6     concerned that the references that the witness is making with the exhibit

 7     are potentially identifying and that we possibly should be in private

 8     session.

 9             MR. IVETIC:  We can go into private session.

10             JUDGE ORIE:  We move into private session.

11                           [Private session]

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

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25   (redacted)

Page 22265











11  Pages 22265-22269 redacted.  Private session.















Page 22270

 1   (redacted)

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 3   (redacted)

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 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

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15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20                           [Open session]

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

22             JUDGE ORIE:  Thank you, Madam Registrar.

23             MR. IVETIC:

24        Q.   Sir, did you have occasion to know of any situation where the

25     ABiH used heavy weapons to fire upon their own territory; and if so,

Page 22271

 1     could you tell us the circumstances of that?

 2        A.   Yes, on the way to the factory, not far away from TV Sarajevo,

 3     where the Miljacka River flows, and then the TV building is separated

 4     from the parking-lot for trams.  They call that Remiza.  Every day two

 5     weapons were firing from there.  Mostly these shells would detonate in

 6     Svrakino Selo and Hrasno Brdo.  The following day after that, all the

 7     Sarajevo media reported that criminals from the hills destroyed

 8     Svrakino Selo and they mentioned the number of casualties, victims, and

 9     also from Hrasno Brdo.

10        Q.   For the record, could you identify for us when the Sarajevo media

11     talked about criminals from the hills, who were they understood by you to

12     be referencing?

13        A.   They were talking about the Serb forces that were defending their

14     territory.

15        Q.   Thank you.  And the territory that you identified, Svrakino Selo

16     and Hrasno Brdo, under whose -- whose territory were those positions

17     located within?

18        A.   Those territories were under the control of the Army of

19     Bosnia-Herzegovina.

20        Q.   Thank you, sir.

21             MR. IVETIC:  Your Honours, I have no further questions in direct

22     for this witness and I thank you for the additional extension of the

23     time.

24             JUDGE ORIE:  Yes.

25             I'd like to inform the parties that there was a specific request

Page 22272

 1     which will be relayed to you from the Victims and Witness Section.  Could

 2     you please consider that.  It's about timing, it's nothing very special.

 3             First the witness should be escorted out of the courtroom, and

 4     for that reason we will turn into closed session.  We will remain in

 5     closed session when we take a break.  And when resuming at 25 minutes

 6     past 12.00, we'll start in closed session and immediately after that turn

 7     into open session again.

 8                           [Closed session]

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

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25   (redacted)

Page 22273

 1   (redacted)

 2                           [Open session]

 3             THE REGISTRAR:  We're in open session.

 4             JUDGE ORIE:  Thank you, Madam Registrar.

 5             Ms. MacGregor, if you are ready to cross-examine the witness.

 6             Witness GRM311, you'll now be cross-examined by Ms. MacGregor.

 7     Ms. MacGregor, you'll find her to your right and she's counsel for the

 8     Prosecution.

 9             Please proceed.

10             MS. MacGREGOR:  Thank you, Mr. President.

11                           Cross-examination by Ms. MacGregor:

12        Q.   Good afternoon, Mr. Witness.  I'm going --

13        A.   Good afternoon.

14        Q.   I'm going to try to finish my exam today so that you can go home

15     as soon as possible, and I will do that by asking specific questions.

16     You can help me do that by listening closely to what I ask and only

17     answering those questions that I ask.

18             My first question is:  Is it correct that you were a witness for

19     the Defence before this Tribunal in the trial of Dragomir Milosevic?

20             JUDGE FLUEGGE:  Ms. MacGregor, you should switch off your

21     microphone when the witness is answering.

22             THE WITNESS: [Interpretation] Yes.

23             MS. MacGREGOR:

24        Q.   That was in July 2007?

25        A.   That's right.

Page 22274

 1             MS. MacGREGOR:  If we can please go into private session,

 2     Your Honours.

 3             JUDGE ORIE:  We move into private session.

 4                           [Private session]

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

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15   (redacted)

16   (redacted)

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25   (redacted)

Page 22275











11  Pages 22275-22280 redacted.  Private session.















Page 22281

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4                           [Open session]

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

 6             JUDGE ORIE:  Thank you, Madam Registrar.

 7             MS. MacGREGOR:  Thank you, Mr. President.

 8        Q.   Starting in May 1992 and up until June of 1994, you worked nearly

 9     every day at the factory?

10        A.   Not nearly every day, every day.

11        Q.   And during that period you would be gone from your flat from

12     approximately 5.00 a.m. until 8.00 or 9.00 p.m.; is that correct?

13        A.   After my injury, it was from 10.00 in the evening until 4.00 in

14     the morning, in the apartment.

15        Q.   I may have misunderstood.  I'm talking about in the period from

16     May 1992 to June 1994 when you were working, what hours were you in your

17     apartment?

18        A.   At that time I was in the apartment from 8.00 in the evening

19     until 5.00 in the morning.

20        Q.   Thank you.  You've discussed two other employees at the factory

21     besides yourself.  Were there other employees manufacturing other items

22     in the factory at that same time?

23        A.   The man who prepared bodies of the shells for processing on the

24     machine, he was there but none of the other manufacturers.  Maybe I

25     should explain this to you a bit -- I do apologise.  As for working on a

Page 22282

 1     machine, it was necessary to cut pipes and prepare the top and the

 2     bottom, to weld that together, and then come to the machine to process it

 3     further.  This man who was involved in the manufacturing, in addition to

 4     the three of us, he was a welder and that is what he had done before

 5     coming to work with us.

 6        Q.   Thank you very much.  The pipes you describe, is it like the pole

 7     that a street sign would sit on?

 8        A.   I don't know where they came from.  It was phi 50, that is to

 9     say, the external diameter was 50 and 75 metres was the length.

10        Q.   And your job was to cut these long pipes into small sections of

11     pipe?

12        A.   Somebody else cut those pipes, probably the person who welded the

13     top and the bottom.  You see, I would just process the part that was

14     given to me on the basis of a drawing and I dealt with that on the

15     machine.  Somebody else had prepared it for this processing beforehand.

16     If you allow me, I could explain this to you so that you could

17     understand.

18        Q.   Mr. Witness, unfortunately we don't --

19        A.   For example, I cut this thing here and --

20        Q.   I think we have enough on the record to understand, and I'm

21     trying to help you get home, but I do understand it's interesting.

22        A.   Thank you.

23        Q.   It's correct that the cylinders after they were complete, they

24     were not filled with a fuse or a charge at your factory; that happened

25     elsewhere?

Page 22283

 1        A.   Yes, that happened at the mechanical technical school at

 2     Marin Dvor.  That was about 300 metres away from the factory as the crow

 3     flies.

 4        Q.   Would you describe the job you did as physically demanding?

 5        A.   Yes.

 6        Q.   Between 1992, at least until June 1994, you received a salary

 7     from the factory; is that correct?

 8        A.   Yes, I received some compensation, something.

 9        Q.   And the factory also provided you with your residential flat; is

10     that correct?

11        A.   Yes.  I got that flat about ten years before the war -- no, no,

12     I'm sorry.  It was three years before the war.

13        Q.   Now, as the only Bosnian Serb working with only Muslims, did you

14     have any problems at work with your colleagues?

15        A.   No, I did not at work, no.

16        Q.   You were not threatened while at work; is that correct?

17        A.   No.

18        Q.   And you never threatened to quit your job; is that correct?

19        A.   No, never.

20        Q.   I want to talk now about the experience you had that you describe

21     in your statement at the pit in paragraphs 5 and 7.

22             MS. MacGREGOR:  And, Your Honours, that's Exhibit D509, I

23     believe, that's the witness statement.

24        Q.   Now, according to your statement -- first of all, are you

25     familiar with which event I'm talking about involving the pit where you

Page 22284

 1     saw the bodies?

 2        A.   Yes.

 3        Q.   According to your statement, this happened in January of 1993; is

 4     that correct?

 5        A.   Yes.  More specifically, on the 5th of January, 1993.

 6             MS. MacGREGOR:  Can we please have 65 ter 30763, page 20.

 7        Q.   As we wait for this to come up on the screen, Mr. Witness, it's

 8     again testimony that you made during your Milosevic case.  So again, I'll

 9     have to read it to you, as it's not in B/C/S.

10             MS. MacGREGOR:  If you can focus, please, on the bottom half of

11     the statement.

12        Q.   Okay.  I'm reading from line number 15.  This is your testimony:

13             "I was taken away during my work there on 11 occasions.  The most

14     drastic example occurred in early November of 1992 ..."

15             And you continue to describe the episode at the pit.  Is this the

16     same episode that you've now today said occurred in January of 1993?

17        A.   [No interpretation]

18             JUDGE ORIE:  We do not receive interpretation at this moment.

19             THE WITNESS: [Interpretation] As for this date that was mentioned

20     here, it was -- it's not correct.  Somebody must have made a mistake.

21     The correct date is 5 January 1993.

22             MS. MacGREGOR:  If I can please have e-court page 51 of the same

23     document, again towards the bottom of the page.

24        Q.   Mr. Witness, later in the same testimony, the Prosecutor again

25     asked you about the date when you saw various atrocities.  I'm going to

Page 22285

 1     read to you your response to that question.  This is at line 18 of the

 2     screen in front of us.

 3             "... I recall that on that earlier incident when they took me to

 4     see that pit, that was on the 27th of October, 1992.  I wanted to write

 5     about that, but then they searched my flat and they found some pieces of

 6     paper where they said I had noted down some of the dates, and after this

 7     happened I no longer wrote about this."

 8             Mr. Witness, did you write some notes, including the date, about

 9     the incident you saw at the pit?

10        A.   Are you referring to these dates, 5 January 1992, or rather, and

11     1992?  Is that the date you're referring to or those dates?

12        Q.   My question is:  Did you write down notes about the incident you

13     saw at the pit?  That's my first question.

14        A.   I noted some dates even before this, before 5 January.  On the

15     5th of January I remember well when I was thrown out, when they threw me

16     out of the car into a ditch and it was dark.  It was a concrete ditch and

17     I know that one of these men said:  Oh, he's going to have a good

18     Christmas.  And there is no doubt about it that there was a mistake made

19     there, that this wasn't 5 January 1993.

20             MS. MacGREGOR:  If I can please turn to page 53 of the document

21     that we have up.  This is again from the same testimony on this page.

22        Q.   At line 12, the Prosecutor asks:

23             "And the incident with the pit was in October 1992; is that

24     right?"

25             And your answer is:

Page 22286

 1             "1992."

 2        A.   No, no, that's not how it was.  And I affirmed this precisely

 3     because of what I've just said, how this man mentioned that on the

 4     following day or two days later, it was Christmas and that I would celebrate

 5     it well following this.  So somebody else made that mistake, not me.

 6        Q.   Mr. Witness, when you testified in the Milosevic case you did not

 7     say that the pit incident happened on Serb Christmas Eve, did you?

 8        A.   No, I did not say that.  I did not because I was sure that I said

 9     it was on the 5th of January and that it would be without this

10     compensation that this man mentioned, that that's how it would be.

11        Q.   I'm going to move on to a slightly different topic.  The

12     Prosecution received from the Defence a report of information that you've

13     given in the past few days since you've been in The Hague.  In that

14     report the information provided says that you stated that every time you

15     were abducted, you were taken into a van which was a red van.  Do you

16     remember telling the Defence that in the past couple days?

17        A.   Yeah, but no, it wasn't a red van, it was black.  The van was

18     black, not red.

19             MS. MacGREGOR:  Your Honours, I have not asked Ms. Stewart to

20     upload the information report into e-court because I don't intend to ask

21     that it be put into evidence, but if possible, I'll raise that at a later

22     time.

23             JUDGE ORIE:  Yes, now first of all, does it contain reference to

24     a red van?  Is that --

25             MR. IVETIC:  It does, Your Honour, the B/C/S words are close for

Page 22287

 1     both.  I may have -- I prepared the information report --

 2             JUDGE ORIE:  Well, I'm just -- I'm just trying to seek whether

 3     the parties agree on that --

 4             MR. IVETIC:  I agree it does say "red" in the information report

 5     drafted by me.

 6             JUDGE ORIE:  -- those words are written in there.

 7             Please proceed, Ms. MacGregor.

 8             MS. MacGREGOR:  Thank you, Mr. President.

 9        Q.   Now, you've testified that as a result of this incident at the

10     pit, your arm and your leg were broken and you could barely stand or

11     walk; is that correct?

12        A.   That's correct.

13        Q.   And after your arm and your leg were broken, you remained

14     employed at the factory until June -- employed and working daily at the

15     factory until June 1994; is that correct?

16        A.   That's correct.

17        Q.   You worked the same hours that you worked before the incident at

18     the pit; is that correct?

19        A.   That's correct.

20        Q.   During that period, you continued to walk to and from work daily

21     along the same route; is that correct?

22        A.   That's correct.

23        Q.   And you had the same tasks at the factory that we've just

24     discussed; is that correct?

25        A.   Yes.

Page 22288

 1        Q.   Now, in June 1994, approximately 18 months later, you approached

 2     a Croatian doctor about your injuries; is that correct?

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

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25   (redacted)

Page 22289

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5                           [Private session]

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

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Page 22290











11  Page 22290 redacted.  Private session.















Page 22291

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4                           [Open session]

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

 6             JUDGE ORIE:  Thank you, Madam Registrar.

 7             MS. MacGREGOR:  Thank you.

 8        Q.   Mr. Witness, today at temporary transcript page 40, today you

 9     stated that you were abducted about 11 times.  And in your statement you

10     say, in paragraph 7, when you're describing the incident at the pit, that

11     you had been taken away before some 11 times while returning home from

12     work.  I understand this to mean that before the pit incident you were

13     taken 11 other times; am I understanding that correctly?

14        A.   Throughout the period of my work there, I was taken away

15     11 times, before and after the pit, 11 times.

16        Q.   And the last time that it happened, do you recall what the date

17     was the last time it happened?

18        A.   No.  I apologise, I remember that it was on the 27th of April,

19     1993, and on that occasion I saw a man, I saw what he looked like.  This

20     wasn't the case before because they had masks on.  Early in the morning I

21     was on my way to work, my leg was broken, and a black -- when a black

22     car, some kind of limousine, stopped between the Novi Grad municipality

23     and Sarajevo TV.  The man offered me a ride.  I refused and then he

24     offered again.  He said:  Why don't you get inside.  I see you can barely

25     walk.  You are going to work, aren't you?  He had a shaved head and a

Page 22292

 1     long beard.  He asked me, obviously knowing where I worked, he asked me

 2     whether it was difficult work and I said:  No, it wasn't.

 3        Q.   Mr. Witness, sorry --

 4        A.   At the place where I was supposed to get off at the social

 5     security administration --

 6        Q.   I'm sorry to interrupt, Mr. Witness, I'm trying to keep us on

 7     pace.  My question is merely to ask you -- and I'll just clarify.  So

 8     April 27th, 1993, is the last time you remember an incident where you

 9     were taken away; is that correct?

10        A.   I think there weren't any other abductions.  If there were any

11     other encounters, it would have only been they would pull me into one of

12     the entrances and ask me:  Where were you?  What were you doing?  And so

13     on.  But this was just harassment.

14             MS. MacGREGOR:  If I can please have 65 ter 30763, e-court

15     page 21.

16        Q.   Again, I'm bringing up some of your testimony from the Milosevic

17     case.  If we can look -- I'm looking at a section where the Prosecutor in

18     that case asked you a similar question, asked you when was the last time

19     that you were abducted.

20             If we can focus on around line 12, I'll read it to you, sir,

21     since you don't have it in B/C/S.  Your answer was:

22             "The last time it happened it was in August of 1994, when, again,

23     I was placed in a black van where there were four persons who had been

24     tied up.  I was taken somewhere in the territory of Pofalici, and before

25     my very eyes all of the four people were shot to death.  They threatened

Page 22293

 1     me that the same thing would happen to me the following day unless I went

 2     to work."

 3             Now, this incident is not included in the statement that you've

 4     made for this case; is that correct?

 5        A.   I didn't say many things, not even on this occasion.  I didn't

 6     say everything to Mr. Ivetic.  I didn't say that it had already been

 7     ready, everything had already been prepared six months in advance, there

 8     were some 6.000 hand-grenades that were supposed to be retrofitted.  So

 9     the factory where I was working, it had been already full of

10     hand-grenades that were just to be processed and finished.  I can't -- so

11     this is the first time I'm saying it.  I can't remember everything after

12     all the mistreatment and everything.

13        Q.   Thank you.  The incident that I've just read about to you, that

14     occurred after you were no longer working at the factory; is that

15     correct?

16        A.   Yes, yes.  Yes, on my way to the doctor's.

17        Q.   So presumably you did not go to work the following day as you

18     were threatened to do?

19        A.   No, I did not go to work.  From the first day when I was put on

20     sick leave, I never worked after that.  I only went to the factory when I

21     needed to get a referral for a specialist examination.

22        Q.   Let's move actually now to that time while you were on sick

23     leave.  Your treatment that you received was from the Kosevo hospital; is

24     that correct?

25        A.   Yes.

Page 22294

 1        Q.   From June 1994 until the middle of 1996, you received treatment

 2     at the Kosevo hospital every seven days; is that right?

 3        A.   No.  I went there monthly, every month, because every time when I

 4     saw the doctor she would extend my sick leave for another month.

 5             MS. MacGREGOR:  If we can have e-court page 64, please, of the

 6     document that's currently on the screen.

 7             JUDGE ORIE:  While waiting for that, I would have one additional

 8     question for you, Witness.  You said about an incident some kind of a

 9     limousine that stopped.  Through the interpretation you may not be aware

10     that I'm putting a question to you at this moment, but I think you

11     earlier said it was always vans.  Was that only one time that it was a

12     limousine or did it happen more often?

13             THE WITNESS: [Interpretation] I've already said that it was

14     always a black van, and on this occasion it was a black limousine.  The

15     man wouldn't stop where I was supposed to get off, but took me to the

16     Bristol Hotel, to the entrance to the Orthodox Church and he told me:

17     Look what they're doing to us.  He said he was also a Serb.  There were

18     three human heads hanging on the front door handle, severed heads.  And

19     then he said:  You can pass here quickly to the factory.  As I crossed to

20     the factory, I ran into an even greater horror, pack of stray dogs, some

21     15 of them, tearing into each other.  When I wanted to pass by, I saw

22     that three of them had human heads hanging around their necks, and they

23     were fighting each other to eat into them.

24             That was on the 27 April ’93.  I arrived earlier because this man

25     had given me a lift, and the armed men at the factory gate would not let

Page 22295

 1     me in.  They made me go farther away, I don't know what they were doing

 2     there.  I returned again at five to 7 and entered the factory.

 3             JUDGE ORIE:  And where exactly were those bodies?  Were they in

 4     the church or ...?

 5             THE WITNESS: [Interpretation] They were at the door of the

 6     church, on the handle of the entrance door, three severed heads were

 7     hung on the door.  It is the Church of Holy Transfiguration in Novo

 8     Sarajevo.

 9             JUDGE ORIE:  And the dogs would then bite in those heads; is that

10     how I have to understand your testimony?

11             THE WITNESS: [Interpretation] Yes.

12             JUDGE ORIE:  And when you said a minute ago:  "They were biting

13     them and biting off parts of their bodies," what did you then have on

14     your mind if they were biting into the heads?

15             THE WITNESS: [Interpretation] No, no, no.  They were

16     biting each other, fighting over who would get to the human head

17     first because obviously those dogs were hungry.  They were

18     attacking those dogs who had human heads tied around their

19     necks.

20             THE INTERPRETER:  The interpreter is not sure that the witness is

21     clearly understood.

22             JUDGE ORIE:  Could I ask you -- then again, biting off parts of

23     their bodies, as you said before, was that one dog biting off parts of

24     the body of another dog or -- it's not entirely clear to me.  Could you

25     further explain?

Page 22296

 1             THE WITNESS: [Interpretation] Other dogs attacked those dogs

 2     that had the human heads hung from their necks.  Other dogs attacked them.

 3             JUDGE ORIE:  And did they bite off parts of the bodies of those

 4     other dogs?

 5             THE WITNESS: [Interpretation] I didn't see that.  It's very hard

 6     to see that.  I was trying to pass by as quickly as possible so they

 7     wouldn't tear into me.

 8             JUDGE ORIE:  And you said the human heads hung from their necks,

 9     from the necks of the dogs?

10             THE WITNESS: [Interpretation] Yes, yes, that's right.

11             JUDGE ORIE:  Yes, I interrupted when you -- I think the last

12     question that was put to you was about the frequency of treatment in

13     Kosevo hospital.  I think you said it was monthly, and Ms. MacGregor was

14     now wants to put part of previous testimony to you.  That's where we

15     were, Ms. MacGregor.

16             MS. MacGREGOR:  Yes, thank you.

17             JUDGE ORIE:  Please --

18             JUDGE MOLOTO:  If I might just interrupt, Ms. MacGregor.

19             This incident with the dogs, did it happen before or after the

20     incident at the pit?

21             THE WITNESS: [Interpretation] After.

22             JUDGE MOLOTO:  After.  And you say on this day you ran into a

23     pack of dogs?

24             THE WITNESS: [Interpretation] Yes, correct.

25             JUDGE MOLOTO:  You were able to run notwithstanding the broken

Page 22297

 1     leg that you sustained at the pit incident?

 2             THE WITNESS: [Interpretation] This sounds a bit funny to me as a

 3     conclusion, but... forgive me.

 4             JUDGE MOLOTO:  I'm asking you --

 5             THE WITNESS: [Interpretation] To run into and to come across are

 6     the same thing.  I only moved with speed when I was thrown into that pit

 7     among the corpses.  The rest of the way I walked as slowly as I could.

 8             JUDGE ORIE:  Now, please carefully listen to the next question of

 9     Ms. MacGregor.  She -- the last thing she asked about your treatment at

10     Kosevo hospital was whether -- what the frequency was and I think you

11     said it was monthly because your sick leave would be extended every

12     month.  And that's where Ms. MacGregor now resumes.

13             Ms. MacGregor.

14             MS. MacGREGOR:  Thank you, Mr. President.  The e-court page that

15     I need on the screen is actually e-court page 18.  Ms. Stewart corrected

16     me.  Thank you.

17        Q.   Mr. Witness, I'm turning to a portion of your testimony from

18     Milosevic trial that was about your treatment at Kosevo hospital.

19             MS. MacGREGOR:  And if we can please scroll down a bit towards

20     line 21.

21        Q.   I'll read to you from the transcript starting actually at

22     line 20.

23             "When I went on sick-leave in mid-1994, every seven days I would

24     go to my doctors for a checkup.  On my way there, I had to pass by the

25     military hospital ..."

Page 22298

 1             Mr. Witness, is it your testimony today that you went to the

 2     Kosevo hospital every seven days or that you went once a month?

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10             MS. MacGREGOR:  Yeah.  And I will just ask one more question and

11     then I know that it's time for a break.

12             JUDGE ORIE:  Yes.

13             MS. MacGREGOR:  Just a clarification.

14        Q.   Just to be clear, you walked from your flat to the

15     Kosevo hospital approximately -- approximately every seven days between

16     June 1994 and mid-1996; is that correct?

17        A.   Yes.

18             JUDGE ORIE:  Could you give us an indication as to how much time

19     you would still need after the break?

20             MS. MacGREGOR:  35 minutes, 30 minutes, I'm doing my best.

21             JUDGE ORIE:  Yes, I'm also looking at you, Mr. Ivetic, because

22     30 minutes and then ...

23             MR. IVETIC:  Right now --

24             JUDGE ORIE:  After we resume that would -- how much time would

25     you need?

Page 22299

 1             MR. IVETIC:  Right now I have only one or two questions.

 2             JUDGE ORIE:  Only one or two questions.  That might, then, be

 3     resolved with an extended session of 10 to 15 minutes.  I asked

 4     Madam Registrar to inquire whether that would be possible.

 5             We turn into closed session for the witness to leave the

 6     courtroom and we'll resume in closed session at ten minutes to 2.00.

 7                           [Closed session]

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21                           [Open session]

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

23             JUDGE ORIE:  Thank you, Madam Registrar.

24             Ms. MacGregor, you may proceed.

25             MS. MacGREGOR:  Thank you very much, Mr. President.

Page 22300

 1        Q.   We were talking before the break about the walk you made from

 2     your flat to the Kosevo hospital.  Is the distance between those

 3     two places approximately 7 to 8 kilometres?

 4        A.   Yes, even more.

 5        Q.   And that walk took you about two hours; is that correct?

 6        A.   Yes.

 7        Q.   And in part because of your injuries you walked slower than you

 8     normally would; is that correct?

 9        A.   Yes.

10             MS. MacGREGOR:  Can we please have Exhibit 65 ter 30766, not to

11     be broadcast, as it shows the location of the witness's residence.  And,

12     Your Honours, I have printed large copies of the map, if the usher can

13     assist me to bring those up for you, it may help you as we look through

14     this exhibit.

15        Q.   Mr. Witness, on the screen in front of you is a map of Sarajevo

16     that you marked during your testimony in the Milosevic trial.  Now, do

17     you see that, sir, on the screen in front of you?

18        A.   My eyesight is not good because the criminals who had taken me

19     away made me almost blind with the bags full of chemicals they put on my

20     head, so I don't see well.  But let's try.

21             MS. MacGREGOR:  I'll ask, perhaps it can be zoomed in slightly to

22     assist the witness.

23        Q.   Okay.  Do you see there's a red line going along --

24        A.   Yes.

25        Q.   Is that red line -- does that represent the path that you took

Page 22301

 1     from your flat to the Kosevo hospital?

 2             JUDGE ORIE:  No speaking at audible volume.

 3             MS. MacGREGOR:

 4        Q.   I believe you just answered --

 5        A.   Yes.  Here, the map does not show Kosevo hospital.  This map

 6     shows Marin Dvor up to the military hospital and the exit towards the

 7     institute of hygiene, but it doesn't show the Kosevo hospital.

 8        Q.   Is it correct that the Kosevo hospital would be off of this map

 9     to the north-east approximately?

10        A.   I don't understand this very well.  I know that Kosevo hospital

11     is not here.

12             JUDGE ORIE:  Now, is there any disagreement between the parties

13     where Kosevo hospital is in relation to this map?

14             MR. IVETIC:  No, Your Honours.

15             JUDGE ORIE:  And the Chamber is -- so we could -- if the witness

16     tells us Kosevo hospital and we know that -- at least we have seen that

17     before on maps that it is a relatively large compound or large area where

18     the various buildings of the Kosevo hospital are to be found.  We can

19     move on.

20             MS. MacGREGOR:  For your reference, Your Honours, the map in

21     Exhibit P0003, e-court page 72, hard copy page 65, shows that complex

22     marked as 71, and the military hospital which we will be discussing is

23     marked as 72.

24        Q.   Mr. Witness, I wanted to ask you a few questions about your

25     walk -- your route to the hospital that you took.  If you can give me one

Page 22302

 1     moment.  Okay.

 2             As you would be leaving your flat --

 3             JUDGE ORIE:  By the way, since we moved in, it's not visible

 4     anymore.  If we move out again, we find at least the extreme parts of

 5     Kosevo hospital still on the monitor.  There we are at the very right

 6     top.  It's -- even an H is found there.  You see it?  So now we all have

 7     it even on our screens.

 8             MS. MacGREGOR:  The view we have on the screen will be helpful

 9     right now hopefully for the witness with the next series of questions.

10             THE WITNESS: [Interpretation] Yes.  Yes, this should be the

11     Kosevo hospital marked with an H; right?

12             MS. MacGREGOR:

13        Q.   Mr. Witness, if you can not mark the map at this point.  Thank

14     you.

15             JUDGE ORIE:  I think the witness said that it was marked --

16             THE WITNESS: [Interpretation] I didn't.

17             JUDGE ORIE:  No.  And that is, an H appears where approximately

18     the Kosevo hospital apparently is.

19             Please proceed.

20             MS. MacGREGOR:  Okay.  If we can zoom out a bit, please.

21        Q.   Mr. Witness, I have some questions about the route you took and

22     you can use the map as a reference, but also you can just rely on your

23     memory.  Now, across the Bulevar Mese Selimovica, across that street from

24     Alipasino Polje, is that where the PTT building was located?

25             MS. MacGREGOR:  You may need to move the map slightly to the

Page 22303

 1     right.

 2             THE WITNESS: [Interpretation] I can't remember now exactly.  It's

 3     still there but I can't see it because I don't see it well.

 4             JUDGE ORIE:  Could we move in where -- I take it that we need the

 5     left part of the -- that road, that area.  Move in -- zoom in a bit more

 6     perhaps even.

 7             MS. MacGREGOR:

 8        Q.   Mr. Witness, from your memory, is that where the PTT building is

 9     located?

10             JUDGE ORIE:  Witness, Ms. MacGregor asked you to answer the

11     question using your memory.  Is the PTT building located next to the main

12     big road between the -- between Alipasino Polje and Marin Dvor, is it on

13     that main road?  Could you tell us?

14             THE WITNESS: [Interpretation] I can't remember.  I can't.  I'm

15     not sure and I don't want to make a mistake.

16             MS. MacGREGOR:  Your Honours, I'll move on.  And actually, why

17     don't we pull the map off the screen for the time being.  I may come back

18     to it in a moment.

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23        Q.   Please just answer the questions based on your knowledge of the

24     town.  Okay, as you would walk from your residence to the

25     Kosevo hospital, is it correct that you would pass the Marsal Tito

Page 22304

 1     barracks?

 2        A.   Yes, but from the side facing the railway station.

 3        Q.   To be clear, I'm asking about the route you drew on the map which

 4     is along the Bulevar Mese Selimovica; is that consistent with what you've

 5     just answered?

 6        A.   I can't remember where Mese Selimovica Bulevar is.

 7        Q.   My understanding is that it's the main road along which the tram

 8     lines run.  Did you walk along the road that the tram lines run along?

 9        A.   Yes, up to Dolac Malta.

10        Q.   Along that same road, you would pass the Holiday Inn; is that

11     correct?

12        A.   No.

13             MS. MacGREGOR:  I think we better bring the map back up.  If we

14     can please again have Exhibit P30766.

15             JUDGE ORIE:  Perhaps could we ask, you said you walked that road

16     where the tram lines are up to Dolac Malta.  What did you do at

17     Dolac Malta?  Did you leave that road?

18             THE WITNESS: [No interpretation]

19             JUDGE ORIE:  In which direction, to the left or to the right when

20     you were heading for Marin Dvor?

21             THE WITNESS: [Interpretation] To the left.

22             JUDGE ORIE:  Yes.  That is not indicated on the map as marked, it

23     seems.

24             MS. MacGREGOR:  Your Honours, can you give me one moment, please?

25             JUDGE ORIE:  Yes.

Page 22305

 1                           [Prosecution counsel confer]

 2             MS. MacGREGOR:

 3        Q.   Mr. Witness, we're a little confused.  If you look at the map on

 4     the screen in front of you, you drew a red line in the Milosevic trial

 5     and that red line continues along the road where the tram lines are and

 6     it continues along that road past the location that you've just

 7     mentioned, Dolac Malta.  Is the map on the screen in front of you, does

 8     that represent the route that you walked to get to the Kosevo hospital?

 9        A.   To Dolac Malta, yes.

10        Q.   And your testimony now is that at Dolac Malta you turned --

11        A.   Left, because that's where the infirmary was.

12        Q.   Can I ask you, in a pen that's blue, can you please draw starting

13     at Dolac Malta --

14             JUDGE ORIE:  Before we do so, could we first ask the witness.

15     You said:  To the left, that's where the infirmary was.  What infirmary

16     are you talking about?

17             THE WITNESS: [Interpretation] It's the infirmary of the factory

18     where I worked, because I had to get referrals to the hospital or any

19     other doctor there.

20             JUDGE ORIE:  So you first went to the infirmary and from there

21     you went to Kosevo hospital.  Is that ...?

22             THE WITNESS: [Interpretation] Yes.

23             JUDGE ORIE:  And did you need a referral every time you went to

24     Kosevo hospital?

25             THE WITNESS: [Interpretation] Yes, every time.

Page 22306

 1             JUDGE ORIE:  And if you go there with such frequency, why would

 2     it be necessary to get a referral every single time you go to

 3     Kosevo hospital?

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10             JUDGE ORIE:  Yes, and would you then continue your road to the

11     Kosevo hospital, again through Dolac Malta, on the main road where the

12     tram tracks are or did you take a different route?

13             THE WITNESS: [Interpretation] Well, I told you, I went about

14     200 metres to the left from Dolac Malta, to where my infirmary was.  And

15     then I went 500 metres more along the tram tracks, along the railway

16     station, into the city.

17             JUDGE ORIE:  Yes, Ms. MacGregor, I leave it further in your

18     hands.  There may be other trams as well going in east-westerly

19     direction, at least at some spots, I do not know.  But I don't know how

20     important the precise route is.

21             MS. MacGREGOR:  I'd like to ask a few more questions.  I'm

22     actually having trouble understanding the witness's testimony.

23        Q.   If you could please, with the blue pen, starting at Dolac Malta,

24     show the route from that location to Kosevo hospital.

25        A.   Could you enlarge this a bit because I can't see a thing.

Page 22307

 1             JUDGE ORIE:  Is this large enough for you, Witness?

 2             THE WITNESS: [Interpretation] Now I can see.

 3             Can I draw the line?

 4             MS. MacGREGOR:

 5        Q.   Is the pen working?

 6             JUDGE ORIE:  Apparently the pen is working, yes.

 7             MS. MacGREGOR:

 8        Q.   Yes, Witness, so you've marked Dolac Malta.  Can you please

 9     continue to draw the line where you walked from that point?

10        A.   Yes.  It would go like this.  I didn't do this very well, but

11     that's the line.  I would pass on this side up to Marin Dvor, the

12     military hospital is here.

13        Q.   Okay.  Thank you.  That is very helpful.  It looks like you would

14     for a -- for some distance you would -- okay.  My comments aren't

15     necessary.  I understand the drawing.  Thank you.

16             MS. MacGREGOR:  Can I ask that this be admitted as an exhibit

17     with the drawings of the witness, please.

18             JUDGE ORIE:  Madam Registrar.

19             MS. MacGREGOR:  Under seal.

20             THE REGISTRAR:  Document 30766 as marked by the witness receives

21     number P6576, Your Honours.

22             JUDGE ORIE:  And is admitted under seal.

23             Please proceed, Ms. MacGregor.

24             And we have green light for an extended session of 15 minutes.

25             MS. MacGREGOR:  I'll do my best, Your Honour.

Page 22308

 1             JUDGE ORIE:  Yes, the Chamber urges you to --

 2             MS. MacGREGOR:  Thank you.

 3             JUDGE ORIE:  And also to leave time for Mr. Ivetic for two or

 4     three questions.

 5             MS. MacGREGOR:

 6        Q.   In your statement at paragraph 13 and again today during your

 7     testimony, you discuss seeing two ABiH mortars on the grounds of the

 8     military hospital by Marin Dvor; is that correct?

 9        A.   Yes, within the compound of the military hospital at Marin Dvor

10     there were two artillery weapons.

11        Q.   In this same paragraph, which is 13 of your statement, you

12     describe:

13             "On one occasion when I was walking towards the Kosevo hospital,

14     I heard and saw the Muslims firing mortars at the Serbian positions."

15             And to be clear, you're talking about something you saw at the

16     military hospital; is that correct?

17        A.   Yes.

18        Q.   And this paragraph describes the one time that you saw mortars on

19     the military hospital ground being fired?

20        A.   It was not once, several times.

21        Q.   Was there something about this one occasion that caused you to

22     describe it specifically in this statement?

23        A.   Maybe some things were left unsaid, but I just wanted to say that

24     from that location, from health institutions, artillery was firing at

25     Serb positions.

Page 22309

 1        Q.   We have evidence in our record from a doctor who worked at the

 2     military hospital starting in May 1992 and throughout the war.

 3             MS. MacGREGOR:  Your Honours, I'm referring to

 4     Witness Bakir Nakas.

 5        Q.   Now, he testified that he stayed at the hospital practically day

 6     and night around-the-clock and that no unit fired anywhere in the

 7     vicinity of the hospital, nor did he receive any reports from security

 8     that any such firing happened.

 9             MS. MacGREGOR:  I refer to transcript reference 8677.

10        Q.   According to this witness, there was not a single

11     military-related facility in the vicinity of the hospital.

12             MS. MacGREGOR:  Your Honours, that's at that witness's statement

13     which is Exhibit P941.

14        Q.   Mr. Witness, I'm asking you, can you really say with certainty

15     that you saw two mortars on the hospital grounds at the state hospital?

16        A.   Well, somebody probably ordered that witness what he's supposed

17     to say.  Nobody ordered me anything.  I said that to the lawyers too.

18     I'm just saying what I saw.  And I'm claim that I saw that not only once

19     but several times.  Let me just add something else.  From the health

20     centre -- oh, oh, all right.

21        Q.   Mr. Witness, we're trying to -- I'm doing my best to get done

22     with your testimony today so please help me.

23             MS. MacGREGOR:  If I can please have Exhibit 30 -- excuse me,

24     transcript -- excuse me, 65 ter 30763, page 74 in e-court.

25        Q.   Mr. Witness, again I'm going to refer to an excerpt from your

Page 22310

 1     Milosevic testimony.  During that trial, the Prosecutor asked you if you

 2     were aware that in your time in Sarajevo there was a considerable

 3     presence of United Nations monitors and personnel.  And I'm going to read

 4     to you your answer.  I'm starting at line 6 of the page in front of us.

 5             "I never saw them.  I would probably seek help from them.  I had

 6     heard of them being present there."

 7             You were then asked:

 8             "... you never saw United Nations personnel?

 9             "A.  No.

10             "Did you ever see United Nations APC or a United Nations

11     vehicle ...

12             "A.  No."

13             Mr. Witness, so we are clear, from May 1992 until the middle of

14     1996, you did not see UN personnel in the city of Sarajevo?

15        A.   I was interested in getting home alive because from every

16     high-rise and from every window there were barrels, guns hanging.  From

17     Marin Dvor, I would walk by the hospital, I took this other route.  If it

18     weren't for the building of the Executive Council, who knows how many

19     civilians they killed during the war, Croats, Muslims, and Serbs.

20        Q.   My question was:  Did you ever see UN personnel in the city of

21     Sarajevo during the war?  That's a yes or no question.

22        A.   I don't know anything.  No, no.  No.

23        Q.   What about UN vehicles?

24        A.   No.

25             MS. MacGREGOR:  Can I please have Exhibit 30767 -- excuse me,

Page 22311

 1     65 ter, and page 2 in e-court.

 2        Q.   I'm going to be showing you a photograph.

 3             MS. MacGREGOR:  Page 2, please.  Oh, excuse me, that is page 2.

 4     You know what, can we please go to the first page of this exhibit.

 5        Q.   Mr. Witness, do you recognise the Assembly building as the

 6     building on the right side of this picture?

 7        A.   Maybe.  I'm not sure.

 8        Q.   Do you see the vehicle, the UN APC, in front of the building in

 9     that picture?

10        A.   Yes, I see that.  I don't know whose vehicle it is, but I see it.

11        Q.   Well, you may not be able to see, but the letters "UN" are

12     written on the vehicle near the head of the man on the bicycle.  There's

13     also a --

14        A.   I see that now.

15        Q.   There's also a blue flag, the UN flag, coming off the vehicle.

16     Do you see on the left-hand side a container?

17        A.   Yes, I see that.

18        Q.   When you walked along this street during the war, did you see

19     this kind of vehicle along the road?

20        A.   No -- well, I wasn't interested.  I've already told you, I was

21     interested in getting home alive.

22        Q.   Did you see that kind of container that's featured on the left

23     side of the picture?

24        A.   Well, to this day there are so many containers like that in

25     Sarajevo, in front of those private businesses.

Page 22312

 1             MS. MacGREGOR:  If we can look at the second page of this exhibit

 2     again, please.

 3        Q.   You'll see in this picture there's another picture of the

 4     containers.  Are you aware these containers were used to protect

 5     civilians walking along this route?

 6        A.   No.  I did not see those containers anywhere along the route that

 7     I took.

 8             JUDGE ORIE:  Witness, were you at all aware that containers were

 9     used to protect pedestrians in the town of Sarajevo?

10             THE WITNESS: [Interpretation] Maybe.  But I've told you, on my

11     way to the factory there weren't any containers anywhere.

12             JUDGE ORIE:  And on your way to Kosevo hospital?

13             THE WITNESS: [Interpretation] No, not there either.  At least I

14     didn't notice.

15             JUDGE ORIE:  Please proceed.

16             MS. MacGREGOR:

17        Q.   I'm going to read to you from your testimony again in Milosevic.

18     This is transcript reference 8858.  You were being asked about walking

19     down this route.

20             "On your trip, sir, down this road that you took to the

21     Kosevo hospital, did you ever notice barricades, containers, and other

22     contraptions that were used to protection civilians?"

23             Your answer:

24             "I was only looking at the containers and barricades."

25             Now, you've just said at line -- page 94, line 23, when asked a

Page 22313

 1     similar question:  I did not see those containers anywhere along that

 2     route.  And you said that you were not looking at anything, you were just

 3     trying to stay alive.

 4             Can you explain why in the Milosevic trial you testified that you

 5     did see such barricades?

 6        A.   I doubt I said that.

 7             MS. MacGREGOR:  Can I please have this exhibit entered into

 8     evidence?

 9             JUDGE ORIE:  Madam Registrar.

10             THE REGISTRAR:  Document 30767 receives number P6577,

11     Your Honours.

12             JUDGE ORIE:  And is admitted into evidence.

13             If the parties are interested in verifying the audio from the

14     Milosevic case, of course there's always an opportunity to do that.

15             I'm looking at the clock, Ms. MacGregor, and --

16             MS. MacGREGOR:  I realise -- I'm not finished.  The answers of

17     the witness haven't been as I expected and I expect I would need an

18     additional 10 to 15 minutes.

19             MR. IVETIC:  I'm still at two or three questions, Your Honour.

20             JUDGE ORIE:  Yes.  Let me ...

21                           [Trial Chamber confers]

22             JUDGE ORIE:  The Chamber is inclined not to push any further and

23     to -- and to continue tomorrow.  But before doing so, I would like to

24     move briefly into private session.

25                           [Private session]

Page 22314

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19                           [Open session]

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

21             JUDGE ORIE:  Yes, the Chamber has considered the reasons why you

22     would prefer to go home today.  The Chamber has decided that we'll

23     unfortunately have to go on tomorrow.  It will not take much time

24     tomorrow morning, most likely only half a session or even less, that

25     means that most likely we'll conclude before 10.30.  But we need your

Page 22315

 1     presence still tomorrow.  And before you'll be escorted out of the

 2     courtroom, I'd like to instruct you that you should not speak with anyone

 3     about your testimony, whether it is testimony you have given today or the

 4     testimony that is still there to be given tomorrow.  And we'd like to see

 5     you back tomorrow morning at 9.30.

 6             I announce already to the public that once we are back in

 7     closed session, that we'll adjourn for the day and that we'll resume

 8     tomorrow, Friday, the 6th of June, at 9.30 in the morning, in this same

 9     courtroom, I.

10             Yes, Ms. MacGregor.

11             MS. MacGREGOR:  If I may raise one administrative matter.  If I

12     could have 65 ter 30766, which is the map before he marked in it zoomed

13     out, if I could also ask that that be admitted as an exhibit because the

14     map that we currently have in evidence doesn't show the entire map.

15             JUDGE ORIE:  Is that the blue marking?  I know that once we are

16     zooming in and out that there are limitations of what can still be stored

17     and not.  Could you perhaps -- once we have adjourned check whether

18     there's any technical problem.  If not, a decision will be taken

19     tomorrow.

20             JUDGE FLUEGGE:  Just to be clear, is that the map where the

21     red line was drawn in the previous case?

22             MS. MacGREGOR:  Yes.

23             JUDGE FLUEGGE:  That should be at least under seal, as you

24     indicated earlier?

25             MS. MacGREGOR:  You're correct, Your Honour.  Thank you.

Page 22316

 1             JUDGE ORIE:  Yes.  You mean just the map as marked by the witness

 2     in the other case, without the blue markings?  Or with the blue markings?

 3             MS. MacGREGOR:  I actually would like there to be two exhibits.

 4             JUDGE ORIE:  Okay.

 5             MS. MacGREGOR:  Because I think -- I'll talk with your staff.

 6             JUDGE ORIE:  Okay, then -- well, Madam Registrar is always of

 7     great assistance to us but is not our staff.  Perhaps she would not even

 8     like to be our staff.

 9             We turn into closed session in order to adjourn for the day and

10     for the witness to be allowed to leave the courtroom.

11                           [Closed session]

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17                           --- Whereupon the hearing adjourned at 2.32 p.m.,

18                           to be reconvened on Friday, the 6th day of

19                           June, 2014, at 9.30 a.m.