Page 11074
1 Wednesday, 15th April 1998
2 (10.08 a.m.)
3 JUDGE KARIBI-WHYTE: Good morning, ladies
4 and gentlemen. May we have the appearances now?
5 MS. McHENRY: Good morning, your Honours.
6 I am Teresa McHenry for the Prosecution. I appear with
7 Mr. Turone and Ms. Udo. Mr. Niemann will be joining us
8 later this morning.
9 JUDGE KARIBI-WHYTE: Could we have the
10 appearances for the Defence?
11 MS. RESIDOVIC: Good morning, your Honours. I
12 am Edina Residovic, appearing on behalf of Mr. Zejnil
13 Delalic, along with my colleague, Professor Eugene
14 O'Sullivan from Canada
15 MR. OLUJIC: Good morning, your Honours. I am
16 Zeljko Olujic appearing on behalf of Mr. Zdravko Mucic,
17 along with my colleague, Mr. Michael Greaves.
18 MR. KARABDIC: Good morning, your Honours.
19 I am Salih Karabdic, attorney from Sarajevo, appearing
20 on behalf of Mr. Hazim Delic, along with Mr. Thomas
21 Moran, attorney from Houston, Texas.
22 MS. McMURREY: Good morning, your Honours.
23 I am Cynthia McMurrey. I am here on behalf of Esad
24 Landzo, along with my esteemed counsel, Ms. Nancy Boler.
25 JUDGE KARIBI-WHYTE: Would you kindly invite
Page 11075
1 the witness?
2 (The witness entered court)
3 JUDGE KARIBI-WHYTE: Please remind the
4 witness he is still on his oath.
5 THE REGISTRAR: I remind you, Sir, that you
6 are still under oath.
7 THE WITNESS: I understand that.
8 JUDGE KARIBI-WHYTE: Ms. McHenry, you may
9 proceed.
10 ARIF SULTANIC (continued)
11 Cross-examined by MS. McHENRY (continued)
12 Q. May I ask the witness be shown Defence
13 Exhibit 163. (Handed). This is the document that you
14 were shown yesterday by Defence counsel in direct
15 examination and I just have a couple of questions about
16 it. First, did you actually see this document in June
17 1992?
18 A. Yes.
19 Q. Was this order carried out? In other words,
20 is it the case that all communication units were taken
21 from the existing communication centres and moved into
22 the Zlatar facilities?
23 A. Not on that day, but within a short period of
24 time -- actually, at the end of July -- no, end of
25 June, as the HVO separated from the TO, they split, and
Page 11076
1 they moved the communications centre. I am not quite
2 sure whether this was within five days, but I do know
3 that they moved their own communications centre,
4 because of the frequent shelling and the lack of safety
5 -- if we had only one communication centre -- so we
6 needed several. So, when the HVO split from the TO and
7 formed its separate command, then this communications
8 centre was set up on Mount Zlatar.
9 JUDGE KARIBI-WHYTE: Actually, the question
10 is whether this order was carried out. Did you carry
11 out the order?
12 THE WITNESS: I did not. I was not the
13 person carrying out the order, because this order was
14 to be carried out by Mr. Vlado Azinovic, who was chief
15 of communications in HVO, and Mr. Muhamed Alic was
16 supposed to ensure telephone lines -- the lines
17 connecting that facility.
18 MS. McHENRY: If I understand you, it was
19 never the case that all communication units were moved
20 to Zlatar, although it is the case that some weeks
21 later the HVO moved some of their communication
22 equipment to Zlatar; is that correct?
23 A. As I have already said, in the town of
24 Konjic, there were several communication centres, such
25 as the MUP, the operational centre, the centre for
Page 11077
1 warning and information, and the centre of the joint
2 command.
3 Q. Let me ask you more directly. It is the case
4 that the TO communication centres were not moved to
5 Zlatar; correct?
6 A. At that point in time, when this
7 communications centre was transferred, because a day or
8 two after this a decision was taken not to form the
9 communications centre at Zlatar because the HVO forces
10 later I think -- and this is clear to you -- they moved
11 later on, they separated from the TO and that is how
12 they formed this communications centre.
13 Q. Sir, I am correct that what happened is that
14 this order was issued and it was never carried out and
15 a couple of days later there was a decision made to
16 move the TO communication facilities to Mr. Delalic's
17 house; is that correct?
18 A. Yes, if you were following what I said
19 earlier on, then it is clear that the TO communications
20 centre was later moved to Mr. Delalic's house --
21 parallel with the time when this communications centre
22 was being formed at Zlatar.
23 Q. When the communications centre was moved to
24 Mr. Delalic's house, was there a written order, like
25 this one -- like the one about Zlatar? Did you see a
Page 11078
1 written order?
2 A. I did not see it, because, as I said, the
3 head of communications was somebody else -- not me.
4 Therefore, whatever I was told by the person in charge
5 of communications, I implemented.
6 Q. So you saw this order of 8 June, but you
7 never saw the subsequent order; correct? You just did
8 as you were told; is that correct?
9 A. Yes, certainly.
10 Q. Did I understand you correctly yesterday that
11 the person who told you that all the equipment was to
12 be moved to Mr. Delalic's house was Mustafa Bajgoric --
13 I may be pronouncing that name incorrectly.
14 A. This person, Mustafa Bajgoric, did not tell
15 me that this equipment had to be moved to Mr. Zejnil
16 Delalic's house, because that person at the time was in
17 Mostar. Since we as a company had two Harrison-type
18 installations, one of these was used by the HVO and the
19 other was supposed to be transferred to Konjic and this
20 is what I discussed with Mr. Mustafa Bajgoric.
21 I apologise, but please allow me to continue. We
22 discussed where we should move it -- I beg your pardon
23 -- so, with the head of communications and with the TO
24 bodies, we were discussing which would be the best
25 position and, since these other centres had been
Page 11079
1 distributed in town, and in view of the installations
2 that Mr. Delalic already had in his house -- electrical
3 installations -- he had a generator -- since he needed
4 this generator earlier on, he had used it for his
5 discotheque, so I proposed that this communications
6 centre be moved there, as it was the safest place --
7 even though there was some shelling around there, but
8 not any direct hits at the house. However --
9 Q. Sir, who exactly from the TO ordered you to
10 move this equipment to Mr. Delalic's house, if anyone?
11 A. I think it was Mr. Azinovic.
12 Q. Sir, after the communications equipment was
13 moved to Mr. Delalic's house, in addition to the
14 powerful radio equipment that you have already talked
15 about, am I correct that the communications centre
16 could receive and send faxes?
17 A. No, you are not right, because the
18 communications centre could not send faxes. Fax
19 messages used telephone lines and Konjic did not have
20 telephone connections with Sarajevo or Mostar, and
21 I already said that, when I arrived at Mr. Delalic's
22 house, I did not see any fax machine. I did see a
23 radio station and equipment that had arrived with the
24 convoy from Zagreb and these radio transmitters needed
25 to be distributed among the units and energy supply
Page 11080
1 ensured for them.
2 MS. McHENRY: We did listen to your direct
3 testimony. Sometimes, when I am asking you a question,
4 I do not need you to give details about other things
5 that I have not asked you about. If you think it is
6 necessary to give a fair answer, you can give them, but
7 it is prolonging the process.
8 Do I understood you; during the entire time
9 you worked at the communications centre, the
10 communications centre could neither receive nor send
11 faxes; is that correct?
12 JUDGE JAN: That is exactly what he said.
13 MS. McHENRY: I want to make sure this is for
14 the entire time period, because I think this is an
15 important point?
16 A. I said earlier on that I was not there all
17 the time. Occasionally, when I needed to assemble
18 something or to repair any of the installations or set
19 them in operation, I said that the fax was not working
20 there.
21 Secondly, if I am speaking under oath,
22 I think that if I was just to say "Yes" or "No",
23 I would not be conveying the substance of my testimony.
24 Q. So, do I understand you that you do not know
25 for sure whether or not the communications centre could
Page 11081
1 receive or send faxes; is that correct?
2 A. I am sure that that communications centre
3 could not receive or send faxes.
4 Q. Thank you. Could the communications centre
5 receive or send telegrams or telexes?
6 A. It could send telegrams by means of short-wave
7 radio -- it could do that by means of radio waves, but
8 it could not send telexes.
9 MS. McHENRY: Sir, when written orders were
10 delivered by messengers to Konjic, did those written
11 orders also come to the communications centre; in other
12 words, was it a sort of clearing house for written
13 orders also that came through messengers?
14 JUDGE JAN: I am not sure that the question
15 is clear. Do you mean all the couriers who brought
16 messages, they first came to the communications
17 centre? Ask him that.
18 MS. McHENRY: When couriers came from other
19 places outside Konjic to deliver messages, would they
20 go to the communications centre, or would they deliver
21 the message right to whomever it was addressed to?
22 A. Messages that arrived and had to do with the
23 communications centres and that had to be forwarded
24 from there were brought to the communications centre,
25 but I was not there all the time. I had a broad field
Page 11082
1 of activity, so I was not there and I cannot know
2 whether all those messages came there, but if there
3 were messages that had to be sent on by radio waves,
4 then they would come to the communications centres and
5 would be forwarded by radio, but I believe that
6 messages that applied to anyone in town would be handed
7 directly to the addressee -- that is my assumption --
8 I am not sure of that.
9 Q. Do you know, Sir, if Sarajevo was sending an
10 order to the TO commander -- would it go through your
11 communications centre or not, or do you just not know?
12 A. I am not sure of that -- I do not know. That
13 was not my speciality.
14 Q. Did the TO have ways to communicate with
15 Sarajevo other than through the radio at the
16 communications centre; in other words, did the TO have
17 its own separate equipment such that it could
18 communicate directly with Sarajevo without going
19 through the communications centre?
20 A. This was the communications centre of the TO,
21 so I do not see why you are mentioning any other TO.
22 This was the TO communications centre.
23 Q. So do I understand you correctly that,
24 whenever the TO wanted to communicate with Sarajevo,
25 they would do it through the communications centre?
Page 11083
1 A. As you said yourself, yes.
2 Q. Thank you. Sir, were the officers of a
3 company named INDA-BAU ever used to facilitate
4 communications that you are aware of?
5 A. Could you please repeat the question, I did
6 not understand it?
7 Q. Sir, do you know whether or not any officers
8 of a company called INDA-BAU located in Zagreb, do you
9 know whether or not those officers and their
10 communications equipment were ever used to facilitate
11 communications?
12 A. Could you please explain what INDA-BAU is --
13 what is it?
14 Q. If you do not know, all you have to do is
15 say, "I do not know".
16 A. This is the first time I have heard of this
17 word, of this company and of that communications
18 centre.
19 Q. Thank you, Sir. Am I correct that the
20 communications centre was used not just by the TO but
21 also on occasion by the war presidency and the MUP?
22 A. In the event that their power was down, or
23 due to shelling, one of the centres was incapacitated,
24 then they would also use this centre.
25 Q. Sir, am I correct that the communications
Page 11084
1 centre also served as a kind of office and, indeed, was
2 considered by some persons, including persons who
3 worked there, as the headquarters for the TO?
4 A. No, it was not considered as an office, nor
5 was it an office, but, when a message needed to be sent
6 on, a courier would bring it and it would be forwarded
7 by radio, because please bear in mind that there was
8 also here a workshop -- my own workshop for the repair
9 of installations, and also the people manning the
10 installations slept there, so it could not be an
11 office.
12 Q. Sir, you would agree with me, though, that
13 typists worked there, for instance, and they would type
14 orders?
15 A. If you consider the personnel using the
16 communications equipment as typists, then, yes, they
17 did send orders by radio waves, but they cannot type
18 them if they did not have typewriters.
19 Q. Sir, where were the headquarters of the TO --
20 where were they located?
21 A. The TO command would move around -- while the
22 TO and HVO were together, they were near the bus
23 station, but after the split, the TO was relocated just
24 away from that building -- a short way away from the
25 building, to a local school.
Page 11085
1 MS. McHENRY: Sir, you would agree with me
2 that meetings were sometimes conducted in the
3 communications centre, both downstairs and upstairs of
4 Mr. Delalic's house.
5 JUDGE JAN: Which meetings -- be more
6 specific.
7 MS. McHENRY: Meetings of persons involved in
8 the war presidency and the Konjic defence forces?
9 A. I think I told you clearly -- occasionally,
10 on the upper floor, Mr. Delalic would come there. I did
11 not see any persons meeting there, because I had no
12 need to see them. If I went outside, I would not see
13 anyone, of course.
14 Q. Approximately how many people worked in the
15 communications centre -- just approximately?
16 A. I was there when I was there, and two or
17 three of my associates, experts and there were a couple
18 of signals men in a shift, two or three -- anyway, they
19 worked in shifts, they would rest for five or six hours
20 and then continue, so there were quite a number of
21 these signals men. Whether there were 10 or 12 or
22 less, I did not count, because what was important to me
23 was to know the status of the persons working with me,
24 whether they were present or not.
25 Q. Did Habiba Bukvic ever work in the
Page 11086
1 communications centre?
2 A. I remember that there was Mira and another
3 lady, Djina or something like that -- I am not quite
4 sure about Habiba that you mentioned -- did you say
5 Buklic?
6 Q. Bukvic?
7 A. I am not sure about that, I do not know.
8 Q. In addition to Mira, did Dina Pilas work
9 there?
10 A. If you are referring to Dina Pilas as Djina,
11 I seem to remember the name Djina -- if that is the
12 same person, I do not know -- later on, maybe.
13 Q. How about Ismeta Pozder, did she ever work in
14 the communications centre?
15 A. In this communications centre that we are
16 talking about?
17 Q. Yes, Sir.
18 A. I do not know. I know that girl very well,
19 but I do not know that she worked there.
20 Q. Thank you, Sir. Sir, I know that you
21 testified yesterday that you do not know exactly when
22 Mr. Rizvanovic became your superior, but can you tell me
23 approximately for how long Mr. Rizvanovic was your
24 superior -- until what time approximately?
25 A. Until what time -- let me see. It would have
Page 11087
1 been 18 or 19 April 1993 and then I moved to another
2 position.
3 Q. I am sorry, until April 1993; is that correct
4 -- I am not sure that I heard correctly.
5 A. Yes, you heard me correctly.
6 Q. Sir, do you know exactly when Mr. Delalic
7 became coordinator and for how long he served as
8 coordinator?
9 A. I do not know when he became the coordinator
10 and he was coordinator until he was appointed commander
11 of TG1 in Pazaric.
12 Q. You testified you had seen Prosecution
13 Exhibit 127, which is the document signed by Mr. Delalic
14 and two other persons about the railroad. My question
15 is: did you ever see any other documents signed by
16 Mr. Delalic in his role as coordinator, or was that the
17 only document that you saw?
18 A. I saw that one document and I did not see any
19 other documents. I do not know.
20 Q. Thank you. Sir, when Mr. Delalic was
21 coordinator, you indicated that he sometimes spent time
22 in the field and, indeed, he was in the field when he
23 was appointed commander of TG1; is that correct?
24 A. He had the role of coordinator for almost the
25 entire time and I said that it started in 2 June and it
Page 11088
1 went until about 26 July -- maybe it could have been
2 only four or five days that we were not together and
3 I told about the train thing and then the electric
4 lines in those villages there, and then there was also
5 the communications centre in his house, but he could
6 not be there all the time; he had other things to look
7 after -- supply of food and then everything that
8 concerned the war presidency.
9 Q. Sir, is the answer to my question therefore
10 "Yes", that he was sometimes in the field when he was
11 coordinator and in fact he was in the field at the time
12 he was appointed TG1 commander?
13 A. Yes, he was in the field.
14 Q. At the time when he was in the field, when he
15 was appointed TG1 commander and you contacted him to
16 tell him about his appointment, for approximately how
17 long had Mr. Delalic been in the field during that time;
18 in other words, without coming back to Konjic?
19 A. He was out in the field the entire month of
20 June -- he may have come home occasionally to change
21 clothes and it was his communications centre but it was
22 also his home, so I could not monitor his comings and
23 goings, but I know that he spent that entire month in
24 the field. Maybe he occasionally came home for a
25 couple of hours to change clothes or rest or things
Page 11089
1 like that.
2 Q. Let me just make sure that there is not a
3 miscommunication. Are you stating that Mr. Delalic was
4 in the field for almost the entire month of June -- did
5 I understand the month correctly?
6 A. No, he was in June with me and we worked on
7 these problems that I described, but in July he was in
8 Vranjske Stijene and that is what I stated yesterday.
9 Q. I think there may have been an interpretation
10 problem. You stated you knew Mr. Mustafa Polutak. When
11 he was commander of TG1, did he use the communications
12 centre in Konjic?
13 A. He used it occasionally, this communications
14 centre in Konjic, but very frequently -- maybe once or
15 twice when he needed to have some message sent to
16 Sarajevo, because this communications centre in Pazaric
17 was shelled quite frequently, so some of the equipment
18 was damaged and then he used our own facility to send
19 some messages over to Sarajevo.
20 Q. Sir, you were aware that Mr. Polutak had an
21 accident in early August, are you not?
22 A. It is not "Poletak"; it is "Polutak" and
23 I was not aware of the accident.
24 Q. Excuse me. I am sure that is not the last
25 name I am going to mispronounce. It is very fair of
Page 11090
1 you to try and correct that. When he was Tactical
2 Group commander, what geographic zone was Mr. Polutak
3 responsible for?
4 A. Who?
5 Q. Mr. Polutak.
6 A. I really would not be able to tell you that.
7 Strategy was not my job. My job was exclusively
8 technical stuff.
9 Q. Fair enough, Sir. After Mr. Delalic became
10 commander of TG1, did he use the communications centre
11 in his house?
12 A. Sometimes, yes -- only sometimes though --
13 very infrequently.
14 Q. You have indicated that Sarajevo sometimes
15 sent Mr. Delalic messages using this communications
16 centre; is that correct?
17 A. Yes. As I said, if the equipment was damaged
18 in Pazarici or there was no power, then they used our
19 facility to communicate their messages.
20 Q. And if Sarajevo wanted to send a message by
21 courier to Mr. Delalic, would they send that through the
22 communications centre, or would they go directly to
23 where Mr. Delalic was, the headquarters of TG1?
24 A. I do not know how they thought about these
25 things, how they would contemplate doing them, so I do
Page 11091
1 not know.
2 Q. When Mr. Delalic was -- were there problems in
3 getting messages to Mr. Delalic from Sarajevo?
4 A. It depended. Sometimes there were problems,
5 sometimes not -- it all depended on the situation both
6 in the city of Sarajevo, that is, the availability of
7 gas and electricity and, also, it depended on us -- you
8 never knew when you would get it or when you would
9 not. Sometimes you would wait a day or even two days
10 to send the message, because if the communications
11 centres did not work, then you could not send these
12 communications. In such cases, couriers were used
13 then.
14 Q. Were there also problems in getting messages
15 to the TO commander?
16 A. Certainly. If it had to do with power
17 shortages or with shelling, but if everything was okay,
18 if the communications centre had regular supply of
19 power, then that was not a problem.
20 Q. Sir, you indicated that the order appointing
21 Mr. Delalic head of the Tactical Group came by messenger
22 from Fojnica and you contacted Mr. Delalic personally to
23 tell him about it; is this correct?
24 A. Yes, it happened so that, on that day --
25 I think it was in the afternoon, I was in the
Page 11092
1 communications centre.
2 Q. That is fine -- if it is just "yes" you can
3 say "yes" and I can go on to my next question.
4 I wanted to ensure I understood you correctly before
5 I went to my next question.
6 When you contacted Mr. Delalic, did you
7 contact him using the radio?
8 A. Yes. As I said, this communications centre,
9 those outposts radio transmitters were out in the
10 field, and they had a very different way of
11 communicating. You used the FM communications and this
12 is how we passed on the message to him, to Mr. Delalic,
13 that he became one of the important persons in our
14 area.
15 Q. Was the order that you told Mr. Delalic about
16 -- do you remember if the order was dated around this
17 same time period, the end of July, or could the order
18 have been dated in mid July?
19 A. As far as I recall, it should have been late
20 July, because the courier who brought this order said
21 that he travelled for two days, so if he had to travel
22 for two days because of some misunderstanding with the
23 HVO, then that could have been dated two days before he
24 brought it.
25 Q. Sir, when this courier from Fojnica came, was
Page 11093
1 this the first that you had heard about Mr. Delalic
2 being appointed head of TG1, or had you received any
3 kind of oral notification before that day?
4 A. It was the first time that I heard that.
5 Q. When you told Mr. Delalic about his
6 appointment, did you read out the order, word for word,
7 to him, or did you just interpret it for him and tell
8 him the important parts?
9 A. We did not read it to him. The courier told
10 us that he was going to replace Polutak. Since we knew
11 who was Polutak, at least I knew who Polutak was, then
12 I congratulated him on this, how shall I put it,
13 promotion, so that I did not read the contents of this
14 order -- I do not know if it was information on
15 promotion or what. As I said, the courier told us that
16 he was replacing Polutak.
17 Q. I am sorry, Sir, did I understand you -- did
18 you yourself even read the order from the courier?
19 Even if you did not read it to Mr. Delalic, did you
20 yourself read it?
21 A. No, I did not, I did not. I did not read the
22 order, because the courier told us that this is what
23 happened, and I myself did not read the order.
24 Q. So, if I understand correctly, the courier
25 came with an order -- the courier told you about the
Page 11094
1 order. You immediately contacted Mr. Delalic and you
2 never yourself looked at the order or told Mr. Delalic
3 what was in the order?
4 A. As I said, the communications people did
5 their job, and I just did it informally. I called him
6 to congratulate him, and what kind of an order it was
7 -- there was a text there, I know that there was a
8 text.
9 Q. Sir, at some later point, did you ever see
10 any other appointment order for Mr. Delalic?
11 A. No.
12 Q. Sir, when Mr. Delalic gave orders to the TO or
13 municipal headquarters, would he use the communications
14 centre to do so?
15 A. You mean as a commander of TG1?
16 Q. Yes, Sir.
17 A. I do not know that he was able to issue
18 orders to the municipal staff. That is, I am not
19 familiar with that, or to the municipal bodies. He was
20 a separate body. He was his own unit and, as far as
21 I could tell, these different TOs, these different
22 staffs were supposed to send us a certain number of
23 soldiers, but as I tell you, I am a technical person,
24 so I do not know about these superiority things and
25 chains of command.
Page 11095
1 MS. McHENRY: Thank you, Sir. Am I correct
2 that you stated that there were about 50 soldiers from
3 Konjic who were assigned to TG1?
4 MS. RESIDOVIC: Objection. The witness has
5 stated several times that he did not know about these
6 things and I think that it should not continue -- that
7 these questions should not continue.
8 MS. McHENRY: I am asking him about something
9 he explicitly stated in direct.
10 JUDGE KARIBI-WHYTE: Put it to him. If he
11 does not know, he will say he does not.
12 MS. McHENRY: Did I understand you yesterday
13 to say there were about 50 soldiers from Konjic who
14 were assigned to TG1?
15 A. To be honest with you, I do not know the
16 exact number of soldiers. It is possible -- I said
17 that it was possible that it was 50 soldiers, but
18 whether it was more or less, I am not sure. It is
19 possible.
20 Q. Sir, do you know from what unit or brigade
21 these soldiers were, however many there were?
22 A. No.
23 MS. McHENRY: Sir, do you know whether or not
24 Mr. Delalic was a superior to the staff of TG1?
25 JUDGE KARIBI-WHYTE: What type of a question
Page 11096
1 is that? Are you asking him --
2 JUDGE JAN: It was his own staff -- he was
3 superior to that staff.
4 MS. McHENRY: Would you agree with me that
5 Mr. Delalic was superior to his own staff -- the staff
6 of the TG1?
7 A. If he was appointed commander of this group,
8 he certainly was superior.
9 Q. Sir, if I understood you correctly during
10 your direct testimony, you would deny that you were
11 ever a part of Mr. Delalic's staff when he was commander
12 of Tactical Group 1?
13 A. I was never, but, as I said, we worked on all
14 technical projects, but, as to whether Mr. Delalic had
15 any authority over me or these communications chiefs --
16 no.
17 MS. McHENRY: If Mr. Delalic reports that for a
18 period of time when he was commander of Tactical
19 Group 1 you were a member of his staff, he would be
20 wrong?
21 MS. RESIDOVIC: Objection. The witness
22 answered.
23 JUDGE KARIBI-WHYTE: I do not know what type
24 of objection this is. What is the difficulty in him
25 saying whether they are members of his Tactical Group
Page 11097
1 or not? This question is not unfair.
2 Please, answer the question whether you were
3 part of Tactical Group 1.
4 THE WITNESS: I was never subordinate to
5 Mr. Delalic.
6 MS. McHENRY: My question, Sir, directly
7 was: so, if Mr. Delalic reported that you were a member
8 of his staff when he was commander of TG1, he would be
9 wrong; is that correct?
10 A. Certainly.
11 Q. Was Mr. Arsen Rizvanovic, your superior, was
12 he ever commander of Tactical Group 1?
13 A. I do not know.
14 Q. Do you know whether or not Major Kevric was
15 part of the command staff of TG1?
16 A. I do not know -- I do not believe he was.
17 Q. How about Habiba Bukvic?
18 A. I do not know -- I have no idea. I do not
19 know.
20 Q. Sir, when Mr. Delalic was commander of
21 Tactical Group 1 and he needed additional units, or he
22 wanted a particular unit moved to a different location
23 for battle, do you know how he would communicate his
24 orders in that regard?
25 A. I am not familiar with that method of work of
Page 11098
1 the staff. I am a technical person and whatever I am
2 told, I do. If I am told to set up a communications
3 centre, that is what I do, but as far as the
4 organisation and command, that is not what I did, and
5 I was not concerned with that at all.
6 JUDGE KARIBI-WHYTE: Actually, apart from
7 setting up the communications centre, did you do
8 anything other than that? Did you continue to operate
9 it for Mr. Delalic?
10 THE WITNESS: I worked on the railroad until
11 7 January 1993 and parallel to that --
12 JUDGE KARIBI-WHYTE: I am limiting you to
13 the communications centre -- apart from setting up the
14 communications facilities, did you do anything with
15 respect to communications, that is, organising how his
16 future communications unit should be. Did you do
17 anything other than setting up the facilities?
18 THE WITNESS: I did repairs of radio
19 equipment, of these radio transmitters and I did that
20 throughout this period. As I said yesterday, those two
21 or three centres which we set up for the Oganj
22 Operation, I also worked on that, so it was not just a
23 single communications centre, so there were several
24 communications centres which we set up as a technical
25 team and, of course, doing some other telephone lines
Page 11099
1 later on, but it is not part of the matter that we are
2 discussing here right now.
3 JUDGE KARIBI-WHYTE: You may continue,
4 Ms. McHenry.
5 MS. McHENRY: Thank you, Sir.
6 Sir, when you first began working with
7 Mr. Delalic, and you stated you were with him
8 frequently, were you present at a meeting with
9 Mr. Delalic and a number of other persons when the
10 problems in Celebici were discussed and Mr. Delalic
11 suggested Mr. Mucic as commander of Celebici?
12 A. If I made myself clear, I said at the very
13 beginning that I saw Mr. Delalic for the first time when
14 I actually met him -- that was on 2 June and that was
15 the only working contact that I had with Mr. Delalic.
16 Q. Do you know when Mr. Mucic became commander of
17 Celebici camp?
18 A. No.
19 MS. McHENRY: You stated, Sir, that sometimes
20 Mr. Mucic would contact Mr. Delalic. Did I understand
21 you correctly that you were not present during their
22 conversations, so you do not know the subject matter of
23 their conversations?
24 MS. RESIDOVIC: Your Honours, objection.
25 I did not hear this witness saying ever that Mr. Mucic
Page 11100
1 contacted Mr. Delalic, so I think the question is not in
2 order.
3 MS. McHENRY: Your Honour, I thought he did,
4 but, if not, let me ask the question.
5 Did you state during your testimony yesterday
6 that, on occasion, Mr. Mucic would contact Mr. Delalic?
7 A. I did not say that. I said that we were
8 called up to set in operation a telephone exchange in
9 the Celebici barracks in August. As for Pavo, that he
10 contacted somebody and talked to somebody, and
11 especially Zejnil, I did not see that. You have the
12 minutes, you have the transcript and you can check. I
13 do not remember saying that.
14 Q. Who asked you to fix the telephones in
15 Celebici?
16 A. The head of the communications, upon approval
17 of the commander of the TO -- probably somebody from
18 the barracks had asked for it, because if there was a
19 failure, they must have asked for it to be repaired.
20 Q. Sir, is it correct that you went out to the
21 Celebici barracks after being called there by Pavo
22 Mucic, the prison warden?
23 A. I am saying again, it is possible that Pavo
24 made the call, but I did go to the Celebici barracks to
25 repair the telephones which were not functioning.
Page 11101
1 Q. When you went to Celebici, who went with you?
2 A. I went and there was Mr. Dulic, a
3 telecommunications engineer, who was familiar with
4 Iskra's telephone exchanges -- he had a better
5 knowledge of them than I did.
6 Q. Did Mr. Rizvanovic go with you to fix the
7 phones?
8 A. I do not remember -- possibly he may have
9 driven us there and come back to fetch us, but I am not
10 sure about that.
11 Q. Can you tell us, what part of the camp did
12 you go into? In particular, what buildings did you go
13 into? Are you familiar with the building that is
14 referred to as the reception building and the building
15 that is referred to as the command building? If you
16 are not, Sir, there is a model in front of you and
17 maybe, if you are not familiar with those terms, maybe
18 you can just point to us and show us the building or
19 buildings that you went to when you were in Celebici?
20 A. I went to this building here to the left
21 (witness indicates with pointer). This part here is
22 probably the reception and this office where the
23 telephone exchange was, I think it is this window in
24 the middle -- left from the entrance -- I assume that
25 was the one.
Page 11102
1 Q. Did I understand you correctly to say, Sir,
2 then that you did not go into the reception building at
3 all?
4 A. I had no need to go to the reception
5 building. There was a guard there. I did not
6 communicate with him. We passed on directly and looked
7 for the telephone exchange. Of course, a soldier met
8 us there and asked what we wanted. We said that we had
9 come to repair the telephone exchange. He said,
10 "Please, go ahead" and we went to the office in
11 question.
12 Q. Did you see Mr. Mucic when you were at the
13 camp?
14 A. Let me see -- I did not personally know
15 Mr. Mucic at the time. I may have seen him, because if
16 he was there, he should have contacted with us. If
17 Mr. Rizvanovic had brought us there, then he should have
18 contacted him.
19 JUDGE KARIBI-WHYTE: Was anybody so
20 introduced to you -- as Mr. Mucic?
21 THE WITNESS: I think there was a woman and
22 she said, "The warden is in the next office and that is
23 where the telephone exchange is, too."
24 JUDGE KARIBI-WHYTE: Kindly answer the
25 question of counsel, whether you saw Mr. Mucic there.
Page 11103
1 MS. McHENRY: Sir, when you went into the
2 next office where the telephone exchange was, was the
3 warden there?
4 MR. OLUJIC: Objection, your Honour.
5 JUDGE KARIBI-WHYTE: He said the warden was
6 in the next room and the follow-up question was whether
7 he saw the warden in the next room. So what is the
8 objection about?
9 MR. OLUJIC: Allow me to explain, your
10 Honours.
11 JUDGE KARIBI-WHYTE: There is nothing to
12 explain.
13 MR. OLUJIC: He said he did not know Mucic at
14 the time, that is what he said.
15 JUDGE KARIBI-WHYTE: Yes. Then he was told
16 the warden was in the next room -- that is what he was
17 told. If he then went and saw the warden, then that is
18 what the counsel is trying to find out, whether he went
19 to see the warden in the next room. It is quite a
20 legitimate and proper question to ask. Whether he knew
21 him or not, he would have seen who was the warden.
22 MR. OLUJIC: The warden, yes, but not
23 Mr. Mucic.
24 JUDGE KARIBI-WHYTE: You are wasting the
25 time of counsel. Please, let us continue.
Page 11104
1 MS. McHENRY: When you went into the next
2 office where the telephone exchange was, was the warden
3 present?
4 A. I do not remember that he was present,
5 because this lady told me, "In the next office is the
6 warden's office and that is where the telephone
7 exchange is which is faulty."
8 MS. McHENRY: Thank you. Sir, did you state
9 yesterday that, from the time the train began working
10 in early June, the families of the detained persons
11 were allowed to visit the prisoners in Celebici.
12 JUDGE JAN: Were allowed to use the train --
13 the first time they were allowed to use the train.
14 MS. McHENRY: Presumably they would be using
15 the train.
16 My question, Sir, is: is it correct that you
17 stated that the families of the detainees were allowed
18 to use the train and beginning in early June they used
19 the train to visit their family members detained in
20 Celebici?
21 A. You see, everyone had transportation free of
22 charge. You could see that on the tape -- if there was
23 a tape, I was a participant in the filming, there were
24 several cameras used and the person in charge of the
25 organisation of transportation, Mr. Buntic, said that a
Page 11105
1 timetable had been made and according to that timetable
2 for the trains, all persons who needed to travel could
3 use the train free of charge on the line from Pazarici
4 to Jablanica, so everyone could use the train --
5 whoever needed to use it could use it, free.
6 JUDGE KARIBI-WHYTE: Relax a little bit.
7 I think you are on the right part when you said the
8 train was free to everyone and it was legitimate to
9 understand that -- everybody, how everybody, whether or
10 not they were families of detainees, would use the
11 train, free of charge. Nobody was stopped from using
12 the train, so you could have answered the question
13 without all this apprehension you had.
14 THE WITNESS: Everyone could use the train.
15 JUDGE JAN: This is what you have said.
16 They could be families of detainees or anyone else,
17 anyone could use it. That is what you said.
18 THE WITNESS: Yes, that is right.
19 MS. McHENRY: Sir, my specific question is
20 not whether or not anyone had to pay . Is it your
21 testimony that families of detainees were allowed to
22 visit prisoners in Celebici from the beginning of June
23 when the train started running?
24 JUDGE JAN: He was not a warden there. He
25 said the train could be used.
Page 11106
1 MS. McHENRY: I would agree with that. That
2 is not what he testified to yesterday. Yesterday he
3 was more explicit.
4 JUDGE JAN: Read that portion to him.
5 MS. McHENRY: I do not have it right in front
6 of me, which is why I am trying to clarify -- which is
7 why my question was, "Did I understand you correctly?"
8 Sir, do you know when the detainees' families
9 were allowed to visit prisoners in Celebici.
10 JUDGE JAN: In fact, your own witness -- the
11 doctor's wife said that she used that train to go to
12 Celebici -- I do not want to mention the doctor's name,
13 because that is a protected witness -- but she said she
14 used that train to go to Celebici.
15 MS. McHENRY: That is correct.
16 JUDGE JAN: On the return, she could not and
17 she walked back, but she used the train for going to
18 the Celebici camp.
19 MS. McHENRY: That is correct. My question
20 has to do with the timing and whether or not this
21 witness knows whether or not, beginning in early June,
22 people were allowed to visit their family members in
23 Celebici. If he knows, he can say so. If he does not
24 know, obviously he can say, "I do not know."
25 JUDGE JAN: He can speak about the use of
Page 11107
1 the train.
2 THE INTERPRETER: Microphone, please.
3 JUDGE JAN: He cannot speak about whether or
4 not they were allowed to visit the detainees.
5 MS. McHENRY: I would agree with that.
6 Is it correct that you have no idea whether
7 or not the families of detained persons were allowed
8 actually to visit the detainees?
9 JUDGE KARIBI-WHYTE: Actually, I do not even
10 know why you ask him such a question. Does he really
11 need to go into that, whether they were visiting their
12 families? We have had evidence here that members of
13 their families visited them.
14 MS. McHENRY: Your Honour, I am asking it,
15 because he stated it in direct testimony and I think
16 timing of when visits may or may not have been allowed
17 is relevant. That is why I am asking the question.
18 Is it correct you do not know whether or not
19 families were allowed to visit detainees?
20 A. I know that it was permitted -- visits of
21 family members were permitted and that they used the
22 train for that purpose. Some people did; others did
23 not, that did not need to be transported by train.
24 Q. How exactly do you know that visits were
25 permitted and from what time period were they
Page 11108
1 permitted?
2 A. Probably from the day they were detained. A
3 part of my acquaintances were detained and their wives
4 addressed me at the railway station and asked me when
5 visits were allowed and I said that visits were allowed
6 every day and I knew that others were using the train
7 -- 6 or 7 June, until then I did not know that there
8 was a prison there at all, until 7 June.
9 Q. Let me move on, Sir. Sir, you testified in
10 direct about some communication with the supreme
11 command, about the visit of the Red Cross to Celebici
12 camp. You were aware that ultimately Mr. Delalic was
13 the person who was supposed to arrange this visit;
14 correct?
15 A. I was not aware of the fact that Mr. Delalic
16 was to arrange that visit. In my statement that I made
17 some time in 1996, I did not pay much attention to the
18 sequence of events. I said that this had happened and
19 that Zejnil called, but, as far as I remember, in the
20 next sentence I already corrected myself and said that
21 Mr. Delalic had called us up in the communications
22 centre, saying that this should be allowed, because
23 they had some problems with their car and that we
24 should see what was the hitch with the TO staff
25 regarding allowing their visit and then we contacted
Page 11109
1 the TO staff and they replied immediately that the
2 visit of the International Red Cross should be
3 organised to the prison or the prisons -- the prison in
4 Celebici. I do not know which one.
5 Anyway, all it said was that the visit of the
6 Red Cross should be organised. After that, I do not
7 remember exactly whether it was that day or the next
8 day, a short telegram arrived and this was forwarded on
9 to Sarajevo. Whether the answer came back to Zejnil
10 Delalic or not, I have no idea. I know that it was
11 forwarded on to Sarajevo.
12 Q. Sir, is your prior statement incorrect when
13 you stated that the Red Cross gave their report to
14 Mr. Delalic?
15 A. I would not say it was incorrect, but when
16 this lady, the investigator, authorised by the Defence
17 to take my statement -- she probably turned around the
18 word order so that the meaning of the sentence was
19 changed.
20 Q. Sir, you said you are aware that the report
21 was sent through the communications centre to
22 Sarajevo. I assume then, Sir, that you are aware that
23 the report was extremely critical of the conditions in
24 Celebici?
25 A. You see, I said a short report had been sent
Page 11110
1 in the direction of Sarajevo, but, if necessary, I will
2 repeat 100 times: I did not read all those documents;
3 I did not need to do that. I am a technical person.
4 Sometimes I would hand a document to somebody and tell
5 him that it was an urgent thing that had to be sent if
6 the others were busy.
7 Q. Do I understand, Sir, you have no idea that
8 it was in the Red Cross report -- is that your
9 testimony?
10 A. I have no idea, because I did not read the
11 document.
12 Q. That is fair enough, Sir. You mentioned this
13 prior statement you gave. Would you agree with me, and
14 can you tell me if this is a mistake or not, that in
15 your prior statement you stated that you went to
16 Celebici after being called there by Pavo Mucic, the
17 prison warden?
18 A. Yes, that is what I said, because, according
19 to that statement of mine, because I assumed he was the
20 prison warden.
21 Q. You would also agree with me, would you not,
22 that you do not know who Mr. Mucic's superior was with
23 respect to Celebici camp, do you?
24 A. I have no idea who was superior to any
25 gentlemen in the prison.
Page 11111
1 JUDGE JAN: Did he make a statement to an
2 investigator?
3 MS. McHENRY: He made a statement to a
4 representative from the Defence, not to the Office of
5 the Prosecutor.
6 JUDGE JAN: I see.
7 MS. McHENRY: Sir, although she introduced
8 herself to you here in court, am I correct that you had
9 met Ms. McMurrey before yesterday -- the blonde woman
10 who represents Mr. Landzo?
11 A. Only yesterday.
12 Q. Yesterday in court was the first time you
13 ever met her, or anyone who represents the Landzo
14 Defence; is that correct?
15 A. I saw her around. I did not know who she was
16 -- I saw her walking around but I did not know who she
17 was.
18 Q. Had you ever talked with anyone working as
19 part of the Landzo Defence about your testimony?
20 A. Are you referring to my testimony yesterday?
21 Q. Yes, Sir?
22 A. No.
23 Q. Sir, do you know Mr. Rajko Gotovac and a
24 Marijan Rajic, persons who were foresters in Konjic?
25 A. Marijan what?
Page 11112
1 Q. Rajko Gotovac and Marijan Rajic -- persons
2 who were foresters in Konjic?
3 A. I do not know Gotovac, and this other one
4 could be Marijan Rajic, this other one. Maybe it is a
5 printing error.
6 Q. Was that person a forester?
7 A. Marijan was a forester and he lived near a
8 road tunnel in Celebici on the left side of the road.
9 Q. Sir, are you aware that at some time Mr. Rajic
10 and another person had an accident in a chalk mine
11 which caused some burns?
12 A. I know that Mr. Babic, Mirko, had an accident
13 with this chalk pit near his village of Bjelovcina that
14 where he resided.
15 Q. I am going to ask you about that in a
16 minute. I am asking you now whether you know that
17 Mr. Rajic is a person in fact who had an accident in a
18 chalk mine?
19 A. Possibly, because he was working with
20 Mr. Babic in the chalk mine. I did not see Marijan in
21 that situation but I did see Babic in that situation
22 and I was saying how I saw Babic at the railway station
23 waiting for the train.
24 Q. When you saw Mr. Babic, was he wearing shorts
25 rather than long pants?
Page 11113
1 A. He was bandaged -- his legs were bandaged.
2 What kind of trousers he was wearing, I really do not
3 know whether they were long or short.
4 Q. Were the bandages under his trousers?
5 A. The bandages were below his knee.
6 Q. Were there trousers covering the bandages?
7 A. Whether his trousers were rolled up, or
8 whether he was wearing shorts, I really do not
9 remember.
10 Q. Was anyone else with you on this occasion, or
11 with Mr. Babic when you saw the bandages?
12 A. I think his late brother, Branko, was with
13 him, because at the time he was working at the
14 railroads. I think he was with me when he came by --
15 I assume so, but I am not sure of that, because
16 I remember this about Mirko, how he had got burnt
17 working on the chalk mine.
18 Q. So other than his late brother, you are not
19 aware of anyone else who was present; is that correct?
20 A. No.
21 Q. Were both legs bandaged, or just one?
22 A. I do not remember.
23 Q. Do you remember whether or not the bandages
24 went all the way from the knee to the ankle, or was it
25 just part of the leg?
Page 11114
1 A. Around the ankle.
2 THE INTERPRETER: We did not hear that very
3 well.
4 MS. McHENRY: The interpreters did not
5 necessarily hear you. Can you just repeat your answer,
6 Sir? What part of his leg was bandaged?
7 A. Below the knee towards the ankle.
8 Q. After his leg was not bandaged, you never had
9 the occasion to see Mr. Babic's leg again, did you?
10 A. I did not, because he did not come to the
11 railway station every day, and that was where I worked,
12 so I saw him there on that day.
13 MS. McHENRY: Sir, yesterday you were shown a
14 picture and you recognised it as Mr. Babic's leg and you
15 further testified about the cause of the injury on
16 Mr. Babic's leg. Sir, my question is: can you normally
17 recognise a person merely by looking at a picture of
18 their shin?
19 MS. McMURREY: I am going to object. The
20 question that I asked him was whether that was the
21 location of the burn on Mr. Babic's leg, not whether he
22 recognised the leg of Mr. Babic.
23 JUDGE JAN: That was the leg of Mr. Babic.
24 JUDGE KARIBI-WHYTE: That is the issue.
25 MS. McMURREY: Whether that was the location
Page 11115
1 of the injury that he had seen before, that was the
2 question.
3 JUDGE KARIBI-WHYTE: Counsel is entitled to
4 ask whether you can recognise a person from the area
5 where there was an injury -- whether, by looking at the
6 shin, you identify that as that of the other person.
7 If he cannot, he should say so.
8 MS. McHENRY: Sir, my question is: are you
9 in a position to recognise persons just by looking at
10 photographs of their shin?
11 A. I recognise the person from his portrait, not
12 from his leg -- I was first shown a photograph of his
13 head and shoulders, and normally, after that, if
14 somebody asks him whether his leg was burnt and whether
15 this was a leg or an arm, and it was obvious that this
16 was a leg.
17 MS. McHENRY: Sir, when you stated that the
18 injury shown on the photograph was the result of the
19 burn he got from the lime, I am correct, Sir, that you
20 yourself do not know where he got that injury and in
21 fact you yourself do not know whether or not Mr. Landzo
22 set Mr. Babic on fire when he was detained in Celebici?
23 JUDGE KARIBI-WHYTE: I think you are adding
24 something different. He did not extend it to any other
25 thing. He indicated the type of injury which he
Page 11116
1 thought Mr. Babic had.
2 MS. McHENRY: Maybe I will just ask him to
3 clarify.
4 When you stated yesterday, Sir, in your
5 examination, when shown the photograph, "That is the
6 injury due to the burn that he got from the lime" --
7 that is not actually correct, is it -- you do not
8 actually know where that injury is from, do you?
9 A. In view of the fact that, as I said a moment
10 ago, I saw the man with bandages on his leg, so
11 I assumed that that could be that burn, because it is
12 familiar knowledge that the man was burnt in the lime
13 several years before the war. I do not know exactly
14 how many, so that is why I believe that that was the
15 burn. I am not claiming now that this was that
16 particular burn, but what I do know is that he did
17 suffer a burn on his legs and it is possible that this
18 could be that burn.
19 Q. Sir, do you remember the FM radio frequency
20 on which Konjic could be reached and whether or not it
21 was 3704.3 MHz?
22 A. First of all, 370 -- what did you say --
23 370 --
24 Q. 3704.3 MHz?
25 A. That frequency is not an ultra short-wave
Page 11117
1 frequency -- this is a short-wave frequency.
2 JUDGE KARIBI-WHYTE: Ms. McHenry, I think we
3 will have to break until 12 and we will continue at
4 noon.
5 MS. McHENRY: I will have either no or one
6 question.
7 (11.30 a.m.)
8 (Short break)
9 (12.05 p.m.)
10 (The witness entered court)
11 JUDGE KARIBI-WHYTE: Remind the witness he
12 is still on his oath.
13 THE REGISTRAR: I remind you, Sir, that you
14 are still under oath.
15 THE INTERPRETER: Could the witness repeat
16 that?
17 THE WITNESS: I may have not understood
18 correctly, or I may have misstated my answer, but when
19 asked by the Defence attorney, that is, Ms. McMurrey,
20 the Defence counsel of Mr. Landzo, that I did not see
21 her before I came here to The Hague, to this Tribunal
22 -- now, that is true, but, if the question concerned
23 whether I saw her in the Tribunal, then the answer
24 would be yes, we were in touch before I entered the
25 courtroom. We had a short conversation with the entire
Page 11118
1 team, and they asked me several questions -- each one
2 of them. At that time I did not know who represented
3 whom in this case, with the exception of Ms. Residovic,
4 and I would like you to accept this answer as truthful
5 and correct and would appreciate that.
6 I also apologise to Madam Prosecutor, and
7 I would like her to accept this answer, because, when
8 you first asked me, I did not understand it properly.
9 JUDGE KARIBI-WHYTE: Thank you very much,
10 Mr. Sultanic. What we advise you to do -- calm down and
11 do not be too apprehensive, and answer questions in the
12 way you get them and you will be alright. Do not
13 anticipate too much. The questions normally follow
14 from your own answers and then, if you are relaxed, you
15 will have no problems at all. Thank you very much.
16 You may continue, Ms. McHenry.
17 MS. McHENRY: Thank you. I have only one
18 question, your Honours.
19 Sir, do you know what location is 3704.3 MHz
20 in Konjic?
21 A. The location 3704.3, it does not exist. It
22 is a frequency of one of the radio stations and that
23 could change on a daily basis, or maybe a weekly basis.
24 MS. McHENRY: Thank you. I have no further
25 questions.
Page 11119
1 JUDGE KARIBI-WHYTE: Thank you very much.
2 JUDGE JAN: Just one question. Which leg of
3 Mr. Babic did you see bandaged -- right or left?
4 THE WITNESS: Your Honour, I could not tell.
5 I was not paying attention to those details at the
6 time, because I kind of just took it as a joke,
7 because, you know, he would like to drink a little bit
8 and maybe it was in poor taste -- he was burned so
9 much, but I was not paying any attention to which leg.
10 JUDGE JAN: Thank you very much.
11 JUDGE KARIBI-WHYTE: Any re-examination.
12 MS. RESIDOVIC: I have only two questions for
13 this witness.
14 Re-examined by MS. RESIDOVIC
15 Q. Mr. Sultanic, you said that many people were
16 wearing uniforms and that for a while there was no
17 difference between the civilians and soldiers. Could
18 you tell me now, when carrying out your duties and
19 activities, were there any differences between the
20 duties carried out by soldiers and civilians?
21 A. I pointed out that it was kind of a fashion
22 to wear uniforms, but, as far as the duties, the jobs,
23 are concerned, the difference was absolute. The
24 soldiers were mobilised and had to do whatever they had
25 to do and the civilians worked for different civilian
Page 11120
1 enterprises.
2 Q. Thank you. You also stated to the Prosecutor
3 that you did not know Habiba Bukvic but did you know a
4 certain Mira and Djina, can you tell me now whether
5 Mira and Djina worked in the communication centre of
6 the TO staff which was located in the house of
7 Mr. Delalic and on the ground floor?
8 A. No, they did not work at the communications
9 centre, because it was a hard job -- they only worked
10 in the house -- I think that they just worked in Zejnil
11 Delalic's residence, so I saw them there, but they
12 would not enter the communications centre. As a rule,
13 the communications centre has to have certain
14 restricted access, so no, persons who do not work there
15 should not have access to it, so they did not work
16 there, and none of these women, some of whom were
17 married and some who were not, were not entering
18 there. They just went about certain jobs which was
19 part of the housework in Zejnil Delalic's residence on
20 the top floor.
21 Q. Very well, just one additional question,
22 please. Did Zejnil Delalic have anything to do with
23 issuing orders to have the communications centre set up
24 in his residence -- in his house?
25 A. He should not have had anything to do with
Page 11121
1 that, because I think it was the TO staff that was
2 supposed to set it up there.
3 MS. RESIDOVIC: Thank you, I have no further
4 questions of this witness.
5 MR. OLUJIC: Your Honours, just one
6 clarification, with your permission.
7 Mr. Sultanic, can we say that in the latter
8 part of August 1992 you did not know Mr. Zdravko Mucic?
9 A. No, I did not.
10 JUDGE KARIBI-WHYTE: This is the end of this
11 witness's testimony. Thank you very much,
12 Mr. Sultanic. We are very grateful for your assistance
13 and your ability to assist here. You can now be
14 discharged.
15 Will you now call your next witness?
16 You are now discharged.
17 (The witness withdrew)
18 MS. RESIDOVIC: Can we please call the next
19 Defence witness. The next witness is Sefkija Kevric.
20 JUDGE KARIBI-WHYTE: Please let the witness
21 make the declaration.
22 THE WITNESS: Your Honours, I solemnly
23 declare that I will speak the truth, the whole truth
24 and nothing but the truth.
25 JUDGE KARIBI-WHYTE: You may sit down, take
Page 11122
1 your seat.
2 MS. RESIDOVIC: May I proceed, your Honours?
3 JUDGE KARIBI-WHYTE: Yes.
4 SEFKIJA KEVRIC
5 Examined by MS. RESIDOVIC
6 Q. Good afternoon, Sir. Will you please
7 introduce yourself -- could you please tell us your
8 full name?
9 A. I am Sefkija Kevric.
10 Q. Mr. Kevric, before I proceed with my
11 questions, let me give you a very short technical
12 explanation. My questions and your answers need to be
13 interpreted in order for our conversation to be
14 understandable to everybody in the courtroom and for it
15 to be taken down on the record. So, please, when you
16 hear a question, listen to its interpretation coming
17 through the headphones on the desk and, only when you
18 hear that it is completed, answer my question. Did you
19 understand that?
20 A. Yes, I understood.
21 Q. When and where were you born, Mr. Kevric?
22 A. I was born in Dragan Selo in the Jablanica
23 municipality in Bosnia-Herzegovina on 22 April 1953.
24 Q. What is your ethnic background and what is
25 your citizenship, Sir?
Page 11123
1 A. I am a Bosniak and a citizen of Bosnia and
2 Herzegovina.
3 Q. Can you tell us what is your education and
4 where you received it?
5 A. I graduated from high school in 1983, the
6 Military Economic Academy in 1987.
7 Q. What are you by profession, Mr. Kevric?
8 A. I am an officer by profession.
9 Q. So, you are a professional soldier; is that
10 correct?
11 A. Yes, I was a professional soldier of the
12 former Yugoslav People's Army and now I am an officer
13 -- a commissioned officer of the Bosnian Federation
14 Army.
15 Q. Mr. Kevric, where were you in early April
16 1992?
17 A. In early April 1992 I was in Banja Luka.
18 Q. From where did you come to Banja Luka on the
19 very eve of the war?
20 A. As a commissioned officer of the former JNA,
21 I was stationed in Ljubljana in the Republic of
22 Slovenia and when the conflict broke out in Slovenia,
23 with the 14th Corps, on 12 June 1992, we were
24 transferred to Banja Luka.
25 Q. Mr. Kevric, could you be wrong about the --
Page 11124
1 would you be wrong about the year of your transfer?
2 A. Yes, my apologies, it was in 1991, not 1992 .
3 Q. Thank you. Did there come a time in the
4 spring of 1992 when you came to Konjic?
5 A. During my service in Banja Luka I realised
6 that the Yugoslav People's Army was no longer the
7 people's army -- that is, it did not belong to all
8 people, that it was just the Serb people's army,
9 which was protecting just one people, and in the
10 morning hours of 13 April 1992 I fled.
11 Q. What was your specialisation as a
12 commissioned officer of the former JNA?
13 A. Commissioned officer of the former JNA -- my
14 specialisation was logistics, that is, quartermaster.
15 Q. What was your rank in the former JNA?
16 A. In the former JNA, I had the rank of major.
17 Q. What is your rank in the Federation of
18 Bosnia-Herzegovina army?
19 A. In the Federation of Bosnia-Herzegovina army
20 I have a rank of a colonel.
21 Q. When on 13 April 1992 you arrived in Konjic,
22 did you report to certain structures there?
23 A. Upon arrival in Konjic on 13 April 1992
24 I reported to the municipal TO staff in Konjic. I did
25 not start working right away -- I only started working
Page 11125
1 on 17 April.
2 Q. When you reported to the municipal staff of
3 the TO Konjic, could you tell us who was the commander
4 of the TO?
5 A. When I reported, the commander of the TO
6 staff was Mr. Smajo Prevljak.
7 Q. When you started working on the 17th, that
8 is, at the municipal staff of the TO Konjic, what post
9 did you start working at?
10 A. When I started working, I worked as a
11 logistics officer -- I was appointed the assistant
12 commander for logistics by the new commander, Enver
13 Redzepovic.
14 Q. When did the commander of the municipal staff
15 of the TO Konjic change, that is, when Mr. Prevljak left
16 and Mr. Redzepovic assumed that post?
17 A. Mr. Redzepovic started working on the 17th as
18 commander.
19 Q. Can you tell me, what were the competencies
20 of the municipal assembly with regard to the
21 appointment of the commander -- who confirmed such
22 appointments in that period?
23 A. In that period and according to the law which
24 was in force in the former Yugoslavia, there was the
25 presidency and it was the body which confirmed this.
Page 11126
1 However, later, the presidency ceased having this role.
2 Q. Mr. Kevric, did I understand you correctly?
3 You are referring to the presidency of the republic, or
4 the SFRY -- I did not understand you well. To whom was
5 the TO headquarters subordinate -- that is what you
6 started explaining -- before the war?
7 A. There was a republican staff, then there were
8 district staffs and municipal staffs.
9 Q. Thank you. When you arrived in Konjic,
10 Mr. Kevric, in this TO staff where you started working
11 as a logistics officer, was Mr. Zejnil Delalic a member
12 of this staff?
13 A. Mr. Delalic was not a member of the municipal
14 staff.
15 Q. Do you know whether, at the time when you
16 arrived in Konjic, which was on the 13th and then you
17 started working on the 17th, in that period did
18 Mr. Delalic have any military post in Konjic?
19 A. Mr. Zejnil Delalic had no military post in the
20 municipality, that is, in the municipal staff.
21 Q. Before your coming to Konjic in April 1992,
22 did you know Mr. Delalic at all?
23 A. I had never met Mr. Zejnil Delalic prior to
24 April 1992. I knew his three brothers, but not him
25 personally.
Page 11127
1 Q. In April 1992, did you meet Mr. Delalic?
2 A. I met him in the town of Konjic on 18 April
3 1992.
4 Q. When you met him, what was he doing -- what
5 kind of activities was he engaged in when you met him?
6 A. Mr. Delalic was a civilian and talking to him,
7 he offered to assist me in supplying and equipping the
8 municipal staff of Konjic. He told me that he had
9 business contacts, that he knew a large number of
10 people, and that he could help me with supplies and all
11 the equipment, technical equipment and communications
12 equipment that we needed.
13 Q. The things you discussed with Mr. Delalic,
14 that is, the possibility of obtaining supplies, was
15 this for you, as a man responsible for logistics in the
16 TO, of significance at that time?
17 A. It was very important indeed, because the TO
18 staff of Konjic at the time did not have any technical
19 or material resources or communications equipment or
20 quartermaster supplies -- it did not have food depots,
21 because all the warehouses were located in the Ljuta
22 barracks, which the Yugoslav People's Army was
23 guarding.
24 Q. At that time, did you have any arms for TO
25 members who had been mobilised?
Page 11128
1 A. At that point in time, we had certain
2 quantities of weapons, mostly hunting weapons --
3 weapons legally held and for which individuals had
4 licences to wear those weapons. The MUP also had some
5 weapons and persons who sought to purchase weapons with
6 their own funds, because of the danger of war -- we had
7 no other sources.
8 Q. Mr. Kevric, did you, in April 1992, take over
9 a certain quantity of weapons from one of the barracks
10 of the former JNA?
11 A. In the second decade of the month of April
12 some weapons were taken over from the Celebici barracks
13 and some other technical and material resources, but
14 small quantities -- a unit of MUP and a small number of
15 TO members took over the Celebici barracks peacefully.
16 They took over the weapons and they transferred them to
17 the farm at Ovcari. According to lists, a part of
18 those weapons were issued to members of the units that
19 participated in the take-over of the Celebici barracks.
20 Q. Mr. Kevric, are you aware whether any
21 assignment with respect to the take-over of the Celebici
22 barracks was given to Mr. Delalic?
23 A. Mr. Delalic had the task of taking over those
24 weapons and transferring them in a motor vehicle to
25 Ovcari.
Page 11129
1 Q. Did you personally take over those weapons?
2 A. I personally took over weapons, together with
3 Sadih Dzumka, known as Diksa, and I stored it in the
4 warehouse at the farm at Ovcari.
5 Q. For how long were you a member of the TO
6 staff, or later the Army of Bosnia-Herzegovina?
7 A. I was a member from 17 April 1992 until the
8 end of 1992.
9 Q. I have just asked you about some activities
10 in the month of April. In view of the fact that you
11 were a member of the TO staff, do you know what was
12 happening in the first half of May 1992, in terms of
13 military activities?
14 A. In the first half of May 1992, we captured
15 the Ljuta barracks, we took over a certain part of the
16 armament -- we did not manage to take everything,
17 because the Yugoslav People's Army air force hit the
18 depot of the 114th Brigade, so that it was destroyed.
19 We took over the facility D0, known as "Ark", which is
20 the reserve command post of the army, the underground
21 facility there, and we captured the facility Zlatar.
22 Q. After this, Mr. Kevric, did all members of the
23 Yugoslav People's Army who did not join the ranks of
24 Territorial Defence -- did they all abandon Konjic?
25 Are you familiar with this?
Page 11130
1 A. Members of the Yugoslav People's Army,
2 through a side exit of the facility D0, abandoned the
3 facility and, together with the members who were
4 stationed at Zlatar, they were transferred by
5 helicopter, except for warrant officer Serif Grabovica,
6 whom they did not wish to take in the helicopter, even
7 though he was working with them.
8 Q. Mr. Kevric, do you know what were the
9 activities of Mr. Delalic in that period? We are
10 talking about the first two decades of the month of
11 May?
12 A. Mr. Delalic, at the beginning of April -- at
13 the beginning of -- I am sorry, at the beginning of
14 May, was authorised to go to Zagreb to obtain certain
15 quantities of material -- technical resources,
16 communication equipment and quartermaster supplies.
17 I may not be quite precise about this, but he stayed in
18 Zagreb until 19 or 20 May and, before Mr. Zejnil Delalic
19 returned, a convoy reached Celebici with weapons and
20 material technical supplies. A day or two later,
21 Mr. Delalic arrived with another two or three truck
22 loads of materiel and quartermaster supplies.
23 Q. Thank you. You told us, Mr. Kevric, that, for
24 the whole of 1992, you were a member of the Territorial
25 Defence staff from 17 April. Then you can certainly
Page 11131
1 tell the court whether that Territorial Defence staff
2 was a small staff, a medium sized one, or one compared
3 to a more developed entity?
4 A. The staff we had at the time was a large
5 staff that corresponded to a developed structure.
6 Q. Some time in April did the Territorial
7 Defence staff of Bosnia and Herzegovina require from
8 your staff certain information about persons who may be
9 engaged in the staff?
10 A. Yes. As I was working in the staff, the body
11 for personnel required each member to give his
12 particulars, so there were people who were working in
13 the staff already, and on the basis of applications by
14 former JNA members, they were engaged as members of the
15 staff. Then there were certain members who had not
16 been members of the JNA, but they were employed by the
17 staff because the members of the former staff of
18 Serb ethnic origin abandoned the staff.
19 MS. RESIDOVIC: I would now like the witness
20 to be shown a document and may it first be marked for
21 identification, please? I have a sufficient number of
22 copies for the court and for the Prosecutor.
23 (Handed).
24 THE REGISTRAR: Defence Exhibit D165/1.
25 MS. RESIDOVIC: I apologise -- we had only
Page 11132
1 one copy with two persons. It consists of a letter and
2 five annexes, so will you please take into
3 consideration this correction, because I have the full
4 number of pages with me here, so all the others may not
5 be complete.
6 Mr. Kevric, will you please look at this
7 document? Are you familiar with this document?
8 A. I am familiar with the contents of this
9 document. It was never given to me, but I know that it
10 was sent, because this information was required. I can
11 also recognise Enes Pajic, who was responsible for
12 personnel in the staff. He is still a member of the
13 army of the Federation of Bosnia-Herzegovina.
14 Q. Do you find on these lists your own name?
15 A. Yes, my name is number 1 on the list of
16 active military personnel working in the municipal TO
17 staff of Konjic.
18 Q. Mr. Kevric, can you confirm in this court that
19 you personally know that all these persons, at the time
20 indicated by the date when the list was compiled, were
21 in fact working in the TO staff as indicated in these
22 lists?
23 A. Yes. I know all these persons and the posts
24 they held at the time are indicated and their
25 qualifications are also indicated, with the exception
Page 11133
1 of, in the last part, Halilic, an active military
2 person -- he was killed during the war and he was an
3 officer in the quartermaster department, working with
4 me in the logistics department.
5 MS. RESIDOVIC: Your Honours, since these are
6 lists of members of TO staff on this date as indicated
7 on the list, that is, the end of April, and in view of
8 the fact that this witness has confirmed the
9 truthfulness of the contents and as this is a relevant
10 document, I tender it as a Defence exhibit.
11 JUDGE KARIBI-WHYTE: Yes.
12 MS. RESIDOVIC: Thank you.
13 JUDGE KARIBI-WHYTE: You may tender it.
14 MS. RESIDOVIC: Thank you.
15 Mr. Kevric, this list, as you have said, does
16 not include Zejnil Delalic, because he was not a member
17 of the TO staff, as you have said. But I have another
18 question to put to you. As you were a member of the TO
19 staff, or, rather, of the Army of Bosnia-Herzegovina
20 throughout 1992, can you tell the court whether
21 Mr. Delalic was at any time the commander of the
22 municipal Territorial Defence staff?
23 A. Mr. Zejnil Delalic was never performing the
24 duties of commander of the municipal TO staff.
25 Q. Mr. Kevric, did Mr. Zejnil Delalic at any point
Page 11134
1 in time in the course of 1992 -- was he a member of the
2 staff of the Territorial Defence of Konjic?
3 A. Mr. Zejnil Delalic was never a member of the
4 TO staff.
5 Q. Mr. Kevric, are you familiar with the
6 composition of your staff and its structure?
7 A. I am familiar with the structure of the TO
8 staff. I am familiar with all the persons who were
9 working in the staff.
10 MS. RESIDOVIC: I would now like to ask the
11 witness to be shown a chart from the third volume of
12 the expert witness document, V-D/5. I have it here in
13 Bosnian in a sufficient number of copies, but I think
14 it may be shown to the court and the witness on the
15 ELMO as well as the chart in English, which is included
16 in the folder. (Handed).
17 Could the English version be placed on the
18 ELMO and could the witness be given the Bosnian
19 version? I cannot see it on the ELMO. We do not have
20 it on the monitor.
21 Can we see the chart in English on the ELMO,
22 please?
23 Mr. Kevric, when pointing to anything, will
24 you please move it so that the court can see it and all
25 the other participants in the hearing? First, may
Page 11135
1 I ask you whether you recognise what this chart means?
2 A. This is a diagram of the structure of the
3 staff. Heading the staff is the commander of the
4 municipal staff of Territorial Defence.
5 Q. Before beginning any explanations, do you
6 personally figure here as a person serving in a
7 particular area on this chart?
8 A. Yes, I am here as a logistics body.
9 Q. Will you indicate what part of it that is?
10 A. The rear -- it is this part (witness
11 indicates).
12 Q. Was your rear agency a developed structure,
13 did it have services, officers in charge of those
14 services and the like?
15 A. Yes, it did. The rear agency was developed
16 and all the services were represented from the
17 quartermasters, transportation service, technical,
18 medical, building construction, financial -- all of
19 these services had one or two officers working there.
20 Here we have the supply service, traffic service and
21 technical service and these are indicated on the chart.
22 Q. Could you tell us who were the commanders of
23 the municipal TO Defence staff in the course of 1992?
24 A. The commander of the staff of the Territorial
25 Defence of Konjic was first Redzepovic, then Esad
Page 11136
1 Ramic, then Omer Boric, also Catic Mirsad, and after
2 that, Enver Tahirovic.
3 Q. Thank you. Can you confirm, Mr. Kevric, that
4 this is a truthful diagram of the structure of the
5 Territorial Defence staff, all the staff of the armed
6 forces of Konjic in 1992?
7 A. I confirm that this organisational chart is
8 indeed correct.
9 MS. RESIDOVIC: In view of the fact that the
10 witness is a part of the staff represented on this
11 diagram and that he confirmed the truthfulness of the
12 same, I would like to tender it into evidence.
13 JUDGE KARIBI-WHYTE: You may do so.
14 MS. RESIDOVIC: Thank you. Can I have the
15 number, please.
16 THE REGISTRAR: This is the number D145/1,
17 annex 5D, 5/1.
18 MS. RESIDOVIC: Mr. Kevric -- no, let me
19 rephrase that question -- which were the defence forces
20 of Konjic at the time, in addition to the Territorial
21 Defence?
22 A. Apart from the Territorial Defence, there
23 were HVO units and there was the MUP of the Konjic
24 municipality.
25 Q. When taking over military facilities in the
Page 11137
1 first 10 days of May, did the HVO participate with you
2 -- both the HVO and the MUP -- in those operations?
3 A. Yes. Initially, as I have already said,
4 participating were HVO units and reserve units of the
5 police -- the MUP.
6 Q. Mr. Kevric, do you know whether, in that
7 period, that is, the first 10 days of May 1992, were
8 there any attempts for the control and command over TO
9 and HVO units to be united, and was some kind of a
10 joint body set up?
11 A. Yes -- yes, for the operations to be prepared
12 properly and for the town of Konjic to be defended, the
13 representatives of the TO staff of Bosnia-Herzegovina
14 insisted on the formation of joint commands and a joint
15 command was indeed formed on 12 May and after a session
16 of the war presidency, that joint command was
17 appointed.
18 MS. RESIDOVIC: Your Honours, would it be
19 convenient for us to break now before I go on to
20 another area?
21 JUDGE KARIBI-WHYTE: I think so. We can
22 break now. We will reassemble at 2.30.
23 (1.00 p.m.)
24 (Luncheon adjournment)
25 (2.35 p.m.)
Page 11138
1 (The witness entered court)
2 JUDGE KARIBI-WHYTE: Please remind the
3 witness he is still on his oath.
4 THE REGISTRAR: I remind you, Sir, that you
5 are still under oath.
6 THE WITNESS: I understand.
7 MS. RESIDOVIC: Your Honours, the witness
8 requested of me, and I would like to suggest that we
9 all try to speak a little bit louder, and also the
10 witness had some damage in his ears as a consequence of
11 war, so if we could turn up the volume -- if I can ask
12 the technical booth if we can turn it up so that my
13 microphone could be put on louder and also especially
14 what the interpreters are saying.
15 JUDGE KARIBI-WHYTE: My understanding of
16 this equipment is that you can increase your own volume
17 -- each one can increase their own volume.
18 MS. RESIDOVIC: Thank you.
19 Mr. Kevric -- your Honours, may I proceed the
20 court?
21 JUDGE KARIBI-WHYTE: Yes, you may.
22 MS. RESIDOVIC: Thank you. Before the break,
23 Mr. Kevric, if you will recall, we were talking about
24 the establishment of the joint command. Can you please
25 tell me whether you personally were a member of the
Page 11139
1 joint command?
2 A. Yes, I was a member of the joint command.
3 I was on duty as an assistant commander for logistics.
4 Q. Are you familiar with the structure of the
5 joint command during the period when it was
6 operational?
7 A. Yes, I am familiar with the structure of the
8 joint command and I can also explain it.
9 Q. Very well. I will ask the questions. Can
10 you please tell me who was the commander of the joint
11 command and who was his deputy, that is, who was his
12 chief of staff?
13 A. The commander of the joint command was
14 Mr. Esad Ramic and his deputy was Mr. Zebic.
15 Q. At the very beginning, was another person the
16 commander of the joint command -- that is, not at the
17 very beginning but during an initial period?
18 A. Yes, at first the commander was Omer Boric.
19 Q. And what were Esad Ramic and Omer Boric --
20 what positions did they hold in the staff of the
21 Territorial Defence before they moved to these
22 positions in the joint command? Did you understand my
23 question? What duties did Omer Boric and Esad Ramic
24 have in the TO staff?
25 A. I could not give you precise answers to
Page 11140
1 that. I know that Esad Ramic was the commander of the
2 staff of the Territorial Defence, but I know that at
3 one point he was an operations officer. When Ramic was
4 in operations, then I know that Omer Boric was the
5 commander of the TO.
6 MS. RESIDOVIC: Very well, thank you.
7 I would now like to show the witness a chart
8 of the structure of the joint command. I have enough
9 copies both in Bosnian and English. I would like them
10 distributed to the Trial Chamber and everybody else.
11 (Handed). .
12 Mr. Kevric, would you please look at this
13 chart carefully and then I will ask you, when I ask
14 questions of you regarding the chart, that you look at
15 the ELMO and that you use the pointer in order to show
16 me the appropriate duties that I will be asking you
17 about. Can you tell me, in the upper rectangle where
18 you have commander of the joint command you have two
19 names, Esad Ramic and Omer Boric. Can you tell me, did
20 these people -- these two persons relieve each other as
21 commanders of the joint command?
22 A. Yes, they did.
23 Q. Can you tell me whether, during the period
24 when Omer Boric and Esad Ramic were commanders of the
25 joint command, that is, in both those periods, was the
Page 11141
1 same chief of staff on duty and is that also marked in
2 the appropriate rectangle?
3 A. Yes. Throughout the period of this relevant
4 time, Dinko Zebic was the chief of staff.
5 Q. What was the role of Dinko Zebic in the HVO?
6 A. Dinko Zebic was on duty as commander of the
7 HVO.
8 Q. Could you please show me, what was your place
9 in this particular organisational scheme that you
10 occupied?
11 A. (Witness indicates).
12 Q. Mr. Kevric, within your department, that is,
13 within your section of the joint command, were there
14 other services involved which are represented on this
15 chart?
16 A. Yes, in this chart several services were
17 indicated. The medical, traffic, construction services
18 are also indicated.
19 Q. Mr. Kevric, is this a truthful representation
20 which shows that both the members of the HVO and the TO
21 were equally represented in the joint command?
22 A. Yes, it is a truthful representation and it
23 is truthful in terms of representation of both the HVO
24 and the TO members.
25 Q. As far as you know, during which period did
Page 11142
1 this joint command function as it is presented here on
2 this chart?
3 A. This joint command functioned up until the
4 preparation for the operations at Borci.
5 Q. Mr. Kevric, was Mr. Zejnil Delalic at any time
6 commander of the joint command?
7 A. Mr. Zejnil Delalic was at no time commander of
8 the joint command, nor was he a member of the joint
9 command.
10 Q. Was Zejnil Delalic during this period at any
11 time a superior officer in terms of the joint command?
12 A. No, Mr. Zejnil Delalic was never a superior
13 person to the joint command.
14 MS. RESIDOVIC: Your Honours, since this
15 witness authenticated this chart, since he was a part
16 of the structure displayed here and since this is a
17 relevant chart, I tender it into evidence.
18 JUDGE KARIBI-WHYTE: You can tender it.
19 MS. RESIDOVIC: Thank you. This chart has
20 been admitted under the number that it was marked for
21 identification?
22 THE REGISTRAR: It is admitted as Defence
23 Exhibit D166/1.
24 MS. RESIDOVIC: Thank you.
25 Mr. Kevric, did you have a relationship of
Page 11143
1 cooperation with the HVO and MUP, even at the time when
2 there was no joint command between the TO and the HVO?
3 A. Yes, we did have a relationship of
4 cooperation, that is, during the initial operations
5 during the take-over of the Ljuta barracks and the
6 facility at Zlatar and what I stated at the beginning
7 -- the take-over of the Celebici barracks, which was
8 only with the members of MUP.
9 Q. Was the Konjic HVO accepting the unity of
10 command and the supreme command of the Army of
11 Bosnia-Herzegovina?
12 A. No, the HVO did not accept the superiority of
13 the TO staff of Bosnia-Herzegovina.
14 Q. Who, during 1992, was the superior structure
15 over the units, that is, the staff of the Konjic HVO?
16 A. The staff that was superior to the Konjic HVO
17 staff was the staff in Grude.
18 Q. Mr. Kevric, who was the superior body to the
19 station of public security in Konjic?
20 A. The Ministry of Internal Affairs of
21 Bosnia-Herzegovina was superior to the station of
22 public security in Konjic.
23 Q. Which was your superior command, that is,
24 either the staff or the command which was superior to
25 the municipal staff in Konjic in 1992?
Page 11144
1 A. In the course of 1992, the staff of TO in
2 Bosnia-Herzegovina was superior to the municipal staff
3 TO -- until 17 November of that year, when the 4th
4 Corps was formed and, from then on, the TO staff in
5 Konjic is subordinate to the 4th Corps command.
6 Q. After the establishment of the joint command,
7 were certain joint combat operations prepared and then
8 implemented?
9 A. Yes, there were some joint combat operations
10 which were carried out in the area of Bradina.
11 Q. As a member of the TO staff, do you know who
12 issued, that is, who was signing the orders for combat
13 operations?
14 A. The orders for combat operations were signed
15 jointly. The commander of the joint command and the
16 chief of staff would sign them.
17 MS. RESIDOVIC: Can the witness now please be
18 shown a document which has been marked in the third
19 volume of the expert material and which had been
20 admitted into evidence, so that I could ask certain
21 questions. I have enough copies for the Chamber and
22 for my colleagues and for the Prosecution. (Handed).
23 Mr. Kevric, would you please look at this
24 order?
25 Please, if the document has already been
Page 11145
1 marked, would you tell me its number?
2 THE REGISTRAR: This document has been
3 already marked. It is D145/1, annex 5D, 15.
4 MS. RESIDOVIC: Thank you.
5 Mr. Kevric, have you had a chance to look
6 through this document?
7 A. Yes, I did look at it.
8 MS. RESIDOVIC: Was this document issued on 25
9 May 1992 at the time when the joint command was
10 functioning?
11 JUDGE JAN: 27 May, not 25 May.
12 MS. RESIDOVIC: Yes, 27 May?
13 A. Yes, this document was issued at a time when
14 the joint command was functioning.
15 Q. Could you tell me whether this was a usual
16 way in which documents, that is, orders, were signed by
17 the joint command, that is, the documents that were
18 issued by the joint command?
19 A. Yes, this is the usual way in which all
20 documents were signed when there was agreement about
21 mutual participation in combat operations.
22 Q. Mr. Kevric, do you personally know of this
23 joint order which was issued on 27 May 1992?
24 A. I did not understand your question very well.
25 Q. Do you personally know of the existence of
Page 11146
1 this order that you are now holding in your hand?
2 A. I received this order, because I had to
3 support these units in the event that they needed
4 logistic support.
5 Q. Mr. Kevric, are you personally familiar with
6 who was the responsible commander in the combat
7 operations for the preparation of units, the course and
8 outcome of the combat operations?
9 A. Yes. The person responsible for combat
10 operations was Mr. Zvonko Zovko who was in command of
11 the unit, who was situated on Mount Preslica.
12 MS. RESIDOVIC: In view of the fact that this
13 exhibit has already been admitted into evidence as a
14 Defence exhibit, the witness has just confirmed the
15 truth of its contents. May it now be returned into the
16 record?
17 Mr. Kevric, do you know whether, after the
18 Operation Donje Selo, military weapons were found and
19 seized from the inhabitants of that village?
20 A. Yes, weapons were found on the inhabitants of
21 Donje Selo and the technical service that was assigned
22 to collect those weapons took over the weapons found
23 from the military police commander, Pijo Luicevic, the
24 police of the HVO. On that occasion up-to-date
25 weaponry was found, machine-guns, M80 of the latest
Page 11147
1 date, with a folding butt used by units of the former
2 Yugoslav People's Army, that is, by armoured units.
3 Q. Did the technical service that collected
4 those weapons come under your authority?
5 A. The technical service was under my control
6 and it was the service that collected and registered
7 the weapons.
8 Q. Thank you. Mr. Kevric, will you tell me,
9 please, whether, after the battles for the liberation
10 of Bradina, weapons were found, captured and collected
11 from the persons who participated in the fighting at
12 Bradina?
13 A. Yes, weapons were found among the inhabitants
14 of Bradina. Some of those weapons were immediately
15 issued to units participating in the combat operations
16 and a smaller share was taken to the Celebici barracks.
17 Q. What was held at the Celebici barracks where
18 the weapons were placed -- you referred to the Celebici
19 barracks just now?
20 A. In the Celebici barracks, there was an
21 underground facility, which was used to store fuel in
22 barrels and, as this was the safest facility protected
23 from the air force, we had that facility to store the
24 weapons there.
25 Q. Thank you. Mr. Kevric, you said that orders
Page 11148
1 on which agreement was reached were signed by the
2 commander of the TO and the commander of the HVO. Will
3 you tell me, please, regarding the appointments made by
4 the joint command, who would sign those appointments?
5 A. Appointments to positions in the formations
6 by the joint command would be signed by the commander
7 and the chief of staff.
8 Q. Did you personally, at that time, when you
9 were appointed assistant commander for logistics -- did
10 you have an appointment signed in that way?
11 A. Yes, I had an appointment that was signed in
12 that way.
13 Q. Did Zejnil Delalic, as far as you know, ever
14 sign any appointment that was signed by the joint
15 command?
16 A. As far as I know, Mr. Zejnil Delalic never
17 signed an appointment, because he was not a member of
18 the joint command.
19 Q. Mr. Kevric, do you know whether the war
20 presidency of Konjic municipality appointed Zejnil
21 Delalic as coordinator between the war presidency and
22 the defence forces?
23 A. Yes, I am aware of that. The war presidency
24 did appoint Mr. Zejnil Delalic in the second half of
25 May. I really could not tell you the exact date,
Page 11149
1 whether it was the 19th or the 18th -- I do not know
2 exactly.
3 Q. Do you know what activities Mr. Delalic
4 predominantly engaged in while holding this position of
5 coordinator?
6 A. Mr. Zejnil Delalic mainly engaged in logistic
7 matters -- supplies of materiel, equipment, food,
8 communications equipment. Also, Mr. Zejnil Delalic was
9 active in the project of setting in motion a mini
10 railway from Konjic to Jablanica and, later on, from
11 Konjic to Tarcin. He was also involved in the
12 transportation of a vast number of refugees arriving in
13 Konjic from eastern Bosnia and eastern Herzegovina. He
14 was also active as a coordinator in linking up the
15 electricity grid.
16 Q. Mr. Kevric, let me ask you, in view of these
17 activities that you have described and the work that
18 you yourself performed, did you personally have
19 occasional or frequent contacts with Mr. Delalic
20 regarding his activities?
21 A. Because of my very considerable
22 responsibilities at the time, ranging from the
23 organisation of the army, or, rather, the logistic
24 body, and logistic units which had to carry out tasks
25 assigned to them, I would occasionally have contact
Page 11150
1 with Mr. Zejnil Delalic, but I authorised my heads of
2 services and especially the head of the technical
3 transportation and building construction service to be
4 able to contact Mr. Zejnil Delalic and, on several
5 occasions, I was officially absent from the town of
6 Konjic, so I was away looking for materiel and other
7 equipment from other units and other staffs.
8 Q. Mr. Kevric, in view of the fact that you had
9 such a difficult task to perform, that is, while
10 fighting was going on, to try to find the resources
11 required for life and for combat, tell me whether the
12 TO staff had several requests for logistic support from
13 the civilian authorities?
14 A. The TO staff really did receive a vast number
15 of requests, starting from requirements in terms of
16 food stuffs, containers for the transportation of food,
17 blankets, communication equipment, and other technical
18 supplies.
19 Q. Did the war presidency have the legal duty to
20 provide logistic support for the defence?
21 A. The war presidency of Konjic municipality was
22 obliged, by law, to provide what I have already listed,
23 because we, as the TO staff, did not have any reserves,
24 nor the possibility of receiving regular supplies from
25 the Bosnia-Herzegovina TO staff.
Page 11151
1 Q. Because of these numerous requests and very
2 limited possibilities, did the need arise for
3 coordinating views and coming to an agreement that
4 would then be addressed to the war presidency?
5 A. There was a need for coordination, especially
6 when planning combat operations so as to convey to the
7 war presidency the real needs, because, under those
8 conditions, the war presidency had to be very
9 economical and in order to avoid members of the army
10 contacting the war presidency directly, the coordinator
11 would occasionally attend when such logistic problems
12 were discussed and would inform the war presidency.
13 Q. Mr. Kevric, did Mr. Zejnil Delalic, as a
14 coordinator -- was Mr. Zejnil Delalic at any point in
15 time a person of superior authority in relation to you,
16 or the TO staff, or the war presidency?
17 A. No, Mr. Zejnil Delalic was never a superior
18 for me -- I had my own staff commander and the joint
19 command. I received orders only from them.
20 Q. In those agreements regarding your logistic
21 needs and the coordination of those needs, do you know,
22 or did you ever see the coordinator signing any such
23 document?
24 A. Yes, I did see it, mostly documents when the
25 meeting was attended by the coordinator in connection
Page 11152
1 with those logistic needs. In the interests of
2 expediency while the army was being set up and in order
3 to provide logistic support as quickly as possible,
4 Mr. Zejnil Delalic would attend as a witness so as to be
5 able to convey the information to the war presidency.
6 MS. RESIDOVIC: Could the witness be shown two
7 documents which the Prosecutor has had marked as his
8 own exhibits? I do not have the numbers, but I have
9 sufficient copies for the Trial Chamber and the
10 Prosecution, and these are documents dated 6 June and 8
11 June. (Handed). I think the number is P211 -- I am
12 not sure about the other one. The documents have
13 already been marked for identification by the
14 Prosecution. I am not going to tender them into
15 evidence by the Defence; I just have a question to put
16 to the witness in connection with these documents.
17 Could you please tell me under what number
18 they have been marked?
19 THE REGISTRAR: The order dated 8 June 1992
20 is D167/1 and the order number 1/5, 92. The other
21 order number 1/4, 92 is D168/1.
22 MS. RESIDOVIC: Mr. Kevric, will you please
23 look at this document dated 6 June
24 called "organisational order"? Tell me, please, does
25 an order of this kind have anything to do with the
Page 11153
1 affairs you were engaged in, that is, logistics?
2 A. Yes, this kind of order is related to
3 logistic activities, because we did not have in our
4 possession a sufficient number of motor vehicles which
5 could be used for the transportation of artillery
6 pieces.
7 Q. Thank you. Will you please look at the other
8 document, dated 8 June, called "order"? Will you
9 please look at the document first? Is this order
10 related in any way to the activities you engaged in
11 related to logistics?
12 A. This order is also related to the logistics
13 agency -- before sending a unit to perform a particular
14 task a logistic unit had to supply the unit with all
15 the materiel and equipment, meals and other supplies.
16 Q. Was this order submitted to your agency as
17 well?
18 A. Yes, this order was submitted to the
19 logistics agency for the above-mentioned reasons.
20 Q. Mr. Kevric, were both of these orders signed
21 in the customary way by the joint command, that is,
22 both by the TO commander and the HVO commander?
23 A. Yes, they were signed as shown on this
24 document.
25 Q. As you are a professional military man,
Page 11154
1 Mr. Kevric, when does an order become an order that you
2 have to comply with?
3 A. For me, an order is an order when it is
4 signed by my commander. If he signs that order, then
5 I can act on it.
6 Q. Mr. Kevric, if a document, even it is called
7 an "order", is signed by a person who is not your
8 commander, or your superior, does it oblige you in any
9 way?
10 A. If an order is signed by someone else, it is
11 not obligatory for me as an assistant commander of
12 logistics.
13 Q. In 1992, did you also act in the way that you
14 have just told us? In other words, did you act in 1992
15 only on the basis of orders by your authorised
16 superiors?
17 A. As an old soldier and familiar with the rules
18 on the chain of command, that is how I always acted,
19 and I think this is well known by everyone in Konjic,
20 that I never did anything for which I was not ordered
21 to act by my commander or about which I had not
22 consulted him.
23 MS. RESIDOVIC: Thank you, Mr. Kevric. These
24 documents can now be returned to the files.
25 Mr. Kevric, do you know that, for a time in
Page 11155
1 1992 -- that at some point in time the supreme command
2 formed Tactical Groups, or, to be more precise, do you
3 know whether a Tactical Group known as Tactical Group 1
4 was formed?
5 A. I do know that Tactical Groups were formed
6 and particularly Tactical Group 1 and Tactical Group 2.
7 Q. What was the reason, Mr. Kevric, for the
8 formation of Tactical Groups by the supreme command?
9 A. The reason for the formation of Tactical
10 Groups 1 and 2 was to lift the siege of the city of
11 Sarajevo.
12 Q. Do you know, Mr. Kevric, who was the first
13 commander of Tactical Group 1 and where it was based?
14 A. The commander of Tactical Group 1 was
15 Mr. Mustafa Polutak, a former lieutenant-colonel in the
16 former Yugoslav People's Army. Tactical Group 1 was
17 based in Pazarici.
18 Q. As a member of the staff, you probably know
19 and please will you tell the Trial Chamber if you do,
20 whether, at some time early in June, a group of
21 soldiers from Konjic was subordinated to the commander
22 of the Tactical Group?
23 A. At the beginning of June, the Gajret unit was
24 subordinated to Tactical Group 1 which was sent from
25 the town of Konjic.
Page 11156
1 Q. Was this the first group of soldiers leaving
2 Konjic in the direction of Sarajevo?
3 A. Yes, that was the first time that, from the
4 municipal staff, a unit was going outside the area of
5 responsibility of the municipal staff and was being
6 placed under the command of another unit.
7 Q. Did you, in the staff, have certain problems,
8 bearing in mind what you have told us so far, in
9 providing the unit with the necessary uniforms, boots
10 and everything else?
11 A. Yes, we did have problems, as I have already
12 said, because we were unprepared for the war and we had
13 no reserves, and in order to equip those units with
14 communications equipment, meals, cigarettes, we had to
15 engage in preparations before sending this unit to
16 Tactical Group 1.
17 Q. Who was particularly active in carrying out
18 this task assigned to him with regard to providing
19 supplies and equipment for this unit?
20 A. Particularly active in this respect was
21 Mr. Zejnil Delalic, who ensured communications
22 equipment, quartermaster supplies, that is, uniforms,
23 and cigarettes.
24 Q. Before this group in Pazarici was
25 subordinated to Mr. Polutak, did you, in the staff, talk
Page 11157
1 about or reach any decisions on how this unit should be
2 outfitted?
3 A. Yes. Since this was the first time that a
4 unit was being sent outside of the area of
5 responsibility of the municipal TO command, we decided
6 to make it a celebration and so members of the war
7 presidency and members of the municipal staff and
8 Mr. Zejnil Delalic was there together with members of
9 the war presidency and TO headquarters.
10 Q. At the time of the send-off of these units,
11 did Mr. Delalic have any command role in the TO staff?
12 A. No, Mr. Zejnil Delalic had no command
13 responsibility in the TO staff. He was there as a
14 guest and he was shown special respect, because he was
15 able to provide all this equipment and cigarettes, and
16 we were honoured to have him as our guest.
17 Q. Mr. Kevric, do you know who ordered the
18 establishment of this unit, Gajret?
19 A. It was the commander of the TO staff who
20 ordered the establishment of the Gajret unit.
21 Q. Mr. Kevric, were you personally present at
22 this celebration when the unit was sent off?
23 A. I was personally present there and, after
24 this official part and the parade, I went to Tarcin
25 with the unit and with some officers. At Tarcin we
Page 11158
1 stopped because of security reasons -- we could not go
2 all the way to Pazaric. Subsequently, the unit was
3 taken to Pazaric and then engaged in its task, which
4 had to do with the lifting of the siege of Sarajevo.
5 MS. RESIDOVIC: Your Honours, in order to
6 identify the send-off of this Gajret unit, I wanted to
7 have the videotape shown where Mr. Kevric was also
8 present, but knowing your position in relation to
9 showing it again, I do not know if I should play it
10 again, or maybe just continue with the rest of the
11 questions without it.
12 JUDGE KARIBI-WHYTE: It is not necessary --
13 it is not in dispute whether there was a send-off force
14 or not. Does it matter if we play the tape? You can
15 carry on.
16 MS. RESIDOVIC: This is precisely why I asked
17 you, your Honours. I think the only controversy about
18 it is that it relates to evidence according to which my
19 client is a person of superior authority, but I do not
20 need to belabour that, so I think that there is no
21 controversy over the fact whether the witness was
22 there. So, what I am going to do is I am going to
23 limit myself to asking questions about his role in it.
24 JUDGE KARIBI-WHYTE: Thank you very much.
25 MS. RESIDOVIC: I am not going to try to show
Page 11159
1 it again. Trust me, I do not wish to go into any kind
2 of debate or argument over this.
3 So, Mr. Kevric, can you please tell me, when a
4 soldier addresses a superior officer, that is, in that
5 period, how would the soldier address him?
6 A. As a soldier, when I would address my
7 commander, I would address him as "Sir" and the rank,
8 say "Major", or if there was no rank, then I had to
9 tell him "Sir" or "Mr.", and say "Commander". So a
10 soldier would also have to say, "Mr. Commander, soldier
11 such and such needs such and such."
12 Q. Mr. Kevric, if the person whom you are
13 addressing has no military function, you do not need to
14 address him with these titles; is that correct?
15 A. Yes, that is correct.
16 Q. Thank you. Let me ask you a direct
17 question. During this celebration when you were
18 sending off these first units to Pazarici in order to
19 be subordinated to Mr. Polutak, did Mr. Zejnil Delalic
20 have any position of superiority, either military or
21 civilian? You are a witness of these events.
22 A. No, Mr. Zejnil Delalic had no military or
23 civilian function there.
24 Q. Mr. Kevric, do you know anything about the
25 subsequent combat operations that were conducted by the
Page 11160
1 staff of the Territorial Defence, or the joint command,
2 or, more specifically, did you make any preparation in
3 your command and in your staff for certain combat
4 operations?
5 A. Yes, since I was a member of the staff, we
6 received an order from the TO staff of Bosnia to start
7 preparations for combat operations in the direction of
8 Borci and (INAUDIBLE).
9 Q. Did the HVO initially take an active role in
10 preparation of these combat operations?
11 A. Yes, in our joint meetings, they were at
12 first agreeing to joint combat operations. However,
13 when we were supposed to go and start these operations,
14 the HVO pulled out from this operation at Borci.
15 MS. RESIDOVIC: I would like to ask the usher
16 to help me give the witness documents which we have
17 already seen. They are in volume III of the supplement
18 to the expert report of the military expert, and they
19 are marked V-D/24 and V-D/25. I would like to ask
20 certain questions. I am not going to ask again that
21 these documents be admitted, since they have already
22 been admitted before. (Handed).
23 Could you first look at this document which
24 is dated 12/6/92? Mr. Kevric, as a member of the TO
25 staff, are you familiar with this order of this TO
Page 11161
1 staff of the Republic of Bosnia-Herzegovina?
2 A. Yes, I am familiar with this order, because,
3 as a member of the TO staff, I was involved in the
4 preparation of this order, in its logistical aspects.
5 Q. Mr. Kevric, when you received this order, did
6 you start joint preparations for the operation which
7 was to follow in Borci?
8 A. Yes, we started the preparations for the
9 aspect that was envisaged by the TO. We immediately
10 requested additional equipment and food supplies so
11 that the units would be completely ready when they go
12 into combat. However, later, when the HVO pulled out
13 from this operation, the TO staff found itself in a
14 very difficult situation, because now it was virtually
15 impossible to carry out this operation. So, we had an
16 emergency mobilisation, but these new conscripts were
17 not prepared and then the terrain in which these
18 operations were to take place was very difficult.
19 Q. Very well, Mr. Kevric, I think you have
20 provided enough details about what I wanted to address
21 here. I would now like to ask you to look at the
22 document dated 25 June 1992. It is addressed to the
23 HVO staff, to the attention of Dinko Zebic.
24 Mr. Kevric, since Mr. Dinko Zebic was the chief
25 of staff in the joint command, can you tell me whether
Page 11162
1 Dinko Zebic was personally involved in part of the
2 preparation for this operation?
3 A. Yes, Mr. Dinko Zebic wanted to take part in
4 this operation with his unit. However, this did not
5 happen and I do not know the reason why the HVO did not
6 take part in this operation, but he was the point
7 person in the planning of this combat operation.
8 Q. Thank you. What was this operation called --
9 what was its name?
10 A. This operation's name was Oganj.
11 Q. In this document certain Tactical Groups are
12 indicated. My first question to you, Mr. Kevric, is
13 whether these Tactical Groups which are mentioned in
14 this document have anything to do with the Tactical
15 Groups established by the main staff of the armed
16 forces of Bosnia-Herzegovina for the lifting of the
17 siege of Sarajevo?
18 A. These Tactical Groups really have nothing to
19 do with Tactical Groups 1 and 2, which were established
20 by the staff of the TO of Bosnia-Herzegovina. These
21 are Tactical Groups that are at about 100 or 150 men
22 strength and these were just in limited areas and they
23 were just marked 1, 2, 3 and 4, to point to the
24 particular areas. They have nothing to do with those
25 Tactical Groups 1 and 2.
Page 11163
1 Q. Very well, Mr. Kevric. Can you now tell me,
2 after parting ways with the HVO, who issued the order
3 for the combat Operation Oganj?
4 A. The order for the Operation Oganj was issued
5 by the commander of the TO Konjic, Mr. Esad Ramic.
6 Q. Can you tell the Trial Chamber who was the
7 commander of the Oganj Operation?
8 A. The commander of the Operation Oganj was
9 Mr. Esad Ramic.
10 Q. Do you know -- actually, let me ask you
11 first, how long did this combat operation last?
12 A. The combat operation Oganj lasted for about a
13 month, or, more precisely, it started on 27 June and
14 ended on 30 or 31 July.
15 Q. During the Operation Oganj, did a new
16 commander of this operation arrive?
17 A. Yes, a change took place, because Mr. Esad
18 Ramic, the commander of this operation, was slightly
19 wounded and Mr. Midhat Cerovac acted as commander of
20 this operation and at that time he was chief of staff.
21 Q. Mr. Kevric, do you know whether Mr. Zejnil
22 Delalic took part in this combat operation which had
23 its codename Oganj?
24 A. Mr. Zejnil Delalic, as coordinator, was given
25 the task to be at Vranjske Stijene in order to
Page 11164
1 coordinate with me. I was in the town of Konjic, or,
2 more accurately, in the brewery, and we were to
3 coordinate all units that were out in the field,
4 because for this operation, we had several points where
5 different units were placed and in order to facilitate
6 the communication with me in Konjic and with Celebici,
7 we had these several points.
8 Q. Mr. Kevric, was at any time during the
9 Operation Oganj, Mr. Zejnil Delalic become either the
10 commander of this operation or any person of superior
11 authority in this operation?
12 A. No, Mr. Delalic did not become a person of
13 superior authority, nor did he take part in the combat
14 operation, except in the sense that I have just
15 indicated.
16 Q. Thank you. Mr. Kevric, let me now turn to
17 some further questions on issues that you would have
18 been familiar with as a member of the TO at that time.
19 I would first like to talk to you about the development
20 of the Territorial Defence in Konjic, that is, the Army
21 of Bosnia-Herzegovina in the town itself. You have
22 already testified to the document of 28 April in which
23 you informed the staff of the supreme command about the
24 persons who were already involved at that time. My
25 question to you is: at the beginning, were there any
Page 11165
1 officers of the former JNA in the TO staff, that is,
2 the officers with previous experience?
3 A. At the beginning, when I first came to
4 Konjic, there were three members of the former JNA.
5 Those were Mr. Dinko Zebic, Hamza Janovic and Enver
6 Redzepovic. They were former members of the Yugoslav
7 People's Army, and, when they left it, they reported to
8 the staff, and they were members of the staff before
9 I arrived there.
10 Q. During your testimony, you mentioned the
11 assembly, that is, a session of the 17th April of
12 1992. Can you please tell me, war started after the
13 declaration of independence. Did this State
14 immediately pass certain laws that had to do with
15 establishment of its armed forces?
16 A. Yes, a temporary instruction was adopted --
17 the former republican staff was renamed into the staff
18 of the Territorial Defence of Bosnia-Herzegovina; then
19 the district staffs were established and the municipal
20 staffs, which were established in municipalities. The
21 municipal staff in Konjic, according to this
22 provisional instruction, was subordinate directly to
23 the BH TO staff, because the district staff in Mostar
24 was not functional at the time, and this was the case
25 until 17 November 1992.
Page 11166
1 Q. Mr. Kevric, that means that you had the
2 provisional instruction, which was issued by the TO of
3 Bosnia-Herzegovina as early as April?
4 A. Yes, based on this instruction, the commander
5 of the TO staff was no longer a member of war
6 presidency -- he is subordinate directly to the staff
7 of the TO of Bosnia-Herzegovina.
8 Q. Do you know whether, during that period, that
9 is, in April 1992, there was a mobilisation of the
10 population and how was the Territorial Defence in
11 Konjic organised?
12 A. After the decision of 17 April, a
13 mobilisation took place, that is, units started being
14 established and it depended on the settlements, or
15 where there were small communities, platoons were
16 formed and there was a detachment formed in Konjic.
17 So, these units were later grouped, so companies were
18 grouped into detachments and in Konjic there were about
19 12 detachments established in the end and then
20 different branches were formed, which was an
21 anti-aircraft company and artillery and then there was
22 one platoon left, which was a platoon to Brdjani.
23 Later platoons were established.
24 The first attempt to establish a brigade in
25 August failed, because of the combat operations, but
Page 11167
1 later on the brigades were established -- in October
2 and November the Suad Alic brigade was formed in Konjic
3 and another one in, and then finally the 4th Corps was
4 established and the municipal TO remains in place until
5 January 1994; however, now, under the command under the
6 4th Corps.
7 Q. You very briefly but very graphically showed
8 us the organisation and the development of Territorial
9 Defence, that is, the units of the TO staff in Konjic.
10 Can you tell me, in this development, from April until
11 November, was there a phase during this development
12 when there was a coordinator?
13 A. Could the Defence please repeat the
14 question? I did not understand it well.
15 Q. You explained to us how companies, platoons,
16 detachments, battalions, brigades were established. My
17 question to you now is: during the development of the
18 army, was there a phase in which the role of
19 coordinator was established in the army?
20 A. In the army, there was no such phase in which
21 there was a coordinator -- the role of coordinator.
22 MS. RESIDOVIC: Mr. Kevric, let us move to
23 another area.
24 JUDGE KARIBI-WHYTE: I think before you move
25 into that area, we will have a break. When we come
Page 11168
1 back, we will start in that area we are moving into.
2 (4.00 p.m.)
3 (A short break)
4 (4.35 p.m.)
5 JUDGE KARIBI-WHYTE: Will you please invite
6 the witness to come in?
7 I see two of you standing. What is it all
8 about?
9 MR. OLUJIC: Your Honours, with your
10 permission, as you can see, my client, Mr. Mucic, is not
11 in the courtroom. He has refused to come to the
12 courtroom, because the Registry has prevented him from
13 having contact with the investigator. At the same
14 time, he has not waived his right to be present in the
15 courtroom and for the hearing to continue.
16 JUDGE KARIBI-WHYTE: He has waived his right
17 to do that when he voluntarily and without any good
18 reason stays away. I think he should be allowed to
19 stay away until he decides to come back. We would not
20 allow anybody's disobedience or rudeness to intimidate
21 the Trial Chamber from doing the right thing. If he
22 wants to stay away, he is free to do so.
23 You may proceed, Ms. Residovic.
24 (The witness entered court)
25 MS. RESIDOVIC: Mr. Kevric, have you rested a
Page 11169
1 little?
2 A. Yes, I have.
3 Q. Before the break, I said that we would be
4 moving on to another issue. Tell me, please,
5 Mr. Kevric, do you know whether, in 1992, the war
6 presidency was superior in relation to the TO staff of
7 Konjic?
8 A. The war presidency of the municipality of
9 Konjic was never superior to the TO staff of Konjic.
10 JUDGE JAN: But you have already covered
11 that -- other witnesses have said that. How does it
12 help to get the same statement repeated?
13 MS. RESIDOVIC: Your Honours, I think that
14 the expert witness was the only one who spoke about
15 that. This is a fact witness. An expert speaks on the
16 basis of documents and this witness on the basis of
17 personal knowledge, so I thought it was worth hearing
18 it, and in view of the fact that in the folder of the
19 expert witness there are two orders that could affect
20 this witness, I would like those documents to be shown
21 to the witness so we can hear his opinion.
22 These are exhibits in the third volume of the
23 documents attached to the expert report under V-A/12
24 and V-A/16. I have a sufficient number of copies for
25 the Trial Chamber, for my colleagues and for the
Page 11170
1 Prosecution.
2 JUDGE KARIBI-WHYTE: The first statement he
3 made appeared to be conclusive as to whatever you want
4 to say. He clearly stated that. At no stage could the
5 war presidency be superior to the territorial group.
6 If you want to compound it by going further, you could,
7 but I think he said it all.
8 MS. RESIDOVIC: Your Honours, very briefly,
9 so we can hear the view of the witness -- I will not
10 tender this as exhibits, into evidence, but as these
11 are documents from that time period and they may be
12 familiar to the witness, perhaps it would be useful to
13 hear him on them.
14 Mr. Kevric, have you looked at these two
15 documents?
16 A. I have.
17 Q. Were both documents issued by the war
18 presidency?
19 A. Yes, both documents were issued by the war
20 presidency and signed by the president of the war
21 presidency of the municipality of Konjic.
22 Q. As they are similar in content and both
23 documents are orders, will you please look at the order
24 that might have applied to your area of responsibility,
25 saying that it is addressed to the rear agency, and
Page 11171
1 requiring a certain kind of behaviour. Mr. Kevric, will
2 you tell me -- let me first ask you whether you
3 received this order from the war presidency at any
4 time?
5 A. Yes, I received this order from the war
6 presidency. I am familiar with it. However, the same
7 order does not apply to the rear body and the TO staff,
8 because the war presidency cannot give orders to the TO
9 staff. For me, this was just an information and
10 nothing more -- without the permission or approval of
11 my commander, I could not carry out this task.
12 MS. RESIDOVIC: Thank you. That is all. Will
13 these documents be returned to the files, please?
14 Mr. Kevric, you have already told the court
15 that you were appointed in April as assistant commander
16 for logistics by the commander at the time, and then to
17 the joint command by commander Boric and the chief of
18 staff Zebic. In the course of the development of the
19 army, as you described before the break, were new
20 appointments made for the activities that you were
21 responsible for in the TO staff?
22 A. Yes. After the small difference with the HVO
23 because they did not participate in the Operation
24 Oganj, the commander of the TO staff appointed me again
25 assistant commander for logistics in the TO staff.
Page 11172
1 MS. RESIDOVIC: Could this document be marked
2 for identification and shown to the witness, please?
3 I have a sufficient number of copies for the Trial
4 Chamber, the Prosecution and my colleagues. (Handed).
5 Could you tell me the number, please.
6 THE REGISTRAR: Defence Exhibit D169/1.
7 MS. RESIDOVIC: Thank you.
8 Mr. Kevric, have you looked at this document?
9 A. I have looked at this document. It was
10 signed by commander Ramic and it appoints me assistant
11 commander for logistics.
12 MS. RESIDOVIC: Is this one of the
13 appointments you received in the course of 1992?
14 JUDGE JAN: There is one thing I am not able
15 to understand. Mr. Kevric had the rank of a major and
16 Mr. Ramic has the rank of a captain. How can a captain
17 be ordering a major around?
18 MS. RESIDOVIC: Perhaps Colonel Kevric could
19 explain this, because this was the first year of the
20 war -- as we heard from generals and others, there were
21 no ranks. There were just titles.
22 THE INTERPRETER: Microphone, your Honour, we
23 cannot hear you.
24 JUDGE JAN: But there must be ranks within
25 the TO. It was a military organisation.
Page 11173
1 MS. RESIDOVIC: I will ask Mr. Kevric. I am
2 not very knowledgeable about such things. Maybe he can
3 answer this question for you.
4 Did you understand the question, Mr. Kevric?
5 A. Yes, I fully understood the question and
6 I shall try and answer it. Mr. Ramic Esad is an officer
7 who completed the Academy of the Ground Forces for the
8 infantry. Therefore, he is familiar -- he is more
9 familiar with the planning of combat operations, he is
10 familiar with weaponry. I am a logistics man and
11 I could not be a unit commander. I could not be the
12 commander of the TO staff and that is the reason why
13 Mr. Ramic was appointed commander of the TO staff.
14 Q. Mr. Kevric, in the course of 1992, were there,
15 generally, ranks in the TO, or later the Army of
16 Bosnia-Herzegovina, and these ranks indicated here,
17 were they the ranks that you had in the former JNA?
18 A. No, there were no ranks. There were duties
19 by formations until 1994 when the Republic of
20 Bosnia-Herzegovina established ranks -- until then, we
21 only had duties such as commander, chief of staff --
22 the body for logistics, et cetera.
23 MS. RESIDOVIC: I hope you are satisfied,
24 your Honour, and as this is an appointment for
25 Mr. Kevric issued on 3 August by the commander of the
Page 11174
1 staff at the time, I think this document can be
2 admitted into evidence as a Defence exhibit.
3 JUDGE KARIBI-WHYTE: Yes, you may tender
4 that.
5 MS. RESIDOVIC: Thank you.
6 So Exhibit 169/1; is that right?
7 THE REGISTRAR: That is correct.
8 MS. RESIDOVIC: Mr. Kevric, do you know
9 whether Zejnil Delalic, for a period of time in 1992,
10 was appointed to any command military duty?
11 A. Yes, I am. I do know that Mr. Zejnil Delalic
12 was appointed commander of Tactical Group 1. I do not
13 know the exact date, but as a staff officer -- that is
14 assistant commander for logistics -- I was informed
15 that at 2300 hours -- I was informed of that on 30 or
16 31 July.
17 Q. How is it that you remember now when you were
18 informed of this?
19 A. When taking over duty, when I moved to the
20 joint command of the army of the federation, and also
21 by looking through my notebook, I came across this note
22 made in my notebook about this.
23 Q. Would it be possible for somebody to be
24 appointed commander of a Tactical Group much earlier,
25 without you being informed about it?
Page 11175
1 A. I really do not know that anyone was
2 appointed commander of a Tactical Group from Konjic
3 before that.
4 Q. From that point in time, when, as you said,
5 you learnt that Zejnil Delalic was appointed commander
6 of Tactical Group 1, Mr. Kevric, was Mr. Zejnil Delalic
7 from then on a person who was superior to you?
8 A. From the moment I learnt that Mr. Zejnil
9 Delalic was appointed commander of Tactical Group 1, he
10 was never my superior commander.
11 Q. Do you know whether the municipal staff of
12 the Territorial Defence of Konjic was subordinated from
13 that moment on to Mr. Delalic, or was Mr. Delalic the
14 superior officer to your territorial staff in the
15 municipality of Konjic?
16 A. The municipal staff of Konjic was never
17 subordinated to Mr. Zejnil Delalic, nor was Mr. Zejnil
18 Delalic ever a superior to the municipal staff.
19 Mr. Zejnil Delalic was superior only to the unit that
20 was sent to the Tactical Group from the TO staff of
21 Konjic.
22 Q. Do you know whether Zejnil Delalic, after
23 being appointed to this position, had any communication
24 with the municipal staff of Konjic?
25 A. Yes, I am aware of that, because I was
Page 11176
1 informed by the commander that there was communication
2 in terms of the forwarding of orders, also a briefing
3 about the HVO, because they had appropriated some
4 equipment and --
5 Q. Mr. Kevric, do you know what the Operation Jug
6 is?
7 A. Yes, I do, I am familiar with that Operation
8 Jug, because our units had to perform certain
9 assignments, that is, the units that were sent to
10 Tactical Group 2.
11 Q. Did I understand you well -- units from
12 Konjic, during Operation South -- Jug -- were sent to
13 Tactical Group 2 and not Tactical Group 1?
14 A. Yes, that is so, Tactical Group 2.
15 Q. Do you perhaps know where the combat
16 operations were conducted in which units from Konjic
17 participated within the framework of Operation Jug?
18 A. I do know, because I personally saw that unit
19 off, and supplied it with resources, equipment, food
20 and ammunition, and sent them to Tactical Group 2.
21 I think that they were engaged in offensive operations
22 around Trnovo.
23 Q. Do you know what duty or function was
24 performed by Mr. Zejnil Delalic within the framework of
25 the provisional command South -- Jug?
Page 11177
1 A. Yes, I do know Mr. Zejnil Delalic, when the
2 provisional command Jug was formed, he was appointed
3 assistant commander.
4 MS. RESIDOVIC: I would now like this exhibit
5 to be marked for identification and then shown to the
6 witness.
7 (Handed).
8 THE REGISTRAR: Defence Exhibit D170/1.
9 MS. RESIDOVIC: Mr. Kevric, are you familiar
10 with this document?
11 A. Yes, I am, because we received it in the
12 municipal staff.
13 Q. Were you assistant commander for logistics at
14 that time in the municipal headquarters in Konjic?
15 A. Yes, I was assistant commander for logistics
16 in the municipal staff of Konjic and our duty was to
17 provide meals for our units, which were participating
18 in combat operations, that is, in the Tactical Group.
19 Actually, Tactical Groups 1 and 2, which both belonged
20 to Operation Jug, because the operative group Jug did
21 not have all the warehouses to keep the units supplied
22 during combat operations.
23 Q. Is it true, Mr. Kevric, that even though
24 Mr. Zejnil Delalic was a commander of the Tactical Group
25 and in the provisional group Jug responsible for
Page 11178
1 logistics, that he did not give you any orders in
2 connection with these tasks, but only a request for
3 providing a certain number of rations?
4 A. It can be seen from this document that it is
5 a request and not an order. If any other unit were to
6 address me, for instance, a unit from Mostar could send
7 a request from Prozor or from Sarajevo, if I had the
8 required supplies, I could issue those supplies to that
9 unit.
10 Q. When you were issuing the supplies, did you
11 issue them based on the order of your own commander?
12 A. Yes, I have already stated that no supplies
13 could be issued without the signature of my commander.
14 MS. RESIDOVIC: Thank you. Since this is a
15 document that is addressed specifically to the witness
16 and is relevant in these proceedings, I tender it into
17 evidence.
18 JUDGE KARIBI-WHYTE: Yes, you may tender it
19 if you want to.
20 MS. RESIDOVIC: Thank you. This is the
21 Defence Exhibit D170/1; is that correct.
22 THE REGISTRAR: That is correct.
23 MS. RESIDOVIC: Mr. Kevric, let me move to
24 another area now. Responding to my questions this
25 morning, you stated that the Celebici barracks were
Page 11179
1 taken over without fighting and that Mr. Delalic in
2 Ovcari turned over the weapons that he found to you,
3 since he was in charge of the transportation of these
4 weapons. Can you tell me whether you know the location
5 of the Celebici barracks?
6 A. Yes, I know the location of the Celebici
7 barracks. It is located nine kilometres from the
8 municipality of Konjic, to the left of the highway,
9 about 150 to 200 metres away from the highway itself.
10 It is surrounded by Paradzici, which is a Croatian
11 village, and the Muslim village of Idbar, and across
12 the Idbar River is the Serb village of Celebici.
13 Q. Do you know for which purposes the Celebici
14 barracks were used after it was taken over and during
15 this period of time of 1992?
16 A. I know first the unit which took over the
17 Celebici barracks was stationed there. These were
18 mobile units, and they stayed there for about three to
19 four days and they were stationed there -- they were
20 accommodated there in order for them not to have to go
21 to their homes, and then there was a storehouse for
22 ammunition as well as later for food and other
23 equipment. Then there was a prison, and a workshop for
24 repair of weaponry.
25 Q. Did there come a time in 1992 when the
Page 11180
1 special units of the Konjic MUP were also stationed in
2 the Celebici barracks?
3 A. I think that, in the beginning, I stated that
4 there was a MUP unit, which was led by Miralem
5 Musinovic, which was stationed there for a period of
6 time.
7 Q. Mr. Kevric, did you have any contact with
8 Celebici barracks with respect to your job and did you
9 have any contacts with the prison?
10 A. As far as contacts with the Celebici barracks
11 is concerned, my job was to control issuance of the
12 equipment in the warehouses that belonged to the TO
13 Konjic. Later on, that included also the repair of
14 weaponry, and the duty of the logistics staff was also
15 feeding the prisoners, that is, the detainees who were
16 in the prison. That is the quartermaster officer of
17 the logistics staff was tasked with that duty.
18 Q. Mr. Kevric, taking into consideration all
19 these duties that you had to perform in the Celebici
20 barracks issuing equipment and food and repair of
21 weaponry, did you ever go to the Celebici barracks?
22 A. Yes, I did visit the barracks in different
23 times -- I would issue different orders to the staff
24 who were guarding and issuing this equipment.
25 Q. So, we can say that you could tell the Trial
Page 11181
1 Chamber what was the space -- the surface that this
2 facility occupied -- was this a large facility, a
3 medium sized or a small sized facility?
4 A. I did not understand the question. Is this a
5 facility that was used by the TO, or the entire
6 barracks?
7 Q. No, the entire compound, was this large,
8 medium or a small sized facility?
9 A. The barracks compound is rather large. There
10 are two parts -- the near part and the far part. There
11 is the administration building, then, since it was used
12 for fuel, it had those facilities. In the upper part
13 -- the far end -- there were three or four fuel
14 storages.
15 Q. When you went to the warehouses where
16 ammunition and equipment were kept, which way did you
17 use to get there?
18 A. When I went to visit the warehouses, from the
19 gate I would go directly to the warehouse on the upper
20 road.
21 Q. Would you please take the pointer and, if you
22 can, show to the Trial Chamber -- if you can recognise
23 it in this model, show us how you went to the
24 ammunition warehouse. You can just extend it?
25 A. So, this is the gate and I would take this
Page 11182
1 road (witness indicates) and then I would come up here
2 -- there are some letters here.
3 Q. In order for us all to be able to hear what
4 you have just said, could you step up to the
5 microphone, please?
6 A. I cannot do it from here.
7 Q. When you take this upper road -- Mr. Kevric,
8 were you in a situation to see the structures that are
9 in a lower end of the compound and, also, were you able
10 to see what was going on there?
11 A. When you enter, you sort of bear to the
12 right, and you only see the roofs of these structures,
13 and they are closed -- there are windows there, which
14 were sort of darkened -- how shall I put it -- they had
15 darkened glass, so you could not see through them. On
16 the way back, it was the same case -- I would take the
17 same road back. It was only if somebody was standing
18 around these buildings that you could see anyone.
19 MS. RESIDOVIC: Your Honours, I would like to
20 play a portion of the tape of the drive through the
21 facility. It has been tendered before, but I would
22 like to play it for the witness again.
23 JUDGE KARIBI-WHYTE: I suppose we could all
24 travel to Celebici to see how we could go into that
25 place. I think that might be a more successful way of
Page 11183
1 doing that.
2 MS. RESIDOVIC: I would not mind suggesting
3 that, if we could set up a hearing there. Could you
4 please play this excerpt number 2, and without audio,
5 please. May I ask the technical booth to play excerpt
6 number 2, please?
7 (Videotape played)
8 (Videotape stopped)
9 MS. RESIDOVIC: Thank you.
10 Mr. Kevric, you probably recognised the
11 facility through which this vehicle drove. Can you
12 just state for the Trial Chamber what facility this
13 was?
14 A. This is the compound of the Celebici
15 barracks. This was the lower part without the fuel
16 depots.
17 Q. When you talked about the structures on the
18 upper part, did your visits to the Celebici camps --
19 or, in order not to make it a leading question, what
20 was the objective of your visits to the Celebici
21 barracks?
22 A. The objective of my visits was exclusively
23 the control of the staff who worked in the warehouse of
24 the military equipment.
25 Q. We saw a large number of trucks in this
Page 11184
1 video. Can you tell me, are these the trucks on which
2 this military materiel was normally brought into the
3 barracks?
4 A. This large number of trucks, which happened
5 to be there -- that was a large convoy, which brought
6 in a lot of military equipment and other equipment and
7 food. When any of this equipment was issued to any of
8 the units, and there were 12 of them all together, for
9 each of these units, two or three truck loads would be
10 sent.
11 Q. Mr. Kevric, you said that you were also in
12 charge of the preparation of meals. Can you tell me,
13 which service within your staff was in charge of food
14 preparation?
15 A. Within the logistics staff, it was the task
16 of the quartermaster service to prepare food.
17 Q. Who did you prepare meals for?
18 A. We prepared meals for the TO units, we would
19 prepare them for the MUP units, we would prepare them
20 for the Igman company, we would prepare them for the
21 prisoners, and we would prepare them for some refugees.
22 Q. Where were these meals prepared?
23 A. The meals were prepared first in a single
24 location -- that was in the Igman company -- and that
25 was because of the shelling which damaged gas
Page 11185
1 installations, and also in Sipad which was the forestry
2 company.
3 Q. Can you tell the court what were the supplies
4 of basic food stocks in Konjic in 1992 and what did you
5 have at your disposal in order to carry out this task?
6 A. Personally, as an assistant commander for
7 logistics, I do not recall a more difficult period than
8 the one between April and August of 1992. The
9 population was not prepared for the war. The TO staff
10 had no reserves. There was just not enough food
11 around. There were only some larger supplies of sugar
12 at that time in Konjic, but as far as flour, meat, meat
13 products, fresh vegetables, spices -- we had none of
14 that, so we really had enormous problems in preparation
15 of meals. We could not give breakfast to either
16 refugees, soldiers, workers or detainees, or anything
17 but soup, which consisted of just rice and oil.
18 The situation changed a little bit later on
19 when we received a shipment of flour. The food which
20 was prepared in our kitchens was such as it could be at
21 the time. We all ate the same food, starting from me,
22 who was in charge of the logistics, down to the
23 soldiers and to the detainees in Celebici.
24 The biggest problems we faced was that, in
25 the month of April, we found no containers for
Page 11186
1 transportation of these meals, or any containers from
2 which these refugees or detainees could eat. We had
3 practically nothing. In the way of an example, let me
4 tell you: since we did not have anything to give to
5 soldiers to eat for breakfast except for some canned
6 food occasionally, we had to, in early fall, make some
7 plum jam. We had a certain amount of sugar so we
8 distributed it around villages for people to make jam
9 and this is what was then distributed around.
10 Q. Since you now mentioned the fall of 1992, can
11 you tell the Trial Chamber whether Konjic is known as a
12 region -- as a plum-growing region?
13 A. Yes, Konjic is indeed known for plum
14 production, especially the left bank of the Neretva
15 River valley.
16 Q. Since you mentioned it, I am familiar with
17 the Turkish local word for jam, which was "bestilj",
18 so can you tell us what you were called at the end of
19 the year by citizens of Konjic?
20 A. Yes, it is a joke -- we were called "Alija's
21 bestiljani", because they knew we had nothing else to
22 give to people, to soldiers but plum jam for breakfast.
23 Q. You said that you basically cooked the food
24 in a single location. At first it was one, then there
25 were two locations. Was this food identical in
Page 11187
1 quality?
2 A. The food was identical, that is, the recipes
3 were the same, even though they were stretched, they
4 were cooked in the same cauldrons and they were in the
5 same pots and they were transported in the same
6 containers.
7 Q. According to your knowledge, were all people
8 to whom these meals -- for whom these meals were
9 prepared, were all these people given the same rations?
10 A. Yes, they were all given the same rations
11 based on the number of people that were put on these
12 lists.
13 MS. RESIDOVIC: Your Honours, I have another
14 area of questioning for this witness, but it is 5.30
15 now. So maybe it would be good for the witness to get
16 a break from this long questioning of today and maybe
17 we, too, could benefit from it.
18 JUDGE KARIBI-WHYTE: I think you might
19 continue tomorrow morning at 10.00 a.m. The Trial Chamber
20 will now rise.
21 (At 5.30 p.m. the matter adjourned
22 until Thursday, 16 April 1998, at 10.00 a.m.)
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