Tribunal Criminal Tribunal for the Former Yugoslavia

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?



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.


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.)