Tribunal Criminal Tribunal for the Former Yugoslavia

Page 13257

1 Monday, 31 October 2005

2 [Open session]

3 --- Upon commencing at 9.10 a.m.

4 [The accused entered court]

5 JUDGE AGIUS: Yes. Madam Registrar, could you call the case,

6 please.

7 THE REGISTRAR: Good morning, Your Honours. This is case number

8 case IT-03-68-T, the Prosecutor versus Naser Oric.

9 JUDGE AGIUS: I don't know if I am expected to switch on to French

10 but I am receiving interpretation in French on channel 4 so there is

11 something wrong there, too. Oh, it has gone to channel 3 now?

12 Yes. Let's go through it again. I am not receiving

13 interpretation in French now so it should be okay.

14 Mr. Jones and Madam Vidovic?

15 MR. JONES: I was receiving in French but I'm getting English

16 now.

17 JUDGE AGIUS: And Prosecution?

18 MR. WUBBEN: It's okay.

19 JUDGE AGIUS: So Mr. Oric, good morning to you, can you follow the

20 proceedings in your own language?

21 THE ACCUSED: [Interpretation] I am receiving the interpretation in

22 my own language, and I can hear you perfectly.

23 JUDGE AGIUS: Yes. Now there is something wrong. I did not

24 receive any interpretation in English at all and I am on channel 3. I

25 should switch now to channel 4? Yes, again I have to ask you again,

Page 13258

1 Mr. Oric because I want to make sure that there is nothing wrong with

2 interpretation on your side. Are you receiving interpretation in your own

3 language?

4 THE ACCUSED: [Interpretation] Your Honours, yes, I am receiving

5 the interpretation in my own language.

6 JUDGE AGIUS: Thank you, and good morning to you.

7 Appearances for the Prosecution.

8 MR. WUBBEN: Good morning, Your Honours, and also good morning to

9 my learned friends of the Defence. My name is Jan Wubben, lead counsel

10 for the Prosecution. I'm here together with co-counsel,

11 Ms. Patricia Sellers, Ms. Joanne Richardson, and our case manager,

12 Mrs. Donnica Henry-Frijlink.

13 JUDGE AGIUS: I thank you, Mr. Wubben and good morning to you and

14 your team.

15 Appearances for Naser Oric?

16 MS. VIDOVIC: [Interpretation] Good morning, Your Honours. Good

17 morning to my learned colleagues from the OTP. My name is Vasvija Vidovic

18 and together with Mr. John Jones I appear for Mr. Naser Oric. And we have

19 here with us our legal assistants, Miss Jasmina Cosic, and our CaseMap

20 manager, Mr. Geoff Roberts.

21 JUDGE AGIUS: Thank you and good morning to your team.

22 Any preliminaries?

23 MR. WUBBEN: No, Your Honour.

24 MS. VIDOVIC: [Interpretation] No, Your Honour.

25 JUDGE AGIUS: My apologies for starting with a few minutes' delay.

Page 13259

1 The problem was traffic jams this morning. I simply don't know what

2 happened, but I would have made it earlier had I walked from my residence

3 to the Tribunal and the same applies to my colleagues.

4 So, let's bring the witness in.

5 [The witness entered court]

6 JUDGE AGIUS: Good morning, to you, Mr. Sacirovic.

7 THE WITNESS: [Interpretation] Good morning.

8 JUDGE AGIUS: Welcome to this Tribunal. You are about to start

9 giving evidence. Before you do so, our rules require that you enter a --

10 you make a solemn declaration equivalent to an oath in some jurisdictions.

11 Since that, in the course of your testimony, you will be speaking the

12 truth, the whole truth, and nothing but the truth. The text is contained

13 in a piece of paper which the usher is going to hand to you now. Please

14 read it out loud and that will be your solemn undertaking with us.


16 [Witness answered through interpreter]

17 THE WITNESS: [Interpretation] I solemnly declare that I will speak

18 the truth, the whole truth, and nothing but the truth.

19 JUDGE AGIUS: Thank you. Please make yourself comfortable.

20 THE WITNESS: [Interpretation] Thank you.

21 JUDGE AGIUS: You will throughout the proceedings be receiving

22 interpretation from what will be said in English into your own language.

23 If at any time there are problems with reception of interpretation, please

24 draw our attention straight away. I am the Presiding Judge in this case.

25 My name is Carmel Agius and I come from Malta. To my right I have

Page 13260

1 Judge Hans Henrik Brydensholt from the Kingdom of Denmark, to my left,

2 Judge Professor Albin Eser from Germany.

3 The procedure is Defence will go first with asking you a series of

4 questions because you are a Defence witness. Later on, you will be

5 cross-examined by Ms. Richardson for the Office of the Prosecutor.

6 Yes, Mr. Jones.

7 MR. JONES: Thank you, Your Honour.

8 Examined by Mr. Jones:

9 Q. And good morning from me, Mr. Sacirovic.

10 A. Good morning.

11 Q. If we could start with you, please, giving the Court your full

12 name.

13 A. Yes.

14 Q. Yes. What is it, please, your full name?

15 A. My name is Mustafa, my last name is Sacirovic.

16 Q. Please confirm the following details: You were born on the 1st of

17 April, 1953 in Hranca, Bratunac municipality?

18 A. Yes.

19 Q. You went to primary school in Bratunac, graduating in 1968?

20 A. Yes.

21 Q. You completed higher education in catering and tourism in Zvornik?

22 A. Yes.

23 Q. You moved to Glogova in 1971?

24 A. Yes.

25 Q. And before the war, you worked as a trader or as a waiter?

Page 13261

1 A. Yes.

2 Q. And after the war, you moved to Portland, Oregon, in the United

3 States?

4 A. Yes.

5 Q. And did you undertake or complete any training in the United

6 States?

7 A. Yes.

8 Q. What training did you undertake?

9 A. I graduated from the school for private investigators.

10 Q. So in other words you trained as a private investigator?

11 A. Yes.

12 Q. And in Portland, you have a registered centre of investigation; is

13 that right?

14 A. Yes. This is the investigation centre of the victims of genocide

15 of Bosnia-Herzegovina. IMSGS.

16 THE INTERPRETER: The interpreter isn't certain about the

17 abbreviation.


19 Q. Could you tell us again the abbreviation for your centre?

20 A. ICGS. Therefore, no S in the abbreviation. It's the letter C.

21 Q. That's fine. In fact, is it right that the full title is "The

22 Union of Victims of Genocide of Bosnia-Herzegovina, Enclave of Srebrenica,

23 Centre of Investigation, Portland?"

24 A. Yes.

25 Q. And as part of your activities for that centre, have you collected

Page 13262

1 tapes, testimonies, and exhibits relating to events in Bosnia in 1992 to

2 1995?

3 A. Yes.

4 Q. And did you give those statements and testimonies to the state

5 commission on war crimes in Bosnia-Herzegovina?

6 A. Yes.

7 Q. And have you also given a statement as well as provided other

8 witness statements and audiotapes to the Prosecutor of this Tribunal in

9 regard to the Deronjic case?

10 A. Yes.

11 Q. Now, for the purposes of your testimony, we are not going to dwell

12 on ethnic cleansing in Bratunac, Srebrenica, in early 1992, since the

13 Judges have indicated they've heard enough evidence on that subject. I

14 simply want to show you an exhibit which is D89.

15 MR. JONES: If the witness could be shown D89, please.

16 JUDGE AGIUS: Incidentally, while this is being transported, we --

17 none of us has the documents relating to -- the documents that you will be

18 using because we only got the list this morning, just before the sitting

19 actually, so our secretaries have not been in a position to prepare

20 anything.

21 MR. JONES: Yes, I think there were some technical --

22 JUDGE AGIUS: Okay. I'm not criticising you. I mean, so it's

23 important that we either have the cooperation of the Prosecution to have

24 the documents available on Sanction, or the Defence, or else to make sure

25 that it is always -- that they are always placed on the ELMO.

Page 13263

1 MS. RICHARDSON: Your Honour -- Good morning to Your Honour and to

2 the Defence. Your Honour, we, just as you have, received the list this

3 morning. We have not had time to prepare, so I'm sorry we can't assist.

4 JUDGE AGIUS: So we'll see, we'll play it by the ear as we go

5 along.

6 MR. JONES: Yes.

7 JUDGE AGIUS: There might be problems. It's important that we

8 have it on the ELMO at all times.

9 MR. JONES: Yes. I would like to say for the record in any event

10 that we did send it out last night and, as I say, there must be a

11 technical hitch.

12 JUDGE AGIUS: Yes, I'm told so, so much so. I told you I'm not

13 blaming you.

14 MR. JONES: I just thought I should state that anyway. And we

15 don't use Sanction so it will be a question of using the ELMO.

16 Q. Now, this exhibit, just for the record as well, it has the name

17 Mustafa Sacirovic at the top left-hand corner and then the address of the

18 International Criminal Tribunal. I'd ask you firstly, did you prepare

19 this document?

20 A. Yes.

21 Q. And is it your signature at the end of this document?

22 A. It is.

23 Q. And is it also signed as being received by an investigator of the

24 Tribunal?

25 A. Yes.

Page 13264

1 Q. Now, are the contents of this document true to the best of your

2 knowledge and belief?

3 A. Absolutely.

4 Q. And did you prepare it with the benefit of testimonies of people

5 who survived these events?

6 A. Yes.

7 Q. And do you therefore vouch for what is stated here about mass

8 killings and expulsions in May 1992 in the following places in Bratunac

9 municipality? And I'm going to, just for the record, read the names of

10 the places: Hranca, Glogova, Bljeceva, Suha, Mihajlovici, Krasan Polje,

11 Bratunac, in particular in the Vuk Karadzic school, Podcaus, Boljevici

12 Zaluzje, Abdulici, Bjelovac, Zapolje, and Tegari? Do you vouch for what's

13 stated here on ethnic cleansing of Muslims from all those villages?

14 A. Yes.

15 Q. As a result of these events as described in this document, were

16 all or practically all of the Muslims expelled from Bratunac municipality

17 in May 1992?

18 A. Most of them were. The majority.

19 Q. And only if you can assist with this before we move on to looking

20 at the document, do you have any explanation of how such massive crimes

21 could be committed in such a wide area in such a short time?

22 A. You have to know that the paramilitary units from Serbia had to do

23 with this, the regular Yugoslav People's Army, and the local Serbs.

24 Q. In your opinion, was this something that was organised or not

25 organised?

Page 13265

1 A. It was an organised action.

2 Q. In terms of the victims mentioned in this document, are they

3 the -- is this a list that's exhaustive or is it simply the victims you

4 know about?

5 A. Listed here are the victims who I know, but this is not a final

6 list of victims. The only possibility is that some of the victims were

7 left out here, but I rule out the possibility of someone being listed here

8 as a victim without being so.

9 Q. So in short there could be more victims than this but certainly

10 not less?

11 A. Yes.

12 Q. Your centre for investigating genocide in Portland, is that

13 dealing only with events in 1995 or does it also deal with events

14 beforehand?

15 A. Our centre deals with the events starting from 1992 throughout the

16 war in Bosnia and Herzegovina.

17 Q. So your conclusion is that the genocide referred to in the title

18 of your centre actually occurred before 1995?

19 A. Yes.

20 Q. When would you say it started, this genocide?

21 A. The genocide started in May 1992 and it was prepared in April and

22 probably even earlier on.

23 Q. All right. Now, I'm just going to go to a few parts of this

24 document. First of all the section dealing with Hranca.

25 MR. JONES: If we could put that on the ELMO, it's pages 1 to 3 of

Page 13266

1 English and pages 1 to 2 in the Bosnian.

2 Q. First of all, can I ask did you in fact grow up in Hranca?

3 A. Yes.

4 Q. And was that a Muslim village or a Serb village or a mixed village

5 before the war?

6 A. It was a mixed village but the majority were Muslims.

7 Q. Do you know Najdan Mladjenovic?

8 A. Yes. Before the war, he used to drive together with my brother.

9 They were drivers before my brother was killed on the 9th of May. They

10 were haulers.

11 Q. But where was your brother killed on the 9th of May?

12 A. He was killed in Glogova, in our family house.

13 Q. Going back to Najdan Mladjenovic, do you know where he's from?

14 A. From Hranca.

15 Q. And -- right. Okay. Now, according to this document, Najdan

16 Mladjenovic was involved in crimes in Hranca on both the 3rd of May 1992

17 and the 9th of May 1992, and I'm just going to read a section from the top

18 of page 2 of the English, where referring to the 3rd of May 1992, it

19 says, "Soon after, at about 1500 hours on the same day, the Bosniak

20 village of Hranca was surrounded on all sides. In this massacre, the SDS

21 paramilitary formations killed," then there is a list, "Bego [phoen]

22 Hodzic, Osman Ramic, Sancir Ramic, and Selma Hodzic, a girl of between

23 five and seven. Between 40 and 50 Bosniak houses were torched in this

24 bloody raid. The SDS Chetnik paramilitary formations were led in this

25 bloody raid by the following who were seen at the scene," and it says

Page 13267

1 Najdan Mladjenovic from Donji Magasici. I'll pause there for a moment.

2 Is Donji Magasici in the Hranca area, or is that a separate village?

3 A. Donji Magasici is in the area of Hranca. Some consider it to be a

4 distinct village but it is a part of Hranca.

5 Q. Okay. So according to the information which you collected, Najdan

6 Mladjenovic led this raid on the 3rd of May 1992 when these people were

7 killed and these houses were torched?

8 A. Yes.

9 Q. And then when we go to the raid or the crime on the 9th of May

10 1992, and it's the same page in English, bottom paragraph, it says, "In

11 this second raid on the defenceless Bosniak village of Hranca, a group of

12 these SDS paramilitary formations led by Najdan Mladjenovic liquidated the

13 men fit for military service and finally expelled the women and children

14 towards Kladanj and Tuzla."

15 Can you confirmed that that's the information you received about

16 the 9th of May 1992?

17 A. Yes.

18 Q. And then finally, I just want to turn before moving to another

19 document, on page 3 of the English, and the end of the first paragraph, it

20 says, "It would not hurt to note that in the second raid the village of

21 Hranca was completely torched and destroyed." Is that true, that Hranca

22 was the Bosniak houses in Hranca were burned on the 9th of May 1992?

23 A. Yes.

24 Q. Do you know who was involved in those torchings?

25 A. According to witness statements, Najdan Mladjenovic and others

Page 13268

1 mentioned in these witness statements took part in this.

2 Q. Do you have witness statements and audiotapes relating to the

3 involvement of Najdan Mladjenovic?

4 A. Yes. The tapes were handed over to The Hague investigator in

5 Tuzla in 2000, I believe it was. It was a tape.

6 Q. If you can keep D89 with you for the moment, I'd like to show the

7 witness P487 which is also P294. And this is a -- it's

8 entitled "report." And it concerns damage allegedly caused during combat

9 activities in Eastern Bosnia and it's particularly the table which I want

10 to ask you about. There is a table which in English it says "table

11 overview of documented facilities burned and destroyed during military

12 actions of 1992-1993." I don't know if you see that in Bosnian. In fact

13 it's just the second page of the Bosnian. And if you look down to number

14 16 of the album, we see the information supplied about properties in

15 Hranca, is Najdan Mladjenovic. Do you see that?

16 A. Yes.

17 Q. Is there more than one Najdan Mladjenovic living in the Hranca

18 area?

19 A. No.

20 Q. Would you say this is the Najdan Mladjenovic who you told us burnt

21 Muslim homes in Hranca?

22 A. Yes.

23 Q. Would you consider Najdan Mladjenovic a reliable, objective source

24 on who damaged property in Hranca during the war?

25 JUDGE AGIUS: Yes? We don't -- we are not seeing anything on the

Page 13269

1 ELMO so we don't really know which document -- is it P487, 294?

2 MR. JONES: Yes, P487 it's the second page in English.

3 JUDGE AGIUS: It's also P294.

4 MR. JONES: Yes.

5 JUDGE AGIUS: Usher could you please put page 2 of that document,

6 the English version?

7 MR. JONES: This is number 16, if we could get 16 in range. We

8 need to raise it a bit higher.

9 JUDGE AGIUS: You have to raise it a bit higher.

10 MR. JONES: The other way.

11 JUDGE AGIUS: No that's -- okay. No.

12 MR. JONES: If you left it as it was.

13 JUDGE AGIUS: No. No, further up.

14 MR. JONES: Yes. And now move it the other direction, please.

15 JUDGE AGIUS: No, no, no, no, no.

16 THE WITNESS: [Interpretation] This page.

17 JUDGE AGIUS: Page 2.

18 MR. JONES: You had it.

19 JUDGE AGIUS: You had it before, usher. Why so much complication

20 with something that is very simple?

21 MR. JONES: Yes, leave it there.

22 JUDGE AGIUS: Yes. Okay. Leave it. Yes, Ms. Richardson?

23 MS. RICHARDSON: Yes, Your Honour, I would object to the last

24 question being put to the witness about whether or not this individual is

25 reliable unless this witness is capable or competent to testify that he

Page 13270

1 spoke to the individual in question and I think that --

2 JUDGE AGIUS: But then you ask him on cross-examination if you

3 contest it. I mean, he's got every right to ask him that question and if

4 you don't like the answer or you want further explanation on the grounds

5 for his answer, you ask him later.

6 MS. RICHARDSON: I will do so, Your Honour.

7 JUDGE AGIUS: Okay, let's not waste time because we are

8 already ...

9 MR. JONES: I'll repeat my question, Mr. Sacirovic, if I need to.

10 Q. Would you consider Najdan Mladjenovic, a reliable, objective

11 source on what caused damage to property in Hranca during the war?

12 A. No.

13 Q. And why not?

14 A. Because Najdan Mladjenovic participated in the destruction of

15 Bosnian homes and the liquidation of the Bosniaks in the area, and I

16 personally, as an investigator, believe that he cannot be a reliable

17 person or, rather, his figures, the information provided by him, cannot be

18 deemed accurate.

19 Q. Do you know how many Muslim houses were actually burned in May

20 1992 in Hranca?

21 A. All the houses were burnt down, and to obtain the data one needs

22 only to look at the 1991 census data wherein in the exact numbers of the

23 homes were listed, but, in any case, all the houses, all of them, were

24 razed down, burnt down.

25 Q. Just roughly what number would that be, if you can attach a

Page 13271

1 number?

2 A. I believe that more than 100 houses were torched. Take a few, add

3 a few, but anyway, I believe when we know what we have Cerovac [phoen],

4 Mjelomina [phoen], Ramici, and the lower part of Polje, four hamlets

5 making all part of Hranca.

6 Q. Thank you. Now, we are going to go back to D89 again, that's your

7 document, and turn to Glogova, which is page 3 of the English. Firstly,

8 you've confirmed the accuracy of this document as a whole. Do you confirm

9 what's stated here about Glogova being attacked, homes being burned, and a

10 great many of its inhabitants being killed by the Serbs on the 9th of May

11 1992?

12 A. I do. I was in Glogova on the 9th of May.

13 Q. In this document, we see the names of some of the Serb

14 perpetrators and participants in this crime. It's on page 4 of the

15 English, page 3 of the B/C/S. And it -- probably should get that on the

16 ELMO for the record. Yes, that's probably -- that's fine, if you just

17 leave it there. Now, without going through all the names, we see that

18 there are Serbs from Kravica, Hranca, Donja Magasici. Is it true that

19 many of the Serbs who participated in killing and burnings in Glogova in

20 May 1992 were from the Kravica area?

21 A. Yes.

22 Q. So as early as May 1992, Serbs from Kravica and local Serbs were

23 killing and raping their Muslim neighbours; would that be correct?

24 A. Yes.

25 Q. Now, let's turn to just a couple more entries. It's not possible

Page 13272

1 to go through the whole document. For Voljavica and Zaluzje it's page 12

2 of the English, page 9 of the Bosnian. I'm going to read part of

3 this. "Crime in the villages of Voljavica and Zaluzje on 13 May 1992. On

4 13 May 1992, the Bosniak villages of Voljavica and Zaluzje were surrounded

5 by Bratunac SDS paramilitary units. Voljavica and Zaluzje are three

6 kilometres to the east of Bratunac in the direction of Fakovici. On this

7 occasion too the SDS goal was achieved and most of the people of these

8 villages were expelled in buses and lorries towards Bratunac and then

9 Kladanj and Tuzla. Both villages," that's Voljavica and Zaluzje, "were

10 torched to a large extent and the following civilians were killed on the

11 spot. And then there is a list of names. And the next paragraph, list of

12 12 names. The following SDS supporters were identified at the scene of

13 the crime, if we go to the very bottom, we see Slavko Rankic from Bjelovac

14 and others. Do you see that?

15 A. Yes.

16 Q. Would it be right that this name, Slavko Rankic from Bjelovac,

17 like the names of the other perpetrators and participants in these events

18 appears in this document because eyewitnesses who survived the events

19 named him or identified him?

20 A. Yes. He was recognised on the spot and his name is on the list on

21 the basis of witness statements.

22 Q. Do you, as a matter of practice, check witness statements against

23 each other, cross-reference them and check that the information is

24 reliable?

25 A. Absolutely, yes. I always use several sources of information to

Page 13273

1 arrive at the actual truth.

2 Q. All right. If we turn back to P487, if that's still there, and

3 it's that same page, and we look at item number 11, and we see there, do

4 we not, that Slavko Rankic is a source of information on damage and

5 destroyed property in Bjelovac. Do you see that?

6 A. Yes.

7 Q. All right. This document, this table, appears to rely, does it

8 not, on information from Serbs who were actually implicated in the crimes

9 of ethnic cleansing in May 1992?

10 A. [No interpretation]

11 Q. Turning back to your document it's page 13 of the English -- of

12 the English version, page 10 of the B/C/S, refers to crime in the villages

13 of Abdulici, Bjelovac, Zapolje, and Tegari, between 16 May and 20 May 1992

14 and again for the record, I'm going to read part of it. "The villages of

15 Bjelovac, Tegari, and Zapolje lie along the River Drina to the east of

16 Bratunac, like the village of Abdulici with its majority Bosniak

17 population. On 16 May 1992, the villages of Tegari and Zapolje and the

18 Roma settlement of Orlica was surrounded by Bratunac SDS paramilitary

19 units. On the same day, the following were killed with firearms at the

20 scene of the crime," and then there are some names of those who were

21 killed. "The villages were completely torched and the people fled to the

22 forest in the free territory of Srebrenica municipality. The following

23 Serbs from Fakovici led by the SDS leadership of the local commune, Slavko

24 Jovanovic, were recognised at the scene of the crime. Tihomir Jovanovic

25 from Orlica, Vidoje Maksimovic from Fakovici, Ognjen Markovic, a.k.a.

Page 13274

1 Bato, Milenko Canic, Dane Katanic, and Desimir Mitrovic, all from Fakovici

2 and the surrounding area." And then it's mentioned, "the following were

3 witnesses to this crime and the names Ednen Zildzic and Sadeta Zildzic."

4 Now, did you take statements from Ednen Zildzic and Sadeta Zildzic

5 about these events?

6 A. [No interpretation]

7 Q. Sorry, we didn't have interpretation.



10 Q. Could you repeat your answer, please? Could you repeat your last

11 answer, Mr. Sacirovic?

12 THE INTERPRETER: The English booth apologises. We were on the

13 wrong channel. Answer: Yes.


15 Q. All right. So that's yes you took the statements of these

16 witnesses Ednen Zildzic and Sadeta Zildzic?

17 A. Yes.

18 Q. Did you give those statements to the Office of the Prosecutor?

19 A. Yes.

20 Q. And when was that?

21 A. I think it was in Tuzla in the year 2000. Together with those

22 microcassettes.

23 Q. So more than five years ago you gave statements from these

24 witnesses about Serbs from Fakovici committing crimes in Abdulici,

25 Bjelovac, Zapolje and Tegari?

Page 13275

1 A. Yes.

2 Q. All right. Finally let's go to the last page of this document.

3 It's page 15 in English. And I read, "However, in its attempt to take

4 control of these parts, the SDS and its paramilitary units made new

5 victims of the Bosniak people. In their attempt to ethnically cleanse the

6 villages of Joseva and Jagodnja on the 14th of May 1992 they killed the

7 following civilians in Joseva. Sacir Ibrahimovic and Hasib Kurtic who

8 were killed in their village. In a repeated attempt on 22 May 1992, the

9 following civilians were killed in Joseva: Rukija Paraganlija, Safija

10 Paraganlija, Amira Paraganlija," -- sorry, Amira, that was, Paraganlija,

11 "Amir Paraganlija, Fehim Dugonjic, Mustafa Dugonjic, Sefik," possibly

12 Ketonic, "and Zineta Paraganlija, a pregnant woman. All those civilians

13 killed were from Joseva. The following are surviving witnesses to the

14 crime. Ibro Alic from Joseva, Bratunac Municipality, currently living in

15 the Sarajevo area and Junuz Smajlovic from Joseva, Bratunac Municipality,

16 currently living in the Osgova refugee settlement, Zivinice Municipality,

17 and others."

18 Now, would it be right to read this to mean that Ibro Alic and

19 others provided you with information regarding these crimes committed by

20 Serb forces in Jagodnja and Joseva in May 1992?

21 A. Yes.

22 Q. And that that information implicated the SDS and paramilitary

23 units referred to at the start of that paragraph in those crimes?

24 A. Yes.

25 Q. And did you provide that information to the investigator of the

Page 13276

1 Tribunal in July 2000?

2 A. I provided that information. However, there were statements I

3 took when I was in Srebrenica in 1992, 1993, and right up to 1995, which I

4 provided to the president of the War Presidency, Mr. Hajrudin Avdic.

5 However, all this documentation remained in Srebrenica and I don't know

6 what happened to it, if the Serbs didn't find it.

7 Q. Okay. We will come to that in a moment. Finally, Miroslav

8 Deronjic you may know has been convicted by this Tribunal only in relation

9 to events in Glogova. According to this document, and your information,

10 was he only involved in events of ethnic cleansing in Glogova or in a

11 broader area?

12 A. Miroslav Deronjic is responsible not only for the crimes in

13 Glogova but for all the crimes, all over Bratunac municipality, throughout

14 1992 and later.

15 Q. I've finished with those two documents. You've mentioned how your

16 brother was killed by the Serbs in Glogova in May 1992. Were any of your

17 other family members killed by the Serbs, firstly in Hranca in May 1992?

18 A. Yes. Over 20 members of my family were killed in Hranca and my

19 father was killed in Glogova on the 9th of May as well as my brother

20 Vahid, Mehmed, my uncle Mujo, and not to enumerate them further, many,

21 many members of my family were killed, because my mother originates from

22 Glogova and my father from Hranca.

23 Q. As a result of those tragedies, did you start to collect

24 information on war crimes?

25 A. Yes. As soon as Glogova fell, as soon as there was an attack on

Page 13277

1 Glogova, I managed to pull out to survive, and I immediately grabbed a

2 pencil and started noting down events, who was killed, where, when, by

3 whom, and so on.

4 Q. And it may be an obvious question, but why did you do that?

5 A. I did that simply so that it would not be forgotten. I hoped if I

6 was killed somebody would find those documents and would know that these

7 events took place on those dates.

8 Q. And how did you collect information?

9 A. Mostly from surviving witnesses. If I was unable to go to the

10 scene and establish what happened, I collected information from more than

11 one witness, compared the information, and then came to the conclusion

12 that what they were saying was true.

13 Q. And where did you go after Glogova fell on the 9th of May 1992?

14 A. I managed to break through and get to the village of Pale in

15 Srebrenica municipality.

16 Q. And did you continue or not your activities of taking statements

17 and collecting information on war crimes when you were in Pale?

18 A. Yes.

19 Q. Was there a group of fighters in Pale in May 1992?

20 A. Yes.

21 Q. Did they have a leader of sorts?

22 A. Their leader was Mirzet Halilovic.

23 Q. To your knowledge, was Mirzet Halilovic under any higher command

24 at that time?

25 A. No. Mirzet Halilovic acted independently.

Page 13278

1 Q. So what was the status of his group of fighters in Pale?

2 A. It was a self-organised group without any particular status. How

3 can I explain this? As far as military matters go, they didn't have

4 anything to do with any kind of army. It was a self-organised group.

5 They did what they wanted.

6 Q. Now, at some stage, did you go on to Srebrenica?

7 A. Yes. Sometime in early July, I received a message from the

8 president of the War Presidency, Mr. Hajrudin Avdic, telling me to report

9 urgently to Srebrenica municipality.

10 Q. And why did Hajrudin Avdic summon you in particular?

11 A. When I got there, he told me he had heard I was writing down and

12 collecting information about events on the ground, that is war crimes that

13 happened on the ground. He knew I had come from Glogova and that I was

14 writing this down, so he wanted to appoint me to the commission for the

15 collecting of facts about war crimes. And that is how I began working in

16 the war crimes commission attached to the War Presidency.

17 Q. All right. And you mentioned Hajrudin Avdic as the president of

18 the War Presidency. When you an arrived in Srebrenica in early July 1992,

19 was the War Presidency already established?

20 A. Yes.

21 Q. All right. Now, was anyone else from Pale summoned to Srebrenica

22 by the War Presidency at that time?

23 A. Yes. Mirzet Halilovic was also summoned.

24 Q. Do you know what he was summoned to do?

25 A. He had already been appointed commander of the military police,

Page 13279

1 the War Presidency had appointed him, as a komandir.

2 Q. And did Mirzet Halilovic in fact go to Srebrenica to take up that

3 appointment?

4 A. Yes. He went there on the same day, took up his duties, and

5 started working as some kind of military police commander.

6 Q. Now, did Hajrudin Avdic have any sort of office in Srebrenica when

7 you arrived there?

8 A. Yes. His office was in the Srebrenica municipal building.

9 Q. All right. And did you go to that building?

10 A. Yes. I did go to that building. Hajrudin Avdic handed me a

11 decision which said that I was the president of the commission for the

12 gathering of facts about war crimes, which was attached to the service for

13 communications and information.

14 Q. And that service for communication and information, what organ did

15 that belong to?

16 A. It belonged to the War Presidency.

17 Q. Now, did you subsequently have an office to work from?

18 A. Yes. I had an office on the second floor, where the office of

19 Mr. Hajrudin Avdic, president of the War Presidency, was also located. We

20 were on the same floor.

21 Q. Did the War Presidency have meetings?

22 A. Yes, occasionally.

23 Q. And where were those meetings held?

24 A. In the municipal building.

25 Q. From working on the same floor as Hajrudin Avdic, where he had his

Page 13280

1 office, did you find out about the War Presidency and its members?

2 A. Well, I knew that apart from Hajrudin Avdic, the president, there

3 was also Hamdija Fejzic, the president of the executive council, Dzemal

4 Becirevic, who was the chief for the economy. Then there was the chief of

5 the civilian and military police, Becir Bogilovic, and there were some

6 other people who were members on the ground and so on.

7 Q. All right. I want to ask you about Becir Bogilovic who you've

8 described as the chief of the civilian and military police. From what

9 period, as far as you were concerned, was he the chief of the civilian and

10 military police?

11 A. Becir Bogilovic was chief of the civilian and military police

12 until he left Srebrenica. This was until the end of 1992, as far as I can

13 recall.

14 Q. And when you arrived in Srebrenica in early July 1992, was he

15 already in that position or did he take that position later?

16 A. No. He was already in that position.

17 Q. Now, why do you say that he was the head of the civilian and

18 military police from July 1992 until the end of 1992 or until he left

19 Srebrenica? Why do you say that?

20 A. Well, I say that because occasionally I saw him bringing in

21 reports in the morning to Mr. Hajrudin Avdic, the president of the War

22 Presidency, true to say he didn't come often. He had been wounded.

23 Mirzet Halilovic and Nurija Jusufovic came more often. The former was a

24 commander of the military police and the latter was commander of the

25 civilian police, and both were subordinated to Becir Bogilovic.

Page 13281












12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.













Page 13282

1 Q. Do you know who subsequently succeeded Becir Bogilovic?

2 A. Becir Bogilovic, when he left, was succeeded, I think, by Atif

3 Krzic.

4 Q. We are going to come to that in a moment. It's simply this: You

5 say that Becir Bogilovic was chief of the civilian and military police

6 until he left Srebrenica. "This was until the end of 1992, as far as I

7 can recall."

8 Are you sure about that date, end of 1992, or could it be either

9 earlier or later?

10 A. It was in that period.

11 Q. Now, where did the civilian police work?

12 A. The civilian and the military police worked in the same building.

13 The former building of the police station in Srebrenica. They were under

14 the same roof.

15 Q. Is that what's also called the SUP or the MUP building?

16 A. Yes.

17 Q. Now, I think you've told us -- well, let me ask: Did you see

18 Becir Bogilovic at the municipal building?

19 A. Yes. Yes, I did. I just mentioned a while ago he didn't come

20 often, but he did. I would see him when I was handing in my reports to

21 the president of the War Presidency, Mr. Avdic. He would also bring in

22 his reports.

23 Q. And he would be bringing his reports to whom?

24 A. He brought his reports to Hajrudin Avdic, the president of the War

25 Presidency, just as I did.

Page 13283

1 Q. Now, you've also mentioned that Mirzet Halilovic and someone else

2 came more often. Who was the other name which you mentions with Mirzet

3 Halilovic?

4 A. Nurija Jusufovic.

5 Q. And what was his function again?

6 A. Nurija Jusufovic was commander, that is komandir of the civilian

7 police.

8 Q. All right. I'm going to come to him in a moment but I want to

9 stick with Mirzet Halilovic for a bit longer. Did Mirzet Halilovic make

10 reports to the president of the War Presidency in this period from July

11 1992 onwards?

12 A. Yes. He came often, together with Nurija. Sometimes all three of

13 them would come along, Becir, Nurija and Mirzet, but most often it was

14 Mirzet and Nurija who came to see the president of the War Presidency of

15 Srebrenica municipality, Mr. Avdic, and brought him their reports. I saw

16 them often, because my office was right there, and very often we would

17 attend the morning briefing together. I would bring in my reports and

18 they would bring in theirs.

19 Q. All right. And just to be totally clear about this, it's no doubt

20 clear already, but you said earlier the former referring to Mirzet

21 Halilovic what the was a commander of the military police and the latter,

22 and that was Nurija Jusufovic was commander of the civilian police and

23 both were subordinated to Becir Bogilovic. Is it right then that Becir

24 Bogilovic was the chief of Mirzet Halilovic?

25 A. Yes. He was the superior of both Mirzet Halilovic and Nurija

Page 13284

1 Jusufovic.

2 MR. JONES: If the witness could now be shown P42 and again we

3 can place it on the ELMO? For the record I'm just going to read a couple

4 of parts of this. It's Republic of Bosnia-Herzegovina, Srebrenica

5 municipality, War Presidency. Srebrenica, 1st July 1992. "On 1 July

6 1992, pursuant to the decision of the Presidency of Bosnia-Herzegovina to

7 declare a state of war, at the initiative of the armed forces and citizens

8 of the free territory of Srebrenica, and in order to fight as successfully

9 as possible against the aggressor, against Bosnia-Herzegovina, the

10 following was adopted in Srebrenica. Decision: To form and appoint

11 members of a War Presidency of Srebrenica municipality." And then

12 "Article 1, the War Presidency of Srebrenica municipality is hereby

13 formed. Article 2: The War Presidency is the most senior organ of

14 government on the free territory of Srebrenica and has all the

15 competencies of the Srebrenica municipal assembly."

16 Now, stopping there, my question is: Was that your understanding,

17 that the War Presidency was the highest organ on the free territory of

18 Srebrenica with all the competencies of the Srebrenica municipal assembly?

19 A. Yes. The War Presidency was the supreme organ of Srebrenica

20 municipality.

21 Q. All right. I skip Article 3. We can see for ourselves what that

22 says. For Article 4, it says "the following are hereby appointed members

23 of the War Presidency," and there is a list of names, one to 11 which I'm

24 going to come to in a moment. The first -- I want you to turn to the last

25 page and we see that it's signed by the president of the War Presidency,

Page 13285

1 Hajrudin Avdic. Do you see that?

2 A. Yes.

3 Q. So would it be right that Hajrudin Avdic, the president of the War

4 Presidency, was the one who made these appointments?

5 A. Yes.

6 Q. Going back to Article 4, I want to ask you about some of the

7 people listed there and how often they appeared at the municipal building

8 and attended meetings of the War Presidency in 1992. Firstly, Hajrudin

9 Avdic.

10 A. Hajrudin Avdic was there more or less constantly, all the time, in

11 the municipal building.

12 Q. Hamdija Fejzic?

13 A. Hamdija Fejzic was also there often. Resid Efendic, occasionally.

14 Naser sometimes rarely. He was the one I saw least. Dzemal Becirovic

15 was there often. Jusuf Halilovic. I don't know what he did, in some kind

16 of civilian protection that wasn't really functioning. Becir Bogilovic

17 came occasionally, as I said. Instead of him, Mirzet Halilovic and Nurija

18 Jusufovic would come because, I repeat, he had been wounded in the leg and

19 couldn't move around so easily. Mirsad Dudic was on the ground more

20 often. He came rarely. Legic [phoen] Mandzic, Azif Nekic, and Senahid

21 Tabakovic also came in rarely to the Srebrenica municipal building.

22 Q. All right. Just one possible correction. In the English, and it

23 may be the interpreters were looking at the English, it does appear to say

24 Lefik [phoen] Mandzic. Could you confirm, please, that -- well, the name

25 at number 9 in B/C/S? Could you read that name for us, please?

Page 13286

1 A. Sefik, Sefik Mandzic.

2 Q. Thank you. Now a moment ago, you said that use you've Halilovic

3 you're not sure what he did, some kind of civilian protection, that wasn't

4 really functioning. Do you know why that wasn't functioning or do you

5 have any explanation?

6 A. Well, simply the conditions were not in place for civilian

7 protection to function.

8 Q. And for the War Presidency as a whole, did that in fact function

9 properly in this period, still with July, July August, 1992? Did it

10 function, as far as you could see?

11 JUDGE AGIUS: Yes, Madam Vidovic?

12 MS. VIDOVIC: [Interpretation] Your Honours, the witness was not

13 receiving interpretation of the last question, if my friend could repeat

14 the last question, please.

15 JUDGE AGIUS: Yes, Mr. Jones.

16 MR. JONES: Yes.

17 JUDGE AGIUS: I suggest you repeat the question, please.

18 MR. JONES: Yes.

19 Q. Was the War Presidency in fact functioning properly, as far as you

20 could see, in July 1992, firstly?

21 A. It could not have functioned in the true sense and, in my opinion,

22 it existed more on paper than in reality. It did not really have the

23 ability to create anything.

24 Q. All right.

25 JUDGE AGIUS: Thank you, Madam Vidovic. Yes, Mr. Jones.

Page 13287

1 MR. JONES: Yes.

2 Q. I was asking about July 1992 but the statement you've just made,

3 that it couldn't function, it existed more on paper, is that for any

4 particular time period or is that right through to demilitarisation?

5 A. That is true for the entire period through to demilitarisation

6 because there were no conditions in place to enable it to function

7 properly.

8 Q. All right. Now, do you know someone called Hakija Meholjic?

9 A. Yes.

10 Q. Do you know whether he took on any function in around spring of

11 1993?

12 A. Yes. In the spring of 1993, he replaced Mr. Becir Bogilovic. He

13 replaced Becir Bogilovic.

14 Q. Thank you. Earlier you mentioned Atif Krdzic. Is it correct that

15 in fact it was Hakija Meholjic who replaced Becir Bogilovic then?

16 A. Akif Krdzic replaced Mirzet Halilovic at the point when Mirzet

17 Halilovic was replaced, I believe, because Mirzet was removed from the

18 post. I don't know why, whether it was misconduct or something else. I

19 wouldn't wish to go into that, but at any rate, Akif Krdzic replaced

20 Mirzet Halilovic.

21 Q. And do you know who replaced or who removed Mirzet Halilovic from

22 his post, who or what organ?

23 A. Mirzet Halilovic was removed by the War Presidency, which had the

24 authority over him and his work.

25 Q. And finally, then, also for the period that Becir Bogilovic was in

Page 13288

1 his function, you said earlier that that -- he was already in that

2 position in early July 1992. You said he was replaced by Hakija Meholjic

3 which was in the spring of 1993. So can you help us now with what in fact

4 was the periods that Becir Bogilovic was in function as the head of the

5 civilian and military police?

6 A. Becir Bogilovic held the position of the chief of the police and

7 civilian police practically through to demilitarisation, because nobody

8 else was appointed to his post except for the stage when Hakija Meholjic

9 arrived. That was the time when the things changed.

10 MS. VIDOVIC: [Interpretation] Your Honours I would just wish to

11 enter a correction on the transcript. The witness said the chief of the

12 military and civilian police. I believe this did not enter into the

13 transcript.

14 JUDGE AGIUS: Yes. I think that needs to be corrected. But first

15 let's have a confirmation from the witness himself. In fact, actually, he

16 had stated it earlier on in the day, you know, so I think we can take it

17 for granted and move ahead.

18 MR. JONES: That's fine. I think I will just ask the witness.

19 JUDGE AGIUS: Let's move because some 30 minutes ago he did

20 precisely state that. So let's move forward.

21 MR. JONES: Okay. Fine, thank you, Your Honour.

22 Q. Now, you've mentioned this police building, this SUP or MUP

23 building. You've mentioned that that was used both by civilian and

24 military police together. Is it right then that that building was under

25 the jurisdiction of Becir Bogilovic as the head of the military police and

Page 13289

1 the civilian police?

2 A. Yes.

3 MR. JONES: If the witness could now be shown P109? Hopefully

4 after the break we'll have -- more of us will have the exhibits.

5 JUDGE AGIUS: Once that has arrived, so don't worry about that.

6 We will find a solution.

7 MR. JONES: There is just a one page document now. Since not

8 everyone has it in front of them I'll read part of it. It's the Republic

9 of Bosnia-Herzegovina, Srebrenica Municipal Territorial Defence Staff,

10 Srebrenica, 2 July 1992. And its subject is "decisions of the Territorial

11 Defence Staff, Srebrenica." It says "At the meeting of the Crisis Staff

12 of Srebrenica TO on 1st July 1992, three decisions were made for solving

13 some of the problems in the current situation on the territory controlled

14 by Srebrenica TO forces. Since the previous War Presidency had left the

15 territory of the municipality, the new War Presidency was formed." And

16 then it mentions the members of the War Presidency.

17 Now, a moment ago you agreed, did you not, that once formed, that

18 body, the War Presidency, was the highest organ on the territory; is that

19 correct?

20 A. Yes.

21 Q. And would you agree that the last document that we saw was in fact

22 a formal act of appointing members the War Presidency signed by the

23 president of the War Presidency, whereas this is a report on formations

24 and appointments? Would that be correct?

25 A. Yes.

Page 13290

1 Q. And it says, paragraph 3, "A decision was made to form wartime

2 military police, Mirzet Halilovic was appointed the commander of this

3 unit."

4 Now first if you can help with this. In the English translation

5 it says "commander," but in Bosnian it says something else, doesn't it?

6 It says "rukovodilac."

7 A. That is practically the same. If you have the military hierarchy

8 in mind, then, of course, it would be logical to call him commander.

9 Otherwise, he could be called "rukovodilac", head.

10 Q. My question is this, really: Is that a normal word to use in this

11 context? Is that the proper term to use?

12 A. Yes. It can be used, the term.

13 Q. Commandant or komandir would be more proper?

14 A. Yes. If a military formation is involved. However, they had two

15 or three rifles perhaps. To put it simply, this record was done by

16 unprofessionals who didn't know what the military, what the civilian

17 hierarchies were, and, in my opinion, this record has not been done

18 properly. It has been done incompetently.

19 Q. All right. Now regarding that paragraph, to your knowledge, which

20 organ formed the military police and appointed Mirzet Halilovic as its

21 head?

22 A. No military organ formed the military police. The military police

23 was established by the War Presidency, as I've already indicated. And the

24 War Presidency had the jurisdiction over the military police.

25 Q. I'm going to the next paragraph, the next two paragraphs it refers

Page 13291

1 to the formation of a communications and information service. And I think

2 you've already explained that that was also under the War Presidency and

3 that your commission was part of that service. Have I summarised that

4 correctly?

5 A. Yes.

6 Q. Do you in fact know Hamed Alic who was apparently appointed the

7 chief of this service?

8 A. Yes.

9 Q. Where did he work in July 1992 and afterwards?

10 A. He worked in the post office building in the Srebrenica

11 municipal -- or, rather, in Srebrenica itself.

12 Q. All right. Just to be absolutely clear because it's an important

13 point. The post office building is a separate building from the municipal

14 building, correct?

15 A. That's right. It's some 400 to 500 metres away from the municipal

16 building.

17 Q. And was there a room there in which Hamid Alic worked?

18 A. Yes. I would frequent Hamid Alic in his office because, in that

19 period, he was my superior. There was a room there with a radio set over

20 which he kept in touch with Tuzla.

21 Q. Was there any sort of armed guard outside that room or not?

22 A. No. Why would there be one? I never saw any armed guards.

23 Q. And do you know who if anyone Hamid Alic delivered his reports to?

24 A. Solely to the president of the War Presidency, Mr. Hajrudin Avdic.

25 Q. And as far as what was transmitted on the radio, was Hamid Alic

Page 13292

1 able to transmit whatever he liked or did he have to have some approval?

2 A. At any rate, he had to have an approval. No information was

3 allowed to be transmitted over the radio without either the signature or

4 the written approval of the president of the War Presidency, Mr. Hajrudin

5 Avdic.

6 Q. And how do you know that?

7 A. I am aware of this because, as I said a minute ago, I went to the

8 post office oftentimes and whenever I had -- something had to be sent

9 over, Hajrudin Avdic [as interpreted], although my superior trusted in me

10 and he would tell me, "I cannot send anything out without Hajrudin Avdic's

11 approval," that is the president of the War Presidency, and that is how I

12 know that he was unable to send out any information without his consent.

13 Q. Sorry, finally, who told you that? I think there might be an

14 error in the transcript. Who told you that he couldn't send anything out

15 without the approval of Hajrudin Avdic?

16 A. Hamid himself.

17 Q. Thank you. I think that's a good moment to break.

18 JUDGE AGIUS: Thank you, Mr. Jones. We will reconvene in 25

19 minutes' time. Thank you.

20 --- Recess taken at 10.30 a.m.

21 --- On resuming at 11.02 a.m.

22 JUDGE AGIUS: Yes, Mr. Jones.

23 MS. RICHARDSON: Your Honour, if I may before Mr. Jones gets

24 started I just want to put on the record that with respect to the area in

25 which Defence has been cross-examining -- has been examining this witness,

Page 13293

1 I would ask that there be no leading questions. I did not object

2 previously. There were a few suggestive questions put. I know we are

3 short on time but I'd only ask that counsel not lead in these areas.

4 JUDGE AGIUS: Which area because he's been touching on several

5 areas.

6 MS. RICHARDSON: Yes, Your Honour, with respect to the functioning

7 of the different organs and who is in charge and who is subordinated to

8 whom.


10 MS. RICHARDSON: Thank you.

11 JUDGE AGIUS: Yes, Mr. Jones, at the same time, at the same time,

12 as we go along, if Mr. Jones touches upon other matters which are not

13 contested by the Prosecution, please stand up and say so because it could

14 spare us -- save us quite a few minutes, I suppose.

15 MS. RICHARDSON: I will, Your Honour.

16 JUDGE AGIUS: Particularly, for example, when he was dealing with

17 attacks on Glogova, attacks here and attacks there. If you agree that

18 there had been such attacks you just stand up and say we agree there have

19 been such attacks on such and such a day and the rest you can deal with

20 obviously without any interference. But you've got the message now.

21 MR. JONES: Yes, may I just say, Your Honour, the principle, of

22 course, is that unless there is a timely objection, then any objection to

23 a leading question is waived. At no time this morning was there an

24 objection from the Prosecution.

25 JUDGE AGIUS: I agree.

Page 13294

1 MR. JONES: And so certainly it's not appropriate to say that any

2 questions were suggestive or leading. If they wanted to make that has an

3 objection then they had to do it on time rather than later. I'll take it

4 as an indication --

5 JUDGE AGIUS: Yes, I think that's ---

6 MS. RICHARDSON: It is. It is, for the future. Thank you.

7 JUDGE AGIUS: Thank you. Let's proceed.

8 MR. JONES: Yes.

9 JUDGE AGIUS: Mr. Jones?

10 MR. JONES: Yes, starting immediately with a new exhibit, and for

11 the record the ERN number is 01787774. And while that's being distributed

12 I'll just read for the record -- after the witness has it. Yes, it says

13 "Republic of Bosnia-Herzegovina, War Presidency of the Municipal Staff of

14 the armed forces, communications and information service, Srebrenica 2

15 August 1992," and then I move down to "the approval is hereby granted to

16 Nijaz Masic to take statements from persons who have reliable information

17 about the genocide perpetrated by the occupier against Muslims, Croats,

18 and other ethnic groups."

19 And then it's signed for the communications service.

20 Q. My question is this, Mr. Sacirovic. You told us before the break

21 that the communications and information service was under the War

22 Presidency. Does this document confirm that or not?

23 A. Yes. It is confirmed.

24 Q. And in this document, it appears Nijaz Masic is being tasked to

25 investigate genocide committed against various ethnic groups. My question

Page 13295

1 is, did you ever receive a similar approval?

2 A. Yes. I did. However, my approval and the decision on my

3 appointment was signed by the president of the War Presidency, Hajrudin

4 Avdic, and not by Hamed Alic, as is the case here for this particular

5 gentleman.

6 JUDGE AGIUS: [Microphone not activated].

7 THE INTERPRETER: Microphone, please. When we have documents

8 please make sure that the English version is put on the ELMO because

9 members of the public and others outside following the proceedings that

10 need, or rather have a right to be able to follow properly. All right?

11 Thank you.

12 So let's put this document on the ELMO for a brief moment. Sorry

13 to have interrupted you, Mr. Jones, but I think it's important.

14 MR. JONES: In the meantime I might just ask the following.

15 JUDGE AGIUS: Yes, go ahead. I mean it's -- I just want to show

16 it to the public, that's all.


18 Q. In terms of the decision on your appointment signed by Hajrudin

19 Avdic, do you know happened to that document? Do you still have it?

20 A. No. I don't have the document. All these documents stayed behind

21 in Srebrenica. I don't have it here with me and I cannot show it to you.

22 Q. All right. Stayed behind in Srebrenica? When?

23 A. On the 11th of July 1995 when Srebrenica was occupied.

24 Q. And what was your mandate, which you received from Hajrudin Avdic?

25 A. My mandate was to hold the position of the president of the

Page 13296

1 commission for the gathering of facts about the war crimes committed in

2 Srebrenica.

3 Q. And was that concerned only with war crimes committed against

4 Muslims or was it for any ethnic group?

5 A. Not only did it involve Muslims but all the inhabitants regardless

6 of their religion or ethnicity. We gathered whatever information we were

7 able to gather, given the terrain itself and the access we had to it. So

8 we gathered information about all the crimes committed, regardless of the

9 victims, because when we talk about the crimes, one should not pay

10 attention to one's creed, race or ethnicity. So we investigated into all

11 the crimes committed against members of all the different ethnicities and

12 religions.

13 Q. And you did so on behalf of and with a mandate from the War

14 Presidency?

15 A. Yes.

16 MR. JONES: I'd ask for an exhibit number for this document,

17 please.

18 JUDGE AGIUS: Yes, thank you, Mr. Jones. What's the next number,

19 please? 800.

20 THE REGISTRAR: D862, Your Honour.

21 JUDGE AGIUS: 862. So this document which consists of two pages,

22 one B/C/S, one in English, with ERN 01787774, is being tendered and marked

23 as Defence Exhibit D862.

24 MR. JONES: Thank you, Your Honour. And we have the next exhibit,

25 there will be a sequence of exhibits now. It's ERN number is 01787792.

Page 13297

1 And just as that's being handed to the witness for the record I'll read at

2 the top. It says, "Communications and reporting" -- well, in English

3 reporting service. In Bosnian it appears to say "information service."

4 I'll ask the witness about that. The date, "Srebrenica, 5 August 1992,

5 entry permit for Sabahudin Gluhic and Edhem Vranjkovina in order to film

6 the damage caused to the factory in Zeleni Jadar."

7 Q. First, could you read at the top, the service which is referred

8 to there? Yes [B/C/S spoken]. Do you see that at the top?

9 A. Yes.

10 Q. Is that the service which you spoke about before the break, headed

11 by Hamed Alic?

12 A. Yes.

13 Q. Now, do you know either or both of Sabahudin Gluhic or Edhem

14 Vranjkovina?

15 A. I know both of them. They were members of my team. They were my

16 subordinates, according to a hierarchy. Sabahudin Lukic [phoen] was a

17 cameraman. He was the one filming and Edhem Vranjkovina was there with me

18 also, and we were together gathering information about the war crimes

19 committed.

20 Q. And did you work from an office at any point, your team?

21 A. Yes.

22 Q. Is that the office you referred to earlier in the municipal

23 building?

24 A. Yes. That's the same office in the municipal building on the

25 second floor, in Srebrenica.

Page 13298

1 MR. JONES: Can I ask for an exhibit number for this document,

2 please?

3 Q. Yes. Can you tell us who signed this, if possible?

4 MR. JONES: Sorry, can you give the document back to him for a

5 moment?

6 Q. Can you help us with --

7 JUDGE AGIUS: I was going to put the same question myself also

8 with regard to the previous document, D862. If he can recognise both or

9 either of those two signatures.

10 THE WITNESS: [Interpretation] This signature here does not really

11 seem familiar.

12 JUDGE AGIUS: All right.

13 THE WITNESS: [Interpretation] Just a moment, please. Let me just

14 take a look at it.

15 JUDGE AGIUS: We are talking of D863.

16 THE WITNESS: [Interpretation] I cannot remember. I cannot.

17 JUDGE AGIUS: No problem. Usher, can you please show him also the

18 previous document, D862, and see whether he recognises that signature?

19 And if you don't recognise it, unless you are sure, Mr. Sacirovic,

20 don't --

21 THE WITNESS: [Interpretation] Yes. Yes. This signature is

22 familiar to me. It's the signature of Hamed Alic.

23 JUDGE AGIUS: Okay. Thank you.

24 MR. JONES: All right. Thank you, thank you very much,

25 Your Honour. And I think for --

Page 13299

1 JUDGE AGIUS: We haven't give it a number.

2 MR. JONES: 01787792.

3 JUDGE AGIUS: So this last document that has been made use of by

4 the Defence consisted of two pages, one B/C/S, one in English, with ERN

5 number 01787792, is being tendered and received and marked as Defence

6 Exhibit D863.

7 MR. JONES: Thank you, Your Honour.

8 Q. And we have another exhibit which is ERN number 01787791. Which

9 is the prior ERN number to the document we just exhibited. And since it's

10 short I'll just read now into the record. It says, "Report. We have

11 successfully prepared and gathered information from the Zeleni Jadar

12 area."

13 Q. Now, do you see that document, Mr. Sacirovic?

14 A. Yes.

15 Q. Can you see who signed it?

16 A. Sabahudin Gluhic.

17 Q. And do you recall an information-gathering exercise undertaken by

18 your team in Zeleni Jadar?

19 A. Yes. A factory had been shelled and badly damaged.

20 Q. Is this the report relating to the entry permit which we just saw

21 a moment ago?

22 A. Yes.

23 Q. Thank you.

24 MR. JONES: I'll just ask for an exhibit number for this document,

25 too, please.

Page 13300

1 JUDGE AGIUS: So this document which also consists of two pages,

2 the one in B/C/S handwritten and the other one consisting in the English

3 translation thereof and in a typed format, is being tendered, received,

4 and marked as Defence Exhibit D864.

5 MR. JONES: Thank you, Your Honour. And then three more exhibits,

6 first D266. This is already a Defence Exhibit. Since it's short I'll

7 just read the following: "Republic of Bosnia-Herzegovina, municipal War

8 Presidency, dated 16 August 1992, order, the employees Edhem Vranjkovina

9 and Sabahudin Gluhic to go to Suceska local commune on 17 August 1992 in

10 order to make a video recording of the war damage and general situation in

11 the local commune of Suceska." It's signed by Hajrudin Avdic for the War

12 Presidency.

13 Q. Now, is it correct to understand this document as the War

14 Presidency ordering members of your commission to collect evidence of war

15 damage in Suceska?

16 A. Yes. You can see that from the order and from Mr. Avdic's

17 signature.

18 Q. And is this still linked to the collection of evidence of war

19 crimes?

20 A. Yes.

21 Q. When you found such evidence in 1992, would you report it to the

22 War Presidency?

23 A. We were duty-bound to bring in and hand over any written documents

24 or videotapes. We would hand all those over to the president of the War

25 Presidency. We were duty-bound to do so. It was our obligation.

Page 13301

1 Q. And that's the same person, is it not, to whom Mirzet Halilovic

2 reported in 1992?

3 A. Yes. All his subordinates brought reports to him. Mirzet

4 Halilovic and Nurija Jusufovic, Becir Bogilovic, myself. Any service over

5 which the War Presidency had competency.

6 Q. Thank you. And then we have a new -- another new document which

7 is 01787789. Yes. I have -- there are actually two documents which are

8 in ERN number sequential and it might be better to have them together just

9 to expedite matters.

10 And the first one, 01787789, "Order. Film the interior of the

11 factory in Potocari, Edhem Vranjkovina, and Sabahudin Gluhic will do the

12 filming, War Presidency," and then a signature.

13 Now, does this confirm what you've told us that the War Presidency

14 issued orders to your commission to do filming?

15 A. Yes.


17 Could we have D863, please, shown again, to the witness?

18 Q. I'm wondering if you could just look at the signature on the

19 document which has just been put in front of you and then the signature

20 which you were asked to look at earlier.

21 A. Ah, yes. Yes, now I recall. Yes. This is the signature of the

22 president of the War Presidency of Srebrenica Municipality, Hajrudin

23 Avdic. Sometimes one has a mental block and I was unable to recognise it

24 but I do recognise it now.

25 Q. Thank you. And then the next document, 01787790 which we are

Page 13302

1 tendering together, this is report from the cameraman and director team,

2 "team consisting of a cameraman and director was supposed to go to

3 Potocari as ordered to film the interior of the factory there. However,

4 the task was not carried out as that area was being heavily shelled by

5 Chetniks from Bratunac."

6 And then, can you tell us there who appears to have signed this

7 document?

8 A. At the bottom of this document are the signatures of

9 Mr. Edhem Vranjkovina and Sabahudin Gluhic, the cameraman.

10 Q. And do you recall this, this assignment in Potocari?

11 A. Yes. I do. I was down there too but you couldn't approach the

12 place. There was no opportunity to go there. There was shelling all day.

13 Q. Thank you.

14 MR. JONES: I'd ask for an exhibit number for these two documents.

15 JUDGE AGIUS: So these two documents, consisting of two pages in

16 B/C/S with ERN number 01787789 and 01787790, together with the

17 corresponding translation into English on two separate sheets of paper is

18 being tendered, marked, and received as Defence Exhibit D865.

19 MR. JONES: Thank you, Your Honour.

20 Q. You just mentioned this shelling all day in Potocari. Was that a

21 common or uncommon occurrence in Potocari?

22 A. It was common. Potocari was shelled every day. Sometimes more,

23 sometimes less intensely but not a day went by without its being shelled.

24 Q. And the next document which I'd like to show the witness is D263.

25 It's already a Defence Exhibit. This is "Republic of Bosnia-Herzegovina

Page 13303

1 Srebrenica Municipality War Presidency 12 November 1992, the War

2 Presidency of the Srebrenica municipality at a meeting held on 9 November

3 1992 adopted the following decision on the establishment of a commission."

4 And we see the members of the commission. And then at Roman numeral II,

5 "The commission has the obligation to check the work of the

6 communications and information service from its establishment to date and

7 submit a report to the War Presidency." It's signed by the chairman of

8 the War Presidency, Hajrudin Avdic.

9 Now, the question is, firstly, are you familiar with the

10 establishment of this commission?

11 A. Yes.

12 Q. And is it correct or not that the War Presidency supervised the

13 work of the communications and information service by, for example,

14 establishing this commission?

15 A. I have clarified this more than once. The War Presidency had

16 jurisdiction over this commission. This commission was strictly

17 subordinated to the War Presidency.

18 Q. All right. Did you in fact at some stage see Serbs in Srebrenica

19 who were going for exchange?

20 A. Yes.

21 Q. And how did that come about?

22 A. Well, Nurija Jusufovic, the commander of the civilian police, came

23 to see me. He said, "Mustafa, we need to have a film taken of the Serbs

24 going to be exchanged. This is under orders from Hajrudin Avdic, the

25 president of the War Presidency." So we went out and filmed the people

Page 13304

1 being exchanged and I interviewed them and there were women among them as

2 well. There were women.

3 Q. And did you seek to find out whether they had been ill treated or

4 if they had been well treated?

5 A. Well, as an investigator, of course the main thing was to ask how

6 they had been treated, whether they had been beaten, maltreated, abused,

7 how they had been treated while they were prisoners in Srebrenica. They

8 replied that everything was all right, that nobody had beaten them, that

9 they had been given food, enough food in view of the situation prevailing

10 in Srebrenica at the time.

11 JUDGE AGIUS: Mr. Jones, perhaps you can address two things in

12 relation to this. Whether you can -- the witness can place it within a

13 time frame and whether it occurred only once or more than once.

14 MR. JONES: Yes.

15 Q. You probably heard that, Mr. Sacirovic. Can you help with those

16 two issues?

17 A. That was my only contact with prisoners in Srebrenica and it was,

18 I think, in the second half of 1992. I cannot recall the precise date. I

19 don't really have a good head for dates. When it comes to remembering

20 telephone numbers, dates or names of streets, my memory fails me, but

21 faces I can remember for a very long time.

22 Q. All right. Well, we have a videoclip we are we are going to show

23 now.

24 JUDGE AGIUS: Is it a new document, this?

25 MR. JONES: Yes, perhaps to explain, Your Honour, we have I think

Page 13305












12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.













Page 13306

1 five new videoclips which we are going to be showing.

2 JUDGE AGIUS: I noticed that.

3 MR. WUBBEN: Two are on one DVD, three are on a CD. We have start

4 and stop times for each one so I'm going to suggest that we each be a

5 separate exhibit because we have transcripts also for each videoclip.

6 JUDGE AGIUS: As you wish, Mr. Jones.

7 MR. JONES: For this videoclip there is a transcript but I don't

8 want to distribute copies to the witness simply because I notice that

9 there are something written there which might be objected to as being

10 suggestive. So until he's answered I'll keep the transcript from him and

11 distribute it to everyone else.

12 JUDGE AGIUS: Thank you.

13 MR. JONES: So if we distribute the transcript, then we'll play

14 this videoclip.

15 I think we can play the video. Thank you.

16 JUDGE AGIUS: Thank you.

17 [Videotape played]

18 THE INTERPRETER: [Voiceover] "We were here. Nobody touched us.

19 We had everything we needed. They gave us food to eat and to drink.

20 Nobody touched us. They are taking us for exchange now."

21 Question: "Please tell us how many times you were taken for the

22 exchange in Potoceska [phoen] Rijeka."

23 Answer: "This is the third time."

24 Question: "And how about the others? Have you been maltreated,

25 beaten, or tortured while were you here with us?"

Page 13307

1 Answer: "No, nobody."

2 Question: "Let me ask these other young two young men over here.

3 You two came in later; is that right? Has someone beaten you, maltreated

4 you, molested you? Please don't be afraid, tell me freely."

5 Answer: "Nobody did."

6 "Nobody touched you? You had food and everything? Everything

7 was okay; is that correct?"

8 Answer: "Yes, we had."

9 "Okay."

10 MR. JONES: We may have to play this video again in a second, but

11 my question is, first, who is the person conducting this interview?

12 A. I was conducting the interview with the prisoners who were about

13 to be exchanged.

14 Q. Is this or is this not the incident you referred to earlier?

15 A. Yes.

16 Q. And who was filming this scene?

17 A. It was Sabahudin Gluhic, the man in my team.

18 Q. If we can cue it back up again for a moment?

19 [Videotape played]

20 MR. JONES: You can just freeze it there.

21 Q. I don't know if you can see there is a date there, if we play it a

22 little bit you may see a date.

23 [Videotape played]

24 THE INTERPRETER: [Voiceover] "How about the others."

25 THE WITNESS: [Interpretation] Yes, it's the 13th of August 1992,

Page 13308

1 at 1330 hours. These dates are correct. I always told the late Mr.

2 Gluhic to put in the date whenever we were filming something, to make this

3 authentic evidence.


5 Q. And what ethnicity are the people who are being interviewed?

6 A. Serbs.

7 Q. And do you know where they were from?

8 A. They were from east of Srebrenica, a small village. I think the

9 name of the village was Karno, to the best of my recollection. It was to

10 the east of Srebrenica, a place called Karno.

11 Q. Yes. And now, we may need to use a little drawing which I

12 prepared for this segment of the testimony. My question is: Would you --

13 how many people do you see in the truck? And if you have difficulty, then

14 we have a means of dealing with that. But do you know how many people are

15 in the truck?

16 A. A total of 11 people.

17 MR. JONES: Your Honour, to assist with this, I did a little

18 sketch which I would like to distribute because I think it's helpful.

19 JUDGE AGIUS: Go ahead.

20 MR. JONES: Thank you. Just to explain, in order to be able to

21 count how many people, and it is relevant for purposes we will come to, I

22 did a little drawing with labels of the people in the truck. What I

23 propose to do is just play the video through one more time and what I'd

24 propose to do, if there is no objection, is simply count off the people as

25 we see them. So if we start the tape -- start at the very beginning.

Page 13309

1 [Videotape played]

2 MR. JONES: And the interpreters needn't interpret for this

3 section.

4 So we have an old lady, then. If you agree, Mr. Sacirovic, as we

5 go along, there is an old woman there who is speaking to you.

6 A. Yes.

7 Q. And a man in a blue cap?

8 A. Yes.

9 [Videotape played]


11 Q. And then we see a man with a black beard looking down, do you

12 agree?

13 A. Yes.

14 Q. A man with a cap behind him, who appears to be looking away?

15 A. Yes.

16 Q. To the left, a man with a white beard?

17 A. Yes.

18 MR. JONES: Keep playing.

19 [Videotape played]


21 Q. And do you agree then in the front we have an old -- always

22 careful about using those terms, a man of elderly appearance with his back

23 to the camera?

24 A. Yes.

25 Q. And to his left, it appears someone wearing a pink headcloth?

Page 13310

1 A. Yes. That's a woman.

2 Q. And to that woman's left, someone in a blue headcloth?

3 A. Yes, another woman.

4 Q. And then a man with another cap on the far left-hand side leaning

5 against the cab of the truck?

6 A. Yes.

7 Q. And if we keep playing just a little further.

8 [Videotape played]


10 Q. And then there you're referring to two lads, two young men, and do

11 we see those two young men, one is partially obscured?

12 A. Yes.

13 Q. Okay. Thank you. That's to establish that that's therefore 11

14 people in total, among them two young men who arrived later, according to

15 what you said.

16 A. Yes.

17 Q. Thank you.

18 MR. JONES: We've finished with that exhibit, although I would ask

19 for an exhibit number for the transcript and the clip.

20 JUDGE AGIUS: The video will be marked as Defence Exhibit D866.

21 The transcript, which is being provided in the original B/C/S language and

22 also in the English translation thereof is being marked as Defence Exhibit

23 D866.1. And the diagram that has been prepared by Mr. Jones is being

24 marked as Defence Exhibit D866.2.

25 MR. JONES: Thank you, Your Honour.

Page 13311

1 JUDGE AGIUS: Does that confuse you, Madam Registrar, or is it

2 okay with you? It's okay with you. Thank you.

3 MR. JONES: Thank you. I would now ask if the witness could be

4 shown Defence Exhibit D245. And this reads "Republic of Srpska Ministry

5 of Interior, public security station SJB, Srebrenica, 22 October 1996.

6 Official note." And I'm just reading the third paragraph which refers to

7 "all gathered materials were found after liberation of Srebrenica in the

8 premises of the former Domavija hotel." And then a list of materials

9 follows, and we need to see the B/C/S version just to see that it is

10 actually a bullet-pointed list without the bullet points. And I want to

11 go to the second-to-last bullet point where it says, "SJB Srebrenica

12 commander Nurija Jusufovic asks a certain Avdic in a note on a piece of

13 paper what to do with nine detained Serbs from Karno." Do you see that,

14 Mr. Sacirovic? It's on the second page and it's the penultimate

15 paragraph.

16 A. Yes, yes. I can see it.

17 Q. Do you know the Nurija Jusufovic referred to here?

18 A. Yes. I mentioned him a little while ago. He was the commander of

19 the civilian police in Srebrenica, and it says here "a certain Avdic." He

20 had to ask Hajrudin Avdic, the president of the War Presidency of

21 Srebrenica municipality.

22 Q. And this refers to nine detained Serbs from Karno. We saw 11

23 people in the truck. Do you have any explanation on whether or not these

24 are the same people?

25 A. Well, I don't know where those two lads were brought in from later

Page 13312

1 on to the public security station. The first time I saw them was during

2 this exchange. Nurija told me they had been brought from the east part,

3 the area to the east of Srebrenica, but I don't know the name of their

4 village or when they were brought in.

5 Q. All right. But do you think this reference to nine detained Serbs

6 from Karno, whether that refers or not to the people or some of the people

7 you interviewed in the truck?

8 A. Yes. Those are these men and women.

9 Q. Thank you.

10 MR. JONES: I'm now going to another videoclip. I've finished

11 with that exhibit. And the next clip is already an exhibit. It's D699.

12 I'm just going to show it very briefly.

13 [Videotape played]

14 MR. JONES: Yes. We just need to see this very briefly. We are

15 not going to dwell on this but we will just play it and tell us, please,

16 if you filmed this or not.

17 A. Yes.

18 Q. And we see the date on the screen, 8/8/92. Is that accurate or

19 not, to your knowledge?

20 A. Yes. This was filmed in the hospital in Srebrenica.

21 Q. Do you know where the person being operated on, do you know where

22 he or she was wounded?

23 A. This person was wounded, as far as I know, in Jezestica.

24 Q. And do you know who the surgeon is? We can play on if need be,

25 but if you recall the surgeon performing this operation?

Page 13313

1 A. The chief surgeon at the time was Nedret Mujkanovic.

2 Q. And what sort of a job was he doing in the hospital in Srebrenica

3 in 1992? Good, bad, indifferent?

4 A. He was a surgeon. He did a lot of operations without anaesthesia.

5 This is only one of thousands of operations he performed in the hospital.

6 This man is a hero, a hero in a white coat. He saved many lives.

7 Q. All right. Thank you.

8 MR. JONES: I'm going to another videoclip to deal with a number

9 all together, and this, again, it's the same situation, we have a

10 transcript, which in fact this one can be distributed to the witness as

11 well.

12 And for the record this is the one with the description "videoclip

13 of interviews with fighters." I'm going to ask the technical booth to

14 turn up the volume, please, because we had difficulties with volume

15 earlier.

16 [Videotape played]

17 MR. JONES: We can play the video now.

18 [Videotape played]

19 THE INTERPRETER: [Voiceover] "Which one of you keeps the frontline

20 here? Is there anyone? Which one is Mustafa? Where is he?" Mustafa?

21 Is that you?"

22 "He just got up. He didn't wash up -- he didn't wash his face

23 yet. And you others are sareni, for sure. You just came from Tuzla with

24 Nurif."

25 "Yes, yes."

Page 13314

1 MR. JONES: Thank you.

2 Q. Now, on that clip, again who is the interviewer in that clip, if

3 you know?

4 A. I. I am.

5 Q. Do you know where these men, the ones we saw in uniform,

6 camouflage uniform, where they had come from?

7 A. It is near to Srebrenica, between Potocari and Srebrenica.

8 Q. Yes. I think there was a mistake with interpretation. My

9 question was: The people -- let me approach it this way. In the clip,

10 it's stated "and you others are sareni for sure, you just came from Tuzla

11 with Nurif."

12 "Yes, yes."

13 Do you recall that being said on the video?

14 A. Yes.

15 Q. My question is: The people in the camouflage uniforms, where, to

16 your knowledge, had they come from?

17 A. They had come from Konjevic Polje. They came somehow with Nurif

18 Rizvanovic. It is a unit of some 400 to 500 men who were armed and

19 wearing camouflage uniforms. There were people from all municipalities,

20 Srebrenica, Bratunac, Vlasenica, the Podrinje area in general. They had

21 their families here so they came for a visit.

22 Q. And you say they had come from Konjevic Polje. Before that, where

23 had they come from?

24 A. They had come from Tuzla with Nurif Rizvanovic from Konjevic

25 Polje, probably under orders of the second corps because Nurif's unit was

Page 13315

1 independent.

2 Q. Do you know what his unit was called?

3 A. The 16th Muslim East Bosnian Brigade.

4 Q. And when you say Nurif's unit was independent, independent from

5 whom?

6 A. It wasn't subordinated to anyone, not even to the War Presidency

7 of Srebrenica. They acted on their own, on their own initiative.

8 Q. All right. And in the video we hear the term "sareni." Can you

9 explain what that term refers to and why it was used?

10 A. We popularly called them sareni or the multi-coloured, including

11 myself, because nobody had such uniforms in the area apart from them, and

12 that's why we called them "sareni" or multi-coloured.

13 Q. So Nurif's men were referred to as "sareni" or "the

14 multi-coloured" because they were the only ones who had those uniforms, is

15 that -- is that correct?

16 A. Yes.

17 Q. All right.

18 Q. Did some of those men also have lilies on their uniforms?

19 A. Yes.

20 Q. Do you know if those uniforms, whether they remained with the men

21 who came from Tuzla or whether they were distributed at all or circulated?

22 A. Let me tell you, these people mostly came from Podrinje and the

23 municipalities there. Someone brought over several uniforms for their

24 brothers or others. I will give you an example of Dzemo Tihic who brought

25 a uniform for his brother, Ahmo Tihic. And there were other people who

Page 13316

1 brought over several uniforms to share but not that many.

2 Q. Thank you. And in fact that takes us to the next videoclip but

3 first I'll ask for an exhibit number, please?

4 JUDGE AGIUS: Yes. There videoclip is being tendered and marked

5 as Defence Exhibit eight -- D867, and the relative transcript is being

6 marked as D867.1 consists of two pages, one in B/C/S, one in English.

7 MR. JONES: The next clip is P433. So we've seen this already and

8 we will just play that through. Yes, for the record, the timing is -- one

9 moment, please. Oh, yes. It's 0020025 [as read]. Apologies, my

10 correction, if you give me one moment. Yes. In fact the video starts

11 from 5400 and goes to 1.00. So we can play.

12 [Videotape played]

13 THE INTERPRETER: [Voiceover] "To look at what these fighters here

14 are doing and to put several questions to our commander Ahmo Tihic. First

15 of all, Ahmo, I would like to ask you the following: I heard before the

16 war that you used to have a very strong armed unit of some 50 barrels of

17 weaponry and that from Tihici you came to Kragljivoda. Is that correct?"

18 Answer: "Yes."

19 "Can you tell us something about the situation where these

20 fighters are and what happened? You are the one who knows about these

21 things."

22 "When the police station was occupied by the Serb extremists, we

23 went out and up to Kragljivoda. However, the people did not want to

24 accept us there. They were afraid that they were going to be torched. So

25 we pushed them back as we entered the village. And all these fighters are

Page 13317

1 here with me now."

2 Question: "So all these fighters here are the one who is were

3 with you who were being rejected by the people so you came here to guard

4 these positions?"

5 Answer: "Yes. Since we were unable to hold positions a bit lower

6 we came up here. This terrain was not held by anyone. And this is where

7 we stayed to defend the area."

8 "Thank you, Ahmo. And what's the situation with you, fighters?"

9 MR. JONES: All right. I'm going to continue in a moment. I'm

10 just pausing there. One thing which I'll say, Your Honour, is that

11 obviously the interpreters are trying hard to keep up with interpreting

12 this. We have an official transcript and so, rather than correcting any

13 mistakes I'm going to rely on the transcripts.

14 JUDGE AGIUS: Thank you, Mr. Jones.

15 MR. JONES: Thank you. Since the witness is hearing the original,

16 so --

17 Q. Now, firstly, again, who is the person conducting this

18 interview?

19 A. I am.

20 Q. And who are you interviewing there? Who is sitting next to

21 you?

22 A. I'm interviewing Ahmo Tihic, the leader of the group from

23 Biljeg.

24 Q. Did you specifically go to Biljeg to interview Ahmo Tihic or were

25 you there for some other reason?

Page 13318

1 A. I went there on the orders of the president of the War Presidency,

2 Hajrudin Avdic, because we had learned that a large numbers of refugees

3 from Skelani stayed in the woods there and that was the only reason for me

4 to go there, to film the situation and see what the situation is, to find

5 out the facts about what was going on in the area in that period of time.

6 Q. And was this in fact filmed in Biljeg or elsewhere?

7 A. This was filmed in Biljeg, yes. In the forest, as you can see.

8 Q. And we heard there Ahmo Tihic saying firstly, "For the most part

9 people did not want to accept us anywhere, people were avoiding us. They

10 were afraid of torching, wherever we went, whatever village we came to

11 they sent us away."

12 What was your understanding of what he was saying there, who were

13 avoiding them and what torching were they afraid of?

14 A. Let me tell you this. The Muslim people in these parts trusted

15 Serbs, and as they were looking at the next village being ablaze, they

16 said, no, they were not going to attack us, they must be looking for

17 someone. And this because the Muslims trusted the Serbs. And they always

18 thought that this was because other villages were on fire because they

19 must be looking for Ahmo Tihic and that's why they did not want to allow

20 Ahmo and his group to enter their own villages.

21 Q. That trust which you just referred to, of the Muslims and the

22 Serbs, was that ultimately well placed?

23 A. At the beginning, they thought that it was well placed, until all

24 the Muslims were disarmed and left without any weapons. Later on, it

25 turned out that this trust was not well place.

Page 13319

1 Q. So then we also heard Ahmo Tihic saying that these why they had

2 chosen the terrain here in Biljeg which nobody had control over. How

3 should we understand that? Was this some no-man's land or what precisely?

4 A. Precisely so. It was no-man's land. Ahmo had his group of men

5 and nobody wanted him.

6 Q. Okay. We are going to carry on playing --

7 A. It was a self-organised group.

8 MR. JONES: We are going to carry on playing a bit more of the

9 video.

10 [Videotape played]

11 THE INTERPRETER: [Voiceover] "Do you have any difficulties with

12 accommodation and food? We see that you have tents put up here. Can you

13 tell us something about this?"

14 "In view of the imminent autumn and rain and so on, you must be

15 the platoon commander. And since you know the terrain I suppose you also

16 know about the accommodation of the soldiers, their morale."


18 Q. My question is, did you hear yourself using the term there,

19 platoon commander?

20 A. Yes.

21 Q. And why did you use that term?

22 A. You know what the situation was like. I wanted to raise his

23 morale. That's why I addressed him as a platoon commander, simply to lift

24 up his morale. That was something that I used as a term.

25 Q. Did you in fact see any sort of military formation up there in

Page 13320

1 Biljeg when you were there?

2 A. No. I only saw Ahmo's group, if what you see here you can call a

3 military formation. But it is far from a military formation. It's a

4 self-organised group in the forest without any control. These were simply

5 people fighting for survival.

6 Q. You said you wanted to lift their morale. How was the morale of

7 these men?

8 A. The population was already traumatised by that time. You could

9 see for yourself just by looking at the footage that they were in bad

10 shape.

11 Q. All right.

12 MR. JONES: We'll play on a bit further.

13 [Videotape played]

14 THE INTERPRETER: [Voiceover] "Everything that we are interested

15 in. For the time being, there is nothing specific to comment on. The

16 morale is high. The food is excellent. We do have our kitchen here and

17 we are finding food. So everything's fine."

18 "Thank you."


20 Q. My question is there you've heard a different version of morale.

21 How do you understand that, what that person has just said about morale

22 being high?

23 A. The morale that existed at the time was the one prompted by the

24 wish for life. That was the only thing that existed at the time. And I

25 believe that that was the only thing that they had left, nothing else.

Page 13321

1 Q. In other words, when that man says that everything is fine and the

2 food is excellent, does that seem truthful? Does that seem to reflect the

3 situation as you saw it or not?

4 A. He suppressed the truth there, and you can see there by looking at

5 the terrain, the feature itself, these people were totally dejected. They

6 were -- they felt happy because they knew what happened to the rest of the

7 population in Skelani. They were happy just to be there, alive and

8 kicking. That's what he meant by saying that his morale was high. My

9 morale was also high because I still had the wish to live.

10 MR. JONES: Continue just a little bit more.

11 [Videotape played]


13 Q. Now, who is that person we see in the frame?

14 A. Yes. This is the man from my team, Edhem Vranjkovina, who was

15 with me on the ground.

16 Q. And what would you say he appears to be wearing? Is it a uniform

17 or not?

18 A. He's wearing jeans and the drab olive shirt belonging to the old

19 Yugoslav army.

20 Q. Do you know where he got that from, the drab olive shirt of the

21 old Yugoslav army?

22 A. At the time, his wife was in Tuzla. She is a judge in Tuzla,

23 still today. She sent him the uniform through the soldiers who came with

24 Nurif Rizvanovic to Konjevic Polje and then later on from Konjevic Polje

25 to Srebrenica.

Page 13322

1 Q. Thank you.

2 MR. JONES: And, yes, we are finished with that videoclip.

3 We now have the next one, which is already an exhibit, D177.

4 Q. Yes, what -- actually, before we start the video I'll ask you to

5 see the video as it's played and to make any comments as we go along which

6 you deem appropriate. And I'll have a couple of questions.

7 JUDGE AGIUS: In other words, he has to tell us stop so that he

8 can then proceed with his commentary.

9 In other words, when you want to tell us something, please, you

10 need to say "stop" so that whoever is running the video knows that he or

11 she has to stop.

12 MR. JONES: In fact, also our CaseMap manager will simply stop the

13 second the witness starts speaking. So we can also do it that way.

14 [Videotape played]

15 THE INTERPRETER: [Voiceover] "I -- you, the son of Osmo [phoen],

16 and you live in this burnt-out house. I live in the stable."

17 "In the stable, here where the cows are? Please film this place

18 where he lives. Who else is with you here?"

19 "My wife."

20 "You and your wife alone? Here we have a stable in which a man

21 shares a living space with cattle."


23 Q. First I want to ask you whether you recognised who is in this

24 video a moment ago?

25 A. It is evident that I interviewed the man.

Page 13323

1 Q. And you appear to have a weapon with you. Is that correct? Did

2 you?

3 A. Yes. Yes.

4 Q. And can you explain for the Trial Chamber why you had a rifle?

5 A. I had to carry a rifle. I did not belong to any armed group, as

6 I've already indicated. I belonged to the War Presidency. However, since

7 I passed through dangerous terrain, I had to carry a rifle for personal

8 protection because there was a war on. This was for my personal safety.

9 MR. JONES: We can continue then with the video.

10 [Videotape played]

11 THE INTERPRETER: [Voiceover] "When was your house set on fire?"

12 "I don't know. I was in the forest."

13 "Today is the 14th of August. We are entering the camp Sehiti

14 with Muslim refugees. We are entering now and we want to film the

15 complete situation and to see the way our refugees live who have been sent

16 off from home from the Chetniks."

17 "Are you all from Tokoljak, or are there people from other

18 places."

19 "People from Radovcici, Trubari, and Livcici [phoen]."

20 "How long have you been here?"

21 "Three months."

22 "Three months. What is the situation here, as we can see this

23 doesn't look to me like a living place for humans in the 20th century.

24 Are there lots of problems here?"

25 "The situation is rather difficult."

Page 13324

1 "What is your major problem? They are shelling us every day from

2 Nezero [phoen]. We cannot go home to bring food for us."

3 "So here we see our villages from Tokalaksi [phoen] and other

4 places from which people were expelled by the Chetniks. This reminds me

5 more of the movies with native Indians I watched over 20 years ago. This

6 is the -- this is really sad and horrible. This is the centre of the

7 camp, where our Muslim men, women, and children are here in exile. You

8 can see for yourself what it looks like. In the 20th century, in the

9 atomic age, when some people used to drive Cadillacs. Maybe 425."


11 Q. Yes. I have a question. How far was this camp from where you had

12 interviewed Ahmo Tihic?

13 A. Several kilometres.

14 Q. Thank you. And while we are on the subject, did you see -- we see

15 a camp there. Did you just see the one camp or did you see others?

16 A. I toured many camps, over 20, some 20 to 30 camps in areas such as

17 this one, even worse ones, and you can see for yourself what the situation

18 was. It is indescribable. I am really shaken.

19 MR. JONES: We will continue with the video and then finish it.

20 [Videotape played]

21 THE INTERPRETER: [Voiceover] "Around 500 people, so around 500

22 refugees."

23 "From which villages?"

24 "From the villages of Tokoljaci, Ravnica hamlet, Radovcici, and

25 Trubari. They are lighting fire here. This is all a very -- impromptu.

Page 13325

1 There are many women and children. I don't think that if we went around

2 the world that we would see such suffering as this suffered by our people.

3 "You are Asim from Tokoljak?"

4 "Yes."

5 "Can you tell us how you came to arrive from this refugee camp,

6 when you arrived in this refugee camp."

7 "Three months ago."

8 "Your village must have been burned and you were expelled."

9 "Yes everything was destroyed by shelling."

10 MR. JONES: Yes, I think the witness is upset.


12 MR. JONES: We'll just see if we can continue.

13 JUDGE AGIUS: Yes. Let's deal with this first.

14 Mr. Sacirovic are you in a position to continue or would you like

15 a break?

16 THE WITNESS: [Interpretation] I'll continue.

17 JUDGE AGIUS: If at any time you are not feeling well or you would

18 prefer a short break, please do not hesitate to let us know.

19 Yes, Mr. Jones.

20 [Videotape played]

21 THE INTERPRETER: [Voiceover] "Whatever was not burnt was shelled,

22 so everything in our village is destroyed."

23 "Can you tell me, were people killed in Tokoljaci? Was there a

24 genocide in your village?"

25 "Yes, people were closed in the houses and burnt alive. This is

Page 13326

1 authentic evidence."

2 "Could you tell me, could you tell us the names and first and

3 last names of people, men, women, and children that were victims of

4 genocide?"

5 "Hasib Hasanovic, Bida Hasanovic, Zahida Civic, Hava Salihovic,

6 Avdo Civic. They were locked in their homes and burned alive."

7 "Feel free to come out here."

8 "We are now in another camp on Sehiti, we are going to ask these

9 people how they are faring. They are mostly refugees from Tokoljak,

10 Radovcici, and Tobarijo [phoen]."

11 "How long have you been here?"

12 "We have been here for four months now, in the camp."

13 "Can you tell us what the situation is like? Do you have any

14 problems?"

15 "As you can see for yourself, we have all people, children, women

16 delivered babies here. We had all sorts of things. On the 15th of May

17 was the date when we came down here on Ravnica, without cottages, without

18 anything. We were receiving refugees that came from all sides."


20 Q. Yes, you heard the young man saying that "we were receiving

21 refugees that came from all sides." The Prosecution may suggest to you

22 that that means Serb refugees, Muslim refugees. Is that how you

23 understood what this young man said?

24 A. There were only Muslim refugees here.

25 Q. Were Serbs being expelled from their homes in the Skelani area in

Page 13327

1 1992, in this period in 1992?

2 A. No. No. There was no one to expel them from there.

3 Q. All right. Now you said how you seen -- saw many camps besides

4 these ones. In your investigations, in your information gathering, was

5 the same pattern being repeated throughout the Bratunac, Srebrenica and

6 Skelani areas in the summer of 1992, of Muslims being expelled from their

7 homes, their homes burned and killings by Serbs?

8 A. Yes.

9 Q. And how would you describe the situation in that period, in August

10 1992 with regard to these Muslims living in the woods?

11 A. As you could see for yourselves, it was very difficult, very

12 chaotic. This was shortage of food. People were living outdoors. It was

13 very, very difficult. Disastrous.

14 Q. And when you said a moment ago when I asked you whether Serbs had

15 been expelled in the Skelani area you said "there was no one to expel them

16 from there." Can you explain what you mean by that? Were there actually

17 Muslims still in the Skelani area in August 1992?

18 A. In August 1992, I seriously doubt that. I -- according to what I

19 know about it, there were none.

20 Q. And we've heard in this video terrible stories of people being --

21 Muslims being burned alive in their homes. Did you document such crimes

22 at the time? Did you -- let me put it this way: Did you report that

23 information to anyone?

24 A. Yes. In addition to these videocassettes, video footages, I

25 gathered written witness statements that I handed over to the president of

Page 13328

1 the War Presidency, Mr. Hajrudin Avdic, and every time I returned from my

2 trip out in the field, I handed over all the information that I had

3 gathered.

4 Q. I don't think we need to see the rest of this videoclip but is

5 there anything you would wish to say, Mr. Sacirovic, about what we have

6 just seen?

7 A. I am only glad that this videotape and this evidence has reached

8 this esteemed Tribunal so that everyone can see what happened. There is

9 nothing much I can add to what we have just seen.

10 Q. Thank you. We have a -- the next videoclip which, again, this is

11 now a new one and it's one which is described as "videoclip of damaged

12 school", on the exhibit list. And again we'll ask for the volume to be

13 turned up because on this clip it's not very -- it's a bit faint. And

14 there is a transcript as well, which I would ask be distributed. But

15 again not to the witness.

16 So we can play the clip.

17 [Videotape played]

18 THE INTERPRETER: [Voiceover] "We are standing next to the

19 elementary school in Bektici which was shelled by the enemy every day from

20 tanks, and heavy howitzers. They mostly fired from Kuprivsko Brdo, Besica

21 Brdo, from the relay, and you can see for yourselves what they did and

22 that everything has been destroyed, almost 100 per cent.

23 "Here, look at this part of the school. It was hit by Chetnik

24 shells directly. Could this facility bother the Serb population and be a

25 threat to them?"

Page 13329


2 Q. Now, firstly, do you recognise the voice which is speaking there?

3 A. Yes. It's my voice.

4 Q. Do you know where the places referred to, Kuprivsko Brdo and

5 Besica Brdo, what area that's in?

6 A. It's to the west in Vlasenica municipality. It's to the west of

7 Srebrenica, that is, to the west of Srebrenica.

8 Q. And there elementary school in Bektici, what area is that?

9 A. That's the school.

10 Q. Yes. In what area is Bektici?

11 A. The school? The school is in Bektici.

12 Q. I'm talking about the wider area.

13 A. Suceska. It's the area of Suceska. Suceska had several villages.

14 It's in Suceska.

15 Q. So, is it correct then that Suceska was being fired on from

16 Kuprivsko Brdo and Besica Brdo, among other places?

17 A. Yes.

18 Q. Now, we saw the pictures a moment ago of the damage which had been

19 caused. Are you able to confirm or not that Serb artillery at this time

20 could cause devastating damage to property in a small space of time?

21 A. Yes.

22 Q. Was the school in Bektici being used for any military purpose at

23 the time, so far as you know?

24 A. No.

25 Q. And last exhibit number please for that?

Page 13330












12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.













Page 13331

1 JUDGE AGIUS: Yes. There videoclip which we have just seen is

2 being marked as Defence Exhibit D868 and the accompanying transcript of

3 part of it is being marked as Defence Exhibit D868.1. Thank you.

4 MR. JONES: Thank you, Your Honour. We have one final videoclip

5 which is described as "videoclip of Besic Brdo," and again we have a

6 transcript.

7 [Videotape played]

8 THE INTERPRETER: [Voiceover] "Here we are looking at Besica."

9 MR. JONES: We will be able to play it now.

10 [Videotape played]

11 THE INTERPRETER: [Voiceover] "From here, we are looking at Besica

12 Brdo, from where the enemies are firing from tanks, howitzers,

13 anti-aircraft machine-guns, on Opetci and other places in the area of

14 Suceska. The youngest country in the world. This is where its youth is."


16 Q. Thank you. And again can you help us with whether your team

17 filmed this?

18 A. Yes. First you can hear my voice and then the voice of

19 Mr. Sabahudin Gluhic, the cameraman.

20 Q. And there is a reference there to enemies firing from tanks,

21 howitzers, anti-aircraft machine-guns. Is that something which you were

22 able to document?

23 A. Yes.

24 Q. Fine.

25 MR. JONES: I think I've finished with that exhibit and.

Page 13332

1 JUDGE AGIUS: This is beak marked as Defence Exhibit D869 and the

2 corresponding transcript in both languages as D869.1.


4 Q. Now, I want to ask you, do you know Zulfo Tursunovic?

5 A. Yes.

6 Q. How well do you know him?

7 A. Quite well.

8 Q. In 1992, did he have any group of men -- well, first of all, where

9 is he from?

10 A. Zulfo Tursunovic is from Suceska.

11 Q. And in 1992, did he have any group of men in Suceska?

12 A. Yes.

13 Q. How many, roughly, if you're able to estimate?

14 A. Well, between 50 and about a hundred men. I'll probably be wrong

15 about the precise number but I do know that it was over 50.

16 Q. Did the number fluctuate from time to time?

17 A. Yes.

18 Q. And was Zulfo Tursunovic and his men, were they under anyone's

19 command in 1992?

20 A. No.

21 Q. Just for clarification, we saw this video a moment ago from

22 Bektici, did you travel in Suceska in 1992?

23 A. Yes.

24 Q. And did you speak to people there?

25 A. Yes.

Page 13333

1 Q. Was it possible, knowing Zulfo Tursunovic's character, do you

2 think, for anyone to issue commands to him or for him to accept to be

3 under anyone else's command?

4 A. No. No one could have issued commands to him. He was the

5 absolute leader in that area, and I really doubt that anyone could have

6 influenced him.

7 MR. JONES: Sorry, one moment, please.

8 [Defence counsel confer]


10 Q. Did you in fact film any interview with Zulfo Tursunovic during

11 the course of 1992?

12 A. Yes.

13 Q. Now, do you know Naser Oric?

14 A. Yes.

15 Q. If you can help us with this, what, if any, reputation did he have

16 in Srebrenica in 1992?

17 A. Well, you know, as for his reputation, he was esteemed as a good

18 fighter, he had set an ambush for Arkan's men from Serbia, who had come to

19 Srebrenica to loot, rape, torch, and he eliminated that gang, which had

20 arrived from Serbia. From that time, he gained great renown among the

21 common people in Srebrenica.

22 Q. Was Zulfo Tursunovic under Naser Oric's command at any stage in

23 1992, to your knowledge?

24 A. No. In 1992, no one was under Naser Oric's command except his

25 group of 20 to 30 men who were with him constantly. This number

Page 13334

1 fluctuated. Sometimes it was 27. But it was 30 men at the most with

2 Naser.

3 Q. And where were they based, that group of 20 to 30 men?

4 A. They didn't have any headquarters. He was supposed to be based in

5 Potocari, but the group went where the worst situation was, where the Serb

6 attacks were fiercest, trying to penetrate into Srebrenica. That's where

7 Naser would most often be with his men.

8 Q. Now, why do you say "in 1992 no one was under Naser Oric's command

9 except his group of men"? Why do you say that?

10 A. It was simply not possible to create any kind of order. Every

11 village had its own group leader and some did not tolerate anyone being

12 superior to them or advising them. Also, the main reason were daily

13 attacks from Serbs, infiltration of sabotage groups. The situation was

14 very confused, and it was not possible to establish any kind of

15 functioning organisation.

16 Q. And we saw a clip with Ahmo Tihic earlier. Was he under anyone

17 else's commands, to your knowledge?

18 A. No. He was independent, too.

19 Q. Finally before the break, do you know Ejub Golic?

20 A. Yes.

21 Q. Did he have a group of fighters in 1992?

22 A. Yes.

23 Q. And where were they based, in what approximate area?

24 A. In Bljeciva.

25 Q. My question is was Ejub Golic under any other command, as far as

Page 13335

1 you know?

2 A. He especially did not tolerate anyone else commanding him. He was

3 independent.

4 Q. And would Ejub Golic's men obey anyone else, as a leader?

5 A. No, never.

6 Q. And were all of Ejub Golic's men based in Bljeceva or were some of

7 them based elsewhere?

8 A. One group was in Glogova and the others were in Bljeceva,

9 scattered around the villages.

10 MR. JONES: I think that's a good moment for the second break.

11 JUDGE AGIUS: Okay. We'll have a 25-minute break starting from

12 now. Thank you.

13 --- Recess taken at 12.32 p.m.

14 --- On resuming at 1.01 p.m.

15 JUDGE AGIUS: Yes, Mr. Jones.

16 MR. JONES: Thank you, Your Honour.

17 Q. Mr. Sacirovic, before the break, we were discussing Ejub Golic and

18 his men. You said how one group of his men was in Glogova and the others

19 were in Bljeceva scattered around the villages. In relation to that I

20 want to ask you this: Do you know a place called Cizmici?

21 A. Yes.

22 Q. Is that near Bljeceva?

23 A. Yes. It's a hamlet of Bljeceva.

24 Q. Now, I want to ask you, do you know Hakija Meholjic?

25 A. Yes.

Page 13336

1 Q. Did he have a group of fighters in 1992?

2 A. Yes.

3 Q. Where were they based?

4 A. First they were in the woods, and later on in hotel Domavija in

5 Srebrenica.

6 Q. Now, was Hakija Meholjic and his men, were they under Naser Oric's

7 command at any stage, to your knowledge?

8 A. No, never.

9 Q. We've discussed some groups of men and their fighters, Ahmo Tihic,

10 Zulfo Tursunovic, Hakija Meholjic. Were there any other groups in

11 1992 which were independent, and that they were not under any other

12 command?

13 A. Yes. There was a group in Kragljivoda. There were other groups

14 as well. Nearly every village had its own group.

15 Q. When you say "every village had its own group," are those groups

16 which were under some higher command or independent?

17 A. These groups were independent. They were not under anybody's

18 command.

19 Q. Was it possible in 1992, just by looking at someone, if you didn't

20 know who they were, to know by sight who was in whose group?

21 A. No.

22 Q. And why not?

23 A. Because these were all ordinary people.

24 MR. JONES: We are moving to a different area now and we have, I

25 think I'm right in saying now, the final videoclip. And again, it's

Page 13337

1 described as "videoclip of people being interviewed in hospital." And we

2 have transcripts. But, again, in this case, not for the witness, please.

3 We'll play a short clip now, Mr. Sacirovic, and if you could watch

4 the video and what's being said.

5 [Videotape played].

6 THE INTERPRETER: [Voiceover] "I was taken in immediately by others

7 and I said to the doctor right away, to cut my arm off, because there was

8 no way it could remain. He answered, 'You're young. I'm sorry.' And he

9 walked out. 15 or 20 minutes later, he came back in and told me,

10 'unfortunately, we have to amputate.'"

11 MR. JONES: If you could get again -- pause.

12 [Videotape played]


14 Q. Now, now, do you recognise the person who is speaking?

15 A. Yes.

16 Q. What's his name?

17 A. Elvir Djozic also known as Zele.

18 Q. Do you know if he survived the fall of Srebrenica?

19 A. As far as I know, he didn't. He went missing along the way.

20 Q. Do you know if he was a musician of some kind before he lost his

21 arm?

22 A. Yes. He played the drums. He was a drummer.

23 Q. And do you know what, if anything, he did in Srebrenica after he'd

24 lost his arm, what sort of a role he played?

25 A. He was in the civilian police, the commander of which was Nurija

Page 13338

1 Jusufovic.

2 Q. And for what period was he in the civilian police, if you know?

3 A. In 1992, when he recovered, after losing his arm, and until the

4 end, I think.

5 Q. And were there any other one-armed policemen in Srebrenica in

6 1992, early 1993 to your knowledge?

7 A. No. He was the only one-armed civilian policeman.

8 Q. Thank you.

9 MR. JONES: I'd ask for an exhibit number for that clip.

10 JUDGE AGIUS: This video clip will become Defence Exhibit D870,

11 and the corresponding transcript, D870.1.

12 MR. JONES: Thank you.

13 Now we have the next exhibit, which is -- just for our references

14 I'll mention it's from Cobblestone collection and it's -- the reference is

15 it's from "the Republic of Bosnia-Herzegovina, Sarajevo, Ministry of the

16 Interior, Tuzla Security Services Centre, Srebrenica public security

17 station," it's dated 25 April 1995, "Subject: List of members of the

18 Srebrenica SJB." And then I'll just read, "With regard to your dispatch,

19 the number and date as above, we hereby provide a list of members of the

20 Srebrenica SJB who have been working at the Srebrenica SJB since the start

21 of the war." And it's signed by Hakija Meholjic, chief, who you testified

22 about already.

23 Q. And if we turn -- I want to draw your attention just to certain

24 names there. Firstly, number 3, Nurija Jusufovic. Is that the person who

25 you've testified about today?

Page 13339

1 A. Yes.

2 Q. Do -- do you know why his date of recruitment goes as far back as

3 1978?

4 A. Because he had been an active-duty policeman before the war.

5 Q. And then the next name 4, Elvir, Djozic, is that the person about

6 whom you gave evidence about a moment ago, whom we saw, who had lost his

7 arm?

8 A. Yes.

9 Q. And then number 7, Edhem Vranjkovina? Is that name familiar to

10 you and, if so, who is that?

11 A. He was a former policeman. Before the war he had worked in the

12 police station in Srebrenica as a police officer. During the war, he was

13 one of my group in the commission for the gathering of facts about war

14 crimes, and we saw him on a videocassette just a little while ago.

15 Q. And when we see that this is public security station SJB, is that

16 or is it not civilian police?

17 A. Yes.

18 Q. Okay.

19 MR. JONES: I'd ask for an exhibit number for this document,

20 please.

21 JUDGE AGIUS: Yes. This document, which is being marked Defence

22 Exhibit D871, consists of ten pages in the B/C/S version and five pages in

23 the English version. It seems that the English version, as far as the

24 list is concerned, only covers the names up to number 43.

25 MR. JONES: Yes.

Page 13340

1 JUDGE AGIUS: It does not go beyond what is contained in the

2 original document. So it's D871.

3 MR. JONES: Thank you, Your Honour.

4 Now we have a new exhibit which is a photograph which we'll

5 distribute.

6 Q. Mr. Sacirovic, I'll ask you to have a look at this photograph.

7 A. Yes.

8 Q. Now, firstly, do you recognise the person with the beard in the

9 middle of the photograph?

10 A. Yes. That's Hamdija Fejzic, the president of the executive

11 council of the War Presidency of Srebrenica Municipality.

12 MR. JONES: And just if there is a public following, we should

13 perhaps zoom out just a bit more for the ELMO. You can leave the

14 photograph there but just so we see the whole picture. Shift it a little

15 bit to the left. There we go.

16 Q. And do you recognise the person on the left?

17 A. In the glasses? Yes. To my left is an American officer. I think

18 he arrived in Srebrenica around that time.

19 Q. And then the person on the right who appears to be speaking, who

20 has his mouth open and who the other two are looking at. Who is that, if

21 you know?

22 A. That's Senad Alic, the interpreter for English. He was employed

23 in the War Presidency of Srebrenica municipality as an interpreter.

24 Q. And do you know if he belonged to any armed group in Srebrenica?

25 A. No. He belonged to the War Presidency.

Page 13341

1 Q. Thank you.

2 MR. JONES: I'd ask for an exhibit number for this photograph.

3 JUDGE AGIUS: Yes. This photograph will become Defence Exhibit

4 D872.

5 MR. JONES: Thank you, Your Honour.

6 I'm moving to a new topic.

7 Q. I want to ask you, Mr. Sacirovic, about the military situation in

8 1992, and particularly as far as the Serbs are concerned. Now, in

9 general, from what you observed when you were moving around the enclave

10 gathering information in 1992, how well or poorly armed were the Serbs in

11 the villages surrounding Srebrenica?

12 A. As far as the Serbs are concerned, at the time they were armed to

13 the teeth. Even their women were armed. They had infantry weapons and

14 artillery pieces, attacking our free haven of Srebrenica, and they had it

15 to the full capacity.

16 Q. You mentioned how even women were armed. How about old people,

17 old Serbs? To your knowledge, did they participate in actions against the

18 Muslims?

19 A. They participated, all of them, simply to carry out ethnic

20 cleansing and to free the territory of Muslims to the full extent.

21 Q. Do you know someone called Golub, Eric?

22 A. Yes. I know Golub Eric very well. He was a merchant before the

23 war, and I know that during World War II, he was a member of the Chetniks

24 and that in 1941 he torched the Muslim village of Sopotnik. He also took

25 part in the 1992 war and was one of the active Serb fighters.

Page 13342

1 Q. And he I take it in 1992 was an old man at that stage?

2 A. Yes. He was of advanced age but was in pretty good shape. I know

3 him personally, and if you showed me a photograph I would be able to tell

4 you that that's him.

5 Q. Was that unusual to find on the Serb side someone who had even

6 been fighting in the Second World War and who was still involved in

7 actions against Muslims in 1992?

8 A. Well, I assure you it was nothing out of the ordinary.

9 Q. Now, did you hear at any stage about the establishment of a

10 Bratunac Brigade?

11 A. The Serb Bratunac Brigade, yes.

12 Q. And when did you hear that it had been established?

13 A. I heard it back in 1992, in Srebrenica, over the radio. You know,

14 we had the electricians who used old car engines and that they would find

15 an old radio transmitter and connect it to it and then would use the old

16 weaving equipment for movement, to turn as a wheel, to turn and then

17 generate energy, and that's how we were able to hear what was going on

18 over the radio and learn about the Bratunac Brigade.

19 Q. All right. And did you also, did you not, hear about Serb

20 volunteers and units coming from Serbia proper to fight in Eastern Bosnia

21 in 1992?

22 A. Yes. I heard about units arriving from Novi Sad and Valjevo.

23 They called them Kohacari and I found it strange at the time. It was only

24 later on that I found out these were people if arriving from Serbia and

25 who were then billeted about the Serb homes in Bratunac.

Page 13343

1 MR. JONES: If we could distribute the next exhibit, which is ERN

2 number 04362997, it's from the Bratunac Brigade command, dated 25 November

3 1992 to the Drina Corps command, and it's a report for 25 November 1992.

4 Q. I'll draw your attention, Mr. Sacirovic, to paragraph 5, where it

5 says, "The billeting party from Vukovar was here yesterday," and then

6 states "They are arriving on 26th, 27th and 28th November 1992. I kindly

7 ask that you plan the forthcoming mission from 2 December 1992 onwards

8 because of preparations I have to make together with them."

9 My question is this: Does that refer to what you've just

10 mentioned about billeting of volunteers in the Bratunac area?

11 A. Yes, precisely. We were able to listen into this bit about the

12 arrival of these Kohacari and this particular document supports that.

13 Q. When you said they were billeted about the Serb homes in Bratunac,

14 does that mean lodged in private homes of Serbs in the Bratunac area? Is

15 that correct?

16 A. Yes. In private homes, in Bratunac proper, and in the surrounding

17 villages.

18 Q. Thank you. I move to the -- well, may I ask you this:

19 Surrounding villages, would that include Kravica?

20 A. Absolutely.

21 Q. Then paragraph 6, "I also kindly ask that you use your authority

22 to help the 7th Novi Sad Company from Brcko VP to come to this area,

23 because if they are not allowed to come they will leave that part of the

24 front of their own accord. Your influence can be used to ensure that this

25 fully armed and equipped unit be incorporated into my forces which would

Page 13344

1 make my work easier." And that's Lieutenant Colonel Borivoje Tesic. The

2 Novi Sad company would be from where?

3 A. Novi Sad, Serbia.

4 Q. Yes. Thank you.

5 MR. JONES: I think that's sufficient for this document. I would

6 ask for an exhibit number, please.

7 JUDGE AGIUS: So this document, which consists of two pages, ERN

8 04362997 one in English, one in B/C/S, is being tendered and marked as

9 Defence Exhibit D873.

10 MR. JONES: Thank you, Your Honour.

11 I would ask the witness to be shown D76. And it's important for

12 the record for me to read the top of this document and then one paragraph.

13 It's from the Main Staff of the army of Republika Srpska, dated 19

14 November 1992, and it's a directive for "further operations of the army of

15 Republika Srpska." And if we go to the end we see it's signed by a

16 commander, Lieutenant General Ratko Mladic. And if we go on the English

17 to the last paragraph, D, the Drina Corps, in the B/C/S it's the page

18 00876282, and it's the second paragraph on that page.

19 Q. Do you see that Mr. Sacirovic, also page 6. Page 6, second

20 paragraph in Bosnian. Do you see that, "Drina Corps"? Do you see it the

21 top the number 6, and then second paragraph D, [B/C/S spoken].

22 A. Yes.

23 Q. Okay. I'm just going to read for the record. "D: The Drina

24 Corps. From its present positions its main forces shall persistently

25 defend Visegrad," the dam, "Zvornik, and the corridor, while the rest of

Page 13345

1 its forces in the wider Podrinje region should exhaust the enemy, inflict

2 the heaviest possible losses on him, and force him to leave the Birac,

3 Zepa, and Gorazde areas together with the Muslim population. First offer

4 the able-bodied and armed men to surrender and, if they refuse, destroy

5 them."

6 Now, just pausing there, how would you understand that expression,

7 "if they refuse, destroy them"?

8 A. I would understand this to mean to liquidate us.

9 Q. All right. Now, were you aware of an intense identified campaign

10 by the VRS in November 1992 to inflict the heaviest possible losses on

11 Muslims in Podrinje?

12 A. Yes.

13 Q. All right. I want to put that document to one side for the moment

14 and go to a new document, which is 04292693.

15 Now, this document is entitled, "Analysis of implementation of

16 combat activities operation known under the code name Proboj," and it says

17 "Operation Proboj was implemented pursuant to the following combat

18 documents, A, directive and order from Main Staff of VRS," and then we see

19 "Directive operation number 4, number 2/5210 from 19 November 1992," and

20 I don't know if you still have D76 with you but you'll see that that's the

21 same number, 02/5210 of 19 November 1992, the order we just saw from

22 General Mladic.

23 A. Yes.

24 Q. And now I want to direct your attention further down where it says

25 "The operation Proboj starts on 24 November 1992 and finishes on 3

Page 13346

1 February 1993. In total, duration of two months and nine days."

2 And then turning on to the second page, we see it's

3 written, "Combat activities were implemented in wider scale of sector

4 Kamenica, Cerska, Konjevic Polje, then in wide sector of Bratunac,

5 Skelani, and in wide sector of Visegrad, Rogatica."

6 My question firstly are you aware of these areas being attacked by

7 the Serbs in early 1993, Kamenica, Konjevic Polje, Cerska?

8 A. Yes, I heard about it.

9 Q. And according to this document, the following Serb forces took

10 part in those combat activities from November 1992 to February 1993:

11 "From the corps, we see the Zvornik Light Infantry Brigade, the 1st

12 Bratunac Light Infantry Brigade, et cetera, and then outside the corps,

13 Motorised Brigade Banja Luka, 1st Krajina Corps, Italian for modernised

14 Brigade, Drva [phoen], 2nd Krajina Corps, special Brigade Panteri, Eastern

15 Bosnian corps., et cetera.

16 My question is: Are you -- were you aware of these units and

17 brigades on the Serb side being employed in those activities, military

18 activities, in late 1992, early 1993?

19 A. Yes.

20 Q. And through what means? How -- in what way were you aware of

21 these activities?

22 A. One could hear about it at the time, I did not belong to any armed

23 group. I was in Srebrenica most of the time, and every day they would

24 bring the wounded to the hospital, and that was where I got the most

25 complete and accurate information.

Page 13347

1 Q. Thank you.

2 MR. JONES: I'll ask for an exhibit number for this document,

3 please.

4 JUDGE AGIUS: Yes, this document which consists of two pages in

5 Serbo-Croat and two pages in English, with ERN 04292693 to 694 is being

6 marked as Defence Exhibit D874.

7 MR. JONES: Thank you, Your Honour. We have another couple of

8 exhibits before we break for the day. The next one is ERN 04337261. And

9 while it's being distributed I'll just read into the record. "Command of

10 the Birac Brigade, dated 12 December 1992, interim combat report, the

11 Drina Corps command." And this is signed by Commander Lieutenant Colonel

12 Svetozar Andric.

13 Q. And if you could follow, Mr. Sacirovic, he refers to an ambush of

14 10 November 1992 and then I read, "Our ambush let the Muslims come to

15 within 40 to 50 metres. About 15 Ustashas were killed and a nurse was

16 wounded. She said that about 500 balija were defending the line and they

17 had three tanks in the sectors of" -- and then these three sectors are

18 mentioned. "Since a counterattack started we had to withdraw and killed

19 the nurse."

20 Now, in relation to this document I want to ask you: Do you know

21 what "rough area" is being referred to here when you see these place

22 names?

23 A. The village of Turalici is in the municipality of Vlasenica. This

24 group that was killed according to my information was the one fleeing from

25 Srebrenica because in Srebrenica the situation was such that very often

Page 13348

1 isolated groups would try and run for their lives in the direction of

2 Tuzla and Veliki Kladanj, and there must be some information indicating as

3 to what group was involved here or including the nurse. But it is

4 definitely the area of Srebrenica.

5 Q. Your understanding is -- is this where people trying to get from

6 Srebrenica to Tuzla and being ambushed?

7 A. Yes.

8 Q. And according to this, a female nurse was wounded. She was

9 interrogated by the men under commander Lieutenant Colonel Svetozar Andric

10 and then executed, although she posed no threat apparently because they

11 withdrew. Is that how you would understand this document?

12 A. Yes. This is a heinous crime, to kill a nurse. This is really

13 out of common sense.

14 Q. This is signed by, as I say, Commander Svetozar Andric of the

15 Birac Brigade. In your work, gathering crimes -- gathering evidence of

16 crimes, was this sort of brutality typical or untypical of the Serbs in

17 your area?

18 A. This is not an isolated case. There were many cases involving

19 massacres over people that were even worse than this what -- than this

20 one. I wouldn't even find it appropriate here or proper to describe what

21 was going on.

22 Q. Yes. I appreciate that. We are interested here in the atmosphere

23 of Srebrenica and the area in late 1992. How did it affect the Muslims in

24 the area knowing that, effectively, they could expect no mercy from the

25 Serbs and that even female nurses were being killed?

Page 13349

1 A. The situation was catastrophic, and, when I say catastrophic, I

2 don't believe I have to expand any further. At one point, the United

3 Nations or, rather, their forces managed to stop the catastrophe in 1995,

4 but the same -- I believe that -- or, rather, they managed to spare us the

5 catastrophe that later happened in 1995. Had they not come at that point,

6 the same catastrophe would have taken place already as early as 1992 or

7 1993.

8 Q. Thank you.

9 MR. JONES: I'd ask for an exhibit number for this document,

10 please.

11 JUDGE AGIUS: Yes, this document will become Defence Exhibit D875,

12 it consists of one page in B/C/S one page in English, with ERN 04337261.


14 Q. And we have one more exhibit for today and the ERN is 04292446.

15 And in the interests of time I'll just read the top. It's "The Drina

16 Corps Command, 7th of January 1993, very urgent to the Zvornik Light

17 Infantry Brigade Command," signed by commander Colonel Milenko

18 Zivanovic. "Immediately send part of Vukotic's unit across the bridge to

19 Zelinje village. There is a pontoon bridge between the villages of

20 Cikarici, and Zelinje."

21 Stopping there, I want to ask you whether you're aware of this

22 pontoon bridge referred to in this document.

23 A. Yes. The bridge was mostly used for transporting artillery pieces

24 and infantry units from Serbia to Bosnia.

25 MR. JONES: And I think it would assist to see this on a map, so

Page 13350

1 we are going to distribute copies of a map.

2 Q. I'm going to ask you, Mr. Sacirovic, if you could locate those two

3 locations, firstly, Cikarici and Zelinje, and with a pen draw a line of

4 where the pontoon bridge would be.

5 For the usher, we need to go the other way.

6 No, I didn't mean the other way in that sense.

7 Actually, if you could do it with a pen, if you could draw where

8 the pontoon bridge went.

9 A. The pontoon bridge was here.

10 Q. And from there, you've mentioned that this bridge was in order to

11 transport - I'm just reading your testimony - artillery pieces and

12 infantry units. Where would they go once they had crossed over the

13 bridge? Was there any road which could be taken?

14 A. They could go either upstream along the Drina River or downstream

15 along the Drina River. If you want me to draw, I can.

16 Q. No. For the moment, no, because also that pen is too thick. I

17 think I'd prefer you use a different pen. But -- but, in fact, if you put

18 that aside for one minute and look back at the document which we were

19 looking at -- that -- you can put the map to one side. And the pen.

20 Yes.

21 If we read the second -- you can -- you can leave the map for a

22 moment. The second paragraph of this document, it says, "As soon as the

23 unit commander arrives, he is to report to the commander in Zelinja, after

24 which the unit should be put into action along the Zelinja-Kravica axis.

25 Directly participate in the Defence of Kravica."

Page 13351

1 So this unit, the Vukotic unit, which is to use the pontoon

2 bridge, is then to be used in the defence of Kravica, correct?

3 A. Yes.

4 Q. Now, do you know how that unit would get from the pontoon bridge

5 in Zelinja into Kravica? And if you could show that on the map, that

6 would be helpful.

7 A. Yes.

8 Q. Could we have another pen? It's not marking.

9 A. [Marks].

10 Q. Thank you. Now, the line you've just drawn, correct me if I'm

11 wrong, goes near Ocenovici, and then further down into Kravica. Now, was

12 that actually --

13 JUDGE AGIUS: One moment. One moment, Mr. Jones.

14 For the record the witness marks on the map a line from the --

15 where he had marked earlier on the pontoon bridge, through Zelinja,

16 through Ocenovici, and right up to Kravica.

17 MR. JONES: Yes. Thank you, Your Honour.

18 Q. Is that a road which you've just drawn or what is it, precisely?

19 A. I've drawn a line which passes through Serb villages. These are

20 all Serb villages. They might be a bit to the left or a bit to the right,

21 but all these villages on the way to Kravica are Serb villages.

22 Q. Yes. And the line itself, what is that? Is that a road? And if

23 so, what sort of a road?

24 A. It was a dirt road for the most part. It was not an asphalt road.

25 Q. And do you know when that road was built?

Page 13352

1 A. This section through to Ocenovici, was road passable for trucks,

2 and only later did they make the rest of the road that I showed here in

3 order for them to be able to use the pontoon bridge and get the forces

4 arriving from Serbia over to Kravica.

5 Q. All right. And when you say the forces arriving from Serbia, does

6 that or does that not also include tanks and artillery pieces?

7 A. The forces, or rather war units, cover the entire range from

8 infantry units, armoured vehicles, artillery pieces, and all the other

9 assets used by the Yugoslav People's Army.

10 Q. And finally just to be clear, this road that you said it was later

11 made and able to use the pontoon bridge, when -- when did that happen? In

12 1992, 1993?

13 A. This section of the road was built in 1991 and 1992. Before the

14 start of the war, as I was passing through Kravica, I saw great heaps of

15 stones, gravel that were later used for the road. So the road must have

16 been made by breaking through the rock in 1991. I don't know about the

17 later part. I wasn't there.

18 Q. Thank you.

19 MR. JONES: Yes, that would be sufficient for today.

20 JUDGE AGIUS: Yes, thank you, Mr. Jones. Perhaps the witness

21 initial -- put list initials or signature on this map which is going to be

22 marked as Defence Exhibit D877. How are we for time, more or less? How

23 much time do you think you require?

24 MR. JONES: I, before I forget Your Honour there is also the other

25 document it to be given an exhibit number as well, 04292446.

Page 13353

1 JUDGE AGIUS: Haven't we given it 876 already? No, if we haven't

2 I'll give it a number now. The document with ERN number 04292446,

3 tendered one page in B/C/S, one page in English, is being marked as

4 Defence Exhibits D876.

5 MR. JONES: Yes. Thank you, Your Honour. And in answer to your

6 question, I'm very much on schedule. I believe in fact I'll probably

7 finish by the end of the first break. Right.

8 JUDGE AGIUS: All right. Which basically means please be prepared

9 to start straight away, Ms. Richardson tomorrow.

10 MS. RICHARDSON: Indeed, Your Honour, I will.

11 JUDGE AGIUS: Thank you. The reason is on Thursday, I think we

12 would be finished by then, but on Thursday I have a very important

13 appointment which, according to Dutch standards, once moved will never

14 happen again before another three months. So I have to finish the sitting

15 not later than 11.00 in the morning on Thursday. Because otherwise I will

16 have to wait another month and a half or two months to get this medical

17 appointment. Anyway. All right?

18 MS. RICHARDSON: Yes, Your Honour. I will be prepared to start

19 tomorrow.

20 JUDGE AGIUS: Thank you. Mr. Sacirovic, we are going to stop here

21 for today. You will now be accompanied back to your hotel. We will

22 continue tomorrow at 9.00 in the morning. In the meantime you're not to

23 communicate with anyone or let anyone communicate with you on the matters

24 related to this case or to the events that you are testifying about. All

25 right.

Page 13354

1 Thank you, and good afternoon.

2 THE WITNESS: [Interpretation] Thank you.

3 --- Whereupon the hearing adjourned at 1.47 p.m.,

4 to be reconvened on Tuesday, the 1st day of

5 November, 2005, at 9.00 a.m.