1 Wednesday, 23 November 2005

2 [Open session]

3 --- Upon commencing at 9.04 a.m.

4 [The accused entered court]

5 JUDGE AGIUS: Yes, good morning to you, Madam Registrar. Could

6 you call the case, please.

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

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

9 JUDGE AGIUS: I thank you, Madam, and good morning to you, as I

10 said.

11 Mr. Oric, can you follow the proceedings in your own language?

12 THE ACCUSED: [Interpretation] Good morning, Your Honours, ladies

13 and gentlemen. Yes, I can follow the proceedings in my own language.

14 JUDGE AGIUS: I thank you. You may sit down and good morning to

15 you.

16 Appearances for the Prosecution.

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

18 my learned friends from the Defence. My name is Jan Wubben, lead counsel

19 for the Prosecution. I am here together with co-counsel Patricia Sellers,

20 Ms. Joanne Richardson, and our acting case manager, Ms. Sanja Bokulic.

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

22 your team.

23 Appearances for Naser Oric.

24 MS. VIDOVIC: [Interpretation] Good morning, Your Honours. My name

25 is Vasvija Vidovic, and I appear for Mr. Naser Oric. I have with me here

1 my legal assistant, Ms. Adisa Mehic, and our CaseMap manager, Mr. Geoff

2 Roberts.

3 JUDGE AGIUS: I thank you, Madam Vidovic, and good morning to you

4 and your team.

5 Any preliminaries?

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

7 JUDGE AGIUS: Later on today I hope to be able to sign the Nikolic

8 certification decision. All right. Thank you.

9 So let's bring the witness in. I think you have to draw down the

10 curtains, Madam Usher.

11 The air in here is unbelievable. The moment I walk in the place I

12 start ...

13 [The witness entered court]

14 JUDGE AGIUS: Good morning to you, sir.

15 THE WITNESS: [Interpretation] Good morning, Your Honour.

16 JUDGE AGIUS: And welcome back. We are going to proceed with your

17 testimony. Madam Vidovic will go and today will be devoted entirely for

18 the rest of the examination-in-chief. Thank you.

19 One other thing. Please try -- you are a good witness, in other

20 words, you don't get lost in giving descriptions that you are not asked to

21 give or details that you are not asked to give in a question. Please try

22 to remain like -- stay like that. Please try to be as concise as possible

23 in your answers. Basically my advice to witnesses is to answer the

24 question, the whole question, and nothing but the question. It will

25 insure that you will leave this place according to schedule and not stay

1 here beyond the end of the week up to the weekend. It depends very much

2 on you. Thank you.

3 WITNESS: WITNESS D005 [Resumed]

4 [Witness answered through interpreter]

5 Examined by Ms. Vidovic: [Continued]

6 Q. Good morning, sir. I will ask you about the defence of Konjevic

7 Polje in greater detail now.

8 Yesterday you mentioned the fact that there were about a hundred

9 rifles there.

10 MS. VIDOVIC: [Interpretation] For a while, Your Honour, could we

11 go into private session, please?

12 JUDGE AGIUS: Yes, certainly, Madam Vidovic. We are going into

13 private session for a while.

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22 [Open session]

23 MS. VIDOVIC: [Interpretation]

24 Q. To your knowledge, did the group of Ejub Golic keep under its

25 control the entire area of Bljecava?

1 A. No. Ejub Golic only had an area of Bljecava under him. That was

2 the village of Cizmici.

3 Q. To your knowledge, was Golic ever the deputy of the leader of the

4 group in Bljecava?

5 A. As I know Ejub Golic very well, I can tell you that he always

6 acted independently, autonomously.

7 Q. Were there people from other areas in Ejub's group, apart from

8 those from Glogova?

9 A. I heard that other people joined Ejub Golic from the village of

10 Pale, and I believe a smaller group of people from Bljecava also joined

11 him so that there were people who were not local.

12 Q. Of all the Muslim groups active in the territory of the

13 municipality of Bratunac, as far as you know which was the largest and

14 strongest group, if any?

15 A. In the municipality of Bratunac, Ejub Golic's group was the

16 strongest.

17 JUDGE AGIUS: Sir, please may I remind you of what I told you

18 yesterday, to allow a brief interval after Ms. Vidovic's question before

19 you answer because we need that for technical purposes and also to give as

20 much assistance as we can to the interpreters who have to translate into

21 English and French.

22 Yes, Ms. Sellers.

23 MS. SELLERS: Your Honour, I would just like to raise the issue.

24 I believe we are in private session --

25 JUDGE AGIUS: No, we are not. We are in open session.

1 MS. SELLERS: Are we in open session? Thank you. Because I

2 wanted to state for the record that some of the people we are talking

3 about are well-known people who many people could know.

4 MS. VIDOVIC: [Interpretation] Not --

5 MS. SELLERS: -- who many people could know. And because of that

6 we do have to be cautious about the witness's particular knowledge of

7 someone as opposed to his knowledge that many people could have knowledge

8 of the characteristics. I would like to say the Prosecution would like to

9 stay in open session as much as possible, allowing for the protective

10 measures that this witness has been granted.

11 JUDGE AGIUS: Yes, yes, certainly. The protective measures that

12 have been put in place will be observed, and you know that quite well.

13 And in fact, that is one of the reasons why I invited Ms. Vidovic, who was

14 very cooperative, to return back to open session when I thought it was a

15 case of returning to open session. We ought to be in private session only

16 when the information sought from the witness is likely or is probable to

17 expose his identity or to reveal his identity, otherwise I think we need

18 to stay in open session. And I think Ms. Vidovic is fully aware of that.

19 She's been cooperative.

20 So let's proceed. And, Witness, please allow the short interval

21 of time, as I suggested. Thank you.

22 Ms. Vidovic.

23 MS. VIDOVIC: [Interpretation]

24 Q. Of all the group leaders in the area, as far as you know, who

25 had -- who enjoyed most respect among the people?

1 A. It was Ejub Golic with his people from Glogova who was held in

2 highest esteem.

3 Q. What was the reason? Can you tell the Trial Chamber, please.

4 A. Ejub Golic did most to protect his people, those who were expelled

5 from Glogova to -- towards Bljecava and Cizmici.

6 MS. VIDOVIC: [Interpretation] Your Honour, could I have the

7 usher's assistance now in showing witness D812. This is a document by the

8 municipality of Bratunac, that's to say, by the Presidency, dated

9 30th June, 1993, entitled "certificate," signed by the commander of the

10 armed forces Bratunac, Ejub Golic.

11 Q. Witness, I will quote from a small portion of this document.

12 "Certificate." The second paragraph of the document

13 reads: "Ibrahim Imamovic was killed in the military action in Glogova."

14 Signed by the commander of the armed forces Bratunac, Ejub Golic.

15 I want to ask you the following, Witness: According to what you

16 know, was Ejub Golic appointed commander of the armed forces in Bratunac?

17 A. Yes, he was.

18 Q. When, do you know?

19 A. We officially learned of his appointment in early 1993, that's to

20 say in January.

21 Q. How did you personally come to know this?

22 A. Whenever a civilian managed to reach Konjevic Polje while in

23 search for food, we would learn that. He -- the person involved in turn

24 would find that out from superiors, that is, group leaders.

25 Q. Did you talk to Bego Uminovic [as interpreted] ever about this

1 matter?

2 A. Yes. I talked to Bego Muminovic, and he told me that Ejub Golic

3 was appointed the commander of the armed forces in Bratunac.

4 Q. Did he tell you how he came to know that?

5 A. As long as the road between Konjevic Polje and Cizmici was

6 blocked, most of the information we learnt was from civilians.

7 Q. This document says "armed forces Bratunac." Can you tell the

8 Trial Chamber what this actually meant, what this was all about.

9 A. Bratunac armed forces formed part of Konjevic Polje, Cizmici,

10 Bljecava, in that the people in Bljecava, as far as I heard, did not want

11 to join Ejub Golic.

12 Q. These armed forces in general, what were they like? Were they

13 uniformed? Were they armed? Did they have the necessary equipment and

14 barracks?

15 A. They had neither the equipment nor weapons. I told you how many

16 weapons there were in the area of Konjevic Polje. People were organised

17 in groups, and they did not have any barracks.

18 Q. Did these groups from Konjevic Polje accept Ejub Golic as a leader

19 of theirs.

20 A. Yes, they did, but their communication was non-existent.

21 Q. Did you hear of a meeting attended by someone like Bego Muminovic

22 or someone else at which Ejub Golic and the command in general were

23 discussed?

24 A. Yes. I heard about the meeting, but I did not learn about what

25 the meeting discussed.

1 Q. Thank you. I will go back now to the events that took place in

2 the course of the summer and autumn of 1992. You described fierce attacks

3 from Kravica and Milici area on the Konjevic Polje area in the course of

4 1992. If the Serb forces attacked a village, therefore if the Serb forces

5 attacked any of the villages in the Konjevic Polje area, what would

6 happen?

7 A. Every village were there was a group of this sort, and if this

8 village came under an attack, then a member of the group would immediately

9 try to inform other members of the group or join them in order to jointly

10 defend the village.

11 MS. VIDOVIC: [Interpretation] Your Honour, could we just go into

12 private session for a moment, please?

13 JUDGE AGIUS: Certainly, Ms. Vidovic.

14 Let's go into private session, please.

15 [Private session]

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21 [Open session]

22 JUDGE AGIUS: We are in open session.

23 MS. VIDOVIC: [Interpretation]

24 Q. Witness, I wanted to ask you something about the 16th Muslim

25 Brigade. Did that brigade at any point come to Konjevic Polje, as far as

1 you know?

2 A. The 16th Muslim Brigade came to Konjevic Polje in early August

3 1992.

4 Q. Do you know who commanded the unit?

5 A. It was headed by Nurif Rizvanovic.

6 Q. Do you remember where they were billeted?

7 A. Having come to Konjevic Polje, Nurif Rizvanovic, with his

8 soldiers, was billeted next to the school. They had some tents and some

9 of them were inside the school, but most of the school was occupied by the

10 refugees. There was some other soldiers as well who were from

11 Konjevic Polje itself, and they left to their homes or the homes of their

12 relatives.

13 Q. Can you remember how many fighters of the 16th Muslim Brigade came

14 alongside Nurif Rizvanovic to Konjevic Polje?

15 A. We don't know the precise numbers, but anywhere between 350 and

16 400.

17 Q. Were they in uniforms and armed?

18 A. Yes. They wore uniforms and had arms.

19 Q. When did Nurif Rizvanovic come to Konjevic Polje -- or rather,

20 when he came, did you know any of his soldiers? Did you see some of those

21 that came with him and that you knew them?

22 A. I knew some of them.

23 Q. Did you speak to any of his soldiers?

24 A. Yes. I tried to speak with several of his soldiers.

25 Q. Doing so did you manage to learn anything more about Nurif

1 Rizvanovic? For example, what he used to do before the war.

2 A. Before the outbreak of the war, Nurif Rizvanovic, if you mean the

3 outbreak of the war in Bosnia, then I know Nurif Rizvanovic was in Croatia

4 fighting on the Croat, or rather, Catholic side. He had a group of his

5 own and then moved towards Konjevic Polje.

6 Q. When Nurif Rizvanovic came to the area of Konjevic Polje, were

7 there any female fighters amongst his ranks?

8 A. Yes. I remember in particular one woman. She had some insignia

9 on her sleeve. I believe it said "Croatian army."

10 Q. If you remember, did you ever hear her speak?

11 A. Yes. Since I spent eight months in Croatia working and I can

12 distinguish the way they speak, it seemed to me that she was from Croatia.

13 MS. VIDOVIC: [Interpretation] I would kindly ask the usher to put

14 a photograph in front of the witness.

15 Your Honours, together with these documents I wanted to tender the

16 letter by Mr. Omerovic, Fahrudin, who forwarded these photographs, and he

17 expressed his willingness to testify, should it be necessary.

18 JUDGE AGIUS: I thank you, Madam Vidovic, for that information.

19 MS. VIDOVIC: [Interpretation]

20 Q. Witness, could you please take a look at photograph number 3. Do

21 you have that photograph in front of you?

22 A. Yes, I do.

23 Q. Do you recognise either of these two people, either personally or

24 from having seen them?

25 A. I know one of the guys because when they came to Konjevic Polje I

1 seemed to notice more the people who had two types of insignia on their

2 sleeves.

3 Q. Is that the person on photograph number 3 who's on the left or on

4 the right side of the photograph?

5 A. The person on the left.

6 Q. Thank you. Please take a look at the insignia that this man is

7 wearing on his sleeve, the lower one. Could you tell the Chamber what

8 sort of a patch this is.

9 A. On his left arm one can clearly see the coat of arms and it

10 says "Croatian army."

11 Q. Is that the insignia used by the Croatian army, as far as you

12 know?

13 A. Yes. The coat of arms is -- was the same used by the HVO and HOS,

14 but one can see here that is actually HV, that is Croatian army.

15 Q. Thank you. You mentioned the patch that the woman wore. Was it

16 the same kind of patch?

17 A. Yes, 100 per cent.

18 Q. I wanted to ask you the following: Did you see any other people

19 amongst Nurif's soldiers who had these patches? Were there several of

20 them?

21 A. I saw five to six of such people. There may have been more, but I

22 saw five or six, not more than that.

23 Q. Thank you.

24 MS. VIDOVIC: [Interpretation] Your Honours, could we please assign

25 an exhibit number to the photograph?

1 JUDGE AGIUS: Do I understand you well, Ms. Vidovic, because in

2 this folder that you gave us, apart from Mr. Fahrudin's certificate, there

3 are three photos. Do you want to tender the three of them or just photo

4 number 3 that you have made use of?

5 MS. VIDOVIC: [Interpretation] All three of them could be put

6 under the same exhibit number, Your Honour.

7 JUDGE AGIUS: So for the record --

8 MS. SELLERS: Excuse me, Your Honour.

9 JUDGE AGIUS: Yes, Ms. Sellers.

10 MS. SELLERS: Right. I would just like to have clarification.

11 Has the witness testified to the other two photographs?

12 JUDGE AGIUS: No. But usually we have adopted the practice to

13 admit the document just the same on the assumption that the other two

14 photos will be made use of later on.

15 MS. SELLERS: Okay. That's clear.

16 JUDGE AGIUS: That's how I have always understood it to be. But

17 if you have an objection, then we can restrict the tendering to photo

18 number 3 now and then proceed later with tendering the other two.

19 MS. SELLERS: Your Honour, I have no objection. I understand for

20 expediency sake, but just to clarify at this time period, this witness has

21 not testified to the other two photos.

22 JUDGE AGIUS: The other two photos have not been put to the

23 witness.

24 So for the record, the following document is being entered into

25 the records, consisting of three photos numbered 1, 2, and 3, respectively

1 on the right side -- on the right side, and two sheets of paper, one in

2 B/C/S and one in English, being a translation into English, with no ERN

3 number, dated 28th of September, 2005, signed in Tuzla by Fahrudin

4 Omerovic and certifying as to the identity of the individuals shown in

5 photos 1 and 2 but certifying also that the two individuals shown in photo

6 number 3 that was put to the witness are unknown to the same Mr. Fahrudin.

7 This document is being tendered and received and marked as D --

8 defence 9 --

9 THE REGISTRAR: 919.

10 JUDGE AGIUS: 919. Thank you.

11 Yes, Judge Brydensholt has a question.

12 JUDGE BRYDENSHOLT: I can see that those photographs has been

13 taken in a place named Banovici. Could you tell us where is that?

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21 Witness, please, again try to not give information that would

22 identify you. I told you yesterday. Yes, that will be redacted.

23 And Judge Eser has a question.

24 JUDGE ESER: Witness, just to make sure with regard to the photo

25 we have seen, there are two insignia. Now, my question is: The people

1 who had patches like this, did they, all of them, have these two insignia?

2 Or was it that some would have one insignia and the other would have a

3 different one? Was it always two together or would some people have only

4 one of these insignia?

5 THE WITNESS: [Interpretation] Among the Nurif's fighters there --

6 some people wore two patches, the HVO and the Army of Bosnia and

7 Herzegovina patches, but only those who accompanied Nurif Rizvanovic to

8 the Croatian battlefield. Those who were in Bosnia-Herzegovina joined the

9 group in Tuzla before coming to Konjevic Polje, and they only had the

10 patch of the Army of Bosnia-Herzegovina, just one.

11 JUDGE AGIUS: Thank you, Judge Eser. And thank you, Witness.

12 MS. VIDOVIC: [Interpretation]

13 Q. Witness --

14 MS. VIDOVIC: [Interpretation] Before that, may I offer a

15 clarification, Your Honours. I will be using all three photographs today,

16 but for practical reasons I asked for one exhibit number.

17 Q. Witness, the people who belonged to the Croatian armed forces

18 before the outbreak of the war in Bosnia-Herzegovina, were they known

19 under the name of "Zenga"?

20 A. Yes. I heard them being called Zengas on several occasions.

21 Q. Did you discuss these patches with anyone? Did they explain to

22 you how come those people had them on their sleeves, as you explained to

23 the Trial Chamber?

24 A. Yes. It is as I explained a minute ago.

25 MS. VIDOVIC: [Interpretation] I would kindly ask the usher to show

1 one of the three photographs, and that is the first one.

2 Q. Witness, could you please take a look at the photograph and tell

3 us, do you know anyone?

4 A. Yes, the person on the right. This is Kemo Muminovic.

5 Q. Did he come to Konjevic Polje with Nurif Rizvanovic?

6 A. Yes. He came with Nurif Rizvanovic.

7 Q. Did you speak with him?

8 A. I spoke with Kemo as well.

9 Q. Did he tell you anything about the woman you mentioned?

10 A. Yes. And he said she came with Nurif from Croatia.

11 Q. Regarding this, I have another question. Did -- were all of the

12 people who came with Nurif, were they all Muslim or not?

13 A. Since I couldn't ask them individually or to try to learn how many

14 Muslims actually came there, I learned from a person called Zoran or Goran

15 that there were some people of other nationalities.

16 Q. Could you please take a look at photograph number 2.

17 THE INTERPRETER: Interpreter's correction. The witness said that

18 he heard somebody being called Zoran or Goran, which would mean that he

19 was of different nationality.

20 MS. VIDOVIC: [Interpretation]

21 Q. Do you recognise anyone in this photograph?

22 A. Yes. This is Hajro Ljubicic from Bratunac.

23 Q. Which of the two do you have in mind on photograph 2, the person

24 on the left or on the right?

25 A. The person on the right.

1 Q. Did he come with Nurif Rizvanovic to the area of Konjevic Polje?

2 A. Yes. When I was in Konjevic Polje and when they arrived, I heard

3 Nurif tell him to command the 3rd Company. So I guess he was the

4 commander of the that company.

5 Q. You saw their uniforms. Did they all wear the same uniforms, more

6 or less, as we saw in the photographs?

7 A. Most of them had the same uniforms; the patches varied, though.

8 MS. VIDOVIC: [Interpretation] Your Honour, could we briefly move

9 into private session, please?

10 JUDGE AGIUS: Yes. Let's go into private session for a while.

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10 [Open session]

11 MS. VIDOVIC: [Interpretation]

12 Q. Please turn to page 10. Unfortunately, this document is not

13 paginated, but could you please count ten pages ahead.

14 MS. VIDOVIC: [Interpretation] Your Honours, that's page 12 in the

15 English version.

16 Q. Please take a look at the name at number 15. This is page

17 beginning with number 1, and under 15 there is Kemal Muminovic, son of

18 Huso, from Mihaljevici. Did you locate the name?

19 A. 10, you said?

20 Q. Yes. This is a page beginning with number 1, and we were

21 interested in number 15. It is stated here Kemal Muminovic, son of Huso,

22 from Mihaljevici. Is that the person you said you spoke with and that

23 that person came to Konjevic Polje with Mr. Rizvanovic?

24 A. Yes, this is the person.

25 Q. Now, please go to page 4. Go to the very beginning and then four

1 pages ahead. Can you see that? Page 4, number 11. Dubicic Hajrudin, son

2 of Mehmedalija. In the English translation this is page 4, at the bottom

3 almost. Hajrudin Dubicic, son of Mehmedalija. Is that the person you

4 said you spoke with about Nurif's fighters?

5 A. Yes, this is the person.

6 Q. Thank you.

7 MS. VIDOVIC: [Interpretation] We can remove the document now. And

8 we will ask for another document to be given to the witness.

9 Your Honours, as concerns D822, I wanted to distribute the

10 original certificate of the directorate of defence of the canton of Tuzla,

11 dated the 18th of August, 2005, and one can see that D822, as well D818,

12 we received from the archives of the directorate. Could we please assign

13 number 2822.1 or A to the other document, please?

14 JUDGE AGIUS: Okay. We'll do that, Ms. Vidovic.

15 MS. VIDOVIC: [Interpretation]

16 Q. Witness, I will read a part of the document. It is

17 entitled "armed forces of Bosnia and Herzegovina, Drina Division command,"

18 signed by the commander of the Drina Division, Nurif Rizvanovic, and I

19 wanted to quote a portion of the document.

20 It begins with "Mr. Ahmic. I was appointed commander of the Drina

21 Division by decision number 1-7/92 of 5 September from municipalities of

22 Bratunac, Zvornik, Vlasenica, and Srebrenica. In view of this, I would

23 like to ask you to help me implement these decisions."

24 For example: "The mass media should keep repeating the order of

25 9 September 1992, strictly confidential number 01/92-1, items 1(a)

1 and (b)," and, "a stamp should be made in accordance with the decision and

2 sent to me by a courier."

3 First of all, I wanted to ask you, do you know who Mr. Ahmic is?

4 A. Mr. Ahmic is from Bratunac. He was attached to a sort of staff in

5 Tuzla, and it is probably on this matter that Nurif Rizvanovic addresses

6 him. That was a forward post where the staff was.

7 Q. This forward post staff, was it from Bratunac? You mentioned

8 Bratunac a while ago.

9 A. Yes. That's the forward post staff from Bratunac, therefore it

10 was relocated from Bratunac -- or rather, it was a forward post in Tuzla.

11 Q. Thank you.

12 THE INTERPRETER: Microphone, please.

13 MS. VIDOVIC: [Interpretation] Could I have the usher's assistance

14 now. This document could be removed from the witness and could the

15 witness be shown Prosecution Exhibit P82.

16 JUDGE AGIUS: So in the meantime, Ms. Vidovic, I'm going to docket

17 this other document that you handed to us, which consists of one page in

18 B/C/S, being a statement of -- listing four documents that were handed

19 over to you by the Ministry of Defence of the Federation of Bosnia and

20 Herzegovina, Tuzla canton defence office, on the 18th of August, 2005,

21 together with the corresponding translation thereof into English,

22 consisting of two pages. These together are being entered and marked as

23 Defence Exhibit D920.

24 MS. VIDOVIC: [Interpretation] Thank you, Your Honour.

25 Q. Witness, I believe that you have before you a document P82. This

1 is a document issued by the Drina Division. It's a decision dated

2 27 October 1992, bearing the number 02110276. First of all, do you see

3 the date that this decision has? That's the date of 27 October 1992.

4 A. Yes, I can see that.

5 Q. Can you please tell us whether you see anyone's signature on this

6 document?

7 A. No signature has been affixed to this document.

8 Q. Before the war you had a job, but after the war you became a

9 professional member of the Army of Bosnia and Herzegovina. Can you tell

10 the Trial Chamber whether it was customary for the documents, particularly

11 decisions, to be signed in Bosnia and Herzegovina?

12 A. Any written document had to have a signature in addition to a

13 stamp.

14 Q. I will quote the last sentence of the document which reads as

15 follows: "The newly appointed commander Nurif Rizvanovic agreed to put

16 himself under Naser Oric's command."

17 Witness, you indicated on several occasions that you were in touch

18 with Nurif's fighters. Did you hear that Nurif Rizvanovic was at any

19 point under the command of anyone from Srebrenica?

20 A. I did not hear that. I never heard of anyone coming from

21 Srebrenica. I only knew about civilians. I didn't know about him meeting

22 with anyone or agreeing to being under Naser Oric's command. No, that I

23 didn't know.

24 Q. Do you know when it was that Nurif Rizvanovic left Konjevic Polje?

25 A. I heard, I did not see, that in early November Nurif Rizvanovic

1 was taken somewhere - this was indicated to me by someone - that he went

2 toward Tuzla. What actually happened, I can't say. I don't know anything

3 about Nurif Rizvanovic.

4 Q. You said that you heard that he had left in early November. Was

5 this only several days after the 27th of October, 1992?

6 A. Yes, that was the case. Several days later, yes.

7 MS. VIDOVIC: [Interpretation] Your Honour, could the witness be

8 shown a different document now. This is a document by the Drina Division

9 command dated 2nd November 1992 bearing the title "war report," signed by

10 the commander of the Drina Division, Nurif Rizvanovic, addressed to

11 Commander Meholjic. The document does bear the ERN number which is

12 02110304.

13 Q. Witness, please take a look at the document. I will quote a part

14 of the document request it says: "Konjevic Polje, the 2nd of November,

15 1992, for commander Meholjic - war report. It is my personal honour and a

16 great pleasure to be able to greet you, your fighters, and the doctor. As

17 for the problems that you wrote about, I have the same problems. The

18 wounded are the most difficult problem for me. At the moment there are

19 200 of them. The other issues are well-known: Medicines, ammunition,

20 decline of morale, and other. I'm delivering you a report. The defenders

21 of Zvornik cowardly abandoned their defence lines and most of the

22 commanders fled. The Cerska lines were taken by the Chetniks. The lines

23 of Konjevic Polje are stable and firm. One fierce offensive more, and I

24 will be forced to leave the territory because of the low morale among the

25 fighters and their commanders."

1 Witness, do you know who is Commander Meholjic to whom Nurif

2 Rizvanovic addresses this war report?

3 A. Yes, I do -- actually, I did not know at the time when I was in

4 Konjevic Polje, but as I came to Srebrenica I learned that Akim Meholjic

5 [as interpreted] was chief of police in Srebrenica. I found that out when

6 I came to Srebrenica from Konjevic Polje.

7 Q. Did you find out anything about his whereabouts and what he was

8 in -- doing in 1992?

9 JUDGE AGIUS: Wait, wait, wait, because I know what Ms. Sellers is

10 coming up with.

11 It's the name.

12 MS. SELLERS: No, Your Honour, as a matter of fact it isn't the

13 name. I have the honour to ask if we have a problem with the translation.

14 Because I understood Madam Vidovic to read "from here that I would be

15 forced to leave the territory." The English translation is "live." And I

16 would like to see if we could just clarify that right away.

17 JUDGE AGIUS: Okay. Let's take both of them, then, one after the

18 other.

19 The first one is the transcript shows the name of Akim Meholjic.

20 We don't -- we are not talking about Akim Meholjic but Hakija Meholjic.

21 Is that correct? You never mentioned Akim but Hakija Meholjic?

22 THE WITNESS: [Interpretation] Yes, Hakija Meholjic.

23 JUDGE AGIUS: Yes, the other part -- it's -- I think Ms. Vidovic

24 will take care of that. Which part in the -- in the Bosnian text, which

25 line would that be? Because this is all handwritten and I can decipher

1 some of it but not all.

2 Ms. Vidovic, can you help us, please.

3 MS. VIDOVIC: [Interpretation] Your Honour, perhaps it will be best

4 for me to read this briefly again. It says: "War report. It is my

5 personal honour and great pleasure to be able to greet you, you, your

6 fighters, and the doctor. As for the problems that you wrote about, I

7 have the same problems. The wounded are the most difficult problem for

8 me. At the moment there are about 200 of them. For the rest, the issues

9 are well-known: Medicines, ammunition, decline of morale, and other

10 matters. I'm hereby giving you the report. The defenders of Zvornik,

11 cowardly abandoned their defence lines, and most of the commanders fled.

12 The lines of Cerska were taken by the Chetniks. The lines of

13 Konjevic Polje are stable and firm. One fierce offensive more, and I will

14 be forced to leave the territory because of the low morale among the

15 fighters and their commanders."

16 And that's what the original says.

17 JUDGE AGIUS: Okay. Stop there. I think that solves the problem.

18 It's definitely "will be forced to leave" --

19 MS. SELLERS: Thank you, Your Honour.

20 JUDGE AGIUS: -- and not anything else.

21 All right. I think we have cleared that up. We can proceed.

22 Thank you, Madam Vidovic. And thank you, Ms. Sellers.

23 MS. VIDOVIC: [Interpretation]

24 Q. Witness, before going back to the document I asked you whether you

25 heard anything about the activities of Mr. Meholjic in the course of 1992

1 in Srebrenica. Did you hear what he was doing there, if you heard

2 anything?

3 A. Since Srebrenica was occupied by the Chetniks, as I arrived in

4 Srebrenica I heard that Hakija Meholjic was the first one to enter

5 Srebrenica with his men. And to me that meant that he had liberated

6 Srebrenica.

7 Q. Thank you, Witness. After Nurif Rizvanovic left Srebrenica, do

8 you know what happened to his men?

9 A. I'm afraid I don't understand the question.

10 Q. In your earlier evidence you stated that you heard that Nurif

11 Rizvanovic had left the area. My question to you was whether his fighters

12 left the area as well or whether they remained in the area of

13 Konjevic Polje or elsewhere.

14 A. Not all of them left the area. Most of them stayed behind in

15 Konjevic Polje. Some of them joined Ejub Golic in Cizmici, and some of

16 them probably went along with him, but not many.

17 Q. Was there a group that stayed behind in Konjevic Polje?

18 A. Yes. As I have said, a larger group stayed behind in

19 Konjevic Polje.

20 Q. Do you remember where?

21 A. They went to the village of Grabovsko.

22 Q. Did this unit stay behind as an independent unit or did it join

23 any other group? And I'm referring to the unit in Grabovsko.

24 A. It continued existing as an independent group without joining any

25 others.

1 Q. Who led the group in Grabovsko?

2 A. Refik Hasanovic.

3 MS. VIDOVIC: [Interpretation] Your Honour, could the witness be

4 shown Defence Exhibit D801, and that's to say photograph number 1.

5 JUDGE AGIUS: I thank you, Madam Vidovic. In the meantime, we

6 need to give this last document that you used a number. And this document

7 consisting of three handwritten pages in B/C/S with ERN 02110304 to 0306

8 included and a typed translation thereof into English, consisting also of

9 three pages, is being tendered, marked as Defence Exhibit D921.

10 MS. VIDOVIC: [Interpretation]

11 Q. Witness, do you have the photograph? Photograph number 1.

12 JUDGE AGIUS: Put it on the ELMO, please.

13 MS. VIDOVIC: [Interpretation]

14 Q. Do you know either or both of the two on the photograph?

15 A. Yes. Refik Hasanovic is on the left-hand side.

16 Q. Thank you. Is that the person you said a while ago had replaced

17 Nurif Rizvanovic when he left and stayed behind in Grabovsko?

18 A. Yes, that's right.

19 Q. Thank you. You can remove the photograph. I have another

20 question in connection with this. Apart from Nurif Rizvanovic's men for

21 whom you said the -- that they had uniforms, did the other groups in

22 Konjevic Polje have uniforms until the -- until Konjevic Polje fell?

23 A. We had no uniforms. We only had our civilian clothes.

24 Q. Thank you. I will put to you a series of brief questions on a

25 different topic. You've been telling us about the organisation of forces

1 up until November 1992. Did you ever hear that in early November 1992 in

2 Konjevic Polje a meeting was held where a decision was taken to establish

3 something that was called a subregion? Did you ever hear anything about

4 this?

5 A. A meeting was held, but I don't know anything specific about it.

6 Q. Did you hear of the establishment of a subregion?

7 A. Yes, I did.

8 Q. In early November 1992, did you notice that the situation on the

9 ground changed in terms of the fact that Konjevic Polje was operating

10 under Srebrenica's command?

11 A. Command itself never changed. From the very beginning up until

12 March 1993, it was organised between smaller groups. There were smaller

13 groups.

14 Q. If someone were to claim that the subregion was operational, that

15 the authorities of the subregion were active and operational in the

16 Konjevic Polje area, would that tally with what you know?

17 A. No, that's not correct. That's not true at all.

18 Q. Thank you.

19 MS. VIDOVIC: [Interpretation] Before the break, I would like the

20 witness to be shown another document bearing the number 04337015. You can

21 remove the photographs, please. This is a document by the Bratunac

22 Battalion command dated --

23 THE INTERPRETER: The interpreter didn't hear which date.

24 MS. VIDOVIC: [Interpretation] September 1992, addressed to the

25 commander of the Birac Brigade.

1 Q. Witness, I will now take you back to the events which transpired

2 in the summer and early autumn of 1992 through to the fall of

3 Konjevic Polje. I will quote from the document. It reads: "Reply to

4 your memo on the exact position of our units:

5 Loznicka Rijeka, Kunjerac, Pobrdje, Mahmutovici, Borici, Trig

6 Point 438, Kaolin, Lomenac, Pajici, Magasici, Jecila, Radukici, Jezevtica,

7 Menjak, Siljkovici, Mratinici, Doljani, Brana, Bacici, Panjevici, Trig

8 Point 445. Sopotnik." Signed by Colonel Dimitrije Sibanic.

9 Witness, did you know of any of these lines held by the Serb

10 forces, namely the lines indicated in the document?

11 A. Yes, I know of many of these lines.

12 Q. Can you tell us specifically which lines you were aware of at the

13 time?

14 A. Siljkovici, then Mratinci, and then another illegible place,

15 Brana, Bacici -- this should not be Panjevici, rather Banjevici.

16 Q. Thank you, Witness. Which of these lines were in the proximity of

17 Urkovici?

18 A. Siljkovici, Mratinci, Brana, Bacici, and Banjevici.

19 MS. VIDOVIC: [Interpretation] Could the witness be shown the map

20 he was shown yesterday to mark the lines for us.

21 Q. While this is being done I'll ask you the following. The places

22 you mentioned, namely Siljkovici, Mratinci, Brana, Bacici, Banjevici, are

23 these hamlets of Kravica?

24 A. Yes, they are hamlets of Kravica.

25 Q. Can you show us the lines, or rather, the places.

1 A. Banjevici, Brana, Bacici, Siljkovici.

2 Q. Please take a look at the area below Kravica. And I have another

3 question in connection with this. To your knowledge -- or let me

4 rephrase. Were you able to see whether these lines went through inhabited

5 places themselves or not?

6 A. Yes, they did. They went through inhabited places.

7 MS. VIDOVIC: [Interpretation] Your Honour, could this document be

8 assigned an exhibit number.

9 JUDGE AGIUS: Certainly, Ms. Vidovic. This document which

10 consists of two pages with ERN 04337015, one in B/C/S and the other one in

11 English, is being assigned Defence Exhibit Number D922.

12 MS. VIDOVIC: [Interpretation] Your Honour, this would be a good

13 moment for a break, if you agree.

14 JUDGE AGIUS: Certainly, Madam Vidovic, and it needs to be 30

15 minutes because of the redaction.

16 MS. SELLERS: Your Honour.

17 JUDGE AGIUS: Yes, Ms. Sellers.

18 MS. SELLERS: Excuse me, could I ask that if the witness could

19 leave the room, and prior to us breaking I would just like to put

20 something on the record for --

21 JUDGE AGIUS: Yes. The thing is we'll have to draw down the

22 curtains before he does that because there are people in the gallery.

23 They don't need to leave -- you don't need to leave, because in

24 any case we will still have to draw the curtains down because of cameras

25 and everything.

1 I think the witness can be escorted out of the courtroom now --

2 yeah, yeah, they are not going to recognise him from his shoes.

3 [The witness stands down]

4 JUDGE AGIUS: Yes, Ms. Sellers.

5 MS. SELLERS: Your Honour, the Prosecution would like to draw the

6 Trial Chamber's and the Defence's attention to the fact that this witness

7 has testified fairly extensively within this session on the actions, the

8 duties of Nurif Rizvanovic.

9 JUDGE AGIUS: Yes.

10 MS. SELLERS: And the effect that that has on relevant issues of

11 command and control, very relevant issues also of what groups took part in

12 what battles, and now relationships between Mr. -- or Commander Rizvanovic

13 and a Prosecution witness. The Defence has fulfilled their obligations,

14 as was seen priorly, in submitting a summary of the possible evidence that

15 a witness should give. When the Prosecution is in the position of not

16 thinking the summary is sufficient, we send correspondence. In this case

17 we sent a letter asking if there were any other areas and some specific

18 questions. And Defence responded to our letter that they would not be

19 elaborating on the summary for the purposes of this witness. And we, the

20 Prosecution, accepted that your summary must have been complete from your

21 point of view.

22 We still think the summary wasn't complete, and now after the

23 witness has testified and gone into a very important area that has been

24 within the Prosecution's pre-trial brief, that has been within other

25 evidence, we do have not only the subregion being brought up, which is not

1 in the summary, but also Commander Rizvanovic.

2 Your Honour, I would ask two things: That the summaries that

3 Defence gives, particularly if it changes during proofing, that the

4 Prosecution be updated as to the areas and the evidence that they intend

5 to lead.

6 The second thing I would have to ask in this case, because it is

7 substantial, and I will say there is a de minimus part of that, that means

8 that our cross-examination certainly must address some of these issues.

9 Since we are only apparently halfway through this witness's testimony,

10 that will not pose enormous problems, but I would just like to alert the

11 Trial Chamber that the contents of the summary certainly relates to our

12 ability to prepare for cross-examination and that actual preparation.

13 Thank you.

14 JUDGE AGIUS: Okay.

15 Your comments, Ms. Vidovic, before we give our own.

16 MS. VIDOVIC: [Interpretation] Of course, Your Honour. We have

17 provided on this specific occasion a very detailed summary, which included

18 the events of the defence of Konjevic Polje. At least two of us -- of our

19 previous witnesses, whenever mentioning Konjevic Polje, undoubtedly also

20 extensively testified about Nurif Rizvanovic. Whoever investigated

21 Konjevic Polje and the defence thereof, wherever there was mention of

22 Konjevic Polje, it could not have come as a surprise to the Prosecutor

23 that this was -- would immediately be linked up with Nurif Rizvanovic's

24 name. Besides, they dealt extensively with Nurif Rizvanovic in their

25 pre-trial brief. There is nothing that comes as a surprise or as

1 something new in what the witness testified so far.

2 We indicated that the witness was going to testify about

3 Konjevic Polje, and I therefore believe that we have fully honoured our

4 obligation. Of course, Your Honour, until the witness comes, until we

5 talk to him shortly before his testimony, we are unable to know all the

6 details that the witness will state. You have to know that the summaries

7 were done in a very short span of time this summer. You have to know that

8 we never talked to a group of witnesses, including this particular

9 witness, we never talked to him prior to meeting him here. I believe that

10 we were quite fair in providing pretty detailed summaries.

11 I was expecting this objection because we had correspondence with

12 the OTP. I checked the case law concerning Defence teams in other cases,

13 and I must say that the summaries provided there were far less concise --

14 or rather, I wanted to say that they were far shorter, less detailed, in

15 all these other cases.

16 If I indicate that the witness is to testify about the events in

17 Konjevic Polje, then anyone who had to do anything with Konjevic Polje,

18 had analysed Konjevic Polje would know that it would also involve Nurif

19 Rizvanovic. I do not believe that we have breached any of our

20 obligations, especially not the one under Rule 65 ter (G).

21 [Trial Chamber confers]

22 JUDGE AGIUS: Yes, I thank you, Madam Vidovic.

23 Your final comments, Ms. Sellers.

24 MS. SELLERS: Your Honour, I appreciate the observations of

25 Defence counsel, but I would say that in this instance whenever they have

1 brought witnesses before Your Honours who would testify about the

2 subregion, that was always stated clearly in their summary. And in this

3 time we have a summary in which that is not stated. So while

4 Konjevic Polje certainly could always imply the subregion, this time it

5 was not there, as if it was specifically not an area that we were going to

6 go into.

7 JUDGE AGIUS: Anyway, before we come back to you on this, between

8 the filing of the Defence witness summaries that we got way back in

9 August, which are the only summaries that we have, did you ever receive

10 anything else in relation to this document from the Defence?

11 MS. SELLERS: No, Your Honour. We are working from the same

12 summaries.

13 JUDGE AGIUS: The same.

14 MS. SELLERS: That's why a time prior to a witness coming forward,

15 we enter into correspondence with our learned friends to ask will there be

16 other information that we can have.

17 JUDGE AGIUS: I just wanted to make sure of that. In other words,

18 after the arrival of the witness here in The Hague and his briefing or

19 proofing by the Defence, you have not received anything?

20 MS. SELLERS: No, the Defence never provides that spontaneously.

21 JUDGE AGIUS: All right. We'll come back to you after the break

22 on this. Thank you.

23 We'll have a 30-minute break starting from now, which basically

24 means we'll reconvene at five past 11.00.

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

1 [Witness entered court]

2 --- On resuming at 11.11 a.m.

3 JUDGE AGIUS: Yes. With the -- with -- pardon? No, no, no,

4 it's -- they have started transmitting. You need to press video monitor

5 once more and it should come.

6 So basically let's deal with the matter that Ms. Sellers raised

7 before the break.

8 We do appreciate, Ms. Vidovic, for sure that when we ask you to

9 submit Defence witness summaries, these are necessarily restricted to what

10 is within your knowledge at the time. So we don't expect you to foresee

11 other matters that might be dealt with by -- by the witness when he or she

12 eventually comes over. But we have the practice here of proofing the

13 witness before giving evidence, and it is usually the case that during

14 this proofing there are issues that you find out the witness will be able

15 to cover. And the most obvious -- you may sit down, please, make yourself

16 comfortable.

17 And the most obvious evidence of this is that while in the summary

18 you would have told us roughly you need 3.5 hours for that witness's

19 statement. As we have been going along after the proofing, sometimes that

20 figure doubles, as has been also in this case.

21 So what we are asking is the following: There is some validity to

22 what you have suggested, that when you indicated in the summary that the

23 witness will be dealing with Konjevic Polje, one would have expected that

24 the name of Nurif Rizvanovic would have come up. I think it's fair to say

25 that I would have expected the witness to at least mention, but to go into

1 all the details that he did.

2 So at that point in time, once the proofing has been made, has

3 been finished, and you are in a position to put it in juxtaposition with

4 the summary that you would have provided, I think if not for any other

5 reasons but at least for courtesy and the good environment that we have

6 tried to secure the relationship between the Prosecution and the Defence

7 in this case would appreciate it if you indicate areas which the witness

8 will be covering beyond what one would expect reading the summary. I have

9 to agree with Ms. Sellers. We -- none of us in fact were expecting

10 reading the Defence witness summary that the Defence witness summary will

11 also be dealing with, for example, command and control issues in

12 Konjevic Polje in relation to Nurif or with regard to the regional set-up.

13 So let's try -- I know that it is not easy. I know that the kind

14 of hours that we work here and the pressure that we have and the stress

15 that is involved by having to work on Saturdays and on Sundays to proof

16 witnesses carries with it its weight and -- I mean, it's stressful for

17 everyone, but let's try to cooperate a little bit more, all right, and so

18 that we don't have to waste five minutes or ten minutes in future having

19 to deal with such matters.

20 Ms. Sellers, I think, is right in complaining that to an extent

21 she has been surprised in some -- with the mentioning of some elements or

22 issues. And of course I have to -- I barely need to put your mind at rest

23 that you will be given all the opportunity to address these issues during

24 your cross-examination. I mean, it's no point in even doubting --

25 doubting that. All right.

1 Do you get my message, Ms. Vidovic?

2 MS. VIDOVIC: [Interpretation] Thank you, Your Honour. I did get

3 your message. I expect that such letters and inquiries will be forwarded

4 to us in a fair manner, just as you put it. If we receive this in -- by

5 way of an order or in an unfair way, then we will only do what we are

6 bound to do. I don't want to trouble you more with that, but the reason

7 why I thought the OTP had sufficient information was that in item 3 of the

8 summary we precisely stated that the witness will testify with regard to

9 paragraph 7, which is the accused's command over Srebrenica, Bratunac,

10 Vlasenica, and Zvornik. And paragraph 7 of the indictment deals with the

11 exact area of the subregion. Paragraph 7 of the indictment mentions the

12 accused's command responsibility over the subregion; that's why I didn't

13 think that would be a surprise. But in any case, I received your message

14 and I will act accordingly.

15 JUDGE AGIUS: I thank you -- thank you both.

16 MS. SELLERS: Thank you, Your Honour.

17 JUDGE AGIUS: And your cooperation in this area, your further

18 cooperation, because I must say -- I must state publicly that all in all,

19 all in all, I have no complaints. I mean, I think you have cooperated to

20 a large extent so far, and I must commend you for that. In the future, if

21 you could possibly avoid further incidents like this, I think we would all

22 benefit from that.

23 Yes, let's continue with the witness, Ms. Vidovic, and we are in

24 open session.

25 MS. VIDOVIC: [Interpretation] I would kindly ask the usher to put

1 another document in front of the witness. This is a Bratunac garrison

2 command number 04337001 dated 8 October 1992. This is a report to brigade

3 commander signed by garrison commander Captain Vaso Gujic.

4 I will quote a part of the document to the witness.

5 Q. Item 1: "Forces attacking Urkovici encountered fierce resistance.

6 One of our men was killed. The troops withdrew to the initial positions.

7 "Ambushes were laid to infiltrate troops into Srebrenica. We

8 will additionally reinforce the ambushes.

9 "By tomorrow, we will reinforce an additional line towards

10 Banjevici.

11 "When the circumstances allow for this, the air force will attack

12 tomorrow. One (Kraguj) airplane is available."

13 Q. Your Honour, could we move into private session, please?

14 JUDGE AGIUS: Yes, by all means, Ms. Vidovic.

15 Let's go into private session for a while, please.

16 [Private session]

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 [Open session]

25 JUDGE AGIUS: We are in open session.

1 Are you finished with this document, Ms. Vidovic?

2 MS. VIDOVIC: [Interpretation] Not yet, Your Honour.

3 JUDGE AGIUS: Okay. Thank you. Then proceed.

4 MS. VIDOVIC: [Interpretation]

5 Q. Witness, in item 2 of the document ambushes are mentioned. Do you

6 remember where those ambushes were laid?

7 A. They usually took place between Siljkovici towards Konjevic Polje

8 at the area called Buljim. Along that axis we encountered ambushes most

9 frequently. Those were the fighters from Milici and Kravica.

10 Q. Those were Serb fighters?

11 A. Yes, they were Serb fighters.

12 Q. Why were those ambushes laid, against whom?

13 A. The ambushes were laid because these were the routes used by

14 civilians the most and that's where they usually got killed.

15 Q. Why did the civilians use that area?

16 A. They went in search of food.

17 Q. What was the situation with food in Konjevic Polje, if you can

18 explain it to the Chamber?

19 A. The situation was grave in Konjevic Polje, and it was even graver

20 in Srebrenica because we occasionally would receive some information from

21 the people who came from there to the territory of Konjevic Polje.

22 MS. VIDOVIC: [Interpretation] Your Honours, could we please assign

23 an exhibit number to this document?

24 JUDGE AGIUS: Yes, Ms. Vidovic. This document which consists of

25 two pages, one in B/C/S and the other one being the corresponding

1 translation of it into English with ERN 04337001 is being assigned Defence

2 Exhibit Number D923.

3 MS. VIDOVIC: [Interpretation] I would kindly ask the usher to put

4 another document in front of the witness. This is a document from the

5 Drina Corps command. It is a Drina Corps command document dated

6 4 November 1992. The ERN number is 04292136. The title of the document

7 is "Order on final stage of combat operations."

8 Q. Witness, I wanted to quote the first three paragraphs of the

9 document.

10 "After months of combat operations conducted in the territory of

11 Zvornik, Sekovici, Vlasenica, Milici, Bratunac, we have entered the final

12 stage of combat operations.

13 "The enemy has been pushed into a very small area" -- the

14 document actually states -- the document has been actually pushed in a

15 small room, as it is stated in B/C/S, but it should be area "with

16 Konjevic Polje at its centre and is completely surrounded and facing a

17 total military defeat."

18 "With the liberation of this territory, combat operations in it

19 will stop and we shall gain invaluable free territory and reinforce our

20 positions towards Tuzla, Kalesija, Kladanj, and Srebrenica."

21 Witness, on the 4th of November, 1992, the Drina Corps commander,

22 Milenko Zivanovic, reports on the final stage of combat operations

23 pertaining to Konjevic Polje. The three paragraphs I read, does it

24 reflect the situation on the ground in the sense that the Muslims were

25 pushed into a very small area with Konjevic Polje at its centre and was

1 completely surrounded on the 4th of November, 1992? Does that tally with

2 what one could experience in Konjevic Polje at the time?

3 A. Yes. The document clearly portrays and proves the situation, and

4 that was the truth.

5 Q. Is that what your experience was like there at that time?

6 A. Precisely so.

7 Q. I will continue quoting some other statements from the document.

8 First and foremost, was it your impression at the time that Konjevic Polje

9 was completely surrounded?

10 A. Our impression was that Konjevic Polje was completely surrounded

11 and there were situations in which we were unable to help each other. We

12 fought to the bitter end.

13 Q. I wanted to quote item 7 of the document. It states: "The areas

14 of responsibility for the units for final clearing up work and territorial

15 control are as follows: A, the Drinjaca Zelinje battalion, Kuslat

16 village, Konjevici village."

17 As regards this, I wanted to ask you the following. In your

18 knowledge, is it correct that Konjevici Polje were attacked from the area

19 of Zelinje in early November 1992?

20 A. Yes, it is correct.

21 Q. Please look at subitem (b) on the next page.

22 "The Kravica Battalion, Urkovici village, Hrncici village,

23 Konjevic Polje."

24 Do you remember and is it correct that on the 4th November, 1992,

25 and the days after that, Hrncici, Urkovici, and Konjevic Polje were

1 attacked from the direction of Kravica, as far as you know?

2 A. Yes, it is correct, because when they were attacking Hrncici and

3 Urkovici, they were also shelling the centre of Konjevic Polje. And it

4 seems that based on this document they thought it would suffice to take

5 over that territory.

6 Q. Did you know that on the 4th of November, 1992, that area was

7 under attack from the area of Kravica? Was it your experience?

8 A. Yes, I just said that a minute ago, when I was in Urkovici.

9 Q. Thank you?

10 MS. VIDOVIC: [Interpretation] Could we give an exhibit number to

11 this document, Your Honour?

12 JUDGE AGIUS: Yes, certainly, Ms. Vidovic. This document which

13 consists of three pages in Serbo-Croat, two of which are typewritten and

14 one of which is handwritten, and three corresponding pages all typed,

15 being the translation thereof into English is being tendered, received,

16 and marked as Defence Exhibit D924.

17 MS. VIDOVIC: [Interpretation]

18 Q. Witness, we will show you another document. This is a Drina Corps

19 command document dated on the 4th of November, 1992 as well, signed by

20 Commander Colonel Milenko Zivanovic, the number being 04293122. It is a

21 short document. I will read out the entire contents:

22 "On 5 November 1992, starting at 7.00 p.m., a working meeting

23 will take place in Siljkovici. You, the brigade commander, and your

24 immediate subordinates, the battalion commanders of Vlasenica, Bratunac,

25 Drinjaca, and Milici, and the 6th Battalion of Zvornik Light Infantry

1 Brigade shall attend the meeting.

2 "You are to come to the working meeting with proposals for the

3 execution of the final actions in Konjevic Polje in your area of

4 responsibility."

5 My question, hence, is the following: Did you have any knowledge

6 about the ensuing attack, a large attack, by the Serbs to finally break

7 through the resistance lines of Konjevic Polje?

8 JUDGE AGIUS: Yes, one moment, one moment.

9 Let's see -- is this an objection?

10 THE INTERPRETER: Microphone, please.

11 MS. SELLERS: I'm sorry. So we can make sure that the record is

12 clear. Madam Vidovic stated in the description of the document that it

13 was signed by colonel Milenko Zivanovic, and when I look at the original

14 B/C/S I certainly see his name there, but I do not see a signature

15 indicated. And in assistance of not only identifying the document but

16 certainly we don't want the witness to think there was a signature on the

17 document as well.

18 JUDGE AGIUS: All right. I think that's a fair point made by

19 Ms. Sellers.

20 Witness, it's not being put to you that this is signed by Mr. --

21 or Colonel Milenko Zivanovic, but the paternity of this document is being

22 attributed to him, this notwithstanding.

23 I suppose you agree to this, Ms. Vidovic? And let's proceed.

24 MS. VIDOVIC: [Interpretation] I agree. It is obviously a

25 dispatch, Your Honour.

1 JUDGE AGIUS: Yeah, okay.

2 MS. VIDOVIC: [Interpretation] But in any case, thank you for your

3 assistance.

4 Q. Witness, I wanted to ask you the following: You, the people in

5 that area, were you able to sense that the final stage of attacks was to

6 take place against Konjevic Polje on the 5th of November, 1992?

7 A. As far as I could see, as well as those around me who could

8 observe with the naked eye and the binoculars we had, one could clearly

9 see that large numbers of people were on the move in the villages and that

10 the tanks and the APCs are getting ready, those standing next to Milo

11 Milanovic's house, as well as in other villages. So quite a number of

12 soldiers grouped and we could foresee a strong offensive against us.

13 Q. Thank you.

14 MS. VIDOVIC: [Interpretation] Your Honour, could we assign an

15 exhibit number to this document?

16 JUDGE AGIUS: Yes, Ms. Vidovic, this document is being assigned

17 Defence Exhibit Number D925, consists of two pages, one in B/C/S, on in

18 English with ERN 04293122.

19 MS. VIDOVIC: [Interpretation] Your Honours, I would kindly ask

20 that another document be shown to the witness. This is a document from

21 the command of the Drina Corps dated the 20th November 1992, the ERN

22 number being 04361528. This is a document forwarding some information.

23 At the end of the document, we can see the name of Commander Lieutenant

24 Colonel Borivoje Tesic. I will read out the entire document to the

25 witness. I would kindly ask him to pay attention.

1 "The Konjevic Polje-Srebrenica route has been cut off along the

2 Zabrdje-Jasikovaca line since 14 November 1992.

3 "The valley towards Hajducko Groblje can be controlled from the

4 Siljkovici feature. The troops chosen to close the line are from the

5 3rd Battalion (commander is Mile Milovanovic, reserve Captain) and from

6 the Derventa Battalion. 35 troops from three battalions of my unit were

7 chosen to close the line; their commander is Milan Ivanovic and the

8 company commander is Rocko Peric. They are only armed with personal

9 weapons. There is an anti-aircraft machine-gun on Siljkovici. The area

10 can be controlled with an 82-millimetre mortar. We will provide

11 preparatory fire. Obstacles must be laid in part of the area on

12 21 November 1992."

13 Q. Witness, as regards this document, will you please answer the

14 following: According to your knowledge, what was actually the direction

15 of Zabrdje and Jasikovaca. Who used that direction, if you know?

16 A. Zabrdje-Jasikovaca, that is the road from Kravica -- or rather,

17 the hamlet of Siljkovici towards Milici. That was the route controlled by

18 the Serbs and they laid an ambush there.

19 Q. In your knowledge, did the Muslim civilians try to use that route

20 in their search of food?

21 A. Yes. That was the route used to reach Konjevic Polje and the

22 other way around.

23 Q. Could you point Zabrdje and Jasikovaca on the map for the Trial

24 Chamber?

25 JUDGE AGIUS: The map needs to be adjusted on the ELMO properly

1 because we can't follow.

2 MS. VIDOVIC: [Interpretation]

3 Q. Witness, it is close to your finger, a bit to the left upwards

4 near Zabrdje. You have pointed the place. Could you please mark it off.

5 It was right under your finger a moment ago. It's a bit down from your

6 pen.

7 JUDGE AGIUS: [Microphone not activated].

8 THE WITNESS: [Interpretation] Jasikovaca and Zabrdje.

9 MS. VIDOVIC: [Interpretation]

10 Q. Thank you, Witness.

11 To your knowledge at this point in time, in mid-November 1992, was

12 this route cut off, thus making it impossible for the civilians to move in

13 the area in search of food or not?

14 A. At the time it was completely cut off. Nobody was able to go to

15 or from Srebrenica.

16 Q. It is stated here that from the Siljkovici feature one could

17 command the valley in the direction of Hajducko Groblje and that the

18 forces charged with this are from the ranks of the 3rd Battalion. Is it

19 true that at this time the villages surrounding Siljkovici as well as

20 Siljkovici itself was targeted?

21 A. Yes, that's true. The surrounding Muslim villages were targeted

22 from Siljkovici, whereas artillery targeted Kamenica.

23 Q. Were you aware of the existence of this anti-aircraft machine-gun?

24 A. Yes, I was. One could see it clearly next to a Howitzer.

25 Q. Did you hear of the 3rd Battalion in November 1992?

1 A. Yes, I heard about the battalion in 1992.

2 Q. Where did the battalion come from, according to what you heard?

3 A. This was a Kravica battalion.

4 MS. VIDOVIC: [Interpretation] Your Honour, could this document be

5 assigned a number, please?

6 JUDGE AGIUS: Yes, certainly. This document, which consists of

7 two pages, one in Serbo-Croat, the other one in English, being a

8 translation, bearing ERN 04361528, in both cases, is being tendered and

9 marked as Defence Exhibit D926.

10 MS. VIDOVIC: [Interpretation]

11 Q. Witness, I will show you another document by the Bratunac Brigade

12 command dated the 24 November 1992, the ERN number being 04361531. I will

13 quote the document.

14 "For the purpose of commander's reconnaissance to be carried out

15 together with subordinate officers, herein you will find the working

16 points in the brigade's area of responsibility for the execution of the

17 task at hand:

18 "1. Working point-1, Banjevici village (Lupoglava).

19 "2. Working point-2, Siljkovici village."

20 Based on your service in the Army of Bosnia and Herzegovina, can

21 you tell us what "working point" means.

22 A. Working point means assigning combat operations, or rather,

23 distributing combat operations from this area.

24 Q. Based on your knowledge and experience from the area, did your

25 villages come under attack in mid-November 1992 from Banjevici and

1 Siljkovici?

2 A. These villages were practically never left alone. They were

3 constantly under attack.

4 JUDGE AGIUS: One moment, Ms. Vidovic, before you proceed. Let me

5 take you back to your Exhibit D922, which was tendered and admitted this

6 morning. There we had the term [B/C/S spoken] and here we have "radna

7 tacka." Can the witness explain the difference, please. One was

8 translated to us as trig point. The [B/C/S spoken] was trigonometric

9 combination, and it's called trig point. This one is given another

10 name,"radna tacka," so perhaps one could enlighten us on where the

11 distinction lies. This is a working point. How is it arrived at?

12 Because I think it would be of some importance to us.

13 Have you understood me? You were in the army, you should know a

14 little bit about this, so...

15 THE WITNESS: [Interpretation] Working point is the point where

16 senior officers meet, like commanders of battalions or brigades, even

17 possibly company commanders, and in that area they are assigned different

18 locations to which their units will move and where they will launch

19 attacks.

20 As for the trigonometric point, I am less familiar with the term.

21 I believe that refers to the line that is closest to where the attack

22 takes place.

23 JUDGE AGIUS: I see -- I see your --

24 MS. VIDOVIC: [Interpretation] If I may, Your Honour.

25 JUDGE AGIUS: I see your client disagreeing with this, so I don't

1 know if you want to pursue it any further with the witness now. You may

2 of course do so. But I noticed the accused disagreeing. And I am not

3 qualified enough on the subject to intervene and explain why one is

4 different from the other. No, I don't want to hear your client, but ...

5 MS. VIDOVIC: [Interpretation] Your Honour, trigonometric point is

6 a geographic term which shows -- or rather, denotes a certain elevation.

7 It is more of a geographical term than a military one.

8 JUDGE AGIUS: Yes. You mean --

9 MS. VIDOVIC: [Interpretation] And that's how it was mentioned in

10 the document.

11 JUDGE AGIUS: Thank you. To me it's the meeting point of two or

12 more, usually three, coordinates. Is that correct?

13 MS. VIDOVIC: [Interpretation] Yes, Your Honour. Exactly,

14 coordinates.

15 JUDGE AGIUS: Let's proceed then.

16 MS. VIDOVIC: [Interpretation] Thank you.

17 Q. As far as you can remember, was the Konjevic Polje area attacked

18 on around the 24th of November, 1992 as well?

19 A. Yes. I've already indicated that it was under attack even before.

20 Q. Was it attacked from the area of Siljkovici and Banjevici, that's

21 to say, from the hamlets of Kravica, if you know?

22 A. Yes. Those were the directions from which most of the attacks

23 came, therefore from the Kravica Battalion.

24 MS. VIDOVIC: [Interpretation] Your Honour, could this document be

25 assigned a number, please?

1 JUDGE AGIUS: Yes. This document, which consists of two pages,

2 one in B/C/S, and one in English, the English being a translation of the

3 former one, is being tendered and marked as Defence Exhibit D927. The ERN

4 number is 04361531.

5 MS. VIDOVIC: [Interpretation] Could I ask the usher now to show

6 the witness another Drina Corps document, also dated 24 November 1992.

7 And it says "very urgent, decision for further action." And I will quote

8 while it is being distributed.

9 "Pursuant to the directive of the Main Staff of the Army of

10 Republika Srpska, strictly confidential, number 02/3 of 19 November 1992

11 and based on an assessment of the situation, I have decided:

12 "Launch an attack using the main body of troops and major

13 equipment to inflict on the enemy the highest possible losses, exhaust

14 them, break them up or force them to surrender, and force the local Muslim

15 population to abandon the area of Cerska, Zepa, Srebrenica, and Gorazde.

16 Liberate and render usable the Milici-Konjevic Polje-Zvornik road and open

17 the corridor towards eastern Herzegovina."

18 Q. Witness, you mentioned the intensity of the attacks around the

19 24th of November, 1992 targeting Konjevic Polje. Could you on the basis

20 of that conclude that the Serbs were trying to force the Muslim population

21 to abandon the Podrinje area?

22 A. Yes. It was concluded that way, and our conclusion was 100

23 per cent that; however, we stood ground, resisted the attacks.

24 Q. Based on the terminology used here "to force them to surrender, to

25 force the local Muslim population to abandon the area of Cerska, Zepa,"

1 and on the basis of what you were able to see and experience in November

2 1992 on the ground, can you infer that the Serbs were already planning at

3 the time to do what in fact happened in the area in 1995?

4 A. Yes, of course I could have inferred that because in addition to

5 all this they were throwing flyers off planes telling us to surrender and

6 surrender our weapons. Right after that, fierce attacks ensued. What we

7 were able to conclude on the basis of these flyers that were distributed

8 and the rest was in fact proved by the events in 1995.

9 Q. I will now read to you from a different portion of this document.

10 Please turn to page 2, paragraph 2. It says: "In the first stage lasting

11 20 to 30 days, crush the enemy forces or force them to surrender

12 unconditionally in the sectors of Cerska, Konjevic Polje, and Zepa, and

13 directly put up a blockade at Olovo."

14 My question to you is: Within some 20 to 30 days after the 24th

15 of November, 1992, did there ensue even fiercer attacks against

16 Konjevic Polje or not?

17 A. Yes. Shortly after these flyers were thrown off planes, attacks

18 were launched against Konjevic Polje.

19 Q. Was this in the course of December 1992?

20 A. Yes.

21 Q. Were these artillery attacks or not? What was the intensity of

22 these attacks? Could you briefly tell the Trial Chamber.

23 A. These were artillery attacks where mortars were engaged, APCs,

24 tanks, Howitzers, anti-aircraft cannons, and various other weapons, and of

25 course infantry forces were engaged as well.

1 Q. Did it happen sometime in December 1992 that there was someone

2 counting the shells that landed in the area on a particular day in that

3 period?

4 A. Given that there was a lot of shelling on the area -- in the area

5 before, there was a lady, if I can say who she was, she was Muminovic,

6 Bego's wife, her name was Fata who started counting shells, and she

7 counted them up to a thousand, and perhaps when she stopped counting,

8 there may have been some 70 more.

9 Q. We have almost finished with this document.

10 Please look at 2.2 of the document where it is stated: "The

11 Bratunac Light Brigade used the main body of troops to launch an attack to

12 break up enemy forces and reach the features of Loznik, Zanik Caus, and

13 Bijela Stijena use the remaining forces to cut the Srebrenica-Cerska road

14 in coordination with part of the Birac Brigade and the Milici Battalion,

15 and then in coordination with the Birac and the Zvornik Brigades, liberate

16 Pobudje, Hrncici, and Konjevic Polje and thus create conditions to open

17 the Vlasenica-Milici-Drinjaca road."

18 Pay specific, please, attention to the following paragraph:

19 "Consolidate the Fakovici Battalion as soon as possible and give

20 it the task of penetrating as deep as possible into the area of Srebrenica

21 using the territory of Serbian villages and attack Srebrenica from there."

22 Witness, is it true, based on what you were able to observe and

23 experience, that Serb villages were used as venues from which the

24 surrounding Muslim villages were attacked?

25 A. Serb villages had always been used for the purpose of attacking

1 Muslim areas. This document states that the Cerska-Srebrenica road should

2 be severed, which shows and proves that the entire Konjevic Polje area

3 should be cleansed in order to be able to link up with Cerska. There was

4 no other way.

5 Q. However, the drift of my question was quite different. I quoted

6 to you a portion of the document which says that the territory of the Serb

7 villages is used for launching attacks against Muslim areas. Based on

8 your experience in Podrinje or specifically in the area where you were

9 residing, can you tell us whether Serb villages were used as venues from

10 which attacks were launched on Muslim areas?

11 A. Yes.

12 MS. VIDOVIC: [Interpretation] Could this document please be

13 assigned a number.

14 JUDGE AGIUS: Yes, this document which consists of six pages,

15 three of which are in B/C/S, the other three in English, being a

16 translation, with ERN 04292352 to 354, page included, is being tendered

17 and marked as Defence Exhibit D928.

18 MS. VIDOVIC: [Interpretation]

19 Q. I will show you another document now.

20 MS. VIDOVIC: [Interpretation] Could the usher show the witness a

21 Drina Corps command document dated 12 December 1992, bearing the number

22 04358084, addressed to the commands of the Zvornik, Birac, and Bratunac

23 Brigade, and so on.

24 The document states: "Very urgent. Order on taking measures to

25 defend from military intervention of foreign countries against

1 Republika Srpska."

2 Q. Please look at point 2 [as interpreted] of the order on the second

3 page where it is stated: "Brigade commands and, if necessary, battalion

4 commands, should be deployed in the basements of massive buildings while

5 undertaking measures to prevent a decrease in efficiency of management and

6 command."

7 My question to you is as follows: Are you surprised by what this

8 document states that the Serbs located their headquarters in massive

9 buildings? Did you know of any headquarters in buildings which were not

10 military features but were quite massive in their construction?

11 A. Yes. I told you that I know very well what the school in Kravica

12 was like. There was a new building and an old one. I also knew about

13 this field above the Bacici dam where there was another building. These

14 were the two buildings that could be used for that purpose.

15 Q. The transcript says that these two buildings could be used for

16 that purpose. Was it the case that they could be used or were they in

17 fact used by the army? Did the army use them as headquarters, as you

18 know?

19 A. Yes. I stated on several occasions that this was indeed the case,

20 they were used for that purpose.

21 Q. Thank you. This was just to clarify the transcript.

22 MS. VIDOVIC: [Interpretation] Could the document be assigned a

23 Defence exhibit number, please?

24 JUDGE AGIUS: Yes. This document which equally consists of three

25 pages in English and three pages in B/C/S with ERN 04358084 to 086 is

1 being tendered and marked as Defence Exhibit D929.

2 Yes, Ms. Sellers.

3 MS. SELLERS: Your Honour, I noted that Madam Vidovic said please

4 look at point 2. I believe she might have wanted to say look at point 4

5 of that document.

6 JUDGE AGIUS: I think I heard her say page 2, not point 2.

7 MS. SELLERS: Then we might need to just correct the transcript

8 which inadvertently picked up point 2.

9 JUDGE AGIUS: All right. Let me search it. Yes, yes, yes, the

10 transcript definitely needs to be corrected. In line 20 of the previous

11 page it says point 2 of the order on the second page. It should

12 read "point 4 of the order on the second page." Thank you.

13 MS. VIDOVIC: [Interpretation] Thank you, Your Honour.

14 I believe the witness already has the document by the Bratunac

15 Brigade command dated 5 January 1993 bearing the number 04359300. This is

16 the order by the commander of the Bratunac Light Infantry Brigade,

17 Lieutenant Colonel Milan Urosevic.

18 Q. I will quote to you item 3: "I hereby order all weapons and

19 ammunition that was distributed to individuals before the establishment of

20 the armed forces of the Serb Republic which are not used and are kept in

21 houses to be returned. The weapons are to be returned to the brigade

22 command by the 10th of January, 1993."

23 MS. VIDOVIC: [Interpretation] In connection with this, Your

24 Honour, could we move into private session for a while, please?

25 JUDGE AGIUS: Yes, let's move into private session for a while.

1 [Private session]

2 (redacted)

3 (redacted)

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7 [Open session]

8 JUDGE AGIUS: Yes, this document which consists of two pages the

9 ERN 04359300, one in B/C/S, one in English, is being tendered and marked

10 as Defence Exhibit D930.

11 MS. VIDOVIC: [Interpretation]

12 Q. Please take a look at the map now. Could you point to the

13 location of Zelinje for Their Honours. Can you see it?

14 JUDGE AGIUS: Yes. Yes, thank you.

15 MS. VIDOVIC: [Interpretation] Thank you.

16 Q. Can you tell us how large the village is?

17 A. It wasn't really large.

18 Q. Was the area of Konjevic Polje attacked from Zelinje in the period

19 between -- starting in 1992 until its fall?

20 A. Yes. It was mostly from Zelinje.

21 Q. Are you referring to Konjevic Polje itself rather than the

22 surrounding area when you say that the attacks mostly came from Zelinje?

23 A. These troops were attacking Konjevici and Banjevici together with

24 Drinjaca -- with Drinjaca command.

25 Q. Thank you.

1 MS. VIDOVIC: [Interpretation] And I would like the usher to show

2 the witness a document dated 24 November 1992 issued by the brigade

3 command -- Bratunac Brigade command bearing the number 04361530, which is

4 a document addressed to the command of the Drina Corps. I will quote from

5 items 1 and 2 of the document, wherein it is stated: "The Zelinje Company

6 was resubordinated to my brigade.

7 "The commander of the Zelinje Company is Radosav Milosevic, the

8 commander of the Sopotnik Company is Slavoljub Vidakovic and the commander

9 of the part of the Zeljova forces is Nikola Mitrovic."

10 It is handwritten here: "The forces resubordinated to me are 154

11 strong."

12 It is stated below: "They are armed with: PM submachine-gun,

13 M-84 two pieces; PM M-72, 7.62 millimetre, 13 pieces; PM M-53, two pieces;

14 automatic rifles, 56 pieces; semi-automatic rifles, 69 pieces; and

15 submachine-guns, 12 pieces."

16 Witness, you stated that Zelinje was not a large village.

17 According to this document, one could conclude Zelinje Company had 17

18 light machine-guns. Can you tell the Trial Chamber whether a light

19 machine-gun is a dangerous piece of weapon?

20 A. The M-72 light machine-gun dates from 1972 that I used during my

21 military service and it has a much longer range than an automatic rifle.

22 Q. Is that a dangerous weapon?

23 A. The longer the range, the more dangerous the weapon.

24 Q. In your experience, the Serb villages around Konjevic Polje, were

25 they all armed or not, if you have any knowledge as to that?

1 A. I will probably be mistaken if I said that not every single one of

2 them was armed. They were all armed.

3 Q. What do you base your conclusion on?

4 A. Because all of the villages that I was able to notice had military

5 troops there.

6 Q. From your testimony so far, did I understand probably that not

7 only trenches were used to open fire at Muslim villages?

8 A. They didn't have much use of trenches. They felt strong and they

9 thought they would be able to deal with the entire situation from their

10 houses rather than from trenches.

11 Q. Thank you.

12 MS. VIDOVIC: [Interpretation] Your Honour, could we assign an

13 exhibit number to the document?

14 JUDGE AGIUS: So this document, which consists of one page in

15 B/C/S, and two pages in English, with ERN 04361530 is being tendered and

16 marked as Defence Exhibit D931.

17 MS. VIDOVIC: [Interpretation] Could we give another document to

18 the witness. This is another Bratunac Brigade command dated 27 November

19 1992, the ERN number being 04363003. The name of Lieutenant Colonel

20 Borivoje Tesic appears and it was sent to the Drina Corps command.

21 Q. Witness, while you're waiting for the document I wanted to quote

22 item 4 of the text. It states: "At about 1200 hours, three vehicles, out

23 of which two cars and a lorry, set off for Kravica. For yet-unestablished

24 reasons, the two last vehicles missed the turning for Kravica and

25 continued straight on. In the Sandici sector they entered among the

1 Muslims. The lorry was destroyed."

2 Further down under item 7 it states: "The lorry carried 80,

3 120-millimetre mortar shells, 40 Zoljas, eight Maljutkas, and three M-84

4 machine-guns. They were all destroyed, and the lorry was set on fire by

5 Muslims' incendiary ammunition."

6 MS. VIDOVIC: [Interpretation] Your Honour, could we move shortly

7 into private session, please?

8 JUDGE AGIUS: Yes, let's move into private session for a while.

9 [Private session]

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23 [Open session]

24 JUDGE AGIUS: So this document bearing ERN 04363003, both in the

25 English and in the original Serbo-Croat text, consisting of two pages,

1 which -- one in each of the two said languages, is being tendered and

2 marked as Defence Exhibit D932.

3 MS. VIDOVIC: [Interpretation]

4 Q. Witness, please take a look at some other documents.

5 MS. VIDOVIC: [Interpretation] I would kindly ask that D819 be

6 given to the witness. This is a Bratunac Brigade command document dated

7 4 December 1992. The title being "Decision to attack."

8 I wanted to quote item 4. It states: "I have decided to regroup

9 and bring in some of the brigade forces along the

10 Bratunac-Kravica-Banjevici village axis and then from an initial position

11 right: Sopotnik village left excluding the group of houses in Gornja

12 Brana village, move on to the attack grouping main forces on the Lupoglava

13 (Banjevici village) Konjic (667)-Drenjak (trig point 771)-elevation

14 overlooking Konjevic Polje axis."

15 Q. Please turn the page. On page 2, item 6 it states in the second

16 paragraph: "Use a frontal attack and combine action in the first and

17 third JGs to destroy the Muslim forces on the axis of attack. Having

18 broken out on to the Haluge feature, create conditions to consolidate the

19 forces of our brigade's 3rd Battalion."

20 Further down it states: "Support 82-millimetre mortar from the

21 Lupoglava sector, self-propelled gun from Goli Vis."

22 In your testimony you stated that the 3rd Battalion was from

23 Kravica. Can you point to Haluge on the map for the Chamber, please.

24 A. [Indicates].

25 Q. Is it also a Muslim village?

1 A. Yes, it is.

2 Q. Is it close to Hrncici?

3 A. This is a village between Hrncici and Konjevici.

4 Q. Thank you. Further down, item 7 in its second sentence it

5 says: "Use an all-out attack in combined action with the 2nd JG to

6 destroy the Muslim forces on the axis of attack. Having broken out on to

7 the elevation overlooking Durakovici village create conditions to

8 consolidate the forces of our 3rd -- of our brigade's 3rd Battalion."

9 MS. VIDOVIC: [Interpretation] Your Honour, could you remind me if

10 we are in open session? If we are, I would kindly ask that we move into

11 private session.

12 JUDGE AGIUS: Yes, we are in open session, Ms. Vidovic, but of

13 course we shall move for a short while to private session.

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25 [Open session]

1 JUDGE AGIUS: We are back into open session, and Ms. Vidovic is

2 suggesting that we could break now. Yes, indeed. No objection.

3 We will have a 30-minute break starting from now. That means we

4 will start a few minutes before 1.00. Thank you.

5 --- Recess taken at 12.30 p.m.

6 --- On resuming at 1.05 p.m.

7 JUDGE AGIUS: Let's continue.

8 By the way, you will recall that yesterday I did mention that I

9 wasn't quite sure what was going to happen on the 6th of December when we

10 were expecting to have a plenary. It has now been decided that we will

11 have a plenary, but due to the fact that Krajisnik and Oric are sitting --

12 and expecting to sit at quarter to 2.00, the plenary will finish by 1.00.

13 So the sitting that is scheduled for that day will happen.

14 Yes, Ms. Vidovic.

15 MS. VIDOVIC: [Interpretation] Thank you, Your Honour.

16 Q. Witness, we left it off at Siljkovici. You stated that one could

17 see the rounds fired with the naked eye. The weapons which were

18 discharged at Siljkovici, how were they positioned in relation to the

19 houses in Siljkovici, if you remember?

20 A. They were in the immediate vicinity of the houses in Siljkovici,

21 some 10 metres away from the houses.

22 Q. I would now ask you to explain to us some of the consequences of

23 the shelling.

24 MS. VIDOVIC: [Interpretation] Your Honour, for a while we'd need

25 to turn into private session. The witness will be mentioning some

1 details.

2 JUDGE AGIUS: Yes. So let's go into private session for a while.

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17 [Open session]

18 JUDGE AGIUS: We are back in open session, Madam Vidovic.

19 MS. VIDOVIC: [Interpretation] Could I have the usher's assistance

20 in showing the witness a new document.

21 This is a rather large document, Your Honour. For easier bearing

22 with the document, we marked the relevant pages in the order that I will

23 be using them. Wherever you can see the yellow Post-its, those are the

24 pages that I will elicit comments on from the witness. This is a list of

25 personal incomes for November, Bratunac Brigade, bearing the number

1 01319748 up until 01319804.

2 Q. First of all, Witness, please look at page 1. Can you see it

3 written there "brigade command, Borivoje Tesic, commander." Do you agree

4 with me that this is what it says?

5 A. Yes, I do.

6 Q. Please turn to page 2 now. We will dwell on this page for a

7 while. It is stated here: "Mixed artillery battery."

8 Please look at the numbers. Do you agree with me that the list of

9 names starts with number 45 and ends with number 85? Please turn to next

10 page.

11 A. Yes.

12 Q. According to this document, therefore, these are some 40-odd

13 persons here. Based on what you observed and experienced in the area

14 where you resided and in view of artillery and other attacks, can you tell

15 us whether the Serb infantry forces in the area had a very strong -- had a

16 very strong artillery support based on the developments?

17 A. Yes, they must have, certainly.

18 Q. During the attacks on the areas you described, were these mixed

19 artillery and infantry attacks or did one come before the other? Can you

20 explain.

21 A. First they started with mortar and artillery attacks, which would

22 then be followed by infantry.

23 Q. Please turn to the next page of the document where it says "mixed

24 armoured mechanised unit" listing persons from number 86 through to 142 on

25 the following page. According to this document, there were 66 persons in

1 all. Based on your experience from the area, did the infantry attacks

2 have the support of tanks and APCs?

3 A. Yes, they did.

4 Q. Please look at the following page. Persons under number 113

5 and 116. The person under number 113, Gordana Martic, and under 116,

6 Snezana Martic. Are these female names in our parts?

7 A. Yes, they are.

8 Q. Does this come to you as a surprise to see that there were women

9 in an armoured mechanised unit?

10 A. No, it does not come as a surprise because the two women who got

11 killed in Lolici were also riding in an APC.

12 Q. Can we clarify one matter. You say "two women who got killed in

13 Lolici," are you referring to the volunteers for which the document states

14 that they got killed in Sandici?

15 A. Yes, that's the document I have in mind.

16 Q. Could we please clarify for the Trial Chamber. Lolici formed part

17 of Sandici, don't they -- doesn't it?

18 A. Yes. In fact, one goes from Urkovici through Sandici to reach

19 Lolici.

20 Q. Thank you. Turn to page 01319752 where it says "air squadron" and

21 there's a list of names there. You've already confirmed this for us, but

22 I will ask you again. Did artillery and infantry attacks also have air

23 support, the ones against your territory?

24 A. Yes, they did.

25 Q. Several times in your evidence you said that you came under attack

1 from the Kravica area. Did those units during those attacks have air

2 support as far as you know?

3 A. Yes, they did have air support.

4 Q. Please turn to page 01319754. Can you find it?

5 A. Yes.

6 Q. It is stated "light" -- or rather, "128-millimetre light rocket

7 battery."

8 As far as you know the villages and hamlets of Konjevic Polje,

9 were they targeted by rocket launchers?

10 A. Yes, by the so-called VBRs, multiple rocket launchers.

11 Q. Please turn to the next page, 01319755, where it says "women

12 volunteers' platoon."

13 You already told us several things about women volunteers. Were

14 there any women volunteers and did you know of them in Bratunac?

15 A. Yes, I did.

16 Q. Please look at page 01319757. Do you agree that the document

17 says "1st Infantry Battalion." It says "command" and then "number 1."

18 A. Yes.

19 Q. I will not dwell much on the document, but please look at the last

20 page before the yellow Post-it, 728 Cirkovic Milivoje. Do you agree with

21 me? Could you turn to the last page before the Post-it numbered 2. Have

22 you found it?

23 A. Yes, number 728.

24 Q. Turn the page now where it is stated "list, 2nd Infantry

25 Battalion." Do you agree with me that this 2nd Infantry Battalion list

1 starts with number 1?

2 A. Yes.

3 Q. Please look at the previous page now. Do you agree with me that

4 it ends with number 420.

5 A. Yes.

6 JUDGE AGIUS: Here -- which page are you referring, the ERN

7 number? Because the previous page, according to me, ends with 728,

8 number 728, Cirkovic Milivoje. 9780 -- so it's not the previous page, so

9 it's a question of translation. 9780 -- the last page then. Yes, the

10 last page of this part of the document, namely the one at ERN 01319780.

11 Correct?

12 MS. VIDOVIC: [Interpretation] Yes, Your Honour. The last page of

13 this document or, rather, of the portion of the document which refers to

14 the 2nd Infantry Battalion ends just as you have described it now.

15 Q. Have you found the page 01319781, Witness, which is the next page,

16 where it is stated "3rd Infantry Battalion." I'd like to discuss this

17 now. You have stated on several occasions that this was the Kravica

18 Battalion. Please look at the name under number 1, Mile Milanovic,

19 commander major. Can you tell us again who that is?

20 A. That is the son of Sveto Milanovic from Kravica.

21 Q. Is that the same person who had been elected the president of the

22 SDS in Kravica in 1991?

23 A. Yes, that's the person.

24 Q. Please look at the name below that one, Jovan Nikolic, deputy

25 commander, is that the person you testified about?

1 A. Yes. That's Jovan Nikolic, aka Jole.

2 Q. Please look at the name under number 4, Nedjo Nikolic, did you

3 testify about that person as well?

4 A. Yes, that's Nedjo Nikolic, aka Djedura.

5 Q. Thank you. All these persons we have been mentioning now from the

6 command, are they all from Kravica?

7 A. Yes, they are all from Kravica.

8 Q. Please look at page 01319796. Look at the number which ends the

9 document, therefore page 01319796, and do you agree that this part of the

10 document ends with number 701 of the 3rd Infantry Battalion?

11 A. Yes.

12 Q. Thank you. Based on your experience on the ground and considering

13 the intensity of the attacks coming from the direction of Kravica, do you

14 find it probable that this battalion had around 700 men in the Kravica

15 area?

16 A. I think that it did have 700 fighters and more because there could

17 have been as many as 1.000 soldiers in the Kravica area.

18 Q. Please flip a few pages back, several pages back, and look at

19 page 01319792. Have you found the page?

20 A. Yes.

21 Q. In the top third of the document it says "volunteers." Can you

22 see that? Do you agree with me that it starts with number 528 and ends

23 with 565?

24 A. Yes.

25 Q. Does this document confirm what you were saying that there were

1 volunteers in the Kravica area?

2 A. Yes.

3 MS. VIDOVIC: [Interpretation] Your Honour, could we assign an

4 exhibit number to the document, please?

5 JUDGE AGIUS: Thank you, Madam Vidovic. This document, which

6 consists of pages in Serbo-Croat from 01319748 to 01319804, and therefore

7 57 pages, together with the corresponding translation thereof into English

8 is being tendered and marked as Defence Exhibit D933.

9 MS. VIDOVIC: [Interpretation] Your Honour, could we put D743 in

10 front of the witness, please. It is a Bratunac Brigade command document

11 dated 10 December 1992 to Drina Corps command signed -- or rather, the

12 name appearing is Borivoje Tesic. The document's number is 04363028.

13 Q. Witness, I will quote a part of the document: "The enemy was

14 quiet. No movements of units were observed.

15 "I have relocated part of the units to the Kravica area. I am

16 carrying out preparations according to your order."

17 The date of the document is the 10th of December, 1992. You

18 mentioned several times that you could see certain lines from the villages

19 of the area of Kravica.

20 During December 1992, did you notice that the Serbs brought new

21 fresh forces in that area?

22 A. Yes, I noticed that they strengthened certain positions amongst

23 those that I could see with the naked eye.

24 Q. Thank you.

25 MS. VIDOVIC: [Interpretation] I will kindly ask the usher to show

1 the witness another document. This is another Drina Corps command

2 document dated 20 December 1992, the number being 04358063, sent by the

3 Drina Corps command, urgent to the Bratunac Brigade for Lieutenant Colonel

4 Milan Milosevic.

5 I wanted to quote the third paragraph to save some time.

6 "Steer the Krajina Battalion in the Kravica direction" --

7 THE INTERPRETER: Interpreter's correction.

8 MS. VIDOVIC: [Interpretation] "You should agree for the 4th

9 Battalion to take over the positions currently held by the Krajina

10 Battalion. Steer the Krajina Battalion in the Kravica direction, and

11 Lieutenant Colonel Tesic will work out the details of its engagement. He

12 will take care of Kravica for the time being so that you can focus on

13 preparing the defence of Bratunac."

14 Q. Witness, my question to you is: Did you know or hear of the

15 Krajina Battalion in the area of Kravica being active?

16 A. Yes, I did hear of it.

17 Q. You told us that you were under the impression, although you've

18 seen the document with about 700 names for the Kravica Battalion, you said

19 that in your estimate there may have been up to 1.000. Did you have any

20 knowledge as to the existence of units from elsewhere to come to the area

21 of Kravica in December 1992?

22 A. Yes, we had certain knowledge. During their attacks, some of

23 their fighters were left behind and we found IDs on them and we knew that

24 they were from elsewhere.

25 Q. Thank you for your clarification, Witness.

1 MS. VIDOVIC: [Interpretation] Your Honour, could we assign an

2 exhibit number to this document, please?

3 JUDGE AGIUS: Yes. This document, Ms. Vidovic, which consists of

4 two pages, one in B/C/S, one in English, with ERN 04358063 is being

5 assigned Defence Exhibit Number D934.

6 MS. VIDOVIC: [Interpretation] I believe we need to clarify

7 something for the record.

8 Q. It states here that their fighters were left behind. The way I

9 understood was that some of their fighters were killed and then you would

10 find some documents on their bodies.

11 A. Yes. They would be killed and they didn't succeed in pulling

12 them out, hence we found the documents and we had proof.

13 Q. Thank you.

14 MS. VIDOVIC: [Interpretation] Your Honour, could we show another

15 document to the witness, please. It is a Bratunac Brigade command

16 document dated 12 December 1992, the number being 04363033 to Drina Corps

17 command.

18 Your Honours, I would kindly ask that we return to private

19 session, please.

20 JUDGE AGIUS: So let's go into private session for a short while.

21 Thank you.

22 [Private session]

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16 [Open session]

17 And this document consisting of two pages, one in B/C/S, one in

18 English, with ERN 04 - this looks to be - 363033 is being tendered and

19 marked as Defence Exhibit D935.

20 MS. VIDOVIC: [Interpretation] Your Honour, could the witness

21 please have a look at D308. These are changes and amendments to the

22 director of the Main Staff of the Army of Republika Srpska dated

23 7 December 1992. The name of General Ratko Mladic appears.

24 Q. Witness, the relevant portion I wanted you to see is to be found

25 on page 00876292.

1 MS. VIDOVIC: [Interpretation] Your Honours, in English that is

2 page 2. I wanted to quote, that is item 2: "Regardless of the previously

3 determined stages from the directive number 4 of the Corps command, they

4 must execute the following tasks in their areas of responsibility by

5 December 13, 1992:

6 "Keep the existing front line positions; liberate Orasje, Trnovo,

7 Konjevic Polje, Cerska, and Teocak."

8 Witness, this document is dated December 7, 1992. You have

9 discussed December of 1992 previously. Can you remember whether after

10 this date, that is the 7th of December, the area where you lived came

11 under even fiercer attacks.

12 A. Yes, we were under attack every day.

13 Q. Did you have any knowledge as to whether the same thing was

14 happening in the area of Mount Glogova and Cizmici?

15 A. At Glogova and Cizmici one could hear strong explosions,

16 detonations, and we were able to observe that, or rather, to hear them

17 quite well.

18 Q. Thank you.

19 MS. VIDOVIC: [Interpretation] We have finished with this document.

20 I would kindly ask that another document be put in front of the witness.

21 And I will conclude with this for today, Your Honour.

22 Could you please give the witness a Bratunac Brigade command

23 document sent to the Drina Corps command, attention commander, the number

24 being 04359301.

25 Q. Witness, I wanted to quote this short document to you. It

1 states -- so the date is January 5, 1993.

2 It states: "Given the forthcoming tasks" -- can you see it,

3 Witness?

4 A. Yes.

5 Q. "Given the forthcoming tasks in the responsibility area of the

6 Corps:

7 "Cleansing of Konjevic Polje and Cerska.

8 "Occupying the front line in front of Bratunac: The village of

9 Jezestica, the village of Pale, Bijela Stijena, Caus, Sase mine, Loznik,

10 the village of Osmace, the village of Medje, the Drina river.

11 "It is necessary that the special brigade stay in the area in

12 responsibility of the Bratunac Brigade in order to execute these tasks.

13 This is why you are to send a request to the RS army Main Staff (General

14 Milovanovic), commander of the East Bosnian Corps."

15 Can you see that the document is dated the 5th of January, 1993,

16 and that it mentions the forthcoming tasks of cleansing of Konjevic Polje

17 and Cerska? Can you see that there?

18 A. Yes, I can.

19 Q. At the beginning of 1993 or, to be more precise, around the 5th of

20 January of that year, in that area were you aware of the planning for the

21 cleansing of the area?

22 A. I mentioned on several occasions - and I can reiterate - one could

23 see it all with the naked eye. They didn't try to hide because they had

24 nothing to fear. We couldn't target them.

25 Q. What is it that you saw exactly?

1 A. We saw infantry columns moving alongside their houses. We could

2 see tanks, APCs next to Milo Milanovic's house. We could see a Howitzer

3 and an anti-aircraft gun at Siljkovici. And above Gornja Brana one could

4 also see a Howitzer. And at Banjevici there was an anti-aircraft gun and

5 a mortar.

6 Q. Did the pressure of the Serb forces increase in particular on the

7 5th of January, 1993?

8 A. Each day was a difficult one, but that one must have been more so.

9 Q. Did you know the existence of this special Serb brigade in the

10 area? Have you -- did you hear of it at the time?

11 A. We heard that there were some special brigades, but we didn't know

12 specific as to what they were.

13 Q. Did you hear of any particular name or a nickname in relation to

14 that special brigade?

15 A. Not at this moment, I can't remember.

16 Q. Thank you, Witness.

17 MS. VIDOVIC: [Interpretation] Your Honour, could we assign an

18 exhibit number to this document, please?

19 JUDGE AGIUS: Yes. This document will be given Defence Exhibit

20 Number D936. It consists of two pages, one in Serbo-Croat, one in

21 English, the ERN 04359301.

22 And I think we can stop here for today because it's time up. We

23 will continue tomorrow morning. We are sitting -- you know that we

24 changed the sitting to the morning tomorrow. All right? We'll be

25 sitting tomorrow morning at 9.00. I thank you so much.

1 I take it from what I can guess you'll finish in about an hour

2 tomorrow, something like that, no? First session?

3 MS. VIDOVIC: [Interpretation] Yes, Your Honour.

4 JUDGE AGIUS: And how much time do you think you require?

5 MS. SELLERS: Your Honour, at this point I think the Prosecution

6 must reserve the right to take 100 per cent of the time that had been

7 previously allocated for this witness.

8 JUDGE AGIUS: All right.

9 Let's meet tomorrow morning at 9.00. Thank you.

10 Same recommendation as yesterday, Witness. You're not to

11 communicate with anyone on the subject matter of your testimony or the

12 events that you are testifying about in any case. Thank you.

13 --- Whereupon the hearing adjourned at 1.46 p.m.,

14 to be reconvened on Thursday, the 24th day of

15 November, 2005, at 9.00 a.m.

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