Tribunal Criminal Tribunal for the Former Yugoslavia

Page 992

 1                          Tuesday, 2 May 2006

 2                          [Open session]

 3                          [The accused entered court]

 4                          --- Upon commencing at 2.25 p.m.

 5            JUDGE ANTONETTI: [Interpretation] Mr. Registrar, will you please

 6    call the case.

 7            THE REGISTRAR:  [Interpretation] Thank you, Your Honours.

 8    IT-04-74-T, Prlic et al. versus the Prosecutor.

 9            JUDGE ANTONETTI: [Interpretation] Thank you.  Can I have the

10    appearances, starting with the Prosecution.

11            MR. MUNDIS:  Thank you, Mr. President.  Good afternoon, Your

12    Honours, counsel, and everyone in and around the courtroom.  For the

13    Prosecution, Daryl Mundis, Ken Scott, Vassily Poryvaev, and our case

14    manager Skye Winner.

15            JUDGE ANTONETTI: [Interpretation] Thank you.  I'm now turning to

16    the Defence counsel.  For the record, can you please introduce yourselves.

17            MR. KARNAVAS:  Good afternoon, Mr. President, Your Honours.

18    Michael Karnavas, counsel for Jadranko Prlic, along with Suzana Tomanovic,

19    co-counsel, and Ana Vlahovic, our legal assistant.

20            MS. NOZICA: [Interpretation] Good afternoon, Your Honour.

21    Mr. Bruno Stojic is represented by myself, Senka Nozica, and our case

22    manager Mr. Slonje Valent.

23            MR. KOVACIC:  Good afternoon, Your Honours.  For accused

24    Mr. Slobodan Praljak, counsel Bozidar Kovacic, co-counsel Mrs. Pinter,

25    Nika Pinter, and our case manager Valentina Ivic.  Thank you, sir.

Page 993

 1            MS. ALABURIC: [Interpretation] Good afternoon, Your Honours.

 2    Vesna Alaburic, Defence counsel for Milivoj Petkovic.  My case manager,

 3    Mr. Davor Lazic, is accompanying me today.

 4            MR. JONJIC: [Interpretation] Good afternoon, Your Honours.  I am

 5    Tomislav Jonjic, appointed Defence counsel for Mr. Coric.  Next to me is

 6    Krystyna Grinberg, legal advisor.

 7            MR. IBRISIMOVIC: [Interpretation] Good afternoon, Your Honours.

 8    For the Defence of Mr. Pusic, Roger Sahota, Fahrudin Ibrisimovic, and case

 9    manager Nermin Mulalic.

10            JUDGE ANTONETTI: [Interpretation] On behalf of the Trial Chamber,

11    let me greet everybody after this long weekend; the accused, the Defence

12    counsel, and the Prosecution representatives, not to forget all the people

13    who support our work today.

14            We are going to start our hearing with a first witness, but before

15    the witness is brought in, let me give you a few explanations in

16    housekeeping matters.

17            As you know, the Trial Chamber issued a ruling on guidelines for

18    the conduct of the trial on the 18th of April, 2006.  We had received on a

19    CD-ROM a chart from the Prosecution that failed to meet the requirements

20    of the order of the 30th of November 2005.  The amended decision of 18th

21    of April is a reminder of the previous order of the 30th of November,

22    2005, requesting the Prosecution to present a chart, an amended chart, by

23    the 4th of September, 2006.  In other words, the Prosecution will have had

24    nearly a year to prepare the chart, the proofing chart.  So I don't want

25    to hear the Prosecution say on the 4th of September that they did not have

Page 994

 1    time enough to prepare the chart.  You've got another several months ahead

 2    of you to complete the chart, so that, faithful to the principle of

 3    equality of arms, the Defence and the Judges can have a document making it

 4    possible to crossmatch witnesses and exhibits with specific references to

 5    Article 7(1) and Article 7(3).  I'm sure you will do this very well.  What

 6    I say for the Prosecution will of course in due course apply to the

 7    Defence.  They will be under the same obligation.

 8            Second housekeeping matter:  As you know, in the next few days, on

 9    Tuesdays and Wednesdays we will have sitting hours until 4.00 in the

10    afternoon.  But I have been told that witnesses need to have a bite and

11    that they need at least one hour to do so, to have lunch.  Otherwise, the

12    witness may feel weak during the hearing, and he needs to be able to

13    restore himself, and he needs an hour to do so.  So this is going to be

14    our schedule for the two long days in the week:  Starting at 9.00, we will

15    work from 9.00 to 10.30.  We'll have a 20-minute break until ten to

16    eleven.  We'll resume at ten to eleven until twenty past twelve.  Then we

17    are going to have a lunch break for the witness from twenty past twelve to

18    1.20.  For the witness and all those who want to eat something, of course.

19    We will start again at twenty past one until ten to three with a break

20    until ten past three, and we shall work from then until twenty to five for

21    the two long days.

22            I also wanted to tell you that, together with the Registry, I

23    looked into the matter of a large screen in this courtroom.  It might be

24    possible to have large screen connected directly to the court deputy, and

25    if you want to see a video excerpt or a see a large document, it will be

Page 995

 1    possible to see it on the large screen.  But there was a technical matter

 2    to be settled.  If the Defence or the Prosecution want to zoom in on the

 3    document, can they do so directly or does it have to go through the court

 4    deputy?  Because you know that normally it will be the court deputy who

 5    will do all the processing of a document.

 6            Well, if you are interested in this, please meet with the court

 7    deputy, Mr. Frejabue, and he will demonstrate to you how the system works.

 8      I've seen it personally and I think it might be useful for our work.

 9            I am the Presiding Judge, and as such under the Statute it is my

10    onus to make sure that the proceedings unfold smoothly.  This is the

11    reason why I looked into this matter.

12            For a few minutes, I would like to deal with a topic in private

13    session.  It's not going to be long.  Please, Mr. Court Deputy, let us

14    move into private session.

15                          [Private session]

16  (redacted)

17  (redacted)

18  (redacted)

19  (redacted)

20  (redacted)

21  (redacted)

22  (redacted)

23  (redacted)

24  (redacted)

25  (redacted)

Page 996

1  (redacted)

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 3  (redacted)

 4  (redacted)

 5  (redacted)

 6                          [Open session]

 7            THE REGISTRAR: [Interpretation] We are in open session, Mr.

 8    President.

 9            JUDGE ANTONETTI: [Interpretation] A witness is due to come in.

10    He's going to be brought in.  I'll have him to make the solemn

11    declaration, after which he will be examined by the Prosecution.  I hope

12    that the Defence counsel have agreed among themselves for the

13    cross-examination of the witness.

14                          [The witness entered court]

15                          WITNESS:  SPOMENKA DRLJEVIC

16                          [Witness answered through interpreter]

17            JUDGE ANTONETTI: [Interpretation] Good afternoon, madam.  I want

18    to first make sure that you can hear what I say in your own language

19    through the headphones.  If it is so, say, "Yes, I can hear you, and I

20    understand you."

21            THE WITNESS: [Interpretation] I hear you, and I can understand

22    you.

23            JUDGE ANTONETTI: [Interpretation] Very well, madam.  Before you

24    make the solemn declaration, can you give me your name, first name, and

25    date of birth.

Page 997

 1            THE WITNESS: [Interpretation] My name is Spomenka Drljevic.  I was

 2    born on the 1st of July, 1954, in Mostar.

 3            JUDGE ANTONETTI: [Interpretation] In which town do you live today?

 4            THE WITNESS: [Interpretation] I reside in Mostar.

 5            JUDGE ANTONETTI: [Interpretation] Do you have a job or not?

 6            THE WITNESS: [Interpretation] I used to work at the Ministry of

 7    Defence, and I'm currently an official -- I'm currently a retiree.

 8            JUDGE ANTONETTI: [Interpretation] Very well, madam.  Please read

 9    the solemn declaration given to you by the usher.

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

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

12            JUDGE ANTONETTI: [Interpretation] Thank you very much, madam.

13    Please sit down.

14            Before I give the floor to the Prosecutor, who is going to put

15    questions to you, let me give you some information on the way your

16    testimony is going to take place.  You should be testifying today and part

17    of tomorrow.  You will first be examined by the Prosecutor, sitting on

18    your right.  Thereafter, the Defence counsel, who are on your left,

19    through one or several of them, will cross-examine you and put questions

20    to you.

21            You have Judges in front of you.  At any time, whenever they deem

22    it appropriate, they can put questions to you if they feel the need to do

23    so.

24            If you should ever have a problem whatsoever, do not hesitate to

25    let us know.

Page 998

 1            I remind you that you made an oath to tell the whole truth and

 2    that, because of the solemn declaration, you're bound to tell the truth

 3    and not to tell lies, because a lie can be regarded as a crime to be

 4    prosecuted by this Tribunal.

 5            This is the general framework for your testimony.

 6            And I give the floor to the Prosecutor, I believe Mr. Mundis,

 7    since he's sitting in the front row and he has just had a cup of water, so

 8    he now can ask his questions of you.

 9            MR. MUNDIS:  Thank you, Mr. President.

10                          Examination by Mr. Mundis:

11       Q.   Good afternoon, Ms. Drljevic.

12       A.   Good afternoon.

13       Q.   Ma'am, I'm going to start by asking you some questions and I'd

14    like to draw your attention to the period 1990, 1991.  Can you please tell

15    the Trial Chamber in what town you were living in 1990, 1991.

16       A.   From birth I have lived in Mostar.  I still live there.  Also, in

17    relation to the period you asked me about, I also lived in Mostar then.

18    At the time I used to work as a representative of a company from the town

19    of Ploce.  I worked in that capacity until the 31st of December, 1991.

20       Q.   Would you please tell the Trial Chamber what happened on the 31st

21    of December, 1991, with respect to your employment with this company.

22       A.   In late March, early April, 1992, I received a dismissal letter

23    which was retroactive, and I had no right to appeal.  They also offered me

24    to work as an exclusive representative of this company.  The company is

25    called Kartonplast, from the town of Ploce.  It wasn't until two years ago

Page 999

 1    that I found out that there is an association, which I joined in Jelah.  I

 2    learned that there was a decision of the Croatian government from that

 3    period of time stating that all of those who do not have a place of

 4    residence in the Republic of Croatia are to be fired.  The members of this

 5    association that I was in contact with, and also in some TV programmes, I

 6    heard that there were about 100.000 mostly Bosniaks and Serbs in a similar

 7    situation; people who were fired during that period of time.

 8            This association that I joined currently has about 10.000 members.

 9       Q.   Ma'am, when you told us that you received in late March or early

10    April, 1992, a dismissal letter, what was the -- what was the stated

11    reason in that dismissal letter for you losing your job?

12       A.   They stated as a reason lack to fulfil my duties for a number of

13    months.  Or, rather, they said that there was a lower demand which --

14    sales demand, which lasted for a number of months.  At the time, the

15    situation was not a stable one, either in Croatia or in Bosnia, so I took

16    it as something that was inevitable.  At any rate, this is something that

17    I will deal with in the future, together with lawyers from Zagreb and this

18    company in view of the fact that there are a number of contradictory

19    issues there.

20            The decision on employment, at least according to the then laws of

21    Yugoslavia, specified that there was a probation period which could exist

22    only when one was just starting to work, which was not my case.  There was

23    no reason to fire me at the time when I worked for them, and I interpreted

24    this dismissal as something that was caused by the existing situation in

25    the then Yugoslavia, and especially in Bosnia.

Page 1000

 1       Q.   Ma'am, can you elaborate or be more specific when you say "the

 2    existing situation in the then Yugoslavia, and especially in Bosnia."

 3    What do you mean by that?

 4       A.   What I have in mind is this period of time, mostly 1991, because

 5    the war was well underway in Croatia at the time.  The town of Ploce was

 6    shelled.  This is a port in Croatia where my company was headquartered.

 7    We had telephone contact with them.  However, in late 1991, it was already

 8    somewhat dangerous to travel through Bosnia, especially to some areas.  So

 9    that was the main reason.

10            In addition to that, people refrained from signing contracts and

11    entering new deals.  So that was the reality that we lived in.  There was

12    little work.  However, Croats were not dismissed and other people were.

13       Q.   Following your dismissal from this company, Ms. Drljevic, can you

14    tell us where you were next employed, and approximately when.

15       A.   Well, I didn't get employment in Mostar.  We could say that the

16    war broke out already in September of 1991 when reservists came to town.

17    I think that it was on the 19th of September.  However, there were no

18    specific clashes.  More provocation, intolerance.  Serb soldiers were

19    passing through, a lot of people were getting drunk.  And this lasted up

20    until the 3rd of April, 1992, when a truck carrying fuel exploded in the

21    northern camp, and this is when the war broke out in town.

22            There was occasional firing during night, also shelling.  Then

23    that started happening during daytime as well.  And in April of 1992, I

24    took four children of my sister to my friends in Kastela.  This is an area

25    comprising five or six small settlements near Split.  I stayed there for

Page 1001

 1    about 15, 20 days, until my sister arrived -- or, rather, she came to

 2    visit the children, and I used that opportunity to go back to Mostar.  And

 3    this is where I saw a terrible sight; destruction, shelling.

 4            In addition to that, I also learned that her father had remained

 5    on the left bank.  Later on, I heard that he was taken to a Chetnik camp

 6    in Bileca.

 7       Q.   Let me interrupt you there, ma'am.  When you say "the left bank,"

 8    what exactly are you referring to and what is the significance of the left

 9    bank?

10       A.   When I say "the left bank," I have in mind the left bank of the

11    Neretva River.  Before the war, it was mostly populated by Bosniak and

12    Serb residents.

13       Q.   And what about -- what about the right bank of the Neretva River?

14       A.   The right bank of the Neretva River, yes, the western portion of

15    the town, had more of a mixed population.  I think that Croats were the

16    dominant group in terms of numbers, although a lot of Bosniaks and Serbs

17    also had apartments in Western Mostar, or, rather, on the right bank of

18    the Neretva.

19       Q.   Let me take your attention, ma'am, to that period in April or May,

20    1992, when you returned to Mostar.  After your return, did you gain any

21    form of employment?

22       A.   It was absurd to even think of looking for new employment.  I

23    started searching for my father, and I found some young man who lived in

24    the part of the town where I was born.  It was the street called Husinjske

25    Bune.  And thus I decided to join this unit.  At the time it was still a

Page 1002

 1    company, not yet a battalion.  And those were mostly young men from this

 2    area and then from another building in Jankovci.

 3            At the time, I learned that several days before the 1st of May the

 4    Party of Democratic Action, which at the time was a leading Bosniak

 5    political party, had signed an agreement with the Croatian Democratic

 6    Union about the HVO being an armed formation which was going to defend

 7    Mostar.  However, at the same time an Independent Mostar Battalion was

 8    also established.  I don't know whether that was May or June, 1992.  I'm

 9    not sure.

10       Q.   Ms. Drljevic, when you mentioned the Independent Mostar Battalion,

11    was that in fact the unit of the army that you joined?

12       A.   Yes.

13       Q.   And can you tell us, please, where that unit, the Mostar

14    Independent Battalion, was headquartered.

15       A.   This is how it was:  The Independent Mostar Battalion was located

16    in various sites, depending on which company.  I think that in May and

17    June -- yes, May and June, there existed a Joint Command in the Vranica

18    building.  It was in Stjepan Radica Street.

19       Q.   Ma'am, when you say May and June, can you tell us what year that

20    was, please.

21       A.   1992.  I apologise.

22       Q.   And again when you indicate to us, ma'am, that it was a Joint

23    Command, can you tell us what were the components of this Joint Command?

24       A.   I really can't say.  I can't answer that.  I know that the

25    battalion was composed of companies, and the first commander of the

Page 1003

 1    battalion was Suad Cupina.  Later on, it was Semso Hasic, and for a time

 2    Arif Pasalic until the brigade was formed in July, 1992.

 3       Q.   You mentioned a few moments ago the HVO being an armed formation

 4    which was going to defend Mostar.  Was the unit that you joined, that is

 5    the unit that you were a member of, was that part of the HVO?

 6       A.   Well, at that time I think it was, in view of the fact that on the

 7    letterhead you had both the chequerboard and the lily signs, emblems.  But

 8    to tell you the truth, this wasn't something that I focused on at the

 9    time.  What was important for me was that I was there to help the unit

10    out.

11       Q.   And, Ms. Drljevic, what was your specific role within the unit?

12       A.   Specifically from the very beginning, I was mostly there to be

13    there.  To clean up, to make coffee, to make some sandwiches in view of

14    the fact that in May, 1992, the young guys moved to Goranci, which is a

15    hill above Mostar.  And I would go there every day, report for duty.  I

16    would make lists of those who volunteered, until the 3rd or 6th of June

17    when a shell fell and hit the window of Lesnina.  There was nobody in the

18    basement, so there were no casualties, just some damage at the entrance

19    across the way.

20            We would see this in other locations because the unit that I

21    belonged to or, rather, the company that I belonged to did not have a set

22    place allocated to it until a little before they moved to the left bank,

23    which means about ten days.

24       Q.   And, ma'am, when you say "they moved to the left bank," to whom

25    are you referring?

Page 1004

 1       A.   I meant my own unit, first of all.  Members of the Luka Company in

 2    the Independent Battalion.  But the crossing of the Neretva River was

 3    organised, and the members of the Independent Battalion took part in it

 4    and organised it, as well as the Croatian Defence Council, and it was

 5    crossing the Neretva River during the night, and they had to force various

 6    positions.  From Rastani and the position of the Marsala bridge, or Tito's

 7    bridge, and further to the south near the Hasan Brkic bridge, in fact, and

 8    that took place between the 14th and 16th of June, 1992.

 9       Q.   And where did your company move to on the left bank?  What

10    location did you actually move to?

11       A.   Well, during those first few days, I did not go there.  I arrived

12    there around the 20th of June.  First of all, we were put up in a private

13    house which was a bakery, served as a bakery as well, in Marsal Tito

14    Street, halfway between Lucki bridge and Saric mosque.

15       Q.   Moving on, Ms. Drljevic, to July, 1992:  Where was your unit at

16    that point in time headquartered?

17       A.   Well, my unit already in July -- the 1st Mostar Brigade was

18    established, and its headquarters were in Vranica.  As to my battalion,

19    together with some additional units attached to the staff, it was in the

20    South Camp barracks.  The battalion commander was Midhat Hujdur.  He was

21    appointed.  When I reported to the unit for the first time he was the

22    deputy of Enver Salcin who was the first commander of the Luka Company.

23            During June, while they were advancing, while the units of the

24    Luka Company, Donja Mahala, and so on, as they were advancing towards the

25    Chetniks or, rather, the Chetniks were fleeing in part, leaving behind

Page 1005

 1    artillery weapons, artillery pieces, which were brought down to the

 2    streets and then collected up on the right bank of the Neretva River, or

 3    in North Camp, which is where the OH -- O -- HVO was located.

 4       Q.   At this point in time, Ms. Drljevic, that is the summer of 1992,

 5    your unit, which was a part of the 1st Mostar Brigade, and the HVO were

 6    engaged in fighting against the Serbs; is that correct?

 7       A.   Yes, that is correct.  But already on the 9th of July, when there

 8    was large-scale shelling, and I think that there were aeroplanes as well

 9    that were firing, that the HVO units withdrew.  I did not take part in

10    that, I just heard about it from my commanders.

11            This was also happening along the Chetnik lines further in-depth

12    towards Cobanovo Polje, so that when we would take up our shifts a part of

13    the territory would have been lost.  But I don't think that I am the right

14    person and competent enough to speak about this strictly military aspect.

15    I'm sure you have better witnesses at your disposal who will be better

16    able to tell you about that.

17       Q.   Ms. Drljevic, can you tell the Trial Chamber in general terms the

18    ethnic composition of the 1st Mostar Brigade.

19       A.   During that period of time, the 1st Mostar Brigade was

20    multi-ethnic, but mostly it was made up of the Bosniaks.  Then you had a

21    certain number of Serbs who stayed on in town and didn't leave with the

22    Chetniks, and there were also some Croats who - how shall I put it? -

23    found themselves in those districts and were -- and joined the units that

24    were there.  When I speak about and refer to Mahala, I mean the old parts

25    of town, the old districts of town.

Page 1006

 1       Q.   Can you tell us about --

 2       A.   Yes, I'm sorry.

 3       Q.   Can you please tell us about any changes in the structure of your

 4    brigade towards the end of 1992.

 5       A.   I'm sorry, I didn't understand your question.  What were you

 6    referring to?  At the end of 1992 there were a number of brigades that

 7    were established and formed a corps.

 8       Q.   That's precisely what I'm referring to, ma'am.  Can you tell us a

 9    little bit about the establishment of the corps in late 1992.

10       A.   I think that that was the policy coming from Sarajevo, and also

11    the number of people who joined up with the units increased, in view of

12    the fact that in 1992, exclusively under the command of the HVO, you had a

13    unit of the Ministry of Defence that was active.  So that people who were

14    included in the army units were not included through the Defence Ministry

15    but were included and joined up on an exclusively voluntary basis.

16            As the number of units increased, there were many people who came

17    in, who were expelled from Nevesinje, and they set up the Nevesinje

18    Battalion.  Then from Gacko as well.  There were many people who arrived

19    from there and from Bileca camp.  They arrived in August, 1992.  When the

20    Gacko Battalion was set up - it was called Sargan - I can't tell you the

21    exact figures, the numbers, but a certain number of people from Stolac as

22    well who did not want to join the HVO in Stolac came to South Camp and set

23    up the Bregava Brigade.  I think that was in August or September, 1992.

24    And then there was the Independent Battalion of Dreznica, a company in

25    Blagaj, a brigade in Jablanica, and then there was the battalion in

Page 1007

 1    Buturovic Polje and the brigade in Konjic.  So that an order arrived, I

 2    think on the 15th or the 17th of November, 1992, about the formation of

 3    the 4th Corps of the army of the Republic of Bosnia Herzegovina, and that

 4    was to be led by the man who was appointed, the late Arif Pasalic.  And

 5    the commander of the 1st Mostar Brigade was - and he's also dead now -

 6    Midhad Hujdur, Hujka.  I don't think I need give you the names of the

 7    other commanders.

 8       Q.   Just so that we're clear, then, Ms. Drljevic, what you're telling

 9    us is that by the middle of November, 1992, a corps, the 4th Corps, of the

10    ABiH was formed in Mostar that included all of these brigades and units

11    that you've just mentioned.  Would that be a fair summary of what you've

12    just told us?

13       A.   Yes.

14       Q.   What -- at the time the 4th Corps was established in mid-November,

15    1992, what was the relationship between the 4th Corps and HVO units in and

16    around Mostar?

17       A.   Well, it was quite proper.  I can say that.  Well, I omitted to

18    state beforehand that in the units of the Croatian Defence Council there

19    were also many Bosniaks organised within it since the HVO had far more

20    weaponry.

21       Q.   Can you tell --

22       A.   But I think that already at that time there were misunderstandings

23    over weapons.  Contingents -- a contingent was supposed to reach the 4th

24    Corps.  But I have to say that I learnt about this only indirectly, quite

25    by chance.  I happened to hear about it quite by chance.  So I would ask a

Page 1008

 1    question here or there.  And I don't know whether it was September or

 2    exactly what month it was, perhaps October, when a truck was supposed to

 3    arrive in Mostar with weapons, but it didn't.  And I know that there was

 4    some negotiations in Goranci and I think that was the only time -- the

 5    only truck that passed through to South Camp in Vranica.  Well, I don't

 6    really know.  I don't know what channels weapons arrived through.  There

 7    were people who were in charge of that kind of thing.  It was their

 8    wartime assignment and their duties, and that was the description of their

 9    job.  That was the kind of work they did.

10            So at one point in time there was some mention of the fact that a

11    certain commander in Bijelo Polje, Andric, Car Andric, had stopped a large

12    convoy.  And Mira Cupina was in charge of that convoy.  And it was a sum

13    of 800.000 German marks was rumoured, was bandied about, but I don't

14    really know.  I didn't see any documents to that effect.

15       Q.   Let me ask you, ma'am, if you can tell us about the evolving

16    nature of the relationship between the 4th Corps of the ABiH and the HVO

17    at the end of 1992 into the beginning of 1993.

18       A.   At the end of 1992 and the beginning of 1993, there was a

19    characteristic situation -- well, can I go back a bit in time, please,

20    back to 1992?

21            In October, 1992, it was rumoured that HVO units had attacked

22    Prozor, and during that period Hujdur and Pasalic -- I'll refer to them by

23    their full names.  Pasalic, that's the surname of the corps commander.

24    That they went to Prozor to see what the situation was like down there.

25    But I think that they kept it rather a secret.  We didn't know what it was

Page 1009

 1    all about.

 2            During that period, a number of volunteers reported, and they were

 3    led by Suad Muharemovic, who is a colonel now.  They wanted to go and

 4    reinforce the troops liberating Jajce.  However, they were sent back from

 5    some villages around Vakuf.  And the explanation given was that the HVO

 6    and the army was already at war there, fighting there.

 7            In November, 1992, in an operation called Bura, the HVO took part

 8    only with artillery weapons from Hum hill, while the army units, BH army

 9    units, unfortunately, unsuccessfully attempted to attack Podvelezje.

10             In December, 1992, the army units went to Mount Igman as

11    reinforcements, but they did not -- members of the HVO did not take part

12    in that particular operation.

13       Q.   If I could, ma'am, let me interrupt you there.  When you talk

14    about this operation called Brua, or Bura, in November, 1992, you said the

15    HVO took part only with artillery weapons from Hum.  Against what force

16    was that operation directed?

17       A.   That was an operation against the Chetnik forces which were

18    located in Podvelezje, the relay station there, and throughout Podvelezje,

19    that is to say the hill behind Mostar, on the mountain behind Mostar, to

20    the east or, rather, on the left bank of the Neretva River.

21       Q.   Let me again ask if you could describe for us the relationship

22    between the 4th Corps of the ABiH and the HVO in early 1993.

23       A.   Already, before, you could feel sporadic tension.  And truth to

24    tell, I personally can't say that I felt it myself; I heard about it from

25    others.  But in January, 1993, specifically, when the HVO issued an order

Page 1010

 1    according to which all the units should be resubordinated, that all units

 2    of the BH army should be resubordinated to HVO units and that the HVO was

 3    the sole legitimate authority in the area, especially in the Mostar

 4    region, then my commanders started to express their dissatisfaction, and I

 5    think that they expressed the will of most of the people who were in the

 6    unit.  But at any rate, they were better versed in politics and the

 7    negotiations taking place with -- between the HDZ and SDA.  And later on,

 8    there was a division in that party over that resubordination.

 9            In January, I was still in South Camp, and forms came to be filled

10    in by the ITMS [as interpreted] people for material and technical

11    equipment, forms relating to material and technical equipment.  And there

12    was an outcry against this.  And there was an order whereby two remaining

13    satellite antennae within the telecom factory, pursuant to an order by the

14    corps commander, Pasalic, were handed over to the HVO.  I think that later

15    on these were used for the communications centre or the PTT links and

16    communication lines.

17       Q.   For the record -- sorry to interrupt, ma'am, but for the record,

18    can you tell us what ITMS refers to?

19       A.   It's not ITMS.  It's without the I.  MTS; material technical

20    resources.  MTS.

21       Q.   At this point in time, that is January of 1993, what military

22    force or forces controlled access to the city of Mostar in terms of the

23    roads and other routes leading in and out of the city of Mostar?

24       A.   Towards Western Herzegovina and Croatia, all the approach roads

25    and exits were controlled by the HVO.  Even the civilians who were leaving

Page 1011

 1    town had to have HVO permits in order to be able to do so, exit permits.

 2            Up until a certain point in time, I can't tell you what exactly,

 3    and for all members leaving town, they could put in a request from the

 4    army.  You couldn't leave town without an HVO permit.

 5       Q.   What about -- what about the roads to the north, the road from

 6    Mostar to Jablanica?  In January, 1993, who controlled access along that

 7    road?

 8       A.   Well, that road to Jablanica as also controlled by the HVO

 9    battalion from Bijelo Polje.  That was the northern part, above Mostar to

10    the north.  Also to the south, towards Buna, it was also controlled by the

11    HVO.

12            For the requirements -- or, rather, for moving round town -- or,

13    rather, you could move around town if you had permits allowing you to do

14    so during curfew hours.  The army of the Republic of Bosnia-Herzegovina.

15    But as of January, 1993, those permits issued by the army were no longer

16    in force.  The police patrols didn't recognise them.  Because I have to

17    explain that there were people who had duties to attend to during the

18    night.  They had to tour the units, for example, or perhaps something

19    else.

20            In January, 1993, all exit and entrance points into Mostar were

21    controlled by the HVO, and there were confiscations of certain quantities

22    of goods being carried, or trucks.

23       Q.   Can you -- Ms. Drljevic, can you explain what you mean by

24    "confiscations of certain quantities of goods" carried by trucks?  What

25    type of confiscations?  What type of goods?  Who was doing the

Page 1012

 1    confiscating?

 2       A.   This is only hearsay, but in the South Camp barracks, they had

 3    accommodation for the troops, but unfortunately, civilians would turn up

 4    there at the time too.  And there was a truck driver who was there on one

 5    occasion, and that Buna in Ortijes - Buna is a place south of Mostar, and

 6    Ortijes is the location of an airport - but there is an air bridge in the

 7    vicinity, and the trucks used this bridge to go to the Suka factory

 8    [phoen] complex on the right bank of the Neretva River and to the south of

 9    Mostar.

10            These were people from Bosnia who would spend a night or two

11    there, and then sometimes people from the command would intervene, but on

12    the whole we would send them to the HVO headquarters.  We did this

13    ourselves, because the HVO represented both the civilian and military

14    authorities at the time.  It was not possible to distinguish between

15    certain fields of competence at the time.

16       Q.   Can you tell us, Ms. Drljevic, about the presence of HVO military

17    forces within the city of Mostar in the period April, early May, 1993.

18       A.   With regard to this order issued in January, 1993, the Bosniak

19    side didn't accept the proposals.  A deadline had been set, which was the

20    15th of April.  By that time, the order was supposed to be executed.  I

21    think that during that period of time there was fighting in Jablanica.  I

22    know that the commander of the corps and Budakovic, his deputy, went to --

23    went to Jablanica in April.  On the 16th and the 17th of April an attack

24    was launched or there was an attempted attack on the Mostar Hotel, which

25    is where the 4th Company and the command of the 2nd Battalion were

Page 1013

 1    located.  There was an attack on Vranica, which is where the brigade

 2    command was located as well.

 3            On that occasion, two young men were wounded.  They were guards.

 4    Their names were Crno Merovic and Kljako.  Crnomerovic.  Crnomerovic.

 5    It's one name; Crnomerovic.

 6       Q.   The court reporters, ma'am, will --

 7       A.   That's great.

 8       Q.   Did you ever see, ma'am, in the city of Mostar, large

 9    concentrations of HVO armed forces?

10       A.   Yes, during that period of time.  I couldn't provide you with the

11    exact date, though, but at that time I had already moved to the Vranica

12    command, and there were a lot of people.  I couldn't say how many exactly.

13    On one occasion I saw them in camouflage uniforms, and they were heading

14    from the direction below Siroki Brijeg, which is where the stadium in

15    Mostar is located, towards -- they were heading from that direction.  And

16    then they took the avenue to the old Velez pitch, and then they went

17    towards Rondo.  I don't know where they went then.  I also saw a large

18    number of people, a large number of men in black uniforms.  I saw them in

19    front of the Ero Hotel.  My niece first mentioned the fact, and then one

20    day I myself heard them speaking with a Dalmatian accent.

21            We thought that they were just trying to mount a display of force,

22    because the 15th of April was the army's day.  And after review in front

23    of the brigade command, troops marched down the avenue, which is near the

24    mine.  So the civilians from that area would approach us.  They

25    congratulated us.  They felt that their morale had been given a boost.

Page 1014

 1            At that time, many members of the army were arrested.

 2       Q.   Let me just try to clarify what you've told us, if that's

 3    possible.  These people -- you said a large number of men in black

 4    uniforms.  Were these people in black uniforms members of the ABiH or the

 5    HVO or some other armed force?

 6       A.   No.  I think that these men didn't have any insignia on them on

 7    that day when I saw that very large column.  They had no insignia on them,

 8    but they certainly were not from Mostar.  I don't know where they came

 9    from, where they had been brought in from.  I don't know where they had

10    been billeted.  For some I assume they had been provided with

11    accommodation in the Ero Hotel, but I don't think there was sufficient

12    accommodation in town for all of them, so I'd say that they had found

13    accommodation somewhere else.

14            I couldn't really say they were from Croatia.  This group, the

15    group that I heard discussing some matters in front of the Ero Hotel, were

16    from Dalmatia; they were Dalmatians.

17            MR. MUNDIS:  Mr. President, I note the time.  This might be an

18    appropriate point for our first break.  I'm about to move into another

19    subject matter.

20            JUDGE ANTONETTI: [Interpretation] Very well, Mr. Mundis.  It is

21    now half past three.  We're going to have a break for 20 minutes, and

22    we'll start again around ten to four.

23                          --- Recess taken at 3.35 p.m.

24                          --- On resuming at 3.58 p.m.

25            JUDGE ANTONETTI: [Interpretation] The hearing is resumed.

Page 1015

 1            Mr. Mundis, please proceed.

 2            MR. MUNDIS:  Thank you, Mr. President.

 3       Q.   Ms. Drljevic, in just a moment I'm going to ask you about the

 4    events of 9 May, 1993, but before I do that I have one question from

 5    earlier this afternoon, and that relates to this:  You've told us about

 6    units of the ABiH that were in Mostar and units of the HVO that were in

 7    Mostar.  Other than those two armed forces, what other military forces, if

 8    any, were present in the city of Mostar in late 1992 or early 1993?

 9            MR. KOVACIC:  Your Honour.  If I may object, I believe this

10    question as it was put is a leading question.  First, there should be a

11    question whether there was any other beside those two forces, and then

12    what.

13            JUDGE ANTONETTI: [Interpretation] Very well.  Continue, please,

14    Mr. Mundis.

15            MR. MUNDIS:

16       Q.   Ms. Drljevic, other than the HVO and the ABiH, were there any

17    other military forces in the town or city of Mostar in late 1992 and early

18    1993?

19       A.   Yes.  I think there were Croatian army forces present there too.

20       Q.   Were there any other international military forces in the town of

21    Mostar in 1992 and 1993?

22       A.   Towards the end of 1992 and at the beginning of 1993, although I

23    don't know what they were called at the time, but there were international

24    military organisations in town at the time, but I don't know whether it

25    was UNPROFOR.

Page 1016

 1            As for the period preceding the 1st of May, there was a transport

 2    unit that had something to do with the Projektant facility, and throughout

 3    that period of time it was patrolling throughout that area.  It was

 4    perhaps a personnel carrier.  It was in front of the Projektant facility

 5    during that period of time or, rather, it was at the crossroads where the

 6    Stjepan Radic Avenue is located.  And it was in the direction of the new

 7    Velez stadium.

 8       Q.   Ms. Drljevic, when you talk about international military

 9    organisations in town, do you know what country or countries this

10    international military organisation was from?

11       A.   I couldn't really say, but I know that this personnel carrier was

12    a SpaBat personnel carrier.  It was a Spanish UNPROFOR unit.  But I

13    wouldn't be able to tell you what it was called at the time.  That's what

14    the contingent was called; UNPROFOR, AROFOR [phoen], SFOR.  The names

15    change so frequently that I couldn't really say for sure what the precise

16    name of that international military organisation was.

17       Q.   And when you say "SpaBat," can you tell us what "SpaBat" refers

18    to?

19       A.   The Spanish Battalion.

20       Q.   Ms. Drljevic, I'd like to draw your attention now to the events of

21    9 May, 1993.  Can you tell us where you were on the day immediately before

22    9 May; that is, on the 8th of May, 1993?  Can you tell us where you were

23    on that day?

24       A.   On the 8th of May, 1993, I was working in the command in Vranica.

25    I was there until about 4.00 in the afternoon.  I remember that it started

Page 1017

 1    to rain at that time, and at that time the president of the cantonal unit,

 2    Zijad Demirovic, and Emir Bijedic, I think he was part of the security for

 3    the 4th Corps, and then there was Demirovic and my commander, Hujdur, I

 4    know that they returned from a joint meeting.  I think it was a meeting

 5    that had been held with the HDZ.  And from the 17th or 19th of April, up

 6    until that day, a number of arrests of army members had been made.  A

 7    number of arrests of ABiH members had been made.  So -- had been made.  So

 8    they were discussing things to see if they could find a solution to

 9    misunderstandings.

10            A day prior to that meeting, two couriers had been arrested.

11    Orhan Zilic was one of them, and the other was the son of Professor Semso

12    Badzak.  I don't know what his name is.  They were released that very same

13    day.  A few days earlier, a group of about 15 soldiers had also been

14    arrested.  They were returning from the lines in Podvelezje.  And when you

15    take all these factors together, they contributed to creating a very tense

16    atmosphere.

17            I asked them whether I should stay on, whether they needed

18    assistance of any kind.  The commander said I should sleep over somewhere

19    in the building, because I lived on my own in my flat.  And on that day --

20    on that day I was in uniform, and he said that anyone who was in army

21    uniform would be arrested.  He said that was being done.

22            And a little earlier I had told him a joke of some kind.  I had

23    some -- a change of clothes in my bag, toothpaste and toothbrush.  I had

24    that with me in case they would not recognise the permit I had been issued

25    with in order to be able to move around freely during the curfew.  I

Page 1018

 1    thought this would only last for a day or two.

 2            So I decided to stay in the building.  Up until 8.00, I was near

 3    the entrance facing the MUP, the Ministry of the Interior, the police

 4    station.  I was with my friend Dzenana.  But as there was nowhere for me

 5    to sleep, I went to the Vranica building.  There was a married couple

 6    there, Svjetlana and Edo Turajlic.  And I think they were on the fourth or

 7    fifth flat, or they lived on the fourth or fifth flat in that building.

 8    On the fourth or fifth floor in that building.

 9            I recently watched the film Escape from Alcatraz on television,

10    but at any case, at 5.00 in the morning --

11            THE INTERPRETER:  At the time they were watching that film,

12    interpreter's correction.

13            THE WITNESS: [Interpretation] -- I was woken up by shots, and then

14    I saw that a shell had hit that flat.

15            MR. MUNDIS:

16       Q.   Ms. Drljevic, when you make reference to 5.00 in the morning, can

17    you tell us what day you're now talking about?

18       A.   I'm talking about the 9th of May.  As I've already said, on the

19    8th of May in the evening or, rather, after 4.00 p.m., I stayed on to

20    sleep at my friend's place.  I am talking about the 9th of May.

21       Q.   Again, what year is that, ma'am?

22       A.   1993.

23       Q.   And at that point in time, was the ABiH command, the personnel of

24    the ABiH command in the Vranica building or were they somewhere else?

25       A.   On the 17th or 19th of April, we had additional guards.  There

Page 1019

 1    were 20 or 30 young men providing security for the building.  Up until

 2    that time, there had only been four or five of them.  It wasn't necessary

 3    to have more of them.  And this is what was changed when these two young

 4    men were wounded.  There were no commanders there.  I don't think it was

 5    necessary.  I assume that the commander Hujdur wasn't familiar with the

 6    situation.  I'll say something more about this later on.

 7            He turned up on the 8th at about 9.00 in the evening.  He visited

 8    those on duty.  I wasn't present, but that's what I was told in the

 9    morning.  His aunt stayed on in the building.  She had brought him up and

10    I'm sure he wouldn't have left her there had he known that there'd be an

11    attack, had he known that there would be such a destructive attack.

12       Q.   Ms. Drljevic, let me return to the events of the early morning of

13    9 May, 1993.  You've told us that at 5.00 in the morning you were woken up

14    by shots and you saw that a shell had hit the flat.  Where did you go

15    after waking up?

16       A.   I got dressed and I went down, because the brigade command was in

17    the cellar of the building.  I'll have to explain this.  Vranica is the

18    name for that complex of buildings.  It's the name of this construction

19    company there, and part of the management was located beneath that

20    building, and its archives were located there too.  The corps command was

21    in Vranica and it was in the entrance where the construction company was

22    located before the war, and during the war too.  And in the part in front

23    of the Stjepan Radica Street where a leather and textile company was

24    located, well, in that part there was some sort of a shop from Visoko - it

25    didn't function during the war - and that's where the unit was located,

Page 1020

 1    the unit from the 1st Mostar Brigade -- or, rather, the command of the 1st

 2    Mostar Brigade.  I apologise.

 3            On that evening, the usual officers were on duty, the

 4    communications officer ...

 5       Q.   When you arrived, ma'am, in the Vranica -- in the basement of the

 6    Vranica building on 9 May, 1993, how many members or how many soldiers of

 7    your unit were present there?

 8       A.   When I went to the cellar, there were about 10 individuals there.

 9    I saw them immediately.  The young men from the communications centre,

10    there was the chief of the communications centre, there was the duty

11    officer, an operations officer, Jusuf Rodovic.  And at the entrance to the

12    building or, rather, in the cellar, since that's where the command was

13    located, there was a wounded man who was about 60 years old, Enver Zekic.

14    He had been wounded in the stomach.  He had either been shot or hit by a

15    piece of shrapnel, I'm not sure.

16            MR. MUNDIS:  Mr. President, with your leave, I'd ask that the

17    witness be shown Prosecution -- or the document that's been marked as

18    9413, which is actually a photograph.

19            If we could please -- if we could please go to the pages marked

20    with ERN number 02068382.  I believe that's page 4 of this document or

21    photo book.

22       Q.   Ma'am, can you please tell us what you see on the screen in front

23    of you.

24       A.   I can see the buildings that go by the name of Vranica in the

25    first photograph.  It's not really visible here, but since I passed by

Page 1021

 1    that building on two occasions about three years ago and also a couple of

 2    months ago, I know that -- in the first photograph you can see the

 3    entrance that was used by the corps command.  They entered the building

 4    through that entrance.

 5       Q.   And when you say, Ms. Drljevic, "that entrance," can you please

 6    describe for us where in the photograph -- or perhaps if the touch pen is

 7    working, we can ask the witness to ...

 8       A.   You can only see one entrance here.  You can see the bars over the

 9    window.  This is the window.  And here it says Vranica.  You have a sign

10    that says Vranica.  And this is the entrance that members of the corps

11    command used, as well as the young men who provided security.

12       Q.   And, ma'am, is that the entrance that members of your unit used in

13    entering the building?

14       A.   That's the entrance used by members from my command.  It's the

15    entrance for the 4th Corps, and the entrance to the corps command was

16    somewhere else.

17            Could we have a look at the other photograph?  There are some

18    trees here, and this is where the entrance to the command of the 1st

19    Mostar Brigade was located.

20            MR. MUNDIS:  For the record, Mr. President, the witness is how

21    referring to the photograph with the ERN number 02068383.  In the bottom

22    centre of that photograph there is a kiosk.  Immediately adjacent to the

23    kiosk is the tree to which the witness was referring where she indicated

24    that that was the entrance to the command of the 1st Mostar Brigade.

25       Q.   Ms. Drljevic, can you tell the Trial Chamber, please, what

Page 1022

 1    happened after you arrived in the cellar of the Vranica building on the --

 2    or in the early morning hours of 9 May, 1993.

 3       A.   In the cellar, in addition to the ten soldiers I saw at the time -

 4    some of them I've only seen in video recordings, in photographs - but

 5    there was some women and children from the building who were there too.

 6    Apart from the local inhabitants, there were many refugees from the left

 7    bank whose houses had been burnt in the fights with the Chetniks.  They

 8    had been destroyed.

 9       Q.   Ms. Drljevic, how long did you remain in the basement of the

10    Vranica building after you arrived there in the early morning hours of 9

11    May, 1993?

12       A.   I remained there up until the afternoon of the 10th May.  Some of

13    the young men who had been allocated to various floors and to the corps, I

14    saw them during those two days and nights.  Some women prepared, as much

15    as they could under the intensive shelling and fire, some food.  They

16    would go upstairs, bake bread, and then come back to the basement.

17            The attack did not come as a surprise -- the attack was a surprise

18    to us, therefore we did not have previously prepared food.  The firing was

19    very intense.  These houses remained in this condition for at least ten

20    years after that, and you can see the type of calibre that was used.

21            That whole time, we had contact with the forward command post of

22    the brigade of the corps on the left bank, which was in the SDK building.

23    They asked from the communications centre to ensure that Dr. Selma

24    Jakupovic and another male doctor would come.  They were

25    anaesthesiologists.

Page 1023

 1       Q.   Ma'am, if I could interrupt you at this point in time.  In

 2    addition to the soldiers who were in the basement, you've told us about

 3    some women and children from the building.  Approximately how many people

 4    in total were in the cellar of the building?  And then if you could give

 5    us a breakdown as to how many were military and how many were civilian.

 6       A.   I wouldn't be able to give you the accurate number, because some

 7    of the soldiers were on various floors while some were in the part where

 8    the corps members entered.  And then again, some soldiers were in the

 9    entrance or, rather, in the building where the entrance is from Stjepan

10    Radica Street where the Kluz shop was, and this is where logistics people

11    were and people securing that area.

12            As for soldiers, I can say that there were 30 to 40 of them,

13    including the 13 listed as missing.  As for civilians, I wouldn't want to

14    speculate.  Perhaps there were about 100 of them in these two entrances.

15    When I say "two entrances," I mean all of the people who were there and

16    assembled in front of the MUP building.  But in that other area, maybe

17    some 50 civilians.

18       Q.   Now, you've told us, ma'am, if I understood you correctly, that

19    from the early morning of the 9th of May until the afternoon of the 10th

20    of May, 1993, you were in the cellar of the Vranica building; is that

21    correct?

22       A.   Yes, that's right.

23       Q.   Can you please describe for the Trial Chamber how it is that you

24    came out of the basement of the Vranica building.

25       A.   Prior to that, I'd like to say that we had telephone contact with

Page 1024

 1    somebody from the HVO.  Mostly they asked for Rudi, Rudi Jozelic, who was

 2    a duty officer.  They wanted him to surrender, which he refused.  And then

 3    they would accuse us on the radio of keeping civilians imprisoned.  Upon

 4    hearing that, we told those who wished so to leave the building.  However,

 5    nobody responded to that.

 6            I can tell you that the population or, rather, tenants of that

 7    building were mixed.  There were Croats, Bosniaks, and most likely Serbs.

 8    I think that most of the people were afraid that the cease-fire would not

 9    be complied with.  All of them remained there to the end.

10            I remember that when Zekic was wounded, we asked for a -- for an

11    emergency ambulance car, and they said that they could only send a truck

12    with petrol.

13            At one point Goran Zekic, whose father had been wounded, called on

14    the phone Jadran Topic.  They were family friends.  He asked him to help

15    him.  However, he refused because Goran was very angry.  He stormed out,

16    and he wanted to start shooting, and then some guys went and fetched him

17    back.

18            Since I was quite exhausted, I withdrew and retired into that

19    office.  I maybe slept there for an hour, and then I was awakened by a

20    group of people.  I saw that some of them were missing, about half of them

21    were missing, and then there was a little girl who was eight to nine years

22    old and who was wounded in her head.

23            I have to say that people started panicking somewhat.  We knew

24    that the upper stories of the building were on fire.  They even brought

25    down on stretchers a man who was suffocating from smoke, who had smoke

Page 1025

 1    inhalation problems.  I think his last name is Kajic.  I remember his

 2    face, but I'm not sure about his last name.

 3            Also, some water pipes had burst, so the floor was flooded.

 4       Q.   And again, ma'am, can you tell us about the efforts that were

 5    undertaken to get out of the cellar of the Vranica building?

 6       A.   They were running out of ammunition.  It was clear that we would

 7    be unable to defend ourselves.  I would rather not go into evaluation of

 8    the situation.  I know that some people wrote books about it.  I didn't

 9    read the books, but apparently one could establish the number of soldiers

10    engaged on the opposite side in order to make a comparison.

11            At one point in time, since Rudolf was there the entire time --

12    from the inception of the brigade, he was there, and another man who

13    previously used to work in Vranica was there as well, and they knew that

14    one of the walls, partition walls in my office, had been erected

15    previously.  So they took out a brick ...

16       Q.   Ms. Drljevic, did they begin taking down the walls in the

17    basement, in the cellar, as a means to trying to get out of that location?

18            MR. KARNAVAS:  Mr. President, if I may object -- if I may object.

19            JUDGE ANTONETTI: [Interpretation] Yes.

20            MR. KARNAVAS:  I understand Mr. Mundis and I commend him, he's

21    done an excellent job so far, though there have been some times where he's

22    posing a question that is rather leading or it assumes a fact that is not

23    in evidence yet.  I think it's so important, at this stage at least, to

24    get as much of the information from the witness as opposed to Mr. Mundis

25    imparting that information on us and then having the witness validate

Page 1026

 1    that.  Thank you.

 2            JUDGE ANTONETTI: [Interpretation] Yes.  Sustained.

 3            Please proceed, Mr. Mundis.

 4            MR. MUNDIS:

 5       Q.   Ms. Drljevic, you said, "So they took out a brick."  Can you tell

 6    us what happened next?

 7       A.   Yes.  I apologise.  I was shaken, because -- yes.  They were

 8    taking bricks out one by one with their hands.  The young man helping him

 9    is not on the list of missing.  Nothing is known about his fate.

10            So I apologise.  I recreated this image in my mind.

11            So there were four or five officers there who decided to attempt

12    to leave that entrance.  Since the people knew that this wall was just a

13    partition wall with just plain bricks, they assumed that it would be

14    easier to break through that wall -- or, rather, to remove that wall.

15            I wouldn't be able to tell you who said that people should change

16    into civilian clothes.  Most people did that.  So did I.  But since this

17    is something I stated in my previous statements, due to stress, I started

18    bleeding, which lasted until --

19            THE INTERPRETER:  The interpreters didn't hear the name of the

20    location.

21            THE WITNESS: [Interpretation] Once they removed the bricks and

22    made an opening big enough for one person to pass through, then we saw a

23    metal door.  The man Alica Pobric started firing.  He started firing from

24    an automatic rifle at the door and then the door opened.

25            In the room next to it -- this was also in the basement, in the

Page 1027

 1    corridor, and then the stairs take you up to another entrance where there

 2    were many civilians.

 3            In addition to this girl and the young man who worked in

 4    encryption, Muradif Habibi -- his name is Muradif Habibija.  He was

 5    wounded.  He had a wound on his back, and there was a large haematoma next

 6    to his spine.  So in addition to others, I also helped carry him out.

 7            In this other building -- this was actually the entrance where I

 8    went on the previous day to visit my friend.  Dr. Jerko was there.  There

 9    were also some men from Luka; Nino Sefic, Hasif Nemic, Corda, Dr. Dzeko

10    was there, and Zijad Demirovic, who took it upon himself to negotiate.

11    Since right next to that building is the MUP building, there were soldiers

12    there who had surrounded the building, so he took it upon himself to

13    negotiate with them.

14       Q.   Ms. Drljevic, if I could interrupt you at this point.  A few

15    moments ago you said, "... due to stress, I started bleeding, which lasted

16    until --" and at that point the interpreters were unable to hear the name

17    of the location.  Can you repeat that part of your answer?

18       A.   Until Ljubuski.  When Dr. Dzeko came and he gave me a rest of 15

19    to 20 days.

20       Q.   Okay.  You were at the point, ma'am, where you told us about some

21    negotiations, the commencement of negotiations.  Can you elaborate upon

22    those negotiations; who was doing the negotiating and what the subject

23    matter of those negotiations were?

24       A.   Mr. Zijad Demirovic, who at the time was president of the cantonal

25    board of the SDA.  He was an architect by profession, and he recently

Page 1028

 1    died.  He took a loudspeaker and started talking to the soldiers who had

 2    surrounded the building and were standing around the building.  He told

 3    them that we were civilians and arranged for us to leave the building one

 4    by one.

 5       Q.   And, ma'am, where did you go -- or did you in fact leave the

 6    building one by one?

 7       A.   Yes, we did, one by one.  However, in the part of the building

 8    that we had left, prior to that some 10 to 15 young men remained there in

 9    uniforms and weapons to attempt to break through to the surgical

10    department.  I don't know whose decision it was for them to remain there

11    and for others to move to another part.  I know that Emir Bijedic remained

12    back there with them.  At the time, he was assistant commander for

13    security within the corps.

14       Q.   And, Ms. Drljevic, when members of the group left the building,

15    the Vranica building, one by one, where did they go?

16       A.   At the end of this building or, rather, next to it at the time

17    there was a yellow fence.  It was definitely yellow then.  I think that

18    it's blue now.  So this was a fence, a metal fence with upright bars.  I

19    don't know how I managed to get over that fence while carrying a young

20    child in my arms.  A friend of mine had two children, girls, who were one

21    and a half.  She carried one of them, and I carried the other one.  We

22    went over the fence and went towards the MUP building.  Now it is the

23    building of the city MUP.

24            I saw Rudolf and Thedja [phoen] carrying somebody in a blanket.  I

25    don't know whether it was Muradif or the girl that they were carrying.

Page 1029

 1       Q.   Ms. Drljevic, as you went towards the city MUP building, did you

 2    see any people in the immediate vicinity of that building?

 3       A.   Excuse me, what do you mean "people"?  Do you mean soldiers

 4    perhaps?  Soldiers, yes.  I saw a large number of uniformed soldiers with

 5    ribbons.  I don't know what colour the ribbons were, ribbons on their

 6    sleeves.  Some of them stood there and directed us to tell us in which

 7    direction we were to move.  Some of them stopped the large number of

 8    people from going to the surgical department.  No, they directed us

 9    towards the fence.  We were to go over the metal fence.  And then right

10    there in front of the building, they separated men from women.

11       Q.   And these soldiers, these uniformed soldiers with ribbons, what

12    armed force were these soldiers a member of, if you know?

13       A.   I wouldn't be able to say whether they were members of some of the

14    brigades or perhaps of MUP of Herceg-Bosnia [as interpreted].

15       Q.   And when you say "there in front of the building, they separated

16    men from women," which building are you referring to?

17       A.   I'm referring to the building of MUP, the MUP building.  Once we

18    went over the fence, they directed us towards that building.  This is the

19    building which houses the city MUP nowadays.  This is where we go to get

20    personal IDs and so on.  This is where they separated men from women.

21       Q.   And where did the women go?

22       A.   The women were taken inside the building to a room which resembles

23    an amphitheatre.  I don't know how to explain that.  It must have been

24    some kind of a conference room, and there were benches there lined up so

25    that they are one above the other.

Page 1030

 1       Q.   And, ma'am, let me interrupt you there, because you say the women

 2    were taken inside the building.  And again, can you be more specific as to

 3    what building you're referring to?

 4       A.   I'm referring to the MUP building.  That's what I have in mind.

 5       Q.   Do you recall, Ms. Drljevic, the approximate date and time that

 6    the women were taken into the city MUP building?

 7       A.   It was on the 10th of May, at around 3.00 p.m.

 8       Q.   Now, Ms. Drljevic, do you know or did you observe where the men

 9    who had been with you in the basement of the Vranica building were taken

10    once they were separated from the women?

11       A.   Some of them remained in the other part of the building, and some

12    of them were taken towards the stone building, which is to the east of

13    this building.

14       Q.   Okay.

15       A.   I can't remember the street name.  I just can't recall it right

16    now.

17       Q.   That's fine.

18       A.   Nowadays this is where the cantonal MUP is housed.

19       Q.   Okay.  Just so we're clear, then, you told us that some of them --

20    some of the men remained in the other part of the building and some of

21    them were taken towards the stone building.  Now, when you say some of

22    them remained in the other part of the building, which building are you

23    referring to?

24       A.   I'm once again referring to the building where women were.  I

25    can't be fully certain, because on the following day I saw some of them on

Page 1031

 1    the floor upstairs.

 2       Q.   And again, because we have -- Ms. Drljevic, we have to maintain

 3    the written record here, the building where the women were located, what

 4    is the name of that building, or what is currently in that building?

 5       A.   At the time, it was the building of the MUP of Herceg-Bosnia [as

 6    interpreted].  It is also the MUP building nowadays.  Since Mostar has a

 7    peculiar organisation, municipal organisation, it is known as the city

 8    MUP, not a municipal MUP.  So it's in the building known nowadays as the

 9    city MUP building.

10       Q.   And in the building that's known nowadays as the city MUP

11    building, the women were kept and some of the men were kept.  Is that what

12    you're testifying?

13       A.   Yes, that's what I'm trying to say.  But I'm also trying to say

14    that initially they were not in the same premises.  The women were in this

15    amphitheatre, and with us there was this young man who in early 1993 lost

16    his leg.  His name is Gosto Adis.  And then there were women and children.

17    I don't know where they took the men.  It wasn't until the next day, where

18    most of the women either went home or to Heliodrom, that I saw some of the

19    men upstairs in the same building.

20       Q.   How long, Ms. Drljevic, did you remain in this city MUP building

21    after you arrived there on the 10th of May, 1993, at approximately 1500

22    hours?

23       A.   I remained there until the 13th of May, late in the evening.  It

24    was night-time, very dark, maybe midnight.  I didn't have a watch.

25       Q.   Approximately how many other people were detained with you in the

Page 1032

 1    Mostar city MUP building during the time that you were there from the 10th

 2    through the 13th of May, 1993?

 3       A.   Well, this is what I can say:  On the 10th, 11th, we stayed in

 4    that room for two nights.  Then on the 12th, a number of women were placed

 5    in a bus, and my friend was among them, and they were taken to the

 6    Heliodrom.

 7            During the night of the 13th, I noticed that some women would come

 8    out from time to time and then go back.  And when they left the second

 9    time, they wouldn't come back so I assumed that they were people who had

10    left the building.  I didn't know them myself except for Jesenka Rajkovic

11    Kragulj.  She was a Bosniak married to a Croat, Tihomir Kragulj, who was

12    in uniform.  He was wearing a police uniform when he met me, and his words

13    were, "Your time is up, Secretary."  Otherwise, a few days before the

14    attack, with him and with Zeljko Budimir, I had a cup of coffee, and I

15    thought that everything was quite normal.

16       Q.   Ms. Drljevic, I'd like to return your attention to the time when

17    you first arrived in the city MUP building on or about the afternoon of

18    the 10th of May, 1993.  Can you tell us, please, what happened when you

19    first arrived in the city MUP building.

20       A.   I don't understand what you're asking me.

21       Q.   Can you please describe for us what you saw when you entered that

22    building and where you were taken in that building.

23       A.   That first day we were taken to that hall where they probably held

24    their meetings, where there was such a large number of women.  We spent

25    another day there, and then those women were taken off by bus.  They said

Page 1033

 1    that Bojana, Selma, and Mirna - they were journalists who worked at the

 2    radio - and I myself, that we would stay for interrogation.

 3       Q.   And during the course of the time from the 10th through the 13th

 4    of May, 1993, while you were in the Mostar city MUP building, were you in

 5    fact at any point in time interrogated?

 6       A.   Yes.  Before that, we had to state our identities, and we were

 7    told that all those without ID documents should come up to the table and

 8    introduce themselves, and that's what I was talking about earlier on.  As

 9    I knew that woman, she was brought up by Hujdur's aunt, when they asked

10    her what relation Hujka was to her, she said that he wasn't any relation

11    at all -- or she.  It seemed to me as if -- well, I think she replaced his

12    mother, and it was like a mother giving up her own child.  That's what it

13    appeared to be like to me.

14            I had no dilemmas.  I introduced myself straight away and said

15    that I was a member of the army, and I think that that -- well, I didn't

16    know anybody, hardly anyone there, and I think that that made the people

17    there leave me alone and instigate proceedings.  But I'm not quite clear

18    about that whole episode to this day.  I don't know the reasons I was held

19    or why I was held for such a long time or under such conditions.

20       Q.   Ms. Drljevic, you told us earlier that you left the city MUP

21    building late in the evening of 13 May, 1993.  Where did you go?

22       A.   May I just go back for a moment to the 12th or 13th, just back a

23    bit before I fast forward, to turn the tape back?  Upstairs, on the floor

24    above, where they questioned us one by one, I was questioned for a very

25    brief time.  I knew Marin Jurica.  He had a marketing agency or a fashion

Page 1034

 1    agency or some such thing.  And his brother worked there before, and he

 2    interrogated me first with respect to my participation in the war and my

 3    stay in Vranica.  I can't actually say that he was brutal or violent in

 4    any way.  It was quite a proper interview.  But at one point

 5    Mr. Demirovic, who was in the hallway outside, and Nino Sefic, Hajdarevic

 6    - I can't remember his first name now - Hazim Memic, Almir Corojevic, at

 7    one point, well, there were some offices and a long corridor or a long

 8    hallway at the end of which there was a television set, and it was

 9    switched on.  And Mr. Demirovic was -- almost started crying, because

10    somewhere in the column he recognised his wife, in the column of civilians

11    that was moving across Varda.  Varda is a hill to the south of Mostar,

12    above the Heliodrom.

13            I also saw -- and this was a programme that was called Slikom na

14    Sliku.  The journalist was Dijana Culjak.  I saw them come out one by one,

15    those young men who provided the security.  Later on, I also watched this

16    footage, but I can't say exactly where it was filmed, whether it was in

17    front of the Vranica building at a spot where there is a makeshift shed,

18    prefabricated shed, which is, I think, where the tax office is today, or

19    something like that, or perhaps it might have been in front of the

20    headquarters of the HVO, in front of the Parkova [phoen] or Lesnina

21    building.  I can't say now for sure, but at any rate, at the end of this

22    footage they showed the people and their names and surnames who obviously

23    knew where those young men were located.  And among other things, I hope

24    that this testimony of mine will contribute to us learning where the bones

25    are at least.

Page 1035

 1            The young men were shown as they were taking out the picture of

 2    Sefer Halilovic and the emblem which indicates the fact that they had been

 3    taken prisoner and that that was how it was staged, because there is very

 4    little likelihood that people would otherwise have stood before an

 5    execution squad, for example, in that way, or whatever you like to call

 6    the people standing in front of them.

 7       Q.   Thank you, ma'am.  Could we now go to the time period when you

 8    left the city MUP building, and if you could please tell the Trial Chamber

 9    where you went.

10       A.   That night, as I say, it was late.  After midnight.  11.00 p.m. or

11    midnight.  I think that that programme Slikom na Sliku was shown very

12    late.  Well, I don't know if it was that day or not, but anyway, all the

13    people were wearing uniforms, and he said that we should collect up our

14    belongings and go, and we even hoped that we were going home.

15            Then the four of us were put into a police car with bars on the

16    windows - and that particular type of vehicle is referred to as a Black

17    Maria - and they drove us to the Kameni or stone MUP.

18       Q.   And again if I --

19       A.   And there --

20       Q.   If I could interrupt you briefly.  When you say "the Kameni or

21    stone MUP," what building are you referring to?  What location or building

22    are you referring to?

23       A.   Well, it's the cantonal MUP, as it is now.

24       Q.   And approximately, ma'am, how far is the cantonal MUP building

25    from the Mostar city MUP building?

Page 1036

 1       A.   Well, it's very close by.  Perhaps some 20 metres away.

 2       Q.   Okay.  Can you tell us what happened after they drove you to the

 3    Kameni or stone MUP building on that evening, 13 May, 1993?

 4       A.   They didn't take us into the building.  They brought us before the

 5    building, in front of the building.  And then they took us in.  I couldn't

 6    see anybody because it was dark, but at one point I saw that a woman had

 7    her hands handcuffed behind her back.

 8            We set out in a column.  There was a car in front of us with

 9    rotational lights, three Kombi vans with the bars on the windows, and

10    three vehicles with rotation lights behind us.  There were two armed young

11    men sitting in the -- inside of the van, and they just said -- they asked

12    us whether we knew where we were going, and we said no, we thought we were

13    going to the Heliodrom, but he said, "No.  You're going to Ljubuski."  I

14    had just heard about Ljubuski as being some sort of central prison before

15    that, and on one occasion I went there -- well, not where we were put up,

16    but I went in 1992 when the group from Bileca was released.

17            Anyway, when we arrived up there, they took us into a building,

18    ordered us to stand up against the wall with our arms raised and legs

19    spread, and they searched us and asked us to give our identities, to give

20    our names and surnames.  At that point in time, I did not see who else was

21    brought in, but I did recognise the voice of Rudolf Jozelic, and a blow

22    when, after asking, "What are you?"  He said, "I'm a Bosnian Catholic."

23    Then I heard this blow.

24            Vlado Fink was there as well.  And there was Kamenko Bosnjak, who

25    was a journalist on radio otherwise.  And when asked the same question, he

Page 1037

 1    said, "I'm here by mistake, sir," and they released him the very next day.

 2            I didn't recognise anybody else or the voice of anybody else.

 3       Q.   Ms. Drljevic, if I can just ask you a few questions about this.

 4    Do you recall approximately what time it was and the date that you arrived

 5    in Ljubuski?

 6       A.   On the 13th during the night.  I don't know what time.  It might

 7    have been one or two hours after we had left Mostar.  I can't be sure of

 8    the time.

 9       Q.   Approximately how many people were in the group that was with you

10    that was transported from Mostar to Ljubuski during the night of 13 March,

11    1993?

12       A.   Well, I don't know.  Perhaps 20.  I'm not quite sure.

13       Q.   Can you tell us about the gender and ages of the people that were

14    transported with you on that evening?

15       A.   Well, no, I can't, because -- well, I can say that I know there

16    were five of us women in the room later on.  However, throughout that time

17    while the people in the black uniforms were there, they weren't the people

18    that we saw later on there.  They were others who came as an escort.  And

19    they asked us to look at the wall, keep our eyes to the wall.  So I don't

20    know who actually came to Ljubuski that night.

21       Q.   Can you tell us, ma'am, approximately how long you remained in

22    Ljubuski?

23       A.   I remained in Ljubuski until the 8th of June, 1993.

24       Q.   Can you describe for the Trial Chamber the building or buildings

25    that you were kept in during this period from 13 May until 8 June, 1993?

Page 1038

 1       A.   That first night when we were brought there, there were no beds in

 2    the rooms, and quite obviously they weren't expecting any women to turn

 3    up, so that we sat on the floor that whole night.  There was a table.

 4    They brought in beds the next day, and we were all put up in one room.

 5    There was this large room in which they placed the beds.  There weren't

 6    any bars on the windows.

 7            There was a smaller room, too, but as several days later they

 8    brought in the men to clear up the parquet flooring, they made a makeshift

 9    sort of dining area, dining-room.  And there was another building which I

10    learnt later was where the men slept who were not detainees, who weren't

11    prisoners.  They were free men who were truck drivers from Bosnia.

12            Up on the upper storey there were the premises of the police.

13    They took me up there for interrogation, but I don't really know how many

14    offices there were there.  And also on the floor above there was a toilet.

15    There was no toilet on the ground floor level.

16            And the buildings in which the men were put up, I asked

17    afterwards, and they said that they used to be sheds, and then they became

18    storerooms after that, changing their purpose.  And I don't think they had

19    any of the proper conditions for life there.  I thought they looked like

20    prefabricated sheds, one placed parallel to the building and the other at

21    an angle.  I know that -- well, there wasn't a tap, there was just a pipe

22    where water ran all the time.

23            I saw this, because I asked if I could take two boxes of

24    cigarettes to the men on one occasion, two cartons of cigarette boxes, and

25    on another occasion some food that -- some leftovers.

Page 1039

 1       Q.   Ms. Drljevic, let me go back and ask you some follow-on questions

 2    from what you've just told us.  You testified that when you were brought

 3    there, there were no beds in the room.  I take it from that answer that

 4    there were no other women in that room at the time you arrived.

 5       A.   No, there weren't.  It was an empty room.  There was just a table

 6    in the middle.

 7       Q.   And how many women were with you on that first evening that you

 8    spent in this room in Ljubuski?

 9       A.   There were five of us in all.  Selma, Bojana, Mirna, Mirzeta - was

10    the woman with her hands tied behind her back and handcuffed - and myself.

11       Q.   And you told us that these men were kept in other buildings.  Do

12    you know approximately how many men there were at the time you were in

13    Ljubuski?

14       A.   I can't give you a number, but as many as could be placed in the

15    room.  Because I would see them from time to time being led out into the

16    open air.  And when I took the carton of cigarettes, they were standing

17    one next to the other, their hands touching.

18       Q.   During the time period, ma'am, that you were in Ljubuski, were you

19    able to come and go as you pleased?

20       A.   Of course not.  Regardless of the fact that there were no bars on

21    the windows, we were not able to communicate, and it was a little

22    unpleasant.  Some people would stop by, and then we asked them -- we asked

23    that they put some curtains up, because it was a little strange.  People

24    found it strange.  The local inhabitants obviously knew that it had been

25    turned into a prison.

Page 1040

 1            Sometimes when there was no water in the building the commander

 2    would let us wash some of the dishes or some of our clothes at a tap that

 3    was located opposite the road.  It was a tap in the street, a public tap.

 4    But of course we couldn't go anywhere else.

 5       Q.   Why couldn't you go anywhere else?

 6       A.   Well, because we were incarcerated.

 7       Q.   You told us just a moment ago, ma'am, that the commander would let

 8    you wash some of the dishes or some of your clothes at a tap.  Do you know

 9    who the commander was?

10       A.   Yes.  Ante Prlic.

11       Q.   How do you know Ante Prlic was the commander of the Ljubuski camp?

12       A.   Well, I don't know how I know.  I don't believe he came up to us

13    and said, "I'm the commander."  I can't say exactly.  I can't answer that

14    question.  But I did know, just as I knew that Santic was the deputy, for

15    instance.  I didn't see it written down anywhere or anything like that,

16    nor did he say it that way.  I don't know.  I didn't pay attention to

17    that.

18       Q.   During the time period, ma'am, that you were in Ljubuski, what

19    type of clothing did you see -- let me start over.  During the time you

20    were in the camp, on approximately how many occasions did you see Mr. Ante

21    Prlic?

22       A.   Almost every day.

23            JUDGE ANTONETTI: [Interpretation] Mr. Kovacic, you have the floor.

24            MR. KOVACIC:  [Previous translation continues] ... complications

25    in the transcript.  I notice that there is a different term used by the

Page 1041

 1    witness and the Prosecutor.  The witness is using the word "zatvor," which

 2    means "prison," while my dear colleague Mr. Mundis is insisting and again

 3    putting in question, I think three times in the row, the word "logor,"

 4    which means "camps."  By definition, those are not the same institutes.

 5    So I would suggest he would either clear up this, because later when we

 6    will refer to these transcripts, we will have a problem.

 7            Thank you, Your Honour.

 8            JUDGE ANTONETTI: [Interpretation] Very well.  Mr. Mundis, please

 9    try and settle this issue, please.

10            MR. MUNDIS:  I'll rephrase the question.

11       Q.   Ma'am, approximately how many times did you see Mr. Ante Prlic

12    while you were in the Ljubuski prison?

13       A.   Well, I can't say every day, but frequently anyway, because later

14    on we concluded that if he wasn't there and Santic wasn't there, then the

15    other guards would let other soldiers, for example from Tuta's unit, to

16    come in and beat the inmates.  I heard that from others, I didn't see it

17    myself.

18       Q.   Ms. Drljevic, you've referred to other guards.  Do you know or can

19    you recall approximately how many guards there were in the Ljubuski

20    prison?

21       A.   There were perhaps between 10 and 12 of them who were present

22    there.  I know some of their names and nicknames, and there are others

23    whose appearance I can remember.

24       Q.   With respect to Mr. Ante Prlic and Mr. Santic and these 10 to 12

25    guards that were at the Ljubuski prison in the time period you were there

Page 1042

 1    from 13 May through 8 June, 1993, do you recall what type of clothing

 2    these people were wearing?

 3       A.   They were wearing camouflage uniforms.

 4       Q.   Did you see any type of insignia on any of these uniforms?

 5       A.   I couldn't say.  I can't remember.

 6            MR. MUNDIS:  Mr. President, I note the time.  This would probably

 7    be the appropriate time for the second break.

 8            JUDGE ANTONETTI: [Interpretation] We shall now have our second

 9    break.  It is 25 minutes past five.  We shall resume at a quarter to six.

10                          --- Recess taken at 5.25 p.m.

11                          --- On resuming at 5.47 p.m.

12            JUDGE ANTONETTI: [Interpretation] We have an hour and a quarter

13    left before the end of this hearing.

14            Mr. Mundis, you have the floor.

15            MR. MUNDIS:  Thank you, Mr. President.

16       Q.   Ms. Drljevic, can you tell the Trial Chamber a little bit more

17    about the conditions in the Ljubuski prison during the time period that

18    you were there.

19       A.   While I was there, we received the same food that the soldiers

20    received.  However, once they had finished eating we would then enter the

21    area where they had eaten and it would then be our turn to eat.  I can't

22    really describe the conditions that the men lived in in great precision,

23    but they were certainly worse than the conditions we lived in, since I saw

24    them when they took them out for a walk and they looked pretty bad.  And

25    on a few occasions when I asked the commander to be allowed to visit them,

Page 1043

 1    I saw how they looked.

 2            During that period, I was interrogated on a couple of occasions,

 3    on a number of occasions, and I remember that one of the persons who

 4    interviewed me was someone called Dr. Lugonja.  He was very angry.  At one

 5    point in time, he asked me whether Hujka had two sons.  I knew that he had

 6    three daughters.  He had obviously mixed him up with his brother whose

 7    wife has two sons.  And he thought that I was lying.  So at one point in

 8    time he said he would kill me.  And then later on, Inspector Pejic told me

 9    that this was because a day earlier, in the city MUP, from the direction

10    of Vranica, shots had been fired, and his brother was killed in the

11    office.  I saw the death certificate.  I think his name was Miso.

12            And someone in uniform also interrogated me.  He had a dark

13    complexion.  He had knitted eyebrows.  It said "ATG" on his sleeve, "ATG

14    Kobra Omis."  That was an inscription he had on his sleeve.

15            And then at one point in time I didn't see them beating any men,

16    but when I went to the toilet upstairs, I could see that Rudi Jozelic's

17    T-shirt was bloody.  The next day I asked for a few T-shirts, and I put

18    them in a pot to wash them.  Later on I was told that in the camp when

19    Prlic and Santic were absent, Tuta's men would appear.

20            On one occasion in the car park I saw Braco Sapo, Slovenac.  I

21    think proceedings were instituted, but I don't know whether they have been

22    concluded.  Legal proceedings were instituted in Bosnia-Herzegovina.

23            I would also like to point out that at one point in time two men

24    entered the room.  One of them introduced himself and said that his name

25    was Cikota, or, rather, that he was Cikota's brother, and his nickname was

Page 1044

 1    also Cikota.  He was tall and lean.  And there was a young man who

 2    accompanied him.  He had fair hair.  He said he was from Rijeka, and he

 3    then had a dispute.  He said that Slovenia was soon to be dealt with.  He

 4    told Bojana this, who was a Slovenian.

 5            But no one really entered our room.  Quite by chance I was

 6    standing by the door when I saw a woman from -- well, a woman whom I knew

 7    who worked for the tourist organisation in Mostar.  Her name was Gordana.

 8    She greeted me, too, and she asked me what I was doing there since my name

 9    is not a typical Muslim name.  And at the time I didn't know that she was

10    a Croat either.

11            She said -- in fact, when I told her that I'd been arrested in

12    Vranica, she told me that no one knew anything about anyone for 15 days.

13    And there was a delegation from the International Red Cross, and they were

14    attempting to establish contact with Ante Prlic, Valentin Coric, and

15    Jadranko Prlic.  When they figured out that I -- when she figured out that

16    I was there, she said they would try to get some sort of a certificate, a

17    permit.

18            After a while, they returned, and they received permission from

19    someone - I don't know who exactly - but they were only granted permission

20    to speak to the women.  And that was the first time I was registered.  It

21    was on the 20th -- the 25th of May, 1993.

22       Q.   Ms. Drljevic, if I could just stop you there.  I have a couple of

23    follow-on questions.  About five minutes ago - and this is on page 52,

24    line 9, of the English transcript - you said the following, or this is

25    what the transcript captured:  "I can't really describe the conditions

Page 1045

 1    that the men lived in in great precision, but they were certainly worse

 2    than the conditions we lived in, since I saw them when they took them out

 3    for a walk, and they looked pretty bad."  And again, page 52, lines 6

 4    through 9 of the English transcript.

 5            Can you tell us a little bit more about this instance or instances

 6    when you saw the men after they had been taken out for a walk?

 7       A.   Well, I wouldn't really say it was a walk.  That yard was barely

 8    larger than the surface we have -- or I have in front of me in this

 9    courtroom.  They were just taken out there to get a little air.  I think

10    that the food they were provided with was worse than the food that we were

11    given.  And a couple of occasions -- I know that we had chicken on one

12    occasion, and I requested that they be provided with this chicken so that

13    it didn't go to waste.

14            The yard was muddy and had some gravel on the ground.  There was a

15    very bad smell in the yard since the water flowed continuously there.  And

16     -- well, I don't really know how to describe this, but only someone who

17    has experienced such conditions could describe them.

18            And on that occasion when I went to give them some cigarettes, I

19    realised that there were a lot of them and that it was very stuffy inside.

20    I don't know if they had any windows on the other side.

21            And later on, when I spoke to some of them, they said that they

22    would take turns to go out because they couldn't all go out at the same

23    time -- or, rather, they would take turns to approach the doorway.  They

24    could get a little more air.

25            And when I asked for permission to wash their shirts -- well,

Page 1046

 1    these were people I knew from before, Tomalovic [phoen], Fink, and Rudi.

 2    These were people who attached a lot of importance to hygiene.  And it was

 3    such -- such a terrible smell, such a terrible stench.  And I think it's

 4    the result of hard work, of sweating, because they'd been wearing the same

 5    shirts for about 15 days.

 6            I don't know where they would go when they had to go to the

 7    toilet.  It wasn't in the building we were in, upstairs.

 8       Q.   Ms. Drljevic, let me interrupt you there, and I apologise for

 9    that, but can you provide us with the basis for your statement that you

10    think it's the result of hard work, of sweating?

11       A.   I know that a lot of them would go away to work.  But it wasn't

12    just the result of hard work and of sweating; the room they were kept in

13    was a very small one.  I know that a lot of prisoners from Doljani and

14    Sovici were brought in there perhaps a month or two before we arrived

15    there.

16       Q.   Again, let me just ask you a follow-on question.  Page 55, line 23

17    of the English transcript, you said:  "I know that a lot of them would go

18    away to work."  Can you elaborate upon that answer and tell the Trial

19    Chamber the basis for that statement.

20       A.   Sometimes I had the opportunity of speaking to them, although this

21    was very rare.  We would exchange a few words.  We couldn't speak to each

22    other for a long time, but they told me that -- well, in fact, it depended

23    on where they went to work.  They said that when they took them to carry

24    out certain tasks, people would give them food, and they wouldn't get very

25    tired.  But there were some tasks that exhausted them.  They would have to

Page 1047

 1    unload bags of some kind.  They had to dig.  Some of them would have more

 2    information about this, some of those who were imprisoned.

 3       Q.   Let me ask you, ma'am, some questions about this person that you

 4    described for us as someone who had worked for the tourist organisation in

 5    Mostar.  And this is page 53, line 17, of the English transcript.  You

 6    told us her name was Gordana.  Do you recall this woman's family name?

 7       A.   Yes.  I didn't know her surname.  Later, I asked a few questions.

 8    They said her name was Begic, her surname was Begic, and that she had

 9    married and that she now lives in Switzerland.  And this concerns the

10    International Red Cross.

11       Q.   You -- again page 53, line 23, you made reference to a delegation

12    from the International Red Cross.  Can you tell us a little bit more about

13    this delegation?  How big was it?  Any of the members of that delegation

14    that you knew, et cetera?

15       A.   That's the organisation -- or, rather, the delegation for which

16    Gordana Begic translated.  There were three or four of them, but she's the

17    only one I knew.  And they were allowed to enter the building and register

18    the women alone.  At that time, there were only three of us.  Previously,

19    two women had returned home.

20       Q.   Ms. Drljevic, again as reflected on page 53, commencing at line 23

21    and running through line 25 of the English transcript, you indicated that

22    there was a delegation from the International Red Cross and they were

23    attempting to establish contact with Ante Prlic, Valentin Coric, and

24    Jadranko Prlic.

25            Ma'am, you've told us about Ante Prlic.  My question for you is at

Page 1048

 1    that time - that is the time you were in Ljubuski prison - did you know

 2    who either Valentin Coric or Jadranko Prlic were?

 3       A.   Well, I knew that Valentin Coric was either a commander or a

 4    high-ranking official in the police, and Jadranko Prlic was the president

 5    of HZ HB of the Croatian Community of Herceg-Bosna, or he was perhaps the

 6    Prime Minister.  I don't really know.  I wasn't too bothered by this,

 7    although later on I had the time to sit down and examine these matters,

 8    but I wasn't interested.  But I do know that these were people of

 9    importance.  I don't think it's difficult for the Court to establish the

10    duties that they had to perform at that period of time.

11       Q.   Ms. Drljevic, during the time period that you were at the Ljubuski

12    prison, did you have any type of contact or communications with any

13    authorities?

14       A.   No.  A few days later, after the International Red Cross had come

15    to visit, Dr. Suko, a gynaecologist from Jablanica, appeared.  Dr. Suko

16    and Darinko Tadic, who at the time was the minister for displaced persons

17    or for the welfare policies, I don't know the exact name.  I don't know

18    who else was with them.  Perhaps another two individuals.

19       Q.   Let me -- sorry to interrupt again.  When you say that Darinko

20    Tadic was at the time the minister for displaced persons or for welfare

21    policies, do you know with which government or agency or entity Mr. Tadic

22    served as this minister?

23       A.   Well, this concerns Herceg-Bosna, but the military, civilian, and

24    executive authorities were intertwined.  It was probably the Herceg-Bosna

25    government that is concerned.  And I say "probably," because I didn't look

Page 1049

 1    into these things.

 2       Q.   Ms. Drljevic, you told us earlier this afternoon that you remained

 3    in the Ljubuski prison until 8 June, 1993; is that correct?

 4       A.   Yes.

 5       Q.   Can you recall the events of 8 June, 1993; and if so, can you

 6    please tell us what happened on that day.

 7       A.   Before the 8th of June, and with your leave, I'd like to say that

 8    I asked Mr. Tadic, since this was an unofficial conversation and Dr. Suko

 9    had given me some kind of drops, and Mr. Tadic said he'd been on the left

10    bank in the army headquarters and had spoken to my commander, so since

11    this is what he said, I asked him whether I could write a message.  I just

12    jotted down a few sentences to the effect that the conflict should be

13    solved in a peaceful manner through negotiations.  And he accepted to

14    render this service.  It was just a few sentences, I have already said,

15    but a few days later, perhaps one day or two days later, a small white car

16    came to a halt.  It said "FO" on the car - it was probably some sort of an

17    Italian inscription - and a young man came out, and he started threatening

18    Bojana, who is a Slovenian by nationality.  He said he would kill her if a

19    message was sent to someone in Mostar again.  And it was at that point in

20    time that I realised that the message had been taken to Grude, because

21    that young man said he had come from Grude.

22            I realised that he had never delivered the message to the person

23    it had been intended for.  I checked this with the Hujdur brothers later

24    on and they told me that they had never received a message of any kind

25    from me.

Page 1050

 1            And as far as the 8th of June, 1993, is concerned, well, I don't

 2    know.  Perhaps it was in the morning, before noon.  Josip Marcinko and

 3    Berislav Pusic appeared.  Marcinko was very angry.  He said we should get

 4    packed immediately and that they would take us -- that they were taking us

 5    to the heliport.  They said that our personal possessions could be

 6    delivered by van later on.

 7            Berko Pusic wanted to know who Spomenka was.  He said -- or he

 8    told me that my relative was saying hello to me.  She had been staying

 9    with my friends in Split, in Kastelj [phoen], near Split.  I then reminded

10    him that I had visited him one year earlier when he was enrolled in the

11    law faculty.  I think that was the case.

12            Perhaps the military part of the organisation for locating

13    displaced persons was involved.  Well, I can't really say what the

14    position was since my father left the Bileca camp, and he registered in

15    this office, in some sort of office for assisting victims, which was in

16    the surgical department near Miroslav Bosnjak's office.  I reminded him of

17    this.  On one occasion I had seen him, and on another occasion I had seen

18    Damir Sipar, and when I was searching for my father, I didn't know that he

19    was in Bileca.  That was in June, 1992.  I also told him that I knew him

20    from before the war, by sight.  He would often socialise with Ramiz

21    Djinovic in front of the Hotel Neretva, and with someone called Bozovic,

22    if I'm not mistaken.  He was the director of a factory in Mostar.

23            After that, he told me that Kemo Bakija was killed.  Bakija is the

24    last name.  And that Ramiz Djinovic had lost his leg.  He saw him when he

25    was transported someplace, I don't know where, but somewhere away from the

Page 1051

 1    left bank.

 2            He also said that there was a possibility for all of us to be

 3    released soon and that that was the reason why they moved us to Heliodrom.

 4            JUDGE ANTONETTI: [Interpretation] Yes.

 5            MR. IBRISIMOVIC: [Interpretation] I think there's a mistake in the

 6    transcript.  When the witness was speaking about first visiting Mr. Pusic,

 7    she said that she wasn't sure whether this was the military or civilian

 8    section, and only the military section or department is recorded in the

 9    transcript.  This is page 59, line 23.

10            MR. MUNDIS:

11       Q.   Ma'am, if I could just -- I thank my colleague for that correction

12    to the record.

13            Ma'am, if I could just ask you, on a number of occasions in the

14    past few moments you've used the pronoun "he."  "He" saw this, "he" told

15    me this.  I would ask you if you could please use the name of the person

16    to whom you're referring rather than the use of the pronoun "he," which

17    can be rather confusing when we go back to review the written transcript

18    in the future.

19            Let me ask you -- let me --

20       A.   I hope that -- this portion where I said "he," when I kept using

21     "he," I was referring to Berko Pusic then.

22       Q.   Just so that we're clear, ma'am, you've told us that on 8 June,

23    1993, Mr. Pusic, along with Josip Marcinko, or Mr. Marcinko, came to

24    Ljubuski prison; is that correct?

25       A.   Yes.  Concerning Josip Marcinko, I knew that he was highly

Page 1052

 1    positioned, that he was a man of influence, that he was high up in the

 2    military police at the faculty of mechanical engineering.  This is what I

 3    knew at the time.  However, I cannot vouch for this.  When I say I knew

 4    this, this means that I heard it from somebody.

 5       Q.   What happened after these two individuals spoke to you at the

 6    Ljubuski prison?

 7       A.   After that, we immediately got ready, and they boarded us into

 8    some kind of a van, and then they drove us to Heliodrom.

 9       Q.   Do you recall approximately what time and on what date you arrived

10    at Heliodrom?

11       A.   It was the 8th.  I can't remember the exact time, but it was

12    extremely hot.  We sat in some kind of a van, and the sun was very strong.

13      We could feel it through the windows.  So it could have been in the

14    afternoon.

15       Q.   And again, Ms. Drljevic, when you say the 8th, can you tell us

16    what month and year?

17       A.   It was the 8th of June, 1993.  I apologise.

18       Q.   When you say "we" -- you've made several references to "we were

19    taken," "they boarded us" into some kind of a van.  Who went with you from

20    Ljubuski prison to Heliodrom?

21       A.   It was the military policemen, two or three of them.  I'm not

22    sure.  They went with us from Ljubuski to Heliodrom.

23       Q.   And when you say "us," to whom are you referring?

24       A.   There were Selma, Bojana, and I there, because Mirna and Mirzeta

25    -- prior to that, Mirna was taken away by the secretary of Mladen Misic.

Page 1053

 1    As for Mirzeta, some woman called Jagoda, where she used to work before

 2    the war, took her away.  She was from Stolac.  Before the Red Cross people

 3    arrived, because they were not registered by the Red Cross.

 4       Q.   Now, Ms. Drljevic, can you tell us where you were taken at the

 5    Heliodrom?

 6       A.   We travelled on the road along Varda, the Varda hill, which is a

 7    hill above Heliodrom.  We went through the gate, and then when we handed

 8    over to the guards all of our belongings, they locked it up somewhere, and

 9    then later on they returned it back to us, the jewellery and metal items

10    that we had on us.  And then they took us to the attic of a building which

11    later on I heard was referred to as the central building.  There in the

12    Heliodrom, before the war, there was a military high school for air force

13    students.

14       Q.   Prior to the time that you were taken there on the 8th of June,

15    1993, had you ever been on the Heliodrom complex before?

16       A.   When I was a child, when I was a student, we would go there to

17    visit the school, but I did not memorise the buildings and where they were

18    located.

19            MR. MUNDIS:  Mr. President, with the assistance of the Registry, I

20    would ask that the witness be shown the bundle of documents that's marked

21    P9020.  I would ask that we go to page 6 and that the witness be shown the

22    photograph on the bottom of page 6, which bears ERN number 02034740.

23       Q.   Ms. Drljevic, do you see an image in front of you on the screen?

24       A.   I see a document on my screen.  Not an image, just a document.

25       Q.   My correction:  It's page 12.  Ms. Drljevic, do you see an image

Page 1054

 1    now, a photograph?

 2       A.   Yes.

 3       Q.   If we could please focus in on the lower photograph.

 4            Ma'am, do you recognise what you see in the photographs in front

 5     -- or the photograph in front of you, which, again for the record, bears

 6    ERN number 02034740.  Do you recognise that, ma'am, what you see in the

 7    picture?

 8       A.   Yes.  Yes.

 9       Q.   Can you --

10       A.   I can recognise what's on the picture, but back then there were no

11    cars there.  This is the building to which they took me on the 8th of

12    June, 1993.

13       Q.   This --

14       A.   We were taken to the attic and housed there.

15       Q.   Okay.

16       A.   These are the windows that are smaller than the ones on the ground

17    floor and on the first floor, and they, according to a man who had been

18    imprisoned there from 1992 and who at that time was free - his name was

19    Novica, he was a Serb - he said this was remodelled.  Up until 1992, this

20    was just an attic where they kept their uniforms.

21       Q.   Ms. Drljevic, if I can just -- I apologise for interrupting you.

22    There are a number of buildings that are visible in this photograph.  Can

23    you please describe for us the building you're referring to.

24       A.   The first building on the right.  Just a minute, please.  Most

25    likely the windows in the middle.  There's something just below the

Page 1055

 1    window.  Perhaps that window.

 2            JUDGE ANTONETTI: [Interpretation] Well, could you please use the

 3    pointer to show us the place on the screen.

 4            THE WITNESS: [Interpretation] This building here.  Just a minute,

 5    please.  Most likely this window and this one, or this and the one on the

 6    other side.

 7            The cars were not there then.  This here is a playground.

 8            MR. MUNDIS:

 9       Q.   Excuse me, ma'am.  Perhaps if Mr. Registrar could assist, I

10    believe -- if we could have the witness mark on the photograph, if that's

11    possible, and then we'll capture that image.

12            Okay.  Witness, can you please describe for us the two Xs that

13    you've just made, what those marks refer to.

14       A.   I'm not sure, but I think that if this is the middle of the

15    building, then this should be the window of the room where I was housed

16    in, because, as one would come up the stairs, it would be on the east

17    side.  This here is east.  So that means that this is the room facing

18    straight.  And then there was a next room -- there was a room next to it

19    with two or three windows, I'm not sure.  But I think that most likely

20    there were two windows, because as one would get to the landing from the

21    stairs, this room was straight ahead, and to the right was a room where

22    they stored old uniforms.  I think that I marked this correctly.

23       Q.   Okay.  And again for the record, the two Xs mark the two rooms

24    that you've just been referring to in the attic of this building; is that

25    correct?

Page 1056

 1       A.   No.  No.  This is referring to the two windows of one room.  This

 2    is what we marked.  And I'll use a circle to mark the windows of another

 3    room.

 4       Q.   I would ask the usher to just remain there for a few more moments.

 5    I'm going to ask you to mark a few other things on this photo.

 6            Ms. Drljevic, during the time that you were in Heliodrom, were

 7    other people also kept in the same building that you were in?

 8       A.   Yes.  On the ground floor and on the first floor there were men.

 9    On the ground floor there were many people from Sovici and Doljani, and on

10    the first floor there were mostly men from Mostar in one part, and in the

11    other part were members of the HVO who were there because they had been

12    sentenced for committing a crime or a misdemeanour.  They were there

13    because of stealing.  There was a woman there.  Her name was Gosta, and he

14    was Sabanac.  He kicked her out of her apartment, and then he was in a

15    room below her.  These rooms in the corridor were separated.

16       Q.   Ma'am, if -- if -- I'm going to -- I'm going to ask you to mark

17    these different areas of the building if you're able to do so.  I would

18    ask you to mark by simply underlining the windows of the area on the

19    ground floor where people from Sovici and Doljani were kept.

20       A.   I can't say exactly which window, but it was in this portion of

21    the building.

22       Q.   Again --

23       A.   So looking towards the building, to the left.  And as one entered

24    the building, it was to the right.

25       Q.   Okay.  If you could please -- it's hard to see.  Could you please

Page 1057

 1    underline the window or the windows that you're referring to on the ground

 2    floor.

 3       A.   [Marks].

 4       Q.   Now -- now, Ms. Drljevic, you've also mentioned on the first floor

 5    there were mostly men from Mostar in one part.  Again, can you underline

 6    with a single line under the windows in the area where the men from Mostar

 7    were detained.

 8       A.   [Marks].

 9       Q.   Now, do you recall or can you see in this photo where the men from

10    the -- who were members of the HVO who were kept there because they had

11    been sentenced were detained?

12       A.   [Marks].

13       Q.   And can you please describe for us the marking that you just made

14    to indicate where the people who were members of the HVO were kept.

15       A.   As one went up the stairs, up the stairs, then, to the right,

16    which means below our windows when facing the building, there was an area

17    closed off with a metal door.  The landing was open, but to the right was

18    the metal door behind which were members of the HVO sentenced for various

19    crimes or violations.

20            I know that a young man called Gosto was there because he had sold

21    someone ammunition or weapons, and this is what he had been charged with.

22    And then there were also people who had stolen things.

23            In November of 1993, deputy commander from Ljubuski, Santic, was

24    also brought here.

25       Q.   Now, Ms. Drljevic, before we move our attention away from this

Page 1058

 1    photograph, are there any other buildings or locations depicted on this

 2    photograph that you have any knowledge about?

 3       A.   I think that this low building -- I'm not sure any longer whether

 4    it's this low building or the building next to it, because I think there's

 5    another even lower building here.  But I think it was the first low

 6    building where warden of the camp was, Stanko Bozic, or camp commander.

 7            The building next is -- I don't know what was housed in that

 8    building, but I know that this is where, in September, Josip Vrdoljak

 9    interrogated me.

10       Q.   Ma'am, if you could please circle, or indicate by circling, the

11    building that you believe was where the warden of the camp, Stanko Bozic

12     -- or the camp commander, Stanko Bozic, was located.

13       A.   [Marks].

14       Q.   And again, for the record, can you please describe that building

15    by indicating to us what colour it is in the picture.

16       A.   It's white in this photograph, with a grey roof made of material

17    called Salonit.  I think it was one storey, a one-storey building.

18       Q.   Thank you, Ms. Drljevic.

19            MR. MUNDIS:  I would ask, Mr. President, that this image be

20    captured with the markings made by the witness.  Perhaps -- if the Chamber

21    wants the witness to perhaps sign the document, or sign the photo and/or

22    date the photo, we could do that as well.

23            JUDGE ANTONETTI: [Interpretation] Well, so far witnesses have sort

24    of authenticated their markings.  I shall ask you, madam, to write your

25    name electronically.

Page 1059

 1            THE WITNESS: [Marks].

 2            JUDGE ANTONETTI:  [Interpretation] I don't know that -- the

 3    witness has put her name in the lower right corner.

 4            MR. MUNDIS:  And again, Mr. President, we would ask that this

 5    document be captured and that it receive an IC number or an "In Court"

 6    number.

 7            JUDGE ANTONETTI: [Interpretation] Please do your work,

 8    Mr. Registrar.

 9            THE REGISTRAR: [Interpretation] Thank you.  This is the first IC

10    document:  00001.

11            JUDGE ANTONETTI: [Interpretation] How many zeros, Mr. Registrar?

12            THE REGISTRAR: [Interpretation] Four 0s before the 1, Your Honour.

13            JUDGE ANTONETTI: [Interpretation] You will notice that you have

14    four 0s before the 1.

15            MR. MUNDIS:  Thank you, Mr. President.

16       Q.   Now, Ms. Drljevic, can you please tell us, you've described and

17    you've marked the photograph where it was that you were taken when you

18    arrived in Heliodrom.  Can you please tell us what the conditions were

19    like in the room when you were first brought into the room.  What did you

20    see, what was in the room, et cetera?

21       A.   At the Heliodrom, we were received and taken to the room by a

22    guard.  He was a policeman, and his surname was Skender.  He took us into

23    a room, and while we were passing by we saw several women in another room,

24    but the room was closed, our room was closed.  All it had was a small

25    window, and he said that we were not to communicate with the other women.

Page 1060

 1    He was very strict in saying that.  And he also told them that.  So that

 2    if we needed to go to the toilet, for instance, we had to wait for him to

 3    come to lock them up in their room and then let us out.  And this would go

 4    on for two or three days.  And then they opened up the room and said that

 5    we could communicate with the other women there.

 6       Q.   Ms. Drljevic, before I forget, can you please tell us how long in

 7    total you remained in Heliodrom after arriving there on 8 June, 1993.

 8       A.   Until the 17th of December, 1993.  From the time we were detained

 9    until the time we were released, it was 222 days.

10       Q.   Now, ma'am, you indicated that there were already some women in

11    the attic of this building when you were first taken there.  Do you recall

12    approximately how many women were already in Heliodrom in the attic of

13    this building when you arrived there on the 8th of June, 1993?

14       A.   Five.

15       Q.   Do you remember the names of any of those other five women?  And

16    if at any point in time, ma'am, that you think for the privacy or to

17    protect those other people, we need to go into private session, we'll ask

18    the Trial Chamber to do that.

19       A.   Well, I think only if we're going to speak about people in greater

20    detail, then perhaps, but if we're just going to mention the names, maybe

21    it's not necessary.

22       Q.   We'll start with the names -- we'll start with the names --

23            JUDGE ANTONETTI: [Interpretation] These five women whose names you

24    are about to mention, were any of these women victims of abuse, or were

25    these women merely detained?

Page 1061

 1            THE WITNESS: [Interpretation] Well, they were those who were

 2    victims.

 3            JUDGE ANTONETTI: [Interpretation] In that case, we shall move into

 4    private session for a few seconds.

 5                          [Private session]

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  (redacted)

25  (redacted)

Page 1062











11    Pages 1062-1064 redacted. Private session.















Page 1065

 1                          [Open session]

 2            THE REGISTRAR: [Interpretation] We are back in open session, Your

 3    Honour.

 4            JUDGE ANTONETTI: [Interpretation] Just for the few minutes we have

 5    left, I'd like to turn to Mr. Mundis.  Tomorrow, how much time will you

 6    need for your examination-in-chief?

 7            MR. MUNDIS:  Mr. President, I'm going to be reviewing the

 8    transcripts and my notes overnight.  I will certainly attempt to move as

 9    quickly as possible.  As the Trial Chamber undoubtedly is aware, the

10    witness has given us a full and rather detailed testimony today.  I

11    realise that we're already over the time we'd estimated in our 65 ter

12    summaries.  I would hope to be done as quickly as possible.  I don't

13    believe it will take more than one hour in the morning, but I'm very

14    hesitant to make any type of estimates at this point in time until I've

15    had a chance to fully review the transcript and the notes.

16            JUDGE ANTONETTI: [Interpretation] Very well.  Second question:

17    You told us, as I had asked you, you did inform us about those documents

18    you wished to introduce.  I've counted some of these documents which could

19    be shown to the witness.  Do you intend showing these documents to the

20    witness or not?

21            MR. MUNDIS:  Again -- again, Mr. President, we'll be reviewing

22    that issue, and pursuant to the guidelines issued by the Trial Chamber

23    last week, we are constantly striving to reduce the number of exhibits.  I

24    don't anticipate that all of those exhibits will in fact be shown to the

25    witness, and as the Trial Chamber probably is also aware we produce the

Page 1066

 1    lists and the exhibits prior to the time the witness actually comes to The

 2    Hague and so, following proofing, some of the exhibits we might have

 3    listed for a witness we might in fact not be showing to the witness

 4    following proofing, and as well, as I indicated, we're constantly trying

 5    to reduce the number of exhibits.  So I can't be certain whether -- which

 6    exhibits will be shown but I can assure you that not all of those exhibits

 7    will be shown to the witness tomorrow morning.

 8            JUDGE ANTONETTI: [Interpretation] Very well.  There are a number

 9    of exhibits, some of which have been written by the witness herself.  Some

10    of the letters are signed by the witness.  I would like to remind you of

11    the fact that if the exhibits are not shown to the witness in the presence

12    of the witness, there will be no question afterwards of filing a written

13    motion for these exhibits to be tendered into evidence.  I hope you have

14    understood me well.

15            MR. MUNDIS:  Fully, Mr. President.

16            JUDGE ANTONETTI: [Interpretation] Very well, then.

17            Mr. Karnavas, you have a few seconds.

18            MR. KARNAVAS:  Just one second.  I didn't want to interrupt

19    Mr. Mundis, but on page 57, line 17, there might have been a

20    mistranslation.  It was Prime Minister instead of president of the

21    government.  If the record could be checked.  I'm not saying it was for

22    sure, but I didn't want to interrupt the flow.  But page 57, line 17.

23            But one other point, if I could just -- maybe I could assist a

24    little bit.  It might be better if, after the witness points to something,

25    or marks, for the lawyer to simply say, "Let the record reflect ..."  We

Page 1067

 1    can move a little quicker that way, Your Honour.  Thank you.

 2            JUDGE ANTONETTI: [Interpretation] Very well.  It is now ten

 3    minutes past seven.  As you know, we shall meet again tomorrow morning at

 4    9.00.

 5                          --- Whereupon the hearing adjourned at 7.07 p.m.,

 6                          to be reconvened on Wednesday, the 3rd day

 7                          of May, 2006, at 9.00 a.m.