Tribunal Criminal Tribunal for the Former Yugoslavia

Page 8753

 1                           Tuesday, 1 July 2008

 2                           [Open session]

 3                           [The witness entered court]

 4                           [The accused entered court]

 5                           --- Upon commencing at 8.37 a.m.

 6             JUDGE ANTONETTI: [Interpretation] Madam Registrar, could you

 7     please call the case.

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

 9     number IT-03-67-T, the Prosecutor versus Vojislav Seselj.

10             JUDGE ANTONETTI: [Interpretation] Thank you, Madam Registrar.

11             Today is Tuesday, July 1st, 2008, and I greet our witness.  I

12     welcome Madam Prosecutors, and I welcome Mr. Seselj as well as everyone

13     helping us.

14             Witness, will you please stand up.  Could you please give me your

15     name, surname, and date of birth.

16             THE WITNESS: [Interpretation] My name is Redzep Karisik, and I

17     was born on the 13th of July, 1952, in Sjenica in Serbia.

18             JUDGE ANTONETTI: [Interpretation] Do you have a job at the

19     moment?

20             THE WITNESS: [Interpretation] No, I'm not employed at all.

21             JUDGE ANTONETTI: [Interpretation] Are you unemployed or retired?

22             THE WITNESS: [Interpretation] I'm unemployed and registered at

23     the job centre.  I want to retire.

24             JUDGE ANTONETTI: [Interpretation] Very well.  Have you already

25     testified in front of an international court or maybe a domestic court

Page 8754

 1     regarding the events that occurred in the former Yugoslavia or is this

 2     the first time that you will testify?

 3             THE WITNESS: [Interpretation] No, today's the first time I am

 4     testifying.

 5             JUDGE ANTONETTI: [Interpretation] Very well.  Would you please

 6     read the solemn declaration.

 7             THE WITNESS: [Interpretation] I solemnly declare that I will

 8     speak the truth, the whole truth, and nothing but the truth.

 9                           WITNESS:  REDZEP KARISIK

10                           [The witness answered through interpreter]

11             JUDGE ANTONETTI: [Interpretation] Thank you.  You may sit down.

12             THE WITNESS: [Interpretation] Thank you.

13             JUDGE ANTONETTI: [Interpretation] May I give you some information

14     on what will happen now.

15             You will be asked questions put to you by the Prosecutor.  I'm

16     sure that you have met Ms. Biersay while preparing for this hearing.

17     Ms. Biersay has one hour and thirty minutes for questions.  After that,

18     Mr. Seselj, who is on your left, will also put questions to you, and this

19     will be the cross-examination.  The three Judges on the Bench in front of

20     you can also intervene and ask questions at any time.

21             Please try and be very specific in your answers.  If you do not

22     understand the meaning of a question, ask for the person putting the

23     question to you to reformulate it.

24             Furthermore, you have just made a solemn declaration, which means

25     that now you are a witness of justice, you are in the hands of justice.

Page 8755

 1     You have undertaken, with the solemn declaration, to say the truth and

 2     only the truth.

 3             Furthermore, we will have 20-minute breaks every hour and a half

 4     so you can rest, and we also need that break in order to change the audio

 5     and videotapes.  However, if at any moment you feel ill at ease, just

 6     raise your hand and I will break, I'll make a break.

 7             Also, if you have a question, just ask the Judges.

 8             I want to tell you all this so we will have a smooth hearing.

 9             Ms. Biersay, I'll greet you once again, and you have the floor.

10             MS. BIERSAY:  Thank you, Your Honour.

11                           Examination by Ms. Biersay:

12        Q.   You described that you were born in Serbia; is that correct?

13        A.   Yes.

14        Q.   Where did you grow up?

15        A.   I grew up in Serbia until I was 15, in Sandzak.

16        Q.   And where did you go after you turned 15?

17        A.   Then I went all over Yugoslavia.

18        Q.   And could you describe for us generally those areas that you went

19     to?

20        A.   Yes, I can.  Banja Luka, that's in Bosnia; Kutina in Croatia;

21     Zajecar in Serbia, Kladovo -- I participated in work campaigns, so I'm

22     familiar with all of Yugoslavia.

23        Q.   Where did you have your education, in what area?

24        A.   Well, I completed the building construction school in Banja Luka.

25     I also engaged in sport, and I was busy with sports and with building

Page 8756

 1     construction.

 2        Q.   Where have you spent the majority of your life, in what area?

 3        A.   In Mostar.

 4        Q.   Well, do you live in Mostar now?

 5        A.   Well, I go here and there, but I'm in Mostar, yes.

 6        Q.   For how long did you live in Mostar?

 7        A.   Thirteen years.

 8             THE INTERPRETER:  Thirteen, the interpreter is not sure.

 9             MS. BIERSAY:

10        Q.   I'm sorry.  For how many years did you live in Mostar or have you

11     lived in Mostar?

12        A.   Thirty years.

13        Q.   And what profession did you have before you described the Court

14     you no longer have a job?  What were you doing before?

15        A.   I did all sorts of things, all sorts of things; building

16     construction, I participated in youth work campaigns.

17        Q.   I would like for you to describe to the Trial Chamber the ethnic

18     makeup of the Mostar area before the war started.  Now, you described

19     that you were born in Serbia.  Are you Serbian or are you something else?

20        A.   Well, at the time I was a Muslim.  Now I'm a Bosniak.  Before the

21     war, we lived as one.  You didn't know who was a Serb, who was a Muslim,

22     who was a Croat, until this terrible war came along.  And then when those

23     so-called clever men caused a war, it was only then that we found out who

24     was what.

25        Q.   Is there a river that flows through Mostar?

Page 8757

 1        A.   Yes, the River Neretva.

 2        Q.   And could you describe to us -- you just talked about Muslims and

 3     Serbs in the Mostar area.  Were there also Croats in the Mostar area?

 4        A.   Yes, yes, yes.

 5        Q.   Could you describe for us generally where they lived in relation

 6     to the river that flowed through Mostar; right bank, left bank, and so

 7     forth?

 8        A.   Yes.  For the most part, the Croats lived on the right bank of

 9     the River Neretva, and the Serbs and Muslims and Croats lived on the left

10     bank.  There were people on all sides, in Vrapcici, Bijelo Polje there

11     were mostly Serbs and Croats and Muslims.  And in Sehovina, south of

12     Mostar, it was the same.  There were mostly Muslim and Croats and down

13     there in Buna and further on, and up there in Nevesinje, Bileca and

14     Gacko, that's how it was.

15             MS. BIERSAY:  Madam Registrar, could we please have 65 ter

16     number 4273, please.

17        Q.   While we're waiting for the map, could you describe to the Trial

18     Chamber what military presence was in the Mostar area before the war

19     started in 1992?  Were there any military barracks in the area?

20        A.   Yes, there were military barracks in the town of Mostar.  There

21     were two, the north camp and the south camp, two barracks in town.

22        Q.   Do you know if there was a military airport in or around Mostar?

23        A.   There was a military airport near Sokol.  The airport was down

24     there in Soko, Rodoc.

25        Q.   You've just described the military presence in Mostar before the

Page 8758

 1     war started.  Where, specifically, did you live in Mostar before the war

 2     started?

 3        A.   In the suburb of Dalejka [phoen].

 4        Q.   Were there any type of military shooting range or anything like

 5     that near your home?

 6        A.   Yes, yes, there was, in Gornji Zalik, not far from the area I was

 7     familiar with.  That was the first automatic shooting range in the former

 8     Yugoslavia.  It was a perfect automatic shooting range.

 9        Q.   And given the proximity of the shooting range to your home, did

10     you have any opportunities to interact with the JNA soldiers who would

11     come there?

12        A.   Yes, with the officers and the soldiers, the privates, because I

13     lived nearby, nearby the shooting range, about 100 or 200 metres away

14     from it.  There were five soldiers working there to maintain the shooting

15     range.

16        Q.   Did you do compulsory military service in the JNA?

17        A.   Yes, I did, in 1970 and 1971, in Tito's Guard in Valjevo.

18        Q.   So you just described that you were familiar with the types of

19     JNA soldiers who would come to the shooting range.  Were you also

20     familiar with the types of JNA soldiers who would be in and around town,

21     connected to the barracks?

22        A.   Well, I knew the four soldiers employed on maintaining the

23     shooting range because there was a playing field there and we would --

24     two were from Novi Sad, one was from Belgrade, and the fourth was from

25     Drvar.  They were active-duty soldiers.  They served for 18 months.

Page 8759

 1     Later on, it was reduced to 15.

 2        Q.   I'd like to now direct your attention to approximately April of

 3     1992.  Around that time, did you notice any JNA reservists coming into

 4     the area?

 5        A.   Yes, they did come.

 6        Q.   And what did they look like?  Did they look like the JNA soldiers

 7     that you were already familiar with?

 8        A.   They looked like JNA soldiers by their uniform, but not by their

 9     behaviour.  And what they looked like, they had long beards and long

10     hair, and they weren't as disciplined as the regular soldiers.

11        Q.   And when you say they weren't as disciplined as the regular

12     soldiers, could you describe to the Trial Chamber what you mean by that?

13        A.   Well, what I mean is the following:  Real soldiers had their hair

14     cut and they were polite and well-behaved.  These men didn't have any

15     commanders.  They obeyed no one.  They did whatever they wanted, these

16     reservists.

17        Q.   You described that they had the long beards and hair.  Did they

18     seem different to you in any other way; for example, through their

19     accents?

20        A.   Well, they each spoke their own -- in their own accent.  I can

21     tell what people in Serbia speak like, talk like.  I can speak that

22     dialect, and so I could tell.

23        Q.   Did all of these JNA reservists have the Serbian dialect or were

24     there different kinds of dialects spoken by them?

25        A.   Different.

Page 8760

 1             THE ACCUSED: [Interpretation] Objection.  This sort of question

 2     can't be put.  It's not a Serbian dialect, it's an Ekavian dialect.  The

 3     Serbs speak Ekavian and Ijekavian, so you can't call the Ekavian dialect

 4     the Serbian dialect.  And the Muslims in Sandzak also speak the Ekavian

 5     dialect.

 6             JUDGE ANTONETTI: [Interpretation] You already said this.

 7     Ms. Biersay, please take what Mr. Seselj said into account.

 8             MS. BIERSAY:  Yes, Your Honour.

 9             JUDGE ANTONETTI: [Interpretation] The witness might complete

10     that.

11             THE WITNESS: [Interpretation] Well, in Tito's time, some people

12     called you "Comrade," other people called you "Sir."  I think that the

13     people spoke every dialect.  Serbia speak Ekavian, Montenegro, Bosnia.

14     That's not just one nation.  All people, whoever lived in Serbia, spoke

15     Ekavian.  I can't say that Serbs and Muslims did not speak Ekavian or

16     Roma.  They all spoke the same.

17        Q.   Mr. Karisik, where were these JNA reservists that you describe?

18     Where were they stationed, as far as you could tell?

19        A.   The south camp and the north camp and Vrapcici.

20             JUDGE ANTONETTI: [Interpretation] Witness, there's a small detail

21     that emerged.  I know we've seen a good number of witnesses, but I've

22     never asked them this question.

23             Obviously, you're someone who travelled a lot in Serbia, you know

24     Serbia.  So these reservists who came in town and who had beards, before

25     these events and before the war, could you tell us whether in Serbia men

Page 8761

 1     were used to wear beards, it was quite commonplace, and to see someone

 2     with a big beard was very normal?  Could you tell us whether those people

 3     who came with those long beards came into Mostar but were very different

 4     from the people you were used to seeing before?

 5             THE WITNESS: [Interpretation] I can answer your question.  I used

 6     to wear a beard, myself.  It was this long [indicates].  But there was

 7     preparation going on for that war, the war was being prepared, and there

 8     were people who didn't cut their hair or shave, and they had hair down to

 9     here [indicates].  And the way they behaved and everything.  If I wear a

10     beard, okay, but I won't be unkempt; I won't be dirty.  I used to wear a

11     beard, too, even though I was a sportsman and participated in youth work

12     drives, I still wore a beard.  But I wasn't preparing for war, because in

13     those reserves, those reservists who came from Serbia, there were also

14     Muslims in the reserves, and as soon as they saw them coming, they fled.

15             JUDGE ANTONETTI: [Interpretation] Ms. Biersay.

16             MS. BIERSAY:

17        Q.   Could I clarify something you just said?  You said that when they

18     saw them coming, they fled.  Who fled?

19        A.   If I had a house, I would have run away.  If I had somewhere to

20     run to, I would have run.

21        Q.   What would you be running away from?  What were people running

22     away from?

23        A.   Well, they were running because they were afraid.

24        Q.   And what were they afraid of?

25        A.   They were afraid because they saw what was happening in Croatia.

Page 8762

 1     There was a war first in Slovenia, then in Croatia, and then it came to

 2     Bosnia.

 3        Q.   You just described the arrival of JNA reservists.  Was there

 4     another wave of military-type people that came after the JNA reservists?

 5        A.   They came and went.  You didn't know who was who, who was doing

 6     what.  Everybody wanted to be in command.  Everybody wanted to have their

 7     say.  And whoever was weaker fled from whoever was stronger.

 8        Q.   I'd like to go back to the JNA soldiers that you got to know

 9     because they were coming to the shooting range next to your house.  Did

10     you ever talk to them about who these different military people were who

11     were coming into the Mostar area?

12        A.   Well, I've forgotten their names.  It was a long time ago, 16 or

13     17 years ago, and I'm sorry.  Well, I'd like to see them again today,

14     I think.

15        Q.   What did they tell you about the people -- the reservists and the

16     JNA soldiers and the other people who were coming into Mostar?  What did

17     the JNA soldiers that you knew say about those people?

18        A.   They said, "It's just the Territorial Defence that's come here.

19     There will be some kind of exercise and it will all be over in a week.

20     It's not going to last long."  That's what they said.

21        Q.   Did that happen or did something else happen?

22        A.   Then the worst happened.  Somebody managed to set -- to start a

23     fire.  They put a cistern in front of the building and then set fire to

24     the thing, and then it all blew up.

25        Q.   Could you tell the Trial Chamber whether or not these JNA

Page 8763

 1     reservists and others were stationed in places like Bileca, Trebinje,

 2     Nevesinje; do you have any information about that?

 3        A.   Well, there is information, but what kind of information, the

 4     active-duty army withdrew when the order came.  The real army withdrew to

 5     Serbia.  That was the order, and the real army withdrew.  Now, who joined

 6     the reservists and who stayed on, they stayed on.  They had weapons,

 7     military weapons.  They had everything the army left behind.  It's just

 8     that the army took away light weapons.  Everything else remained, because

 9     the active-duty soldiers withdrew when the order came for them to do so.

10        Q.   Do you know when they withdrew?

11        A.   I can't remember.

12        Q.   Could you tell the Trial Chamber what the JNA soldiers said about

13     Seseljevci and Red Berets?

14        A.   Well, until they begin doing evil things, there wasn't so much of

15     that.  But as soon as they started doing evil things, then, yes, that's

16     what happened.  There were all sorts.

17        Q.   When you say "all sorts," all sorts of what?

18        A.   All sorts; rape, slaughter, killings, everything.  But until the

19     killing started and -- well, life was normal, you live normally.  But as

20     soon as all that started, all kinds of things started, well, then it was

21     just chaos.

22        Q.   I don't want to focus on what happened as far as crimes yet.

23     What I'd like you to do is to describe for the Trial Chamber what

24     military units or formations were present in Mostar after April 1992.

25        A.   When the army withdrew, the real army, the reservists remained.

Page 8764

 1     And afterwards, those people who joined up with them, the paramilitary

 2     units who nobody commanded.  Everybody wanted to have his own, his own

 3     company to go and fight, loot, kill.

 4        Q.   What paramilitary units were present in Mostar?

 5        A.   Seselj's men, I don't know who commanded them or who was their

 6     vojvoda.

 7        Q.   Mr. Witness --

 8        A.   I don't know who was their vojvoda, but somebody fought to be a

 9     vojvoda.  Now, who the vojvoda was and who gave orders, you, Comrade,

10     know that.

11        Q.   Mr. Karisik, because we have the time that the Trial Chamber just

12     discussed, you have to listen very carefully to my questions and answer

13     just the question so that we can move forward in an efficient manner.

14     Okay?

15        A.   Yes, I can go on talking for a whole night and a whole day if

16     you'll let me.

17        Q.   I know, but we only have 90 minutes and we have to be very

18     efficient.  So my question --

19        A.   Well, you can extend the time, then, and then we can go on,

20     continue on and on.

21        Q.   No, I'm afraid we can't.  So my question to you is :  In addition

22     to the Seselj's men that you described, were there other military

23     formations or units who were present in the area of Mostar, in and around

24     the time period that we're talking about?

25        A.   This is what -- who was there:  The Green Berets, as they were

Page 8765

 1     called, the Seselj's men as they were called, Chetniks, as they called

 2     them, the White Eagles, and who knows what else, what other kind of

 3     soldiers.  And whatever kind of army turned up like that, I would flee, I

 4     would have fled.  You didn't know who anybody belonged to.

 5        Q.   Did you have your family members leave the area of Mostar because

 6     of your concerns?

 7        A.   A colleague of mine, a Croat, suggested that I do that, and I

 8     prepared my -- I got my wife and children ready, and he drove them away.

 9     I couldn't go, but he drove them away.

10        Q.   And why couldn't you go?  Why did you stay?

11        A.   I couldn't go.  I had things to attend to for the company.  I had

12     my duties there.

13             JUDGE ANTONETTI: [Interpretation] Just a moment.  What company

14     were you working for?

15             THE WITNESS: [Interpretation] Vranica.

16             MS. BIERSAY:

17        Q.   And what kind of company was it?  What did they do?

18        A.   A construction firm.

19        Q.   At some point, did it happen that you were forced to work

20     collecting garbage in and around the Mostar area?

21        A.   Yes.

22        Q.   Could you describe for the Trial Chamber how that happened?

23        A.   We were -- we were held for two and a half months in Zalik, Upper

24     Zalik, Lower Zalik, and north camp part of town.  There was Matkovici,

25     and we were there in a collection centre, and from there we would go and

Page 8766

 1     clean garbage and everything else.

 2        Q.   What collection centre were you in?

 3        A.   Some of them were in the shelters.  In Zalik, there are two

 4     shelters.  And some of us went to some houses or went home, but then we

 5     had to report from our homes.

 6        Q.   Let's take one step back for a minute.

 7             You described to the Trial Chamber that at some point, you

 8     were -- you were working with this company that you described; is that

 9     correct?

10        A.   Yes.

11        Q.   And at the same time, you described that people eventually made

12     their way to these shelters.  Could you describe why people were going to

13     shelters in the first place?

14        A.   Well, that was sort of safest for them.  They were safest there.

15        Q.   What were they trying to be safe from?  What were they afraid of?

16        A.   They were afraid.  When the others started looting the houses,

17     they were frightened that they would kill them in the houses.

18        Q.   In addition to looting, was there any type of gunshots heard or

19     were there any kind of shellings in and around the area?

20        A.   Yes, shells were falling from the hills all over, on the left

21     bank and on the right bank too.

22        Q.   And were those things going on at the time people decided to go

23     into shelters?

24        A.   Yes, that's right.

25        Q.   At some point, did the Serb forces take over the left bank of the

Page 8767

 1     River Neretva?

 2        A.   They took control of the left bank straight away, while the real

 3     army was still there, the JNA.  That side was taken.

 4        Q.   And on what side were the shelters?  Were they on the left bank

 5     or on the right bank?

 6        A.   The left bank.

 7        Q.   And where did you live, on the right bank or the left bank?

 8        A.   The left bank.

 9        Q.   After the left bank of the Neretva area of Mostar was taken over

10     by Serb forces, is that when you had to do forced labour?

11        A.   Yes, that's when I went.

12        Q.   Who told you that you had to do this kind of work?

13        A.   Matkovic said, the one that was in Zalik.  He had the warehouse

14     and everything.

15        Q.   And who is he?

16        A.   He was a Serb, and he was the main man down there.

17        Q.   How many people were told that they had to do work that was not

18     their choice?  Do you know, approximately?

19        A.   Well, sometimes there were 50, sometimes 60, sometimes 40,

20     depending on who was able to come.  Some people weren't healthy, they

21     were ill, so they stayed home.

22        Q.   Could you describe for the Trial Chamber what kind of work you

23     were forced to do?

24        A.   All kinds of work.  We cleaned the garbage, took it away; washed

25     the streets; loaded up construction materials, equipment; offloaded,

Page 8768

 1     loaded up, that kind of thing.

 2        Q.   When you did this kind of work, was there anyone guarding you?

 3        A.   Yes.  Two soldiers were there.

 4        Q.   Do you know the names of any of the people who guarded you while

 5     you were forced to do this kind of work?

 6        A.   I've forgotten their names, but they didn't touch us.

 7        Q.   When you were doing this forced work, was there still fighting

 8     going on?

 9        A.   Well, there was shooting up in the hills, but it was quiet in

10     town.

11        Q.   Who is Milan Skoro?

12        A.   Milan Skoro was a former policeman.

13        Q.   And what, if anything, did he do in connection to your forced

14     work that you had to do?

15        A.   He issued orders, telling us where and what we should do.  He

16     would say, "Go there, go over there."

17        Q.   While you were doing this forced labour, did you see any of the

18     units that you talked about; Seseljevci, or Red Berets, or any other

19     units like that?

20        A.   There were, but you couldn't distinguish who was who.  Some had

21     cowboy hats, others had caps.  You couldn't really tell who was who:  Who

22     was commanding people over here and people over there.

23        Q.   You described people going into these shelters.  You said there

24     were two shelters; is that correct?

25        A.   Yes, that's right.

Page 8769

 1        Q.   Do you remember approximately when people started going into the

 2     shelters?

 3        A.   Straight away from the 2nd of April, when the water tank

 4     exploded.  Not two days went by.

 5        Q.   And where is this water tank that you just talked about?

 6        A.   Right up the wall by the barracks, not two metres away in north

 7     camp.

 8        Q.   Approximately how many people would go into these shelters or

 9     into the specific shelter that you're talking about, how many people?

10        A.   There were women and children and men, and 500, 600 in a shelter.

11     Gornji Zalik, Donji Zalik, Upper and Lower Zalik, part of town.

12        Q.   And am I correct in saying that by that, you mean that they came

13     from all the areas around the barracks?

14        A.   The whole area, Zalik, Gornji Zalik, Donji Zalik, and all the

15     settlements 'round about when the shelters were made.

16        Q.   When people first started going into the shelters, were there

17     non-Serbs as well as Serbs?

18        A.   There were Serbs, and Croats, and Muslims, gypsies, anybody who

19     didn't want to go to war.

20        Q.   Did that change after a while?  Were there only non-Serbs who

21     were staying inside the shelter?

22        A.   I was just there for a night in that shelter, and I didn't go

23     anymore.

24        Q.   Where did you go?

25        A.   I was at home, the four of us in houses.  We slept around in

Page 8770

 1     houses.

 2        Q.   When you say "the four of us," are you talking about family

 3     members or other neighbours?

 4        A.   No, neighbours.

 5        Q.   After the water tower you described was blown up, were you taken

 6     into custody for interrogation at the north camp?

 7             THE ACCUSED: [Interpretation] This is completely out of order.

 8     Which water tank was blown up?  A tank truck was brought to north camp,

 9     an explosive was planted there, and then the tank truck was blown up, and

10     otherwise the Prosecutor is posing increasingly leading questions.

11             JUDGE ANTONETTI: [Interpretation] Witness, this water tank which

12     exploded, which is mentioned in the Prosecution's submissions and in the

13     Prosecution's brief, did somebody put an explosive there?  What actually

14     happened?

15             THE WITNESS: [Interpretation] No, it wasn't a water tower.  There

16     was water or fuel, petrol.  We're not talking about a water tower or a

17     water truck.  I wasn't there to fill it up with explosives or planting

18     explosives there.  If it was positioned there, it might have been

19     positioned -- well, explosives or shells or petrol, fuel, might have been

20     put in there, that kind of thing.

21             JUDGE ANTONETTI: [Interpretation] In other words, it's a water

22     tank, it's not a fuel tank?

23             THE WITNESS: [Interpretation] I don't know what kind of tank it

24     was.  Let me put myself right.  It might have been for water.  It might

25     have been for petrol.  It might have been for fuel.  It might have

Page 8771

 1     been --

 2             JUDGE ANTONETTI: [Interpretation] Please proceed, Ms. Biersay.

 3             MS. BIERSAY:  Thank you, Your Honour.

 4        Q.   Did there come a time that you were taken to the north camp for

 5     interrogation?

 6        A.   Yes.

 7        Q.   Who interrogated you there?

 8        A.   I was interrogated by the army, the real army, 14 of us, but then

 9     they let us go.  We spent a night there.  They asked who was shooting at

10     the army.  I didn't know who was shooting.  I wasn't shooting.  If I was

11     shooting -- if I were shooting, I would have been where the shooting was

12     going on.  So don't say I'm a Zenga when I'm not a Zenga.

13        Q.   Do you know anyone with the last name Savic?

14        A.   There's a Savic from Rastani, but I don't know his first name.

15     All I know is that that's his surname, Savic.  He took us to north camp.

16     We spent the night there.  They interrogated us and then they left us go.

17     They sent two to Bileca and they let the rest of us go.

18        Q.   How many of you were taken to north camp for interrogation?

19        A.   Fourteen.

20        Q.   I'm sorry, could you repeat that again?

21        A.   Fourteen.

22        Q.   While you were at the north camp, were you sitting in a chair,

23     were you laying down on a bed?

24        A.   We weren't given anything.  We could just stand like

25     this [indicates] on our knees, with our hands behind our backs, tilted to

Page 8772

 1     the side.  You couldn't even stand straight.

 2        Q.   At some point, now directing your attention to June of 1992, did

 3     you try to leave by going through the town Potoci?

 4        A.   I started to flee from there, I couldn't take it anymore, towards

 5     Jablanica and then, well, to Bijelo Polje, where they captured the four

 6     of us with a Land Rover, and I recognised Mladin Kandic.  He was a former

 7     policeman.

 8        Q.   Did you recognise anybody else?

 9        A.   No, no, I didn't recognise anybody else.

10        Q.   And who were the others that you were travelling with or trying

11     to escape with?

12        A.   [No verbal response]

13        Q.   Mr. Karisik, one minute.  Let me ask you -- what are you looking

14     at?  Are you looking at a statement that you provided to the --

15        A.   No, no, no, I'm looking at Enes Mezet, Omer Hasic and his wife.

16     The four of us started to flee, we started to escape.

17        Q.   And when you were taken by the people that you just mentioned,

18     including this Kandic, is that correct, where did they take you?

19        A.   They took me 19 kilometres away from Mostar towards the north,

20     Rakovac, the post.

21        Q.   When you say "post," what do you mean?  Is it a post office?

22        A.   Yes, post office, the PTT, which was part of the settlement

23     there.  That's where the post office was.

24        Q.   And while you were there with the others, were other people

25     brought in as well as prisoners?

Page 8773

 1        A.   They brought in two more men from Podvelezje.  They caught them

 2     at Rujiste, and they shut them up in a WC.

 3        Q.   And what is Podvelezje?

 4        A.   Podvelezje is a settlement with inhabitants.  Five or

 5     six thousand inhabitants it had.

 6        Q.   Did you at any point while you were being held at the post office

 7     ask Mandzic to let you go?

 8        A.   Since I knew him, I said to him, "Let me go.  I'm gone to look for

 9     my wife and children."  I lied to him just to make him release me.  He said,

10     "A bullet to your head rather than let you go."  "But why?"  He kept quiet.

11             THE INTERPRETER:  The interpreter didn't hear a part of what the

12     witness said after he said "my wife and child," that he had gone looking

13     for them and he lied.

14             MS. BIERSAY:

15        Q.   After you asked to let them go, what did he say to you?

16        A.   Nothing.  He said, "A bullet to your head rather than let you

17     go."

18        Q.   How many days did you spend at the post office, approximately?

19        A.   Three days and three nights.

20        Q.   Where were you taken next?

21        A.   To Sutina.

22        Q.   And what is in Sutina?

23        A.   That's where the cemetery is, the municipal cemetery.

24             MS. BIERSAY:  Your Honours, before us is the map, 65 ter

25     number 4273, which depicts, Konjic, Mostar and Nevesinje and some other

Page 8774

 1     areas.  We'd move for the admission of the map at this time before I

 2     proceed to another map.

 3             JUDGE HARHOFF:  For what purpose?  What is it going to show us?

 4             MS. BIERSAY:  Your Honour, we believe --

 5             JUDGE ANTONETTI: [Interpretation] What is the purpose of showing

 6     us this map?

 7             MS. BIERSAY:  This map before the Court is to orient the Court

 8     with respect to Mostar and the surrounding villages, as described by the

 9     witness, and it includes Vrapcici, which he will address, and the

10     location of Nevesinje, with respect to Mostar as well.

11             JUDGE HARHOFF:  I suggest you wait to seek admission until the

12     witness has provided his information onto the map, because a bare map is

13     worth nothing, in my view.

14             MS. BIERSAY:

15        Q.   Mr. Witness, directing your attention to the map before you

16     that's on your screen --

17        A.   I can see the map very well.  It's like this:  Let me explain to

18     the Trial Chamber.

19             Sutina, that's where -- well, there's a pit there.  Twenty-two

20     were killed.

21        Q.   One minute, please.  One minute, please.  Could you show the

22     Court, by touching the screen, the River Neretva that flows through

23     Mostar?

24        A.   I can do that.  Here [indicates], right by Mostar.

25             MS. BIERSAY:  Is it possible for him to make a mark so we can

Page 8775

 1     capture an annotation?

 2             THE ACCUSED: [Interpretation] Objection.  I think there's no

 3     point in the witness marking the River Neretva, which can be clearly

 4     seen.  It's best if you show us where Sutina is and where Uborak is and

 5     mark that.

 6             THE WITNESS: [Interpretation] That's five or ten kilometres.

 7             MS. BIERSAY:  Madam Registrar, could we now move to 65 ter

 8     number 2863, please.

 9             THE ACCUSED: [Interpretation] Mr. President, does that mean that

10     the Prosecutor has desisted from tendering this document?  What's most

11     important is -- this map is to see where Sutina is, because to be quite

12     honest, I don't know where Sutina and Uborak are, and the witness would

13     show us that.

14             JUDGE ANTONETTI: [Interpretation] Witness, on the map before you,

15     do you see Sutina?

16             THE WITNESS: [Interpretation] It just says "Vrapcici," here.  It

17     just says "Vrapcici."  It doesn't say Sutina.  It doesn't say Uborak

18     either.  Uborak is up there where the military barracks is where there

19     was a rubbish dump next to the barracks.  It doesn't say Uborak it just

20     says garbage dump is.  It doesn't say "Uborak" here.  It just says

21     "Vrapcici," all of Bijelo Polje, all of Vrapcici.  There isn't that place

22     marked here.

23             JUDGE ANTONETTI: [Interpretation] If I understand you well,

24     Vrapcici -- Sutina is next to Vrapcici.

25             MS. BIERSAY:  Your Honour, if I could interrupt for a moment, if

Page 8776

 1     we could have 65 ter number 2863, I think this would assist us all.  The

 2     first purpose of the map was to give us an overall geographical

 3     orientation for the Court.  We're now going to zoom into the specific

 4     area, which is 65 ter number 2863.

 5             It's a pretty dense file, so it's taking some time to load.  So

 6     while it's being loaded:

 7        Q.   Mr. Karisik, could you describe for the Trial Chamber what

 8     happened when you got to Sutina, the Sutina cemetery?

 9        A.   Where the administration of the cemetery was, there was a team

10     questioning people.  And when Kandic got there to be questioned, the

11     people in there said, "They're not for here.  Take them to Vrapcici."

12        Q.   And do you remember the name of the person who said, "They're not

13     for here.  Take them to Vrapcici"?

14        A.   I didn't go inside.  I don't know who was there or how many

15     people there were inside.

16        Q.   Where did you -- where were you taken after they took you from

17     the Sutina cemetery?

18        A.   Along the main road, some 600 or 700 metres down the road, to the

19     stadium in Vrapcici, the changing rooms; locker room, that is.

20        Q.   How big was the locker room where you were taken?

21        A.   Well, the locker room, I didn't measure it, but it was less than

22     30 square metres, all of it together.

23        Q.   When you arrived at the locker room and they took you inside,

24     were there already people inside the locker room?

25        A.   There were 37 men there.

Page 8777

 1        Q.   Were there any women there?

 2        A.   Yes, there were women and children too.

 3        Q.   For how long were you kept in the Vrapcici stadium's locker room?

 4        A.   Six days and six nights.

 5        Q.   And during those six days and six nights, did the number 37

 6     change of the people who were kept in that locker room?

 7        A.   Yes, they brought in people every day and every night.

 8        Q.   And how large a number was there of people in the locker room?

 9        A.   Ninety, in my opinion.

10        Q.   While you were there, did you meet anyone who had been there

11     longer than you had been there?

12        A.   Yes, I did.

13        Q.   And who was that?

14        A.   Omer Brekalo from Kuti Livce.

15        Q.   How long did he say he had been kept in that locker room?

16        A.   Twenty days.

17        Q.   Did you recognise any of the guards who were bringing people in,

18     into the locker room?

19        A.   I only recognised [indiscernible] from Nevesinje.  His name was

20     Mico Bunjas.  He used to work with me in Vranica for 15 years.  I didn't

21     know his real name.  They called him Gunjar, but his name was Misa Vucic.

22     I didn't even know his real name.  We called him Gunjar.  He didn't even

23     see me.

24        Q.   Could you describe for the Trial Chamber what it felt like to be

25     in that locker room with 89 other people in June?  How did it feel?

Page 8778

 1        A.   Well, I longed for death, because before I arrived, 50 Croats

 2     were taken to Bileca, and we thought they would kill us all.  We thought

 3     they wouldn't take us to Bileca to be exchanged.

 4             THE INTERPRETER:  Interpreter's correction, "I expected to die."

 5             MS. BIERSAY:

 6        Q.   While you were kept prisoner in the Vrapcici locker room with

 7     these other 89 people, were you given food, water?

 8        A.   Those six days?  Only once.  On the fourth day when I went to

 9     Podvelezje, I drank and had my fill.

10        Q.   After you'd left the locker room?

11        A.   Yes, after.

12             JUDGE ANTONETTI: [Interpretation] Witness, you say that you drank

13     water, but only after four days.  I'm a bit surprised.  Are you

14     absolutely sure that you could only get a drink once and that you had to

15     stay four days without anything to drink?

16             THE WITNESS: [Interpretation] Yes, I'm sure, only once, only

17     once.

18             JUDGE ANTONETTI: [Interpretation] So if I understood you well,

19     you drank once in four days and you ate once in six days?

20             THE WITNESS: [Interpretation] Yes, that's right.  You understood

21     me well, and I said it right.

22             JUDGE ANTONETTI: [Interpretation] Madam Biersay.

23             MS. BIERSAY:

24        Q.   Could you describe to the Trial Chamber how you were finally

25     taken out of the Vrapcici locker room?  When did that happen?

Page 8779

 1        A.   It was nighttime, about 10.00, 10.30 p.m.  A white van stopped in

 2     front of the door.  A bearded man got out.  He had a helmet on.  He wore

 3     a uniform.  And he said, "You are going to another place."  And we

 4     thought, well, where are we going.  There were five or six of us who were

 5     there together, and he said, "You're going somewhere else."  And we got

 6     into the van.  Five or six of us whom I know got on, and then others got

 7     on as well, 15 or 20, as many as could be packed into the van.

 8        Q.   Where were you in the van; were you in the back or the front?

 9        A.   At the front.

10        Q.   So by "front," you mean the part closer to the driver?

11        A.   Yes, but there was a partition between us and the driver.  We had

12     no contact with the driver.

13        Q.   And what happened next after everyone was crammed into that van?

14        A.   The van started.  We didn't know where we were going.  It wasn't

15     an asphalt road, it was a dirt road; after some ten minutes, that is.

16     First there was this asphalt and then this dirt road or macadam.  And

17     then the van stopped.  The man opened the door, and the people at the end

18     started getting out.  And as they were getting out, this man started

19     shooting them down with bursts of fire.

20             I remember well one who -- one prisoner who got out said,

21     "Dragan, we know each other.  We've known each other for 30 years."  And

22     he just shot him down.  So whoever got out of the van, I don't know how

23     many there were, and I remained.  Are there more?  "Yes, get out."  But I

24     couldn't stand up because my legs were shaking, I couldn't stand up, so I

25     said, "I can't get up.  Kill me here in the van."  Then he swore at my

Page 8780

 1     Ustasha mother.  He slammed the door shut and he said, "We'll kill you in

 2     another way."  And he took me back to Sutina, where I had been first.

 3             The van pulled up.  He said, "Get out."  But I couldn't stand up.

 4     I crawled out on my knees.  There were two of them with beards and

 5     helmets.  It was night.  I didn't know them.  And the one who tied me up,

 6     he spoke Ekavian, Serbian, the way I speak, and that's how I know he was

 7     from Serbia, by his speech.  He used the word "Bre," he swore at my

 8     Ustasha mother, but I am no Ustasha and no Zenga.  I crawled out on my

 9     hands and knees, and I was beaten.  He handcuffed me to the radiator and

10     left.  I said, "Why are you handcuffing me?  You're going to lock the

11     door anyway."  And then he hit me again and left.  I don't know for how

12     long I stayed there handcuffed to that radiator.  He switched the engine

13     on and left in the van.  I was handcuffed by one hand.  I'm sorry, I

14     didn't bring the handcuffs here.  I've kept them as a souvenir, and I

15     wish I'd brought them here to show you.  I managed to wrench it off and

16     escape through the window.  And it was five days later that I was able to

17     eat and drink my fill.

18        Q.   How long did it take you to wrench out of the handcuffs?

19        A.   About ten minutes.  I was fit and strong.

20        Q.   And how did you do it, how did you get out of the handcuffs?

21        A.   I had a little pen knife, so I blocked something so it wouldn't

22     turn, and then I managed to break one of the links in the chain.  So one

23     end of the handcuffs remained on the radiator and the other end on my

24     hand, on my arm, but I managed to break the chain.

25        Q.   Where did you go after you were able to break out of the

Page 8781

 1     handcuffs?

 2        A.   Through the window, through the cemetery, up the hill, and then

 3     to Podvelezje.

 4        Q.   When you left, did you have the part of the handcuffs still

 5     around your wrist?

 6        A.   Yes, until the next day.  They only took it off when I got up

 7     there.  A policeman called Zajko used a needle to take it off.  He

 8     unlocked it with a needle in five seconds.

 9        Q.   After you escaped from the Sutina cemetery, where did you

10     ultimately go after the handcuffs were taken off?  Where did you end up?

11        A.   I went down to Mostar when the BH Army liberated Podvelezje.

12     That's when I went down to Mostar.

13        Q.   Now, I'd like to direct your attention to the map that's before

14     you, which is 65 ter number 2863.  Could you, using --

15        A.   Yes, okay.

16        Q.   Starting at the bottom --

17        A.   Yes, yes, Sutina, Vrapcici stadium, Vrapcici up there, Uborak.

18     It's marked up there, so now you can tell everything, where everything

19     is.

20        Q.   The markings that are on this map, are they accurate?  Is that

21     where Uborak is; is that where Vrapcici stadium is?

22        A.   Well, it's marked here, "Uborak," "Vrapcici," the stadium,

23     "Sutina" down there, and "North camp" and "Zalik."

24        Q.   And where the north camp --

25             JUDGE ANTONETTI: [Interpretation] Ms. Biersay, you're going to

Page 8782

 1     ask for this map be admitted, so maybe you could ask the witness to place

 2     a "1" next to Uborak," a "2" next to the stadium, a "3" next to Sutina, a

 3     "4" next to the north camp.

 4             MS. BIERSAY:  Yes, Your Honour.

 5        Q.   Could you please put a "1" the area Uborak?  If you put a "1."

 6     You can actually use it to write on the screen.  It's like a pen.

 7        A.   Uborak [marks].

 8        Q.   And could you please put a "2" next to the Vrapcici stadium?

 9        A.   Vrapcici stadium [marks].

10        Q.   And then a "3" next to Sutina?

11        A.   [Marks].

12        Q.   And a "4" next to the north camp?

13        A.   [Marks]

14        Q.   How long would it take to drive from Uborak down to the north

15     camp?

16        A.   Well, it depends on whether you use the main road.  Five minutes,

17     five minutes.  If you use the dirt road -- there may be an asphalt road

18     through Vrapcici here, so if you don't go down there towards the Neretva

19     but use the asphalt road, then it's 10 minutes or 15.

20        Q.   When you were being -- when the people in the van were being

21     taken out and shot, did you know where you were at that time?

22        A.   No.  No, I didn't know.

23        Q.   And when is it that you learned that -- you learned where the

24     location of that shooting was?

25        A.   I only learned that when I arrived in Sutina, when I was tied up.

Page 8783

 1     That's when I found out.

 2        Q.   How did you find out?

 3        A.   Because my company had built the city cemetery and the

 4     administration building and everything.  I had worked on the

 5     construction.

 6        Q.   So you knew, when you were in Sutina.  How did you later find out

 7     that you had been taken to the Uborak location?

 8        A.   I learned that only later on, when the mass grave was found, when

 9     north camp was liberated, and Vrapcici and Bijelo Polje.  I identified 22

10     persons in Sutina and 88 from Uborak.

11             MS. BIERSAY:  At this time we would move for the annotated

12     version of 2863 as well as the original, so we'd seek the admission of

13     both versions of the map.

14             JUDGE ANTONETTI: [Interpretation] Very well.  Madam Registrar,

15     could we have a number for the annotated mark -- the annotated map and

16     another number for the more general map, number 4273.

17             THE REGISTRAR:  The annotated map will become Exhibit P479, and

18     the original map will become Exhibit P480, Your Honours.

19             MS. BIERSAY:  And, Madam Registrar, if we could now have 65 ter

20     number 7248, please.

21        Q.   Do you recognise this list that's before you?

22        A.   Yes.

23        Q.   And who do you recognise those people to be?  Who are they?

24        A.   They were all with me in Vrapcici.  They were killed at Uborak.

25             MS. BIERSAY:  At this time, we'd move for the admission of 65 ter

Page 8784

 1     number 7248, please.

 2             JUDGE ANTONETTI: [Interpretation] Madam Registrar, can we have a

 3     number for this exhibit.

 4             THE REGISTRAR:  It will be Exhibit P481, Your Honours.

 5             MS. BIERSAY:

 6        Q.   So just to be clear, these people you recognise as people who

 7     were with you in the Vrapcici locker room; is that correct?

 8        A.   Yes.

 9        Q.   You also described that you participated in the exhumation of the

10     mass grave, and where was that mass grave, the Uborak-related one?  Where

11     was that mass grave in Uborak?  Could you describe it?

12        A.   The rubbish dump 88 in Sutina, next to the River Neretva, 22.

13     That was a separate mass grave.

14        Q.   With respect to the 88 who were found at the Uborak dump -- it's

15     a dump, that's how you describe it?  It's a rubbish dump; is that

16     correct?

17        A.   Yes.

18        Q.   Did you identify other people, as well as the names that we just

19     saw on this exhibit?  There were other people that you knew; is that

20     correct?

21        A.   Yes.

22        Q.   And did you participate in the identification of those other

23     bodies as well?

24        A.   Yes, I did.

25        Q.   Were you present for the actual exhumation, the bodies that were

Page 8785

 1     being dug up?  Were you present for that part or did you just see the

 2     bodies after they were taken out?

 3        A.   I went from Sutina to Uborak and from Uborak by car to Sutina.

 4        Q.   In addition to the -- could we go back to the previous exhibit,

 5     please.  I believe it's P481.

 6             These 18 people on this list, do you know the ethnicity of any of

 7     them?

 8        A.   There were Croats here, Marko Mihalj.  I identified him by his

 9     shoes and his socks, because he couldn't walk.  I called his son to see

10     whether that was his father.  I recognised him by his shoes and his

11     socks.

12        Q.   Now, you described a Croat.  Do you know the ethnicity of the

13     other people on that list?

14        A.   They were all Muslims, now Bosniaks.

15             MS. BIERSAY:  Your Honour, would this be a good time for a pause?

16             JUDGE ANTONETTI: [Interpretation] Yes, let's have a break.

17     According to our computations, I think you have 18 minutes left.

18             We are now going to break for 20 minutes.

19                           --- Recess taken at 10.00 a.m.

20                           --- On resuming at 10.22 a.m.

21             JUDGE ANTONETTI: [Interpretation] Ms. Biersay, you have the

22     floor.  Sorry.

23                           [The accused entered court]

24             JUDGE ANTONETTI: [Interpretation] We have resumed our hearing,

25     and Ms. Biersay has the floor.

Page 8786

 1             MS. BIERSAY:  Thank you, Your Honour.

 2             Just by way of clarification, the Prosecution had asked for the

 3     admission of the original 65 ter number 2863, with the annotation.  That

 4     was the second one that had the local places marked.  And we'd also moved

 5     for the admission of the first one, the orienting one, with Mostar and

 6     Nevesinje, which is 65 ter number 4273.

 7             JUDGE ANTONETTI: [Interpretation] We already have two exhibit

 8     numbers.  This has been done already, Ms. Biersay.

 9             MS. BIERSAY:  And with respect to --

10                           [Trial Chamber and Registrar confer]

11             JUDGE ANTONETTI: [Interpretation] Ms. Biersay, as far as Exhibit

12     number 2863 is concerned, you would like the map to be tendered; in other

13     words, the annotated?  Which do you wish to tender into evidence, the map

14     that has been marked or the one that hasn't been marked?

15             MS. BIERSAY:  We'd like to have both, Your Honour, as an A/B

16     grouping if the Court prefers.

17                           [Trial Chamber confers]

18             MS. BIERSAY:  Mics, Your Honour.

19             JUDGE ANTONETTI: [Interpretation] Ms. Biersay, the Trial Chamber

20     has just deliberated on the matter and holds that the mark -- the map

21     that has been marked is enough.  There is no need to tender into evidence

22     a map that has not been marked.  We already have an exhibit number for

23     this map.

24             MS. BIERSAY:  Thank you, Your Honour.

25             THE REGISTRAR:  Your Honours, then for clarification, map 2863,

Page 8787

 1     with the witness's annotations, is Exhibit P479, and the first map

 2     bearing 65 ter 4273 is Exhibit P480.  Thank you.

 3             MS. BIERSAY:  Thank you for the clarification.

 4             And at this time, Your Honour, the Prosecution would end its

 5     examination-in-chief, and to the extent there's any redirect permitted,

 6     we would ask for the reserve time to be used then.

 7             JUDGE ANTONETTI: [Interpretation] Very well.

 8             Witness, just some recommendations before the cross-examination

 9     starts, which can be a delicate moment.

10             You will have to answer the questions that will be put to you by

11     Mr. Seselj.  Please remain calm and answer the questions.  Sometimes you

12     may not like the questions, but the accused is entitled to ask any

13     question he likes.  So please stay calm.

14             THE WITNESS: [Interpretation] Well, I have the right to answer.

15             JUDGE ANTONETTI: [Interpretation] And wait for him to finish his

16     question before you answer.  Count until five.

17             Since you are going to be speaking the same language, the

18     interpreters have to have enough time to translate what you are saying.

19     So when he puts a question, count until five and then answer.

20             Mr. Seselj, you have the floor.

21             THE ACCUSED: [Interpretation] Judges, I first have to say that

22     telephone wasn't working this morning or the fax machine.  So there were

23     some attempts to send me some documents via fax, but that was

24     unsuccessful because the machine just gobbled up whole sentences.  I just

25     wanted to draw your attention to that.

Page 8788

 1                           Cross-examination by Mr. Seselj:

 2        Q.   Mr. Karisik, I think there is no reason for you to be nervous,

 3     although the Judges brought that to your attention and cautioned you,

 4     because I think you testified truthfully, and within the framework of

 5     what you told to us, I see nothing that I would have to challenge

 6     especially.

 7             So I would like to start off by asking you a question outside the

 8     circle incorporated into the Prosecution questions.  The representative

 9     of the OTP started from April 1992, but since you lived in Mostar, you

10     should know that the conflicts between the JNA and the Croatian military

11     formations started already in September 1991 in Mostar.  Right?

12        A.   I'm not a military analyst for me to know any of these things.

13        Q.   But you were present.  You know of the conflict.

14        A.   Well, I did follow it.  They are things that I follow.

15        Q.   So before the war in Bosnia-Herzegovina broke up, before the

16     Serbs and the Muslims and the before the proclamation of

17     Bosnia-Herzegovina, we're talking about September 1991; right?  You can't

18     remember?

19        A.   I can't remember.  As I say, I'm not a politician.  I don't deal

20     with politics, nor am I interested in politics.  I'm just sorry that the

21     conflict broke out in the first place.  I'm very sorry for that.

22        Q.   In April 1992, the proclamation of independence for

23     Bosnia-Herzegovina came.  The Western powers proclaimed that, and in

24     April the war broke out between the Serbs and Muslims, and there was no

25     war before that.  So for a full seven months, September, October,

Page 8789

 1     November, December, January, February, March, and the beginning of April,

 2     for a full seven months it was exclusively a conflict between the JNA and

 3     the Croatian paramilitary forces in the Mostar area; right?

 4        A.   It was all over the place, on the whole territory, and it

 5     incorporated Bosnia too, that part of Croatia and --

 6        Q.   Wherever there was a high concentration of Croats, there were

 7     conflicts; right?

 8        A.   No.  Wherever you Serbs wanted to have your republic, like you

 9     got it in Bosnia, and you would have got Knin, too, had you gone on.

10        Q.   Let's not have any philosophical questions here or deal in

11     politics.  Let's just look at the facts.  The conflict between the JNA

12     and Croatian paramilitaries lasted for a full seven months, right, before

13     April 1992; isn't that right?  And there was shooting in Mostar?

14             MS. BIERSAY:  He has already posed this question to the witness.

15     The witness has said, "I don't know.  I'm not a politician.  I don't

16     remember."  And he's asked the question at least three times now.

17             JUDGE ANTONETTI: [Interpretation] Witness, please listen to what

18     I'm about to say.

19             Mr. Seselj has put a question to you.  This question is

20     important, because the events that occurred in April 1992, which relate

21     to the Serbs, on the one hand, and the Croats and the Muslims, on the

22     other hand, taken like that one has the feeling that the problems began

23     to arise in April.  But in light of Mr. Seselj's question, purportedly

24     there were paramilitary formations that were Croatian in Mostar.  Did you

25     know that, did you not know that?  And if Croatian paramilitary forces

Page 8790

 1     were present, there may have been a confrontation between these Croatian

 2     paramilitary forces in Mostar and the Serbs before April 1992.  What can

 3     you tell us about this?  Do you know about this or don't you?

 4             THE WITNESS: [Interpretation] I don't know.  I can't really say.

 5     As to conflicts, whether there were any before that, I don't know.

 6             THE ACCUSED: [Interpretation] Mr. President, I have to put you

 7     right.  It was a conflict between the JNA and the Croatian paramilitary

 8     forces, not a conflict between the Serbs and Croats, because in the JNA

 9     you had Muslims too; not in large numbers, because a portion of them

10     failed to respond to the mobilisation call, but there were quite a lot of

11     them.  And it was still officially the JNA as the sole military force of

12     Yugoslavia of the day.

13             MS. BIERSAY:  I object to Mr. Seselj testifying.  He should

14     simply put the question to the witness and have the witness respond.  But

15     these types of explanations amount to testimony.

16             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, first of all, I

17     have not made a mistake.  On line 19, page 37, I mentioned the Croatian

18     paramilitary forces.  This is what I said.  I did not say anything else.

19             THE ACCUSED: [Interpretation] But you said, Mr. President, that

20     they were in conflict with the Serbs, and that's where you corrected what

21     I said erroneously.  I said "with the JNA," but you turned the "JNA" into

22     "Serbia."  You said "Serbia."

23             JUDGE ANTONETTI: [Interpretation] Very well.  Please proceed.

24             MR. SESELJ: [Interpretation]

25        Q.   I find it strange, since you lived in Mostar, that you didn't

Page 8791

 1     know about this conflict between the JNA and the Croatian paramilitaries.

 2     Now, in the autumn of 1991, Mostar was, in actual fact, divided along the

 3     Neretva River, on the one side, on the left bank, it was the JNA that was

 4     in control, and the Croatian paramilitaries controlled the right bank?

 5        A.   I was a construction worker and I was working on site.  I didn't

 6     really live in Mostar.  I was on site.

 7        Q.   Well, in the autumn of 1991, were you working in the field?

 8        A.   I was in Germany.

 9        Q.   And where did you --

10             THE INTERPRETER:  Could the speakers slow down and make pauses

11     between question and answer.  It's impossible to follow at this speed.

12     Thank you.

13             JUDGE ANTONETTI: [Interpretation] Just a minute.  You are going

14     too fast, both of you, and the interpreters can't keep track.  Please go

15     more slowly, speak more slowly.

16             MR. SESELJ: [Interpretation]

17        Q.   When you returned before the new year, the conflict between the

18     JNA and Croatian paramilitaries was still going on, although there was a

19     ceasefire, but Mostar was, to all intents and purposes, divided, so you

20     couldn't go to whichever part of Mostar you wanted freely?

21        A.   The JNA took the left side and you couldn't go anymore, you

22     couldn't cross.

23        Q.   And the right side was held by the Croatian paramilitaries;

24     right?  And the Muslims still did not involve themselves in the conflict,

25     when you came back from Germany just before the new year; right?

Page 8792

 1        A.   You can come and go.  You could go to Germany and to Bosnia and

 2     come back to Bosnia.

 3        Q.   But since you lived on the eastern bank of the Neretva River, you

 4     couldn't cross over to the western bank, could you?

 5        A.   I came from the right bank to the left bank.

 6        Q.   How?

 7        A.   Nicely, I came.

 8        Q.   Did the JNA have control of the bridges?

 9        A.   Yes.

10        Q.   On the other side, did you have the Croatian paramilitaries?

11        A.   There was nobody except soldiers.  It was only the reserve force.

12        Q.   And who had control of West Mostar?

13        A.   You had soldiers on whom the JNA to the last withdrawal --

14        Q.   Whom [as interpreted] is the hill above Mostar?

15        A.   Yes, but the right bank.

16        Q.   Yes, a large hill where the JNA was until its withdrawal in 1992?

17        A.   Yes.

18        Q.   But who controlled the western part of town?  There was no JNA

19     down there, was there?

20        A.   That's where the main hospital was.  By the old hospital, the

21     military hospital.

22        Q.   Just a moment.  Who held control of the largest portion of West

23     Mostar when you arrived?

24        A.   It was under the control of the civilian -- well, the civilians

25     that controlled it before.

Page 8793

 1        Q.   What army controlled it?

 2        A.   Army?  There was no army on that side.  You didn't have to ask

 3     yourself who was in command.

 4        Q.   Well, who went to war against the JNA, then?  Who did -- who

 5     fought against the JNA, then?

 6        A.   The reservists.  The reservists were the ones that caused all the

 7     problems.

 8        Q.   Let's leave problems aside for a moment.  I know what you said

 9     about problems.  But on the one side we had the JNA with its reservists,

10     with its reserve force, its regular troops and reserve force, and who was

11     on the opposite side, the opposing side?

12        A.   You have BosniaBosnia had its army.

13        Q.   I'm talking about 1991, when you came back from Germany, before

14     it was recognised.

15        A.   All you had was the JNA and the reserve force.

16        Q.   Well, who was the adversary, who was opposed to them then?

17        A.   They wanted to rule themselves.

18             MS. BIERSAY:  This is asking, in a different format, the same

19     question that seven to ten minutes ago the witness answered, which is he

20     did not -- does not know about Croatian paramilitaries being in conflict

21     with the JNA in 1991.

22             JUDGE ANTONETTI: [Interpretation] Witness, you have answered, but

23     we are a little bit surprised by your answer, and I shall tell you why.

24             According to what I understand, you went to work in Germany and

25     you came back before the end of the year 1991.  You have East Mostar and

Page 8794

 1     West Mostar.  In West Mostar, were there any military present?  Did you

 2     see any at the time?

 3             THE WITNESS: [Interpretation] There were no paramilitaries over

 4     there then.

 5             JUDGE ANTONETTI: [Interpretation] Are you quite sure?

 6             THE WITNESS: [Interpretation] Certain, sure and certain, except

 7     on the left side the reservists, that was the TO, Territorial Defence.

 8     That's all I can say.

 9             JUDGE ANTONETTI: [Interpretation] And during this period at the

10     end of 1991, January, February, March 1992, was there no fighting that

11     pitched the JNA against those people in West Mostar, according to what

12     you know?  Was there any fighting or not?

13             THE WITNESS: [Interpretation] No, no.

14             MR. SESELJ: [Interpretation]

15        Q.   You didn't find any combat going on because Vance's plan was

16     already in force, which established a truce between Croatia and the

17     Republic of Serbian Krajina, right, so that the fighting stopped in

18     Herzegovina too; right?

19        A.   Owen's plan was not adopted.

20        Q.   That wasn't Owen's plan, that was Vance's plan.

21        A.   Yes, I apologise.  They drew maps here and there, but none of it

22     came into being.

23        Q.   All right.  Since you didn't see any military forces on the West

24     Bank of Mostar, I'm not going to insist upon that anymore.

25             Now, what do you understand by the term "Seselj's men,"

Page 8795

 1     "Seseljevci"?

 2        A.   "Seselj's men"?  Well, soldiers who had command, that is,

 3     Seselj's men.

 4        Q.   An army commanded by Seselj?

 5        A.   Well, if you were the commander, that's how they got their name.

 6     Somebody who has an army, it's his army.  If you had command there, who

 7     else's army would it be there?  Were there any other Seseljs?

 8        Q.   Did you ever see this army of Seselj's?

 9        A.   I just saw the -- I heard the soldiers with their dialect and

10     knew that they were from Serbia, and they called them "Seselj's men."

11        Q.   So what you're saying is that you heard other people refer to

12     them as being Seselj's men?

13        A.   Yes.

14        Q.   And you heard them speaking Ekavian?

15        A.   Yes, they're speaking the same way as I'm speaking now.

16        Q.   And that's all, is it?  You know nothing more that could identify

17     them in any way?

18        A.   I wasn't with them, so how could I know?

19        Q.   All right, fine.  Now, when you were in Vrapcici and Sutina, did

20     you see Seselj's men over there, perhaps?

21        A.   I was incarcerated, so from inside I couldn't see who was

22     outside.

23        Q.   All right, fine.  We'll move a little faster now, I hope.

24             On the 2nd of April, there was this explosion in front of north

25     camp barracks; is that right?

Page 8796

 1        A.   Yes.

 2        Q.   And a tank full of explosives was brought in with some metal

 3     parts, who knows what, a tank truck, and it exploded in front of the

 4     barracks; right?

 5        A.   Well, I don't know what was in it.

 6        Q.   All right.  But the explosion took place, and it destroyed the

 7     barracks, to a large extent; right?

 8        A.   It destroyed the wall and the surrounding parts.

 9        Q.   And some of the dormitories were destroyed, et cetera, things

10     like that; right?  Is that right?

11        A.   Well, there was something like that.

12        Q.   There was, right.  The whole wall to the building toppled down

13     and you could see the inside of the building, the dormitories and so on?

14        A.   There were storehouses, storage space, dormitories, but I

15     couldn't see all that.

16        Q.   You were arrested for the first time when the army conducted an

17     investigation as to who planted the explosive?

18        A.   Yes.

19        Q.   That was in April.  They held you for a month and they released

20     you.  They had two Croatian suspects, and they sent them to Bileca, to

21     the military prison there, is that right, two of them?

22        A.   Yes.

23        Q.   And they let the rest go?

24        A.   Yes, and 12 of us remained.

25             THE INTERPRETER:  Could the speakers kindly slow down.  Thank

Page 8797

 1     you.

 2             JUDGE ANTONETTI: [Interpretation] You're going too fast.

 3     Mr. Seselj, please go more slowly, because the interpreters are having a

 4     hard time.

 5             MR. SESELJ: [Interpretation]

 6        Q.   So of the 14 people, two were suspects.  After making their

 7     statements, they went to prison, and 12 persons were released.  Did the

 8     soldiers beat you while they were interrogating you?

 9        A.   Yes.

10        Q.   Who beat you?

11        A.   I wasn't beaten because I was in the middle, but the ones who

12     were at the back were beaten, the reservists, not the real soldiers, not

13     the real army.

14        Q.   Well, the reservists are the army too.

15        A.   Not as far as I'm concerned, no.

16        Q.   And why did they beat people?

17        A.   I don't know.  They beat the ones who were behind.  I was in the

18     middle, so I don't know why they beat those over there.

19        Q.   Afterwards, you were captured when you tried to escape from the

20     eastern part of Mostar in June; right?

21        A.   Yes.

22        Q.   And do you know that the JNA withdrew from Mostar before the 19th

23     of May, 1992?

24        A.   As I told you earlier on, I didn't follow all this.  I didn't

25     delve into politics.  I wasn't interested in politics at all.  The real

Page 8798

 1     army withdrew.  The people that served in the army, they withdrew.

 2        Q.   All right.  Now let's lighten up.  I have a statement here which

 3     you gave to the Security Services Centre, the Ministry of the Interior,

 4     Bosnia-Herzegovina, in Mostar, on the 23rd of May, 1995.  Do you remember

 5     giving that statement?

 6        A.   Yes, I do remember that, but I had a disagreement with them.

 7        Q.   Over what?

 8        A.   Over some photographs, pictures, because each photograph was

 9     taken -- they said they had pictures of inmates, of the detainees, and

10     they didn't give me the footage taken with a camera, the pictures taken

11     with a camera, so I had a disagreement with them, I argued with them, and

12     I wanted to ask them whether they had the pictures here.  They said they

13     didn't.

14        Q.   All right, since you had a disagreement with them.  Now, that

15     statement is four pages of densely-typed text; do you remember it right?

16        A.   Yes, I remember it in my head.

17        Q.   You signed every page?

18        A.   Yes.

19        Q.   In that statement, you nowhere mentioned Seselj's men, there's no

20     mention of a single Seselj's man.  Do you remember that?

21        A.   I think it's in there somewhere.

22        Q.   Well, let's put it on the ELMO and see whether there is any

23     mention of Seselj's men anywhere.  We'll look for that.  Do you have

24     that?  It's 0363-1490.  My copy can be put on the ELMO, and we'll look at

25     it together.  You should have this, Judges, the statement made by this

Page 8799

 1     gentleman to The Hague investigators.  It follows on from the statement

 2     given to the Muslim police, and you can see that in the third paragraph.

 3     And in the fourth, it says the investigator from the Office of the

 4     Prosecutor "asked me to say more about the information I had given and

 5     clarify some issues discussed in my previous statements."  So the OTP is

 6     treating these two statements as one, so they should have provided the

 7     other one and had it ready.  This is not a special -- or, rather, a

 8     separate statement given to The Hague investigators, but rather a

 9     statement referring to the one given to the Muslim authorities.  So I'm

10     only attempting to draw attention to the lackadaisical way this is being

11     done.

12             So let's have a look now at the statement to see whether you

13     mention Seselj's men anywhere.  Let's see the entire page, please.

14             So that's the statement.  We can see your signature there.  Is

15     that your signature?  Well, that's the first page of the statement.  Can

16     you find the expression "Seselj's men," or "Seselj," or "volunteers of

17     the Serbian Radical Party" mentioned here?

18             Mr. Karisik has this statement, it appears.  No?

19        A.   I didn't give statements to the military Muslim police.

20        Q.   Were the policemen Croats?  Who were they?

21        A.   I'm not interested in that.

22        Q.   You gave it to the official organs of your state.  All I want to

23     know is whether there's any mention of Seselj's men here.  Let's turn to

24     page 2.  You're much faster than we are.  Let's look at page 2 and see

25     whether there's any mention of Seselj's men there.

Page 8800

 1             Do you have page 2?

 2        A.   Yes, yes.

 3        Q.   We don't have to read the whole text, because it's almost

 4     identical to what you stated orally here, and what you spoke about sounds

 5     very convincing.  I don't want to cast doubt on your personal

 6     experiences.  You might have made a mistake due to the state of mind you

 7     were in, but that would be immaterial.  However, there's no mention of

 8     Seselj's men here.

 9             Let's look at page 3.

10             So here we are on page 4.  Is there any mention of Seselj's men

11     here?

12        A.   [No verbal response]

13        Q.   It appears to me there's no mention of that.

14        A.   No, I haven't found it.

15        Q.   Well, I didn't expect you to find anything like that.

16             Now, let's -- can I have the document back, please.

17             Now, Mr. Karisik, on the 10th of June, 2004, you spoke with

18     The Hague investigators; is that correct?  It says here the 10th of June.

19     You have that statement.  I see you have the statement before you.  I

20     didn't object to your following along, referring to the statement,

21     although that's not really permitted here, but I didn't object because I

22     thought you were being sincere.

23             MS. BIERSAY:  For the record, the witness did not consult the

24     statement.  He flipped through it.  I asked him if he was looking at it.

25     He said, "No," and he flipped it back, and he did not refer to it after

Page 8801

 1     then.

 2             JUDGE ANTONETTI: [Interpretation] Yes, but he had it in front of

 3     his eyes.

 4             Proceed, Mr. Seselj.

 5             THE ACCUSED: [Interpretation] As I didn't object, I don't want to

 6     enter into a discussion with Madam Biersay on this issue, so as to avoid

 7     wasting time.

 8        Q.   Do you remember that on the 10th of June, 2004, you gave a

 9     statement to The Hague investigators?

10        A.   Yes, I did.

11        Q.   You have the statement here?

12        A.   Yes, I do.

13        Q.   You see the front page.  What ask it say?  There's your name

14     there, and it says "10th of June, 2004," at the bottom of the page.  So

15     Mr. Karisik, I'm interested in the following:  When you started this

16     interview, The Hague investigators had before them the statement you had

17     previous given to the police; is that correct, in 1995?

18        A.   Yes.

19        Q.   They had that statement, and they say here that you gave that

20     statement to the Security Services Centre in Mostar, Ministry of the

21     Interior, on the 23rd of May, 1995.  It's in paragraph 3 of your

22     statement to The Hague investigators.

23             And then in paragraph 4:

24             "I have now been asked by the office of the prosecutor

25     investigator who is interviewing me at this time to expand the

Page 8802

 1     information provided and to clarify some issues discussed in my previous

 2     statement."

 3             It's in paragraph 4.  You can also see it on the monitor?

 4        A.   Yes, I can find it, yes.

 5        Q.   And you were able to see that they're only interested in trying

 6     to find out something about Seselj or Seselj's men.  They were trying to

 7     dig something out, suggesting that to you, hoping to get something from

 8     you about that.  Do you remember?

 9        A.   Well, it was a long time ago.  You can dig something up,

10     certainly.

11        Q.   Well, people dig tunnels and mines, so you can dig that up too.

12        A.   Well, yes, anything can happen.

13        Q.   I agree with you, Mr. Karisik.  I see that you're a very honest,

14     sincere man, you always speak your mind.  So they insisted on that

15     conversation for a long time, and in the end you confirmed something of

16     what they were insisting on; is that right?

17             If Madam Biersay continues doing these gymnastics, she'll get

18     very tired.

19             Now let's go to page 4 and see what it is they dug up.  Let's

20     turn to page 4, and let's have it on the ELMO for the public to see,

21     since this is public testimony.  So let's have it here.  In paragraph 9,

22     you say, and this is what The Hague investigators are actually putting in

23     your mouth:

24             "After that, we started seeing Seseljevci in town.  Some

25     Seseljevci wore white hats.  Some had todays on and some had sajkacas on,

Page 8803

 1     and some had cockades on their hats.  They settled in the neighbourhood

 2     of Sehovina, East Mostar.  The Nevesinje Serbs populated this settlement.

 3     Seselj comes from East Herzegovina."

 4             Did you see in Mostar, too?

 5        A.   No, I didn't see you, comrade.  I didn't see you, but I heard

 6     that Seseljevci and White Eagles and Chetniks were coming.  Whose army

 7     that was, I just said everyone wanted their own army.  Whoever went to

 8     war had an army of his own.

 9             JUDGE ANTONETTI: [Interpretation] Sir, on paragraph 9 it says

10     Seselj comes from East Herzegovina.  Someone reading this would feel that

11     you, yourself, saw Mr. Seselj in Mostar.  The way it's written, that's

12     what one could infer from this.

13             When the investigator spoke with you, did he ask you whether you

14     had seen Mr. Seselj?  Why is this written?  Why is there this sentence:

15     "Seselj comes from East Herzegovina"?

16             THE WITNESS: [Interpretation] I gave the statement to someone.  I

17     didn't see that, personally.  I didn't see him myself.

18             JUDGE ANTONETTI: [Interpretation] Very well.

19             MR. SESELJ: [Interpretation]

20        Q.   It then goes on to say:

21             "Some Seseljevci came from Serbia, and there was some locals who

22     joined them.  We noticed that some local Serbs joined the Seseljevci and

23     others supported them.  There are a lot of people talking in town that

24     some have gone to join the Seseljevci and some had joined the JNA reserve

25     forces.  We also noticed they started wearing cockades and sajkacas.

Page 8804

 1     Everybody could recognise them by their appearance."

 2             Were these your own words or were they inserted of the OTP?

 3        A.   I said that they wore sajkacas and beards and white hats, and I

 4     say that.  Whose were the White Eagles, whose were the Green Berets,

 5     whose were the Chetniks, whose were Seselj's men?  They were all

 6     together.

 7        Q.   So you couldn't tell the difference, you couldn't tell them

 8     apart?

 9        A.   Well, it didn't say or it wasn't written on their foreheads

10     whether they were JNA or Seselj's men or whatever.  If they put on a

11     cockade on their hat, it was a cockade.  If it was a moon and star, it

12     was a moon and star.  If it was a white hat, it was a white hat.

13        Q.   Did you hear that Draskovic's men were there?

14        A.   Well, I'm telling you, I didn't know who was in command of whom.

15        Q.   All right.  Very well, sir, but you mention that again somewhere

16     here.  In paragraph 14, for example, "we also heard from the JNA

17     soldiers, who were in the firing range, that there were Seseljevci and

18     Red Berets in Mostar."

19             So you always heard it from someone.  You couldn't really tell,

20     yourself, who were Seselj's men, who were White Eagles, who were the

21     Serbian Guard?

22        A.   Well, other people told me.

23        Q.   All right.  I won't deal with that any longer.  I won't weary

24     with that.

25             As you still live in Mostar, are you aware that the District

Page 8805

 1     Public Prosecutor's Office in Mostar, as early as in 1993, on the 16th of

 2     February, submitted a motion to initiate investigative proceedings

 3     against persons who were suspected of having perpetrated a crime against

 4     Muslims in Sutina and Borak?  Do you know that an investigation was set

 5     in motion?

 6        A.   I didn't know that.

 7        Q.   You don't know that.  Well, based on that motion, so that we

 8     don't have to look at both documents, the District Military Court in

 9     Mostar, on the 2nd of March, 1993, issued a decision on conducting an

10     investigative procedure.

11             Can we have that on the ELMO, please, although this is a document

12     given to me by the OTP in some set of documents I was given.  If there is

13     any -- there is no ERN number because only the English version had an ERN

14     number.  There's a number of the translation here.

15             JUDGE ANTONETTI: [Interpretation] Do we have this document?

16             MS. BIERSAY:  I'd just like to clarify, Your Honour.

17             This morning, after the break, the Prosecution was presented with

18     two documents with a fax line reading:  "June 30th, 2008, 8.54 a.m."

19     There is no ERN numbers, as we do put on our documents typically, and I

20     am unsure of why Mr. Seselj thinks we gave this to him if it arrived at

21     8.54 this morning -- yesterday, sorry, that would have been yesterday,

22     but we received it nonetheless.  Even though the fax line says "June

23     30th," which would have been yesterday, we received it today after the

24     first break.  But irrespective of that, I'm not sure if Mr. Seselj is

25     speaking about the ones he gave us today or some other document.

Page 8806

 1             JUDGE ANTONETTI: [Interpretation] Mr. Seselj.

 2             THE ACCUSED: [Interpretation] At the bottom of the page here, you

 3     have the "Reg 9061 Doc/MB."  Those are your markings for translation.

 4     Why there's no ERN number, how should I know.  It was on the English

 5     version.

 6             MS. BIERSAY:  It is not the markings of our documents, and again

 7     I would ask why is a document that has a fax date of June 30, 2008, why

 8     does Mr. Seselj believe that this is a document from us?  We received

 9     this for the first time today in B/C/S, I might add, and I have no idea

10     why he thinks that.

11             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, as Ms. Biersay just

12     said, why can you say that this document comes from the OTP?  Maybe it

13     does.  Maybe your associates found it and faxed it to you, but if they

14     did so, then there would be an ERN number on this document, and it's not

15     there.

16             THE ACCUSED: [Interpretation] Mr. President, let the OTP look for

17     it.  It's their document.  It wasn't found by my associates.  I received

18     this document.  Why there's no ERN number, let the OTP explain.  Let them

19     look in their archives to see if they have this document or not.  Why is

20     there no ERN number?

21             Every time I get material from the OTP, should I check that

22     there's an ERN number?  Just imagine that.  I received that from the OTP.

23             JUDGE ANTONETTI: [Interpretation] Ms. Biersay, Mr. Seselj is

24     telling us that this document does come from the OTP.  Maybe he's right,

25     maybe he's wrong.  I don't know.  Please check that it is not your

Page 8807

 1     document, it does not come from the OTP.

 2             MS. BIERSAY:  Mr. President, Mr. Seselj is the one relying on

 3     this document.  The burden is on him to show the provenance of this

 4     document.  This is not our document.  All the documents that we provide

 5     to Mr. Seselj have an ERN number so that we can track exactly this kind

 6     of thing.  And as has been pointed out to me, the number at the bottom

 7     left of this document is, I believe, a registry number when they receive

 8     these documents in B/C/S and they submit it for translation.

 9             So, again, I would again tell the Trial Chamber that this is not

10     our document.  We did not provide this document to Mr. Seselj, and the

11     burden is on him to prove what the provenance is.

12             JUDGE ANTONETTI: [Interpretation] Well, the plot thickens,

13     obviously.  I don't think we should shed any light on this at the moment.

14     It's quite marginal to know whether it comes from the OTP or from your

15     associates.  The important thing is the content of this document.

16             THE ACCUSED: [Interpretation] Mr. President, I can't accept that.

17     Ms. Biersay has just said that this is a registry number, it's not the

18     registry of my expert team for the Defence, it's the registry of the

19     Tribunal.  Now, whether I received this several years ago, how should I

20     know and why should I care?  It was given to me through the official post

21     of the Tribunal.  Now, whether it was sent to me directly through the

22     Registry or the OTP, or whether it arrived from some other trial as an

23     exhibit or piece of evidence, why should I care?

24             If the Prosecutor doubts the authenticity of the document, they

25     can contact the Cantonal Court in Mostar right away and check it out,

Page 8808

 1     verify whether it's right or not.  I think she's intentionally leading us

 2     astray.  I did not create the document.  We have the registry number

 3     here.  I didn't submit it for translation.  I received it from the

 4     competent organs of the Tribunal.  And when I say "competent organs," I

 5     mean the OTP and Registry.  And now you want me to tell me how I received

 6     this.  How should I know?  You've sent me half a million pages of various

 7     documents so far, so how should I know?  And this is a registry number

 8     here.

 9             JUDGE LATTANZI: [Interpretation] Sorry, Mr. Seselj, you received

10     this by fax or how?  How did you receive this document?

11             THE ACCUSED: [Interpretation] I received this by hand, which is

12     how I receive official documents from the Registry and the Tribunal.  I

13     gave them to my legal advisers and assistants to study, and they sent it

14     back -- they faxed it back as a piece of material which would be

15     interesting for the cross-examination of this witness.

16             Now, the Registry can look at the number there and tell us -- let

17     us know where the document is from and what the document is.  But as far

18     as I'm concerned, what is important for me is that it's got this official

19     title "The District Court of Mostar," the date and the reference number.

20             JUDGE ANTONETTI: [Interpretation] Right, that's what's important.

21     All the rest is very marginal.

22             Please proceed.

23             MR. SESELJ: [Interpretation]

24        Q.   Mr. Karisik, it says here -- let's look at this together -- that:

25             "Zjelko Soldo, an Investigating Judge of the Military District

Page 8809

 1     Court in Mostar, in the criminal proceedings against Milan Skoro and

 2     others accused, accused of committing genocide under Article 141 taken

 3     over from the Criminal Code of the former SFRY, with respect to a request

 4     for an investigative procedure to be set into motion, tabled by the

 5     military prosecutor KT number 37-93 of the 16th of February, 1993, brings

 6     in the following decision about conducting an investigative procedure

 7     against the following individual."

 8             Put that on the overhead projector, please, and as we're dealing

 9     with 30 names here, they don't have to be in public.  It's enough for

10     Mr. Karisik to take a look at it together with me, so that we can see,

11     Mr. Karisik, that all the 30 individuals on that list, with all their

12     basic data, that they were all inhabitants from Mostar, Vrapcici and

13     Nevesinje, and not a single one of them was from Serbia.  That's what it

14     says here.  Take a look at the list.

15        A.   Well, I'm glad that you raised that issue.  You don't have to

16     have 30 people, but I'm happy to see that.  I've never seen that, but it

17     has to come out, this kind of thing.

18        Q.   All right.  Now, do you know that the Cantonal Court of Mostar

19     tabled a request to the State Court of Bosnia-Herzegovina to unleash

20     criminal proceedings for the killing of Muslims in Sutina and Borak; do

21     you know about that?

22        A.   Well, I do know -- I know this court in The Hague.  I'm not

23     interested in the court in Bosnia.  It can be whatever you like.  I'm

24     interested in the Tribunal in The Hague, because in Bosnia they pull this

25     way and that way.

Page 8810

 1        Q.   All right.  Look at this list, please.

 2        A.   Why should I look at it?  I have all these names in my head.

 3        Q.   You don't want to look at the list?

 4        A.   Well, not really.

 5        Q.   You guarantee that there's nobody from Serbia among those 30?

 6        A.   Nobody.

 7        Q.   There are 330, not 30.  But Mr. Karisik --

 8        A.   You don't have to convince me.  We're not here to convince each

 9     other of anything.  You guarantee that there is nobody there from Serbia

10     among these 30.

11        Q.   Well I'm not guaranteeing anything.  I'm looking at the list.

12        A.   Well I don't want to look at the list.  Why should I look at the

13     list.  You're guaranteeing that among those 30 names there's nobody from

14     Serbia.

15        Q.   Well, do you want to have a look at the list?

16        A.   All right, I'll look at the list then.

17        Q.   Well, I'm happy to see you're in a better frame of mind and want

18     to look at the list now.  Let's have it on the overhead projector so

19     Mr. Karisik can see the list.  You don't have to mention any of the

20     names, some you have already mentioned, some you have not mentioned.

21     Now, since they haven't been tried yet and the State Court of

22     Bosnia-Herzegovina agreed to try three of these people, whereas all the

23     rest were sent back to the Cantonal Court in Mostar, we're not going to

24     mention any names -- perhaps there's somebody innocent here, not to

25     mention names, but let's go through the list to see where these people

Page 8811

 1     come from.

 2             Place it on the overhead projector, please.  How come I can't see

 3     this on my screen.  Ah, it's come up now?

 4             Right, number 1, can you see that there?  His address is Mostar,

 5     Zarek 17; right?  Just say "yes" or "no?"

 6        A.   All right, then I'll say "yes."

 7        Q.   Number 2, the address is Vrapcici 178; right?

 8        A.   Yes, that's your court over there in Mostar.

 9        Q.   It's your court.

10        A.   Well, it's your court.  I have a court here, now.  I'm just

11     interested in this tribunal.  I'm not interested in the court in Mostar.

12     I'm interested in this court here.

13        Q.   I agree with you, I'm going to agree with you, but let's move on.

14             JUDGE ANTONETTI: [Interpretation] Witness, please, the problem is

15     not to know which tribunal should deal with this case.  We have a

16     document coming from the Mostar tribunal, Mostar court.  Mr. Seselj would

17     like you to confirm that the names mentioned are the names of people who

18     live in Mostar or around Mostar.  That's all he's asking, and he is

19     asking you to check the addresses of these people.

20             Proceed, Mr. Seselj.

21             MR. SESELJ: [Interpretation] Let's move on.

22        Q.   Number 3, can you see that this person's address was Mostar,

23     Potoci, no number?

24        A.   Yes.

25        Q.   Let's move on to number 4.  Was this man's address Mostar, Sutina

Page 8812

 1     19?

 2        A.   You mean number 4?

 3        Q.   Yes.  You know him, don't you?

 4        A.   Yes, I do know him.

 5        Q.   Well, there you are, then.  Do you know some of the ones before,

 6     above?

 7        A.   No.

 8        Q.   Well, you mentioned some of them.

 9        A.   Well, I mentioned all sorts of people, but it's of no interest.

10        Q.   Just be patient, have a little patience.  I know it might be

11     difficult for you to go through this list, but let's try it.  Let's look

12     at number 5.  Does it say that the address is Mostar, Vrapcici 18?  --

13        A.   Yes.

14        Q.   Number 6, does it say that his address was Vrapcici, no number?

15        A.   Yes.

16        Q.   Number 7, does it say "Mostar, Vrapcici 127"?

17        A.   Yes.

18        Q.   Number 8, does it say "Mostar, Zivote Neimarovica Street,

19     number 17"?

20        A.   Yes.

21        Q.   Turn to page 2 now, please.  Number 9, does it say that his

22     address is in Vrapcici, and then -- it says "Vrapcici, Mostar," right?

23        A.   Yes.

24        Q.   Number 10, does it say the address is Mostar, Prigradjani

25     number 72"?

Page 8813

 1        A.   Yes.

 2        Q.   Number 11, does it say "Vrapcici, Mostar" there for the address?

 3        A.   Yes.

 4        Q.   Number 12, does it say the address is Mostar, Zalik 7/c?

 5        A.   Yes.

 6        Q.   Number 13, does it say that he is from Pluzine, near Nevesinje?

 7        A.   Yes.

 8        Q.   Is Nevesinje the neighbouring municipality to Mostar, does it

 9     border on Mostar?

10        A.   Yes.

11        Q.   Fine.  Now, number 14, does it say that the address is Vrapcici

12     173?

13        A.   Yes.

14        Q.   Number 15, does it say that his address is Vrapcici, Mostar?

15        A.   Yes.

16        Q.   And you mentioned him before, didn't you?  Number 16, does it say

17     the address is Cicevo-Konjic, with an address for residency in Mostar,

18     Zeljusa, no number; right?

19        A.   Yes.

20        Q.   And Konjic is a neighbouring municipality of Mostar, too?

21        A.   Right.

22        Q.   Number 17, does it say that his address is Mostar, Vrapcici

23     number 44?

24        A.   Yes.

25        Q.   Number 18, does it say that the address is Mostar, Vrapcici 13?

Page 8814

 1        A.   I think the number is 18.  It's either 15 or 13.

 2        Q.   It doesn't matter.  Vrapcici 13 or 15?

 3        A.   I think it says "15."

 4        Q.   All right, then, Vrapcici 15.  I agree with you straight away,

 5     you see, sir.

 6        A.   No problem.

 7        Q.   Let's move on.  Number 19, does it say that the address is

 8     Potoci, Humi-Lisani, Mostar?

 9        A.   Yes.

10        Q.   That's a village neighbouring on the Mostar municipality?

11        A.   Yes.

12        Q.   Number 20, does it say it's Vrapcici 256?

13        A.   Yes.

14        Q.   Number 21, does it say that the address is Vrapcici 228?

15        A.   Yes.

16        Q.   Number 22, does it say that the address is Vrapcici, Mostar?

17        A.   Yes.

18        Q.   Let's move on to the third page now, please.  Number 23, does it

19     say that the address is Mostar, Vrapcici 140?

20        A.   Yes.

21        Q.   Number 24, does it say that the address is Mostar, Vrapcici 32?

22        A.   Yes.

23        Q.   25, it is this Boro Antelj?

24        A.   That's what it says.

25        Q.   Did you hear that Boro Antelj was the commander of Draskovic's

Page 8815

 1     Serbian Guard in Konjic?

 2        A.   No, I didn't hear about that.  That's why I say I don't dwell in

 3     politics.

 4        Q.   All right, so then we're not going to speak about politics, but

 5     is this the address of Mostar, Vrapcici no number?

 6        A.   Which number did you say?

 7        Q.   25.

 8        A.   Yes.

 9        Q.   Number 26, is this Mostar, Vrapcici 22, the address?

10        A.   Yes.

11        Q.   27, is the address Mostar, Vrapcici, no number?

12        A.   Yes.

13        Q.   28, is the address there Kuta Livac, Mostar?

14        A.   Yes.  What's the name?

15        Q.   Kuta Livac.  Kuta Livac, Mostar then.

16        A.   Yes.

17        Q.   So 29, is it Kuta Livac?  It says "Livce" here.

18        A.   It's Kuta Livac, Mostar.

19        Q.   I don't know Mostar well, but anyway, number 30, is this Mostar,

20     8 Duk 1 Street?

21        A.   Did you say 8 Duk 1?

22        Q.   Yes.

23        A.   I can't remember what street it is.

24        Q.   That's not important, but that's what it says there, isn't it?

25        A.   Yes.

Page 8816

 1        Q.   So can you see that the court from Mostar held these as suspects,

 2     30 people, and accused them, and most of them were from Vrapcici, which

 3     is a part of Mostar, right, the outskirts of Mostar, right, and all the

 4     rest were from Mostar except for one person from Nevesinje and one person

 5     from Konjic; right?

 6        A.   There is this man from Foca, too.

 7        Q.   He used to live in Foca and then moved to Mostar; right?

 8        A.   No, he was in Foca.

 9        Q.   But Foca is in Herzegovina?

10        A.   Yes, it is, but --

11        Q.   All right, fine.  Now, we have a description of the crime that

12     took place in Sutina and Uborak, and the names of the victims are

13     mentioned here.  We don't need to go through that because it's something

14     that actually happened, so I can't deny any crime.  If a crime took

15     place, it has to be investigated, and thank you, Mr. Karisik, that will

16     be all of I have no further questions for you.  Thank you for having the

17     patience to go through the list with me.

18             THE WITNESS: [Interpretation] Well, I've been through a lot more

19     than the list.

20             MR. SESELJ: [Interpretation] I understand you perfectly.

21             JUDGE ANTONETTI: [Interpretation] Madam Biersay, any redirect?

22             MS. BIERSAY:  Thank you, Your Honour.

23             The first thing I'd like to address, I think it's an error in --

24     perhaps Mr. Seselj misspoke or perhaps it's a translation error.

25     Page 17, line 21, the witness said he'd stayed one day when being

Page 8817

 1     interrogated at the north camp, and in his question posed to the witness

 2     at page 44, line 13, I believe, Mr. Seselj is attributed as saying "one

 3     month."

 4             THE ACCUSED: [Interpretation] That's not what I said.  It's a

 5     translation error.  I said "one day," and I identified the fact that

 6     Mr. Karisik was arrested by the JNA in April 1992, held for one day, and

 7     then he was arrested when the JNA had already withdrawn in June 1992.

 8             MS. BIERSAY:  So then with that, I believe that page 44, that

 9     line 13 should be corrected to read "one day," not "one month."

10                           Re-examination by Ms. Biersay:

11        Q.   I'd like to turn your attention to the local statement that

12     Mr. Seselj showed you.  Do you have that statement before you, the one

13     from 23 May 1995?

14        A.   23rd of May, 1995, is that the one you mean?

15        Q.   Yes.  And if I could now direct your attention to the beginning

16     of the second paragraph that begins:  "Dana, April 9, 1992 ... ," do you

17     see that paragraph?

18        A.   The 3rd of June, 1992?  Yes, I see that.

19        Q.   The paragraph that begins:  "Dana, April 9, 1992."  In that

20     sentence, do you refer to Chetniks?

21        A.   I'm talking about Seseljevci, Chetniks, the White Eagles, the

22     Green Berets.  There was all of that, all of that, all complete.  Now,

23     who commanded them, I don't know.

24        Q.   So was that what you clarified with the investigators from the

25     ICTY, you clarified what you meant by "Chetniks" in your 1995 statement?

Page 8818

 1        A.   All of them together.

 2             THE ACCUSED: [Interpretation] Objection.  The Prosecutor doesn't

 3     have the right to proceed in this way because she's misleading the

 4     witness.  The whole paragraph must be read.  We can see when Mr. Karisik

 5     set off for Zalik with the other people there, that they were intercepted

 6     by a Land Rover, a police vehicle with four policemen inside, and that

 7     among them he recognised one of them, a former MUP worker of

 8     Bosnia-Herzegovina.  Now, he can repeat, he can keep saying all complete,

 9     "Seseljevci," and who knows who else, and a hundred others; but here in

10     the statement he is being very precise.  He recognised one man as local

11     being a local and the other four were policemen.  That's what it says in

12     the paragraph you just quoted from.

13             MS. BIERSAY:  Now if you could turn to, I believe, it's page 3,

14     the second paragraph that you see on page 3.

15        Q.   Do you have that second paragraph that begins:  "Dana, June 13,

16     1992"?

17        A.   Yes, yes, yes.

18        Q.   I'd like you to count nine lines down from the beginning of that

19     paragraph?

20        A.   On the 30th of June, 1992, at around 2230 hours, on the premises

21     of the locker room, two unknown soldiers entered.  Two had helmets and

22     beards.  They were wearing olive-green uniforms.  One of them was around

23     35 years old and the other one was around 45.

24        Q.   And could you now read the sentence that begins:  "Kada se

25     vozilo"?  I apologise for my pronunciation.

Page 8819

 1        A.   When the vehicle stopped, one of the Chetniks -- so I said

 2     Chetniks because they had beards, that's why I called them Chetniks.  One

 3     of the Chetniks got out, opened the door and ordered them to step out.

 4        Q.   I'd like to turn your attention to the statement that you gave to

 5     the ICTY, so the other statement that Mr. Seselj went through with you.

 6             THE ACCUSED: [Interpretation] Objection.  First of all, this

 7     can't be left in the air -- up in the air like that, because where it's

 8     most important, the Prosecutor stops, and here's what happened:  It says

 9     when it first group started to get out, then this one person, one of the

10     soldiers whom the witness referred to as a Chetnik, started shooting and

11     killing, and then Ramo Kolar [phoen] recognised that soldier and said,

12     "Dragan, we've known each other for 30 years," and Dragan killed him

13     straight away.

14             THE WITNESS: [Interpretation] It's not "Kolar," it's "Kuko."

15             THE ACCUSED: [Interpretation] Yes, Kuko.  I read it out wrongly,

16     it's "Kuko."  So this is obviously a falsification by the Prosecutor.

17     Obviously somebody recognised the local man who was doing the killing.

18     This Ramo Kuko, who was killed, recognised this person because he had

19     known him for 30 years.

20             So the essential point is something that the Prosecutor is trying

21     to gloss over.

22             And secondly, my second objection is the Prosecutor does not have

23     the right now to ask the witness to look at a statements he gave to

24     The Hague investigators and the Prosecutor.  As you cautioned him,

25     Mr. President, last year, and your colleague, Judge Harhoff, what he can

Page 8820

 1     do is remind somebody of a date, number, and so on.  But the Prosecutor

 2     cannot ask the witness to comment on the statement to The Hague

 3     investigators.  That is something the Prosecutor cannot do.  That is

 4     something that I can do, but not the Prosecutor.

 5             JUDGE ANTONETTI: [Interpretation] Ms. Biersay, I know what you

 6     would like to demonstrate, but the problem is we have a text that is in

 7     B/C/S, which Mr. Seselj has just read out an excerpt of, when he

 8     discussed Mr. Dragan.  You didn't mention this, but he seems to be a

 9     local.  And now you would like to refer to his statement which he gave in

10     1994 on the same topic; is that right?

11             MS. BIERSAY:  In 2004, Your Honour, not -- it's not on the same

12     topic.  I have covered the points I wanted to, which was in his previous

13     statement in 1995, the witness mentioned "Chetniks," and explained to the

14     Court what he meant by that, meaning Seselj's men, White Eagles, and he

15     puts them altogether in that group; so I am moving on to another issue,

16     which is with respect to paragraph 9 in the statement, which was put

17     forth to the witness by the accused.  I would like to ask the witness

18     about this statement that Seselj's come from East Herzegovina.  So that's

19     my purpose.

20             THE ACCUSED: [Interpretation] Objection.  Mr. President, I come

21     back to the previous statement.  The Prosecutor failed to explain why she

22     kept quiet about a key fact, glossed over it, and that is that one of the

23     soldiers who did the killing was recognised on the spot.  That's the crux

24     of the matter.  And, secondly, her interpretation is bad, because we have

25     the witness saying before us that he concluded that there were two

Page 8821

 1     Chetniks because they had beards.

 2             JUDGE ANTONETTI: [Interpretation] In the same vein, Witness, I

 3     thought the accused would have put to you a question on this, but this

 4     wasn't mentioned.  I would like to get back to the person who stood

 5     guard, a person going by the name of Gunjar.  I apologise for my

 6     pronunciation.  You said you had worked with him for 15 years, this

 7     Gunjar whom you recognised.  Was he a local or was he one of Seselj's

 8     men?

 9             THE WITNESS: [Interpretation] Gunjar, you mean?  What party he

10     was, I don't know.  What side he was, I don't know, whether he was a

11     Chetnik or in the Seselj's, or White Eagles, or Green Berets.  I don't

12     know.  I was held captive.

13             JUDGE ANTONETTI: [Interpretation] But this Gunjar, you worked

14     with him for 15 years, so you knew him, didn't you?

15             THE WITNESS: [Interpretation] He was a cook.

16             JUDGE ANTONETTI: [Interpretation] And he lived next to where you

17     lived, didn't he?  He didn't come from Serbia?

18             THE WITNESS: [Interpretation] No, he was from Nevesinje

19     originally.

20             JUDGE ANTONETTI: [Interpretation] Very well.  Ms. Biersay.

21             MS. BIERSAY:

22        Q.   Could you tell the Trial Chamber if there were locals associated

23     with these Chetniks or Seselj's men, as well as people from other places

24     who were Seselj's men or Chetniks?  Were there both locals and people

25     from other places?

Page 8822

 1        A.   Well, I can't say definitely now who was on what side, or party.

 2     There was Seselj's side, and then there was the Green Berets' side, and

 3     then there was the Vuk Draskovic side.  Everybody had his own party or

 4     side, and it depended where people decided to go.

 5        Q.   But those people, even though they had different sides, what the

 6     Trial Chamber would like to know is:  Did they all come from that area,

 7     Mostar, or did people come from outside, from other places, to Mostar?

 8        A.   They came from Montenegro and Serbia, from all sides.  People

 9     came there from all sides.

10             THE ACCUSED: [Interpretation] Objection.  Once again, the

11     Prosecutor is intentionally causing confusion.  Reservists did come from

12     Serbia, from the Uzice corps, and also from Montenegro; volunteers came

13     in while the JNA was there until the 19th of May, after the 19th of May,

14     nobody came to Mostar.

15             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, when you raise this

16     objection and say the Prosecution is causing confusion, do you believe

17     the Trial Chamber can be manipulated in this way, because the Prosecutor

18     is going to put a question to the witness?  You may trust the Bench.  The

19     Bench can weigh both the question and the answer.  There is no confusion

20     in the minds of the Judges.  There is a question that's being put, there

21     is an answer that's provided, and the Judges will weigh all of this

22     afterwards.

23             When you say that Ms. Biersay is causing confusion, I will turn

24     around and tell you, no, there is no confusion.  The Prosecution holds

25     that it is her duty to do redirect and put additional questions, because

Page 8823

 1     you highlighted through your questions a number of issues which clearly

 2     are not to the liking of the Prosecutor.  This is why the Prosecutor is

 3     putting additional questions to the witness, to try and see how things

 4     stand, and is trying to put this in line with the Prosecution's

 5     standpoint, which may not be the same as that of the Bench.  So let the

 6     Prosecutor put her questions, and the Bench and the Judges are perfectly

 7     capable of drawing their own conclusions.

 8             Please proceed, Ms. Biersay.

 9             MS. BIERSAY:  Thank you, Your Honour.

10        Q.   Now could you turn your attention to paragraph 9 of the statement

11     that you gave to the ICTY.  Mr. Seselj asked you some -- he read it, and

12     the Trial Chamber also asked you a question about it.

13             So what I'm interested in, there is a sentence that says Seselj

14     comes from East Herzegovina.  I don't know if you know this, but do you

15     know where Mr. Seselj comes from, what area he comes from in general?

16     You were born in Serbia and you spent 30 years in Mostar.  Do you know

17     where Mr. Seselj is from, in that sense?

18        A.   Trebinje.

19        Q.   And where is that, geographically?

20        A.   Trebinje is in Herzegovina, towards Montenegro, that area.

21             THE ACCUSED: [Interpretation] Judges, I have to object again.

22     The Prosecutor knows full well where I was born, and it states that in

23     the indictment.  It says where I was born, and it says that I was born on

24     the 11th of October, 1954, in Sarajevo.

25             JUDGE ANTONETTI: [Interpretation] Mr. Question [as interpreted],

Page 8824

 1     with this question Ms. Biersay wanted to highlight the fact that the

 2     witness, before the OTP investigators, when he mentioned you, meant to

 3     say that you came from Eastern Herzegovina and did not mean to say that

 4     you were coming from Eastern Herzegovina to Mostar.  That is the meaning

 5     of her question.

 6             Please proceed, Ms. Biersay.

 7             THE ACCUSED: [Interpretation] I really don't understand anything

 8     now, Mr. President.  You said the point of her question was that I came

 9     from Eastern Herzegovina to Mostar.  That's what was interpreted to me.

10     I never visited Mostar during the war.  If that is a new case of the OTP,

11     that I came to Mostar from East Herzegovina, I should be told about it.

12             JUDGE ANTONETTI: [Interpretation] Ms. Biersay, with her question,

13     wanted to highlight the fact that you are a native of -- that you come

14     from Herzegovina.  To be a native of and to come are two totally

15     different things, and to come from.  And the witness confirmed this,

16     because he was asked where Mr. Seselj came from, and he said that

17     according to him, he came from Eastern Herzegovina.  That's what the

18     witness said, since you are a native of Trebinje.

19             Ms. Biersay.

20             MS. BIERSAY:  Thank you, Your Honour.

21        Q.   I'd now like to turn your attention to the list, the two

22     pieces -- the two documents that Mr. Seselj gave you.  And he went

23     through the 30 names on that list, and specifically, for the record, this

24     is the fax that's dated June 30th, 2008, and the time stamp says "8.56

25     a.m."  One set of documents goes from page 11 to page 14.  It has "P-11"

Page 8825

 1     to P-14" and the other has "P-7" to "P-10."

 2             THE ACCUSED: [Interpretation] Objection.  This is a document I

 3     received from the OTP, and I mentioned it on the 8th of November of last

 4     year in my opening statement.

 5             MS. BIERSAY:  I'm not sure what the objection is.  I'm just

 6     making a record of the document we're looking at.

 7             JUDGE ANTONETTI: [Interpretation] It's not at issue, whether you

 8     received the document or not.  What we're interested in and why

 9     Ms. Biersay is addressing this document again and what it is she wants to

10     demonstrate, and where the documents come from, is really secondary.

11             Please put your question.

12             MS. BIERSAY:

13        Q.   The 30 names that you read with Mr. Seselj, do you know each and

14     every one of these people?

15        A.   I know some quite well.

16        Q.   And of the 30, how many do you think you know, approximately?

17        A.   Well, I know five really well.

18        Q.   So when you previously described how there are people coming from

19     other places, like Serbia or Montenegro, did any of those people give you

20     their full names?

21        A.   Well, each of them had a nickname.  When people go to work or

22     when they go somewhere, they don't want to be called by their first and

23     last names.  They just use their nicknames.

24        Q.   Do you know that Branislav Vakic was declared vojvoda by Seselj

25     and that he was in the Mostar area from May to June of 1992?  Did you

Page 8826

 1     know that?

 2        A.   He knows, himself, that he declared him.  If he did something, it

 3     will be found out.

 4        Q.   Do you know that?  Have you ever heard that name before?

 5        A.   Not yet.  These names were mentioned, but how many of them will

 6     be found guilty in the end, that remains to be seen.  I'd like to see

 7     that, whether they will be people from outside or whether they're local

 8     people from Bosnia-Herzegovina, that remains to be seen.  Time will tell.

 9        Q.   But my question to you is:  Do you know someone by the name of

10     Branislav Vakic, yes or no?

11        A.   I don't know him personally.  I may have seen him around or on

12     pictures.  I didn't have personal contacts with him.  I can't recall.

13     It's been 17 years since then.

14             MS. BIERSAY:  The Prosecution has no further questions,

15     Your Honour.

16             JUDGE ANTONETTI: [Interpretation] Very well.

17             Witness, on behalf of my colleagues and I personally, also, I'd

18     like to thank you for having come to testify, and I wish you well and a

19     safe journey home.

20             I shall ask the usher to escort you out of the courtroom.

21             THE WITNESS: [Interpretation] Thank you, and goodbye.

22             THE ACCUSED: [Interpretation] I have some administrative issues

23     to raise, so please don't break early.

24             JUDGE ANTONETTI: [Interpretation] Yes.

25                           [The witness withdrew]

Page 8827

 1             JUDGE ANTONETTI: [Interpretation] Before I give you the floor, I

 2     shall read out an oral decision relating to a particular witness, but I

 3     need to find this document.

 4             Let's move into private session, please.

 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 8828

 1   (redacted)

 2                           [Open session]

 3             THE REGISTRAR:  Your Honours, we are back in open session.

 4             JUDGE ANTONETTI: [Interpretation] [No interpretation]

 5             THE ACCUSED: [Interpretation] Judges, I request that you review

 6     your decision for Witness VS-1051, testifying tomorrow under Rule 92 ter,

 7     bearing in mind the principles established by yourselves.

 8             This is a witness who is the first to testify about the crimes

 9     that happened on the Borak Lake and the place called Zijemlje.

10             MS. BIERSAY:  Your Honour, I would ask that we move to private

11     session.

12             THE ACCUSED: [Interpretation] Please, I'm not mentioning any

13     names, so we cannot move into private session.

14             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, nonetheless we

15     shall move into private session, because VS-051 [as interpreted] has been

16     granted protective measures.  Registrar, please.

17                           [Private session]

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 8829











11 Pages 8829-8837 redacted. Private session.















Page 8838

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8                           [Open session]

 9             THE REGISTRAR:  Your Honours --

10             THE ACCUSED: [Interpretation] I have nothing further.

11             JUDGE ANTONETTI: [Interpretation] Very well.  Tomorrow, then, in

12     open session, we will start with the witness.  We will very quickly move

13     back into private session because protective measures were granted.

14             Ms. Biersay, one last thing?

15             MS. BIERSAY:  Yes, Your Honour.  In the morning, it is my

16     intention to address the protective measures for 1052.  And given the

17     time, would the Trial Chamber prefer that I do that in the morning?

18             JUDGE ANTONETTI: [Interpretation] Yes.  We will deal with this

19     tomorrow morning.

20             So the hearing is adjourned, and we will meet tomorrow at 8.30.

21                           --- Whereupon the hearing adjourned at 12.14 p.m.,

22                           to be reconvened on Wednesday, the 2nd day of

23                           July, 2008, at 8.30 a.m.