Tribunal Criminal Tribunal for the Former Yugoslavia

Page 3248

 1                          Monday, 21 May 2001

 2                          [Open session]

 3                          [The witness entered court]

 4                          [The accused entered court]

 5                          --- Upon commencing at 9.34 a.m.

 6            JUDGE ROBINSON:  Ms. Baly, have you completed your

 7    examination-in-chief?

 8            MS. BALY:  No, Your Honour.

 9            JUDGE ROBINSON:  Okay.  Please go ahead.

10            MS. BALY:  Thank you, Your Honour

11                          WITNESS:  WITNESS Q [Resumed]

12                          [Witness answered through interpreter]

13                          Examined by Ms. Baly:  [Continued]

14       Q.   Now, on Friday last week you were giving some evidence about the

15    Room 3 massacre.  You said that shooting had been intermittent and that

16    you thought that fragmentation ammunition was used.  Witness Q, can you

17    tell the Court, please, what fragmentation ammunition is and how you

18    formed the view that it was being used during the massacre.

19       A.   I concluded that it was the fragmentation ammunition because in

20    the morning, I found my brother in front of the room, hit, outside, in

21    front of the door.  And, well, that kind of injury on the head could only

22    be caused by fragmentation ammunition.

23       Q.   What exactly is fragmentation ammunition?

24       A.   Well, theoretically it is ammunition which is prohibited by the

25    Geneva Convention and very dangerous because the charge has added

Page 3249

 1    explosives, and at the moment of contact with a solid body, it bursts.

 2       Q.   Now, during the firing, whereabouts were you in Room 3?

 3       A.   I was beneath the window, and there were radiators next to me.

 4       Q.   In Room 3, was there a toilet?

 5       A.   No, there wasn't a toilet.

 6       Q.   Was there a toilet close by Room 3?

 7       A.   As you entered the room, to the left there was something that

 8    looked like a wash basin to wash hands or something.

 9       Q.   Now, you said earlier, that is, on Friday, that the shooting

10    lasted until dawn.  After the shooting finished, what happened to the

11    prisoners in Room 3, those who were not dead or injured?

12       A.   Oh, well, when the morning came, I couldn't believe that I had not

13    been even hit.  There were many dead and wounded around me.  Those who

14    were -- who had been badly frightened were lost.  All the footwear were

15    all scattered around and clothes.  It was at the door where most of the

16    dead and wounded were.  A square in front of the door, a square of the --

17    a square metre of plate had been broken down, and in front of the door, I

18    first saw my brother who was lying face down and the back of his head was

19    missing.  I recognised him by the shirt and his trousers and his shoes.

20            And then beyond him I saw a very large, very large number of dead

21    on the pista and in the room.  I did not count them, but when they were

22    all taken away, when it was cleaned, we were not left many in the room.

23    Very few.

24       Q.   What happened to those -- the bodies of those who had been killed?

25       A.   They requested that we pass the bodies out through that plate

Page 3250

 1    opening.  They even wouldn't -- they wouldn't even open the door.  So we

 2    passed those bodies out, and then they told us that we should also get the

 3    wounded out.  And a few people, those who were not lethally wounded

 4    wounded, who had only received scratches, so they also left.

 5            And I saw how they put them in a cart, in a rubbish cart, the ones

 6    that workers -- the street cleaners use in our town.  We call it a

 7    Japanese cart.  And they were loading the three or four men to a cart and

 8    would move.  And about 50 metres from the room there was a lorry, a

 9    trailer with up to 50 tonne carrying capacity, and they opened the canvas

10    and then threw in men like logs into that trailer.  And after that they

11    lowered the canvas, and all those wounded who worked there, also made them

12    climb this lorry.

13       Q.   Witness Q, you said that the room was cleaned.  How was that done

14    and when was that done?

15       A.   We were made to come out, and then it was cleaned.  And they took

16    away all the clothes, from leather jackets -- they took the leather

17    jackets and put them on a canvas, and they were never returned.  They

18    did -- they were not only into killing, they were also into stealing.

19       Q.   Now, you said that after the room was cleaned you were taken back

20    to the room and that there were very few of you left.  Just, if you could,

21    give an estimate of how many were in fact left in Room 3 after the

22    massacre.

23       A.   About one-third, and the room was crowded before that.  They knew

24    the exact number, how many people there were, how many were killed.

25       Q.   Now, on the day after the massacre, on the morning after the

Page 3251

 1    massacre, did something happen to some of the remaining prisoners in Room

 2    3?

 3       A.   Well, even the first night when we arrived there, they took away

 4    some and brought in others.  They took away some, and those never

 5    returned.  I know some of them, and I never heard again that anybody had

 6    seen them again.

 7            After the butchery, a commission came, but they only cast a look

 8    around and left.  They took no notes, nothing.  I even knew one of them.

 9    I believe he was an inspector, but he only looked around, and they made no

10    investigation or anything.

11       Q.   After the massacre, the day after the massacre, did something

12    happen to some of the prisoners who had been left in Room 3?

13       A.   Some were completely lost.  Others were taken away again.  The

14    next morning, they once again shot 20 people dead.  Well, perhaps not

15    exactly 20, but I think it was 20, right in front of the room, outside in

16    front of the room, on the pista.

17       Q.   And how did that take place?  Can you just describe what happened

18    before those people were shot?

19       A.   Well, they said, I suppose so as to justify their killing, they

20    said that one had escaped.  Now, I, of course, don't know if it's true or

21    not.  Allegedly, if anyone tried to escape, that he would be killed.

22       Q.   And who was it that said that?

23       A.   I don't know who said it.  We heard a voice outside.  Well, it

24    must have been a shift commander or one of the guards.

25       Q.   Now, when those 20 or so were shot, where were you?

Page 3252

 1       A.   I was in this small area which is an area which is behind the

 2    corner where we could wash our hands and the like.  In front of me was my

 3    fellow worker who happened to peep out to see who was it that was calling

 4    at the door, and he was the last one.

 5       Q.   And who was that person, that is, your fellow worker?

 6       A.   It was Adem Habibovic, and I never saw him again.

 7       Q.   Now, Witness Q, were you able to see these 20 or so prisoners

 8    being shot, or did you just hear it from where you were in Room 3?

 9       A.   We could not see anything because I suppose if one tried to see,

10    he'd also be hit.  But they were taken out, and when they had their

11    fill -- we could hear bursts of fire aimed at people, and afterwards one

12    of the responsible, one called here -- one shot fired at the heads so as

13    to make sure that ...

14       Q.   You referred earlier in your evidence to a butchery commission.

15    What is a butchery -- or what was this butchery commission to which you

16    referred, and when did it come to the camp?

17       A.   In the morning following the first chaos.

18       Q.   By the first chaos, do you mean the massacre, the first massacre

19    that took place in Room 3?

20       A.   Yes.  Yes.  That's it.  The first butchery.

21       Q.   And what was this commission?  What was it comprised of and what

22    did it do when it came to the camp?

23       A.   Nothing.  Since that door was all perforated by bullets and

24    fragments, one could see how they came that morning, cast a look around

25    and they must have also been flabbergasted by what had happened.  They

Page 3253

 1    could not believe it but then they ascertained that that was true indeed,

 2    and they did nothing else.

 3       Q.   Who were these people and how many of them were there?

 4       A.   Well, I did not count them but one of them, I think he was the

 5    boss and I knew him.  I think he was somebody from the police, an

 6    inspector, I guess.

 7       Q.   Now, you referred on Friday to this person Kole who was a shift

 8    commander in the camp.

 9       A.   Yes.  At night before the massacre, because that night they took

10    away -- they were taking away very many people, groups of 10 or 15,

11    depends, and they never came back.  And then that night, I told my

12    neighbour, "I think that tonight we'll fare worse."  I meant that night.

13    I didn't know.  It was only a guess.  And my neighbour told me, and he's

14    Refik Behlic said, "There is no need to fear because allegedly, the

15    commander is very good."  And he survived too.  And in the morning, I told

16    him, "There's your Kole.  Look what he did."  He couldn't even believe

17    that he had survived all that.

18       Q.   What was it that your neighbour had told you in -- in response to

19    your saying, "I think that tonight we'll feel better."

20       A.   No.  No.  No.  I said -- I said, "I don't know what will happen

21    tonight, something bad is going to happen tonight."  There was something

22    in the air, some tension or something.  But he learned from somebody that

23    commander -- that Kole would be the commander that night.  Perhaps he knew

24    Kole.  I didn't know him.  So that when he said that, I somehow felt

25    better, but then things turned out to be much worse.

Page 3254

 1       Q.   Now, Witness Q, I want to take you, please, to the last day before

 2    the camp closed.  On that day, was there a new commander in the camp?

 3       A.   A new commander came whom I knew, I mean personally I knew his

 4    name.  But he was a very good man, but I suppose it was not all his -- he

 5    wasn't really responsible for it all.  But he said that nobody would be

 6    beaten again.  Nobody would be killed again.  And indeed, he stood by his

 7    word except that not even he knew that those men who had been called out

 8    to two buses, that they would all be executed, and I suppose he would not

 9    tell us that.

10       Q.   What was this person's name, and when did he arrive as commander

11    in the camp?

12       A.   One day, we were out on the pista and I recognised him then, the

13    man who was there.  And we asked what was he doing there, what was his

14    position.  And he was then responsible for the camp, Marinko.  All I know

15    is that he used to work in a shop, in a store, building materials and

16    household appliances, a shop next to the orthodox cemetery in Prijedor.

17       Q.   When did he take over as commander in the camp?  How many days

18    after the Room 3 massacre was it before he took over?

19       A.   After the second shooting, this shooting in the morning, I told my

20    neighbour Behlic, "Well, how about moving -- if you want to survive, how

21    about moving to Room 4."  And we came across a man who had worked with us

22    in the same company.  He worked for the -- at the railway station, and he

23    must have been a guard that day.

24       Q.   Just pause there, please, Witness Q, and just listen to the

25    question.  Are you able to say when it was that the new commander took

Page 3255

 1    over in the camp as commander?

 2       A.   I was about to tell you how I moved to Room 3.  This colleague of

 3    ours allowed the two of us to move because we knew one another and I

 4    suppose -- without the commander's knowledge.  I don't know.  But we moved

 5    to Room 4, and I think that then, after that, well, I can't tell you the

 6    exact day, but on the pista when we were outside, I saw then the new camp

 7    commander.

 8       Q.   Thank you.  If we can go back to the last day when the camp

 9    closed, what happened to the prisoners on that day?

10       A.   We all knew that the camp would be closed down.  Marinko told us

11    so.  And then some, I suppose, knew where the people would go.  I thought

12    they'd let us go home, but somebody shouted that those whose names were

13    called out should board the bus which would allegedly -- but unfortunately

14    they would be killed.  But at that time, we did not know if those who were

15    taking those buses and who had not been called out or those others, that

16    is, who would go to be slaughtered.

17            And there they called out my uncle and many of our neighbours, and

18    they filled about two buses with them.  I cannot say how many.  What I do

19    know is that a pit where those people had been thrown in and which was

20    discovered, there were 145 men in it near Sanski Most, and that is where

21    they found those fellow workers of mine who had been in Keraterm.

22       Q.   Can you name, please, those fellow workers who were taken away on

23    that day?

24       A.   I can give you -- if the Tribunal has a list of identified

25    persons, then I could give you.  Adem Karupovic, Camil Music, Mujo Music,

Page 3256

 1    Taib Mujadzic, those whom I remember.  But there are very many who have

 2    not been identified yet.

 3       Q.   Did you subsequently see the bodies of some of the men --

 4       A.   Yes, I did.  I saw the skeletons or the skulls of all those

 5    people.

 6       Q.   Now, Witness Q, you were -- you yourself were taken to Trnopolje

 7    camp after the Keraterm camp closed; is that right?

 8       A.   Yes, that's right.

 9       Q.   And you stayed there for, I think, about 15 days; is that correct?

10       A.   Yes, that's right.

11       Q.   Yes, thank you.

12            MS. BALY:  That's the evidence in-chief.

13            JUDGE ROBINSON:  Thank you, Ms. Baly.

14            Mr. Greaves.

15                          Cross-examined by Mr. Greaves:

16       Q.   Witness Q, I'd like to ask you, please, about something which

17    happened to you in 1998.  It's right, isn't it, that you gave evidence

18    before this Tribunal in September of that year in another case?  Do you

19    recall doing that?

20       A.   Yes, I do.

21       Q.   And just so that it's clear, that was the Kupreskic case; is that

22    right?

23       A.   Yes.

24            MR. GREAVES:  May we go briefly into private session, please.

25            JUDGE ROBINSON:  Yes.

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Page 3259

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10                          [Open session]

11            MR. GREAVES:

12       Q.   Witness Q, it's right, isn't it, that you were asked questions in

13    the Kupreskic trial about the process by which you came to make a

14    statement to the Bosnian authorities?  Do you remember that?

15       A.   Yes.

16       Q.   And it's right, isn't it, that you told the court on that occasion

17    that you had made a statement simply by having someone else's statement

18    photocopied and you putting your signature on it?  Do you remember that?

19       A.   We didn't understand each other.  I remember that, but I say once

20    again, that's too difficult for me.  And in that unfortunate case and in

21    that event, someone, and I gave the name there, a colleague -- when we

22    made those statements, they were not 100 per cent identical.  They weren't

23    100 per cent the same.  Of course, we can't all relive, revive a case in

24    the same way, that's quite logical, and write the same thing.  So it can

25    only be similar, but it can't be 100 per cent identical.

Page 3260

 1       Q.   With respect, Witness Q, what you told the Tribunal on oath on

 2    that occasion was this:  "They took statements, the statement from one of

 3    my colleagues, and then just crossed it out and wrote the same thing and

 4    wrote just my name and so on, the same thing that he had said."

 5            Isn't that what you did, simply have someone else's statement

 6    copied out, and you were prepared to sign it as if it were your own story,

 7    your own account?  Isn't that what you did?

 8       A.   You're -- you probably doubt that I was there.

 9       Q.   Witness Q, I haven't suggested anything of the sort.  I simply

10    wish to establish that you are someone who is prepared to advance as your

11    own account of matters the account of somebody else.  Isn't that right?

12       A.   Please, if you can, can we not talk about something that isn't

13    linked to this case, if that is possible.

14            JUDGE ROBINSON:  Witness Q, it is linked to this case, and we will

15    determine whether it is relevant.  Please answer the question.

16            MR. GREAVES:

17       Q.   Witness Q, is your reluctance to answer these questions because

18    you know that you are someone who is prepared to be dishonest and

19    untruthful about accounts that you give to the authorities?  Isn't that

20    why you are reluctant to talk about this particular subject?

21       A.   It's an effort for me, but I'll tell you the real truth now, in

22    that case.  Me and my colleague made a statement.  I gave a statement.  My

23    colleague was there in the same room, and the same person took our

24    statements.  And allegedly -- for him, that is to say, for him not to say

25    the same thing and to say what happened, the man said, "Is that how you

Page 3261

 1    experienced it?  Did you experience it the same way?"

 2            And as that was -- as it would be a waste of time, and it's not

 3    paid, you understand me, it's not paid, then he, quite naturally, would

 4    cross out the statement and add something else not to have it be 100 per

 5    cent the same, copied the statement not to have it the same.

 6       Q.   So this was a man called Zijad Ibric, wasn't it, who was taking

 7    the statements from you and your colleague; is that right?

 8       A.   Yes, it was that person.

 9       Q.   And Mr. Ibric suggested that you make some alterations from the

10    statement of your colleague to make it look as though it was actually a

11    different statement and a different person giving it; is that it?

12       A.   Yes.

13       Q.   So what it comes to, isn't it, is that between you, Mr. Ibric, and

14    your colleague, you were effectively faking an account of what was going

15    on, weren't you?  Prepared to engage in fakery?

16       A.   Not like that.  That person was really there where the crime took

17    place.  But some other circumstances, he didn't wish to -- he didn't -- he

18    was too taken up with his own family.  He didn't want to lose time on

19    things like that, waste time with things like that.

20       Q.   The other person really was there but you weren't; is that what

21    you're saying?

22       A.   Where?  Where do you mean?

23       Q.   You were relating events which took place in -- somewhere in the

24    Lasva River Valley, isn't that right, Ahmici?  Are you saying that the

25    colleague of yours really had been there but you hadn't?

Page 3262

 1       A.   When -- if you establish that I wasn't there, then you can

 2    criminally prosecute me.  Is that all right?  When you're quite sure.

 3       Q.   I just wish to establish with you, Witness Q, please, you said a

 4    moment or two in evidence that person was really there where the crime

 5    took place.  Do you mean by that, Witness Q, that you were not there at

 6    the place where the crime took place but were merely repeating what he had

 7    said?

 8       A.   We should then have to have a look at the proceedings and my

 9    testimony, and then you can assess if you haven't seen it.  You can assess

10    whether I was there or wasn't there.

11       Q.   You see, the colleague that you're talking about, he refused, told

12    the Bosnian authorities he wasn't prepared to testify, didn't he?

13       A.   Well, you know why he wasn't ready, wasn't prepared, because first

14    of all, the man is the kind of man he is, and I don't hold it against

15    him.  He's illiterate.  In fact, he is an illiterate person.  Do you

16    understand me?

17       Q.   So your statement came into existence using his as the basis for

18    it but with some alterations; is that it?

19       A.   You didn't understand me at all.  We're not understanding each

20    other at all.

21       Q.   Well let's just approach it another way.  Was the purpose of you

22    making alterations from your colleague's version of events designed to

23    prevent you being caught out if you were ever asked about these matters?

24    In other words, caught out for having copied someone else's statement.  Is

25    that why it was done?

Page 3263

 1       A.   No, it wasn't because of that.  You can't take a person, for

 2    example, you can't have someone promise that he will come to testify and

 3    then later on say, "No, I don't want to."  And then he says he wants to,

 4    but doesn't want to.  He has to decide, either he does or he doesn't.

 5    Only black and white.  No other way.  Because he thought -- like a quiz,

 6    he probably took it to be a quiz, like a quiz.

 7       Q.   Witness Q, you told the Judges on -- in September 1998 that you

 8    had suffered traumas and when you made one of your statements concerning

 9    matters at Keraterm to the Bosnian authorities, you told them that you

10    were still disturbed as a result of what had happened to you.

11            Have you continued to suffer problems, disturbances, as a result

12    of what you saw in Prijedor and Ahmici?

13       A.   Yes.

14       Q.   Do those problems include things like hallucinations and imagining

15    things happening, Witness Q?

16       A.   No.

17            THE INTERPRETER:  Could the witness be asked to approach the

18    microphone when giving his answers, please.  We cannot hear him.

19            JUDGE ROBINSON:  Witness Q, will you please come closer to the

20    microphones.  The interpreters are having difficulty hearing you.

21       A.   Yes, I can.

22            JUDGE ROBINSON:  Thank you very much.

23            MR. GREAVES:

24       Q.   Do those problems that you suffer, Witness Q, make it difficult

25    for you to remember accurately what happened in Prijedor and Ahmici?

Page 3264

 1       A.   It's very difficult for me, really.  You know why?  I'll tell

 2    you.  I'm still not quite clear on how people can do that to other people,

 3    do what they did to the victims.

 4       Q.   Yes.  That wasn't the question that I asked.  I know it's

 5    difficult, Witness Q, but these are important matters.  Do you, as a

 6    result of the disturbances which affect you, find it difficult to give an

 7    accurate account, an accurate and reliable account of the events which

 8    happened to you in Prijedor and Ahmici?

 9       A.   From the beginning, everything?  You mean from the beginning,

10    everything?

11       Q.   Do you find it difficult to give an accurate and reliable account

12    of what happened to you because of the disturbances which you've suffered,

13    Witness Q?

14       A.   Of course it's difficult.  I wouldn't be a normal man if it

15    weren't difficult.

16       Q.   I understand that.  I fear I must press you a little, Witness Q.

17    Is one of the consequences of the difficulties that you face that you find

18    it very hard to be accurate and reliable when you give details of what

19    happened to you in that period?  Is that --

20       A.   It's not that difficult that I can't tell you.

21       Q.   You see, when you made a statement to the Bosnian authorities in

22    March 1993, which was, what, seven months after you'd been in Keraterm,

23    you told them that you'd been taken to the camp on the 1st of August,

24    1992, didn't you?

25       A.   The date -- you know what?  If you want me to tell you all the

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Page 3266

 1    dates, then I would have to be a computer of some kind, and that's

 2    impossible, isn't it?

 3       Q.   Witness Q, the point is this, isn't it:  This is an example of how

 4    you find it difficult to be accurate and reliable when recounting events

 5    from 1992 and 1993?  You told them in relation to your detention at

 6    Keraterm that it had happened on the 1st of August, 1992.  Do you remember

 7    telling them that?

 8       A.   What I can tell you is that I was taken to Keraterm on the

 9    Orthodox holiday, St. Vitus day.  Is that enough?

10       Q.   And when does St. Vitus day fall, Witness Q?

11       A.   Now, if you want me to quote figures, let me explain something to

12    you.  By profession I was a machine operator on a train, and if I had to

13    remember all the numbers of the trains, would I be a phenomenon or what?

14    Would I be normal if I remembered all the train numbers?

15            So I know I don't have the right to ask you questions, but it's

16    very difficult for me to give you dates.  There are such a lot of

17    unfortunate dates, and figures for me are the most difficult thing.

18            JUDGE ROBINSON:  I believe you have the answer [Realtime

19    transcript read in error "witness"] there, Mr. Greaves.

20            MR. GREAVES:  If I may just explore just two more questions.

21       Q.   You're sure that it was St. Vitus day according to the Orthodox

22    calendar when you were arrested and taken to Keraterm?

23       A.   I'm sure 100 per cent.

24       Q.   And it's right, isn't it, that St. Vitus day is the 28th of June,

25    according to the Orthodox calendar?  Do you accept that?

Page 3267

 1       A.   So if I said the 30th, as you say, but all I can say is I remember

 2    that it was an Orthodox holiday and that that was the day I was taken into

 3    detention.

 4            JUDGE ROBINSON:  Could I just have the transcript corrected as to

 5    what I said.  It reads, "I believe you have the witness there,

 6    Mr. Greaves," and what I said was, "I think effectively you have the

 7    answer there, Mr. Greaves," not "I believe you have the witness there,

 8    Mr. Greaves."

 9            Please proceed, Mr. Greaves.

10            MR. GREAVES:  Yes, I think that's an incorrect transcription.

11       Q.   And Witness Q, you were in Keraterm for no more than 15 days, were

12    you?

13       A.   No, I was there for longer.  I didn't count the days because my

14    life was threatened.

15       Q.   Well, did you not tell the Bosnian authorities in March 1993 that,

16    "I stayed 15 days in Keraterm"?

17       A.   No, I don't think I did.  Could you repeat the question, please?

18       Q.   Yes.  In March 1993, you gave a statement to the Ministry of the

19    Interior Security Services Centre for Banja Luka then having their seat in

20    Travnik.  You were interviewed by a man called Fikret Huskic, and you told

21    him and wrote down a statement to this effect, "I stayed 15 days in

22    Keraterm."  Do you recall doing that?

23       A.   I don't remember that.

24       Q.   You see if that's correct, then you couldn't have been, I suggest

25    in Keraterm, when the Room 3 massacre had took place, if you had arrived

Page 3268

 1    there as early as the 30th of June or the 28th of June.

 2       A.   I can -- there are lots of holidays, but let me explain it like

 3    this, not St. Vitus day, no, not St. Vitus day, I made a mistake there.

 4    It was Petrovdan, St. Peter's day.  That's what it was.  I made a

 5    mistake.  I apologise.  I really did make a mistake there.  So it was

 6    St. Peter's day when I was taken to Keraterm.  You know there are a lot of

 7    holidays where I come from.

 8       Q.   When you made your statement to the Security Services Centre for

 9    Banja Luka in Travnik in March 1993, did you tell them everything which

10    had happened to you and everything which you could recall?

11       A.   I remember that man, but I don't remember that I gave him a

12    statement.

13            MR. GREAVES:  I wonder if my learned friend may have an original

14    or a copy of an original, please and whether it could be shown to him.  I

15    would be very grateful.

16       Q.   Witness Q, would you look at that document, please and, in

17    particular, the end of the document.  Do you see at the very bottom of

18    that document, Witness Q, two signatures right at the end?  One of them

19    appears to be somebody called Fikret Huskic, and then on the other side of

20    the page, is that your signature?

21       A.   Yes.

22       Q.   And would you look, please, at the first page, Witness Q.  Do you

23    see where it says, "I'm ..." and gives your name, don't read out your

24    name, gives your name "... personal details as stated above."  Do you see

25    that paragraph?

Page 3269

 1       A.   You mean after the statement?

 2       Q.   Yes.  There's a heading "Statement," and then it gives personal

 3    details about you in about eight lines or so; do you see that?  And then

 4    the statement actually begins; do you see that?

 5       A.   Yes.

 6       Q.   And it gives your name and says this, doesn't it, "Personal

 7    details as stated above.  Give this statement under full moral and

 8    material responsibility.  I will corroborate with my signature that it is

 9    true, otherwise I am prepared to bear the legal responsibility for it."

10            Do you accept that that's what it says?

11       A.   [No audible response]

12       Q.   Yes.  And when you made that statement, Witness Q, to Mr. Huskic,

13    did you put in it everything that had happened to you in Keraterm and

14    everything which you recall taking place in Keraterm?

15       A.   If I can read everything, then I will.

16       Q.   Would you like just to take a moment to read it over.

17       A.   I need time.  The number of people in the room, probably this man

18    put this figure there just like that.  It's impossible for 500 men to fit

19    there.  300 is possible.

20       Q.   Just pause there, please, Witness Q.  Are you saying that, again,

21    someone put into your statement his words and you went along with it; is

22    that what it comes to?

23       A.   No.  Regarding this figure, it could be a mistake, a typing error,

24    the figure of 500 men in the room.

25            JUDGE ROBINSON:  Mr. Greaves, I think he gave an answer, he says,

Page 3270

 1    "It could be a mistake, a typing error, the figure of 500 men in the

 2    room."

 3            MR. GREAVES:  I've interrupted his reading.  He's completing the

 4    reading.

 5            JUDGE ROBINSON:  He's still reading.

 6            MR. GREAVES:  That's why I hadn't gone on, Your Honour.  It wasn't

 7    that I had dried up completely.

 8       Q.   Now, then, Witness Q, did that statement contain all which

 9    happened at Keraterm during your stay?

10       A.   Yes.  My memories were still fresh then.

11       Q.   Help me about this:  In the light of your assertion now that that

12    statement contains all that happened whilst you were in Keraterm, you've

13    made an allegation about 20 people being shot the following morning why is

14    there no mention of that incident in that statement?

15       A.   There is -- let me see, now.  I'll tell you in a minute.

16    Regarding the numbers for the next morning, I don't know whether I

17    mentioned that.  Let me see, now.

18       Q.   Let me help you, Witness Q.  It isn't there, is it, at all?  Just

19    no mention of it.

20       A.   No, no, but I didn't mention it because -- well, you see, when --

21    I remember my colleague from work, I know he got killed then, and then

22    it's true I didn't mention it here in this first statement.  That doesn't

23    mean that these statements have to be 100 per cent all equal, identical.

24       Q.   Witness Q, help me, please, if you will:  The killing of these 20

25    people, did that take place within just a few hours of the Room 3

Page 3271

 1    massacre, in other words, the very same morning?

 2       A.   No.

 3       Q.   Later that same day?

 4       A.   The next morning, the next morning at dawn.

 5       Q.   You say that you heard automatic fire.  Was that bursts of fire

 6    from several different weapons?

 7       A.   The bursts came from one weapon.

 8       Q.   But it was a --

 9       A.   You mean for the execution, do you?  Are you referring to the

10    execution?

11       Q.   Yes, the incident which you say took place something like 24 hours

12    or so after the Room 3 massacre.  It was a case of automatic fire, are you

13    saying from one weapon alone?

14       A.   Yes, and then a pistol with one shot.

15       Q.   And so when you use the phrase "bursts of fire," you mean the

16    discharge of many rounds of ammunition at the same time from the same

17    weapon; is that correct?

18       A.   Well, naturally at that moment, there may be time for him to pick

19    up another rifle or change the charge and recharge the rifle.

20       Q.   Yes.  I'm not suggesting anything otherwise, but can you confirm

21    what you are saying is that this was a machine-gun-type weapon, and the

22    bursts of fire that you heard amount to many rounds being fired in one

23    discharge?

24       A.   Well, you see, I can't say that I saw how they lined up the men

25    and then say that I saw exactly when I didn't see it.  We just know that

Page 3272

 1    those men are gone, that that morning this burst of fire was heard, that

 2    the bullets hit against the wall, and we also heard single shots fired

 3    from pistols, so it could have been nothing else but an execution.

 4       Q.   Witness Q, this is correct, isn't it:  You did not see what was

 5    going on outside, did you?

 6       A.   That's right.

 7       Q.   You didn't see where the 20 people were when the firing took

 8    place, did you?

 9       A.   I did not.  I just know that they were taken away.

10       Q.   Yes.  And indeed, is this the case:  Nobody in Room 3 could see

11    what was going on, nobody was in a position to see what was going on?

12       A.   Nobody could see.  It was early.  I can't say what time it was;

13    they took our watches away.  We were still -- those who were shot next to

14    us, they may have been half a metre away.  There was a wall separating us,

15    and our lives were really in danger.

16       Q.   And although those 20 people who were taken out have not been seen

17    again, you cannot say, can you, that they were in fact killed that day or

18    killed on some other occasion, can you?

19       A.   I could learn at least about one of them living somewhere on this

20    planet to say, "I have survived the execution," as there have been such

21    cases of people saying, "I was wounded."

22       Q.   Witness Q, let me just put it to you again.  Those people have

23    disappeared, but you cannot say if the cause of their disappearance was

24    that they were killed that day in Keraterm or killed somewhere else on

25    some other occasion, can you?

Page 3273













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14    and the English transcripts.












Page 3274

 1       A.   I cannot answer that for you.

 2       Q.   Just have a look at an aspect of the Room 3 massacre, if we may,

 3    please.  You've told Their Honours that there was some call for a

 4    negotiator.  Were negotiations in fact conducted between detainees and the

 5    people outside?

 6       A.   No, there were not negotiations because probably the people who

 7    were killed in front on the pista over there, they allegedly perhaps

 8    thought that they would negotiate, but they were killed.  So that was

 9    rather - how shall I put it? - naive.

10       Q.   Before the shooting started, was there some sort of disturbance

11    between the detainees in Room 3?

12       A.   Of course there was.  It was overcrowded.  The temperature outside

13    was over 30 degrees probably, in my assessment.  People were perspiring

14    terribly, the stench, and on top of that, a teargas bomb was thrown in

15    which went off in the middle of the room.

16       Q.   Did people in the room, Room 3 start to fight amongst one another

17    before the shooting started?

18       A.   No, not fight, but it was like a nightmare.  People were escaping

19    but there was nowhere to escape to.

20       Q.   Was there any trouble between detainees on a village against

21    village basis that you can recall at this time?

22       A.   No, there weren't any problems of that kind.  There were problems

23    because people were -- some had choked and some were about to choke.

24    Those were the problems.  And they were asking for water.  They didn't

25    have water, and so on.

Page 3275

 1       Q.   I'd like to ask you, please, about the commission that you

 2    described coming to the camp.  Is it your understanding that this was a

 3    commission set up to investigate what had happened?

 4       A.   Probably the most responsible people in the civilian authorities

 5    probably came to see.  They heard, they couldn't believe it, so they came

 6    to see for themselves whether that was really true.

 7       Q.   So would you accept the proposition that this was a commission of

 8    investigation set up to conduct an inquiry into what had happened?

 9       A.   I think that this man that I knew but I didn't know his name, I

10    think he was something like the chief of police or deputy or something

11    like that.

12       Q.   Would that have been Simo Drljaca; is that a name with which

13    you're familiar?

14       A.   No.  No.  Not that one.  No, I didn't know Simo Drljaca at all.  I

15    think this was an older man --

16       Q.   Does the name --

17       A.   -- about 50 years old.

18       Q.   A large man, overweight, grey-haired; would that be right?

19       A.   Short and fat.

20       Q.   Does the name Zivko Knezevic mean anything to you in connection

21    with this man?

22       A.   Could be.  But I knew him only from the beach, and I knew that he

23    worked in the police.  That's all.

24       Q.   Although the commission withdrew from the immediate area of Room

25    3, did you know where it went immediately after that?

Page 3276

 1       A.   I don't know.

 2       Q.   And you don't know one way or the other, do you, whether the

 3    commission carried out its task of investigating what happened, do you?

 4       A.   I don't know.

 5       Q.   Witness Q, you've told us about the closing of the camp.  Is it

 6    right that about 8 to 10 days before the camp closed, that was when the

 7    new commander, Marinko, came and took over; is that right?

 8       A.   Something like that.  I don't know the exact day, but towards the

 9    end anyway.  After everything that had happened, the worst things, then

10    Marinko came, yes, for the commander of the camp.

11       Q.   And Marinko, is that his first name or his last name as far as you

12    know?

13       A.   His name.  I know his name.

14       Q.   Could I suggest to you that his full name is Marinko Sadzak.

15       A.   I don't know.  I know the man because I used to shop in his store,

16    furniture, building material.  That's how I know him.

17                          [Defence counsel confer]

18            MR. GREAVES:  Thank you very much, Your Honour.

19            JUDGE ROBINSON:  Thank you, Mr. Greaves.  Mr. Petrovic.

20            MR. PETROVIC: [Interpretation] Thank you, Your Honour.

21                          Cross-examined by Mr. Petrovic:

22       Q.   Witness, could you please tell me first whether in Central Bosnia,

23    you were engaged in any military unit after you left Prijedor?

24       A.   Yes, I was.

25       Q.   Which military unit?

Page 3277

 1       A.   Do I have to say that?  The army of Bosnia-Herzegovina was, for

 2    me, something normal.  That's no secret.  I was a member.

 3       Q.   Does the nickname Hadzija mean anything to you?

 4       A.   From which area do you mean Hadzija?

 5       Q.   I'm referring to the area of the Central Bosnia, Vitez, Ahmici.

 6       A.   Yes, I did know a man who was a professional driver.  He drove

 7    trucks and trailers for a company in Bugojno, I think it was, which was

 8    transporting goods.

 9       Q.   At the time of the conflict in Central Bosnia, was that man a

10    member of a military unit?

11       A.   I think he was a member, and that man was killed.  After he

12    surrendered all the weapons he had, after that when he surrendered his

13    weapons, he told me, "They are guaranteeing not to hurt us," but then

14    later that man was killed.

15       Q.   Does that mean that he was a commander of that unit?

16       A.   I don't know whether he was.  It wasn't really a unit.  His street

17    and, actually, everyone took up arms, and so they got arms, too.  And then

18    they said that these should hand in their weapons and that nothing would

19    happen to them.

20       Q.   Could you please answer my question, which I think was clear:  Was

21    he the commander of that unit?

22       A.   I don't know.

23       Q.   Were you a member of that unit?

24       A.   Yes, I was.

25       Q.   Who were the other members of that unit?

Page 3278

 1       A.   The other members, most of them had the surname Ahmic.  I don't

 2    know their names.  I know some by their nicknames and so on.

 3       Q.   Were you given any kind of remuneration for belonging to that unit

 4    and fighting in that unit?

 5       A.   In those days it was patriotic.

 6       Q.   Did you have any other benefits?

 7       A.   No, I didn't.

 8       Q.   How do you know about fragmentation ammunition?

 9       A.   When I was younger, I knew that it was prohibited.

10       Q.   No.  My question is, so please answer my question, how do you know

11    the effect of fragmentation ammunition?

12       A.   I was a member of the former JNA.  I did my military service as a

13    recruit.

14       Q.   While you were doing your military service in the JNA, did you

15    ever once have occasion to see the effect of such ammunition or to see

16    such a bullet, a fragmentation bullet, while you were serving in the

17    former Yugoslav People's Army?

18       A.   We were just informed about the effects of such ammunition and

19    nothing more than that.  I didn't see any.

20       Q.   Did anyone offer you any money to testify?

21       A.   No.

22       Q.   When you testified in the case that we have already mentioned, in

23    this Tribunal on the 21st of September, 1998, on page 2563 of the

24    transcript you said that money was offered to you to make statements but

25    that you didn't accept.

Page 3279

 1       A.   That is not true.

 2       Q.   What is not true, that money was offered to you, or is it not true

 3    what I have just read from the LiveNote on the 21st of September?

 4       A.   It is not true that money was offered to me.

 5       Q.   In the case I mentioned, you said under oath, "Money was offered

 6    to me, but I didn't think I had the right to earn money at somebody else's

 7    expense, at the expense of somebody's tragedy."

 8       A.   Yes, normally.  Yes, that's natural.  That's right.

 9       Q.   Don't you see a contradiction there, that you said then that you

10    were offered money and you didn't want it, and today you are telling us

11    that you were never offered anything?  These are two different things.

12       A.   Yes, they are two different things, but they're two questions,

13    too.  How do you explain that?

14            MR. PETROVIC: [Interpretation] Your Honour, with your

15    suggestion -- with your approval, could we have a break now, please?

16    Would that be appropriate?

17            JUDGE ROBINSON:  Yes.

18            Witness Q, we are going to take a break of half an hour.  During

19    the adjournment, you are not to discuss your evidence with anybody,

20    including the members of the Prosecution team.

21            We're adjourned.

22                          --- Recess taken at 11.01 a.m.

23                          --- On resuming at 11.34 a.m.

24            JUDGE ROBINSON:  Yes, Mr. Petrovic, please.

25            MR. PETROVIC: [Interpretation] Thank you, Your Honour.

Page 3280

 1       Q.   Witness Q, you said that in Room 3, and you were in that room, to

 2    the left in that allocated part there was a wash basin or something like

 3    it.  Was there any water there?

 4       A.   No.  All the faucets had been removed.  Everything was destroyed.

 5       Q.   Was there a barrel with water in Room 3?

 6       A.   There was a barrel of sorts, but what was in it, now ...

 7       Q.   Was the barrel there in the night of the massacre in Room 3, if

 8    you can remember, that is?

 9       A.   Yes.  It was there, but there was also a barrel of maybe of 50

10    litres for all those people there.

11       Q.   When you came to Keraterm, before the night of the massacre, were

12    you locked all the time in that room that you were in?

13       A.   One day we came out onto the pista.  It was terribly hot.

14       Q.   Which means you were not kept locked up all the time?

15       A.   No.  It was in daytime, and we were laying down face down, our

16    hands above our heads, and when we were very hot, they poured water from

17    the hydrant over us.

18       Q.   So you said that the night of the massacre -- very well.  The

19    second night, the second night you spent in Keraterm, it was the first

20    morning after your arrival in Keraterm; is that correct?

21       A.   Well, I don't remember exactly, but I know that one day we spent

22    lying down on the pista, and that that was what they did to us.

23       Q.   Tell me, regarding the commission which turned up in the morning

24    after the massacre, do you remember when was that, or roughly?  Was it

25    before the daybreak or was it full daylight?

Page 3281













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14    and the English transcripts.












Page 3282

 1       A.   It was after the daybreak.  It was around 8.00.

 2       Q.   So it was in full daylight?

 3       A.   Yes, it was.  I think it was around 8.00.

 4       Q.   How many people were there in that group which you described to us

 5    as a commission, roughly?

 6       A.   Well, naturally, I looked at one that I knew.  I couldn't -- I saw

 7    the car arrive, one of them, the one whom I knew, he had approached the

 8    weigh bridge where the freight was weighed.  That was he.  Others did not

 9    come close.

10       Q.   And what car was it?

11       A.   I didn't see the car.

12       Q.   And that one that you knew, if I understood you well, you do not

13    remember his name, is it?  Do you remember what the man was called?

14       A.   No, I didn't know his name at all.  I knew him because in summer,

15    he would come to the beach and that is how I remembered him.  That's all.

16       Q.   Do you remember what he looked like?  Could you describe him to

17    us?

18       A.   Well, I described him once.  I can do it again if you want me to.

19    Then I will.

20       Q.   Well, will you try, please.

21       A.   He was short, I'd say up to 50 years of age.  He was bald or,

22    rather, losing his hair, greying.

23       Q.   And do you know what he did before the war?

24       A.   Before the war, I saw that he had some rank insignia, but I did

25    not know which rank.  He was either the chief of his or his deputy.

Page 3283

 1       Q.   In other words, he held a relatively high rank?

 2       A.   Yes, he had a high rank.

 3       Q.   And that also applies to the pre-war period?

 4       A.   Yes, before the war and during the war, yes, he assumed the role.

 5       Q.   Do you, perhaps, recall what uniform he had that morning?

 6       A.   He wasn't in a uniform, he had civilian clothes.

 7       Q.   Did you, perhaps, see if somebody tape-recorded anything?

 8       A.   No, I did not see anything.

 9       Q.   Did you, perhaps, see if those people, that commission, took notes

10    of what they could see at Keraterm that morning?

11       A.   No, they did not take any notes.  They did not tape anything or

12    anything.  Of all the things that they should have done, they did nothing.

13       Q.   That morning when the bodies of people who had died that night

14    were taken out, were there any shots fired at that time or was it all calm

15    by then?

16       A.   In the morning when the day broke, it was all calm.  Nobody did

17    anything.

18       Q.   That day after the massacre, did you leave the room?

19       A.   We only left so that the room could be cleaned.

20       Q.   So that morning, nobody ill-treated you when you came out of that

21    room that you had spent the night in?

22       A.   That's right.

23                          [Defence counsel and accused Dosen confer]

24            MR. PETROVIC: [Interpretation] Thank you, Your Honours.  I have no

25    further questions.

Page 3284

 1            JUDGE ROBINSON:  Thank you, Mr. Petrovic.

 2            Sir Ivan.

 3                          Cross-examined by Mr. Lawrence:

 4       Q.   Witness Q, you told us that before the Room 3 massacre, you had

 5    the feeling that something bad was going to happen, that there was tension

 6    in the air; do you recall that?

 7       A.   Well, you see, there was tension because of the previous night,

 8    because of people beaten up, because of those who had left and not come

 9    back.  Those who had been taken away.

10       Q.   Yes.  Can you just answer my question yes or no unless there's

11    more that you need to say.

12            Did you tell us that in the minutes or hours leading up to the

13    shooting of the people in Room 3, there was growing tension, and you had

14    the feeling that something bad might be happening?  Yes or no?

15       A.   Yes.

16       Q.   Thank you.  And --

17            THE INTERPRETER:  Could the witness please come closer to the

18    microphone.

19            MR. LAWRENCE:

20       Q.   Please come closer to the microphone, Witness Q, because the

21    interpreters can't hear you.  Thank you.

22            Is it possible that one of the reasons why you felt increasing

23    tension in the air was because there was a lot of movement which you

24    couldn't see outside in the camp that night, a lot of coming, people

25    coming on to the camp?

Page 3285

 1       A.   Well, yes.  People opened the door as they pleased, and took

 2    out -- they either went through a list or would point at someone, one of

 3    the detainees, that they needed to speak to them.

 4       Q.   I'm not talking about that.  I'm talking about the evidence - I'm

 5    so sorry - the evidence you gave about an increasing feeling of tension

 6    that evening, a buildup of a feeling that something bad was going to

 7    happen, which was unusual.  Was there such a feeling that evening?

 8       A.   There was, yes.

 9       Q.   And was that or may that have been because a lot more people were

10    coming on to the camp that evening?

11       A.   That's right.

12       Q.   And was the atmosphere that you were feeling consistent with a lot

13    of soldiers coming on to the camp, vehicles coming on to the camp, and

14    movement of people outside on the pista or elsewhere in the camp?

15       A.   Well, I made that statement earlier, that I had told my neighbour,

16    "Tonight will be a bad night."  And he, too, calmed me down, to help me,

17    to put it that way.  He said, "Don't be afraid.  Tonight -- Kole's on

18    tonight, and he's a good man, so we'll fare all right while his shift is

19    on."  I don't know if he knew Kole personally, but that's what he told

20    me.  But everything turned out the other way around.

21       Q.   And if there were soldiers coming on to the camp, they might have

22    been responsible, for all you know, for the smoke bomb coming in through

23    the window?

24       A.   I could even assume that the biggest problem was caused by

25    Banovic, and I could recognise him if he were there, but he is not here.

Page 3286

 1    He had a pigtail.  I cannot [sic] recognise him.  There were two brothers

 2    Banovic, and he sowed most of this unrest or this restlessness amongst the

 3    detainees.  He was there in the night of the massacre.  Cupo, he was

 4    called, but I do not know which one, but one of the two brothers, and one

 5    of them I'd -- I'm sure I would recognise.

 6       Q.   Can you please, Witness, just concentrate on the questions that

 7    I'm asking you and give as simple answers as you can.

 8            My question was, if it were so that a lot of the movement on the

 9    camp was because soldiers were coming on to the camp, might it be that the

10    soldiers were responsible for throwing the smoke bomb through the window?

11       A.   Yes.

12       Q.   You didn't see Banovics throwing smoke bombs through the window,

13    that's what I ought to ask you, did you?

14       A.   I didn't.  I didn't see who had thrown the bomb --

15       Q.   Of course not.

16       A.   -- but ...

17       Q.   Now, when you said that you thought you heard somebody asking for

18    somebody to come out and negotiate, which you rightly thought was absurd

19    in the circumstances, do you remember that incident?

20       A.   I do remember the incident.

21       Q.   Might it have been that the soldiers were provocatively trying to

22    encourage residents, the inmates of Room 3, to come out so that they could

23    be shot?  Might you have misunderstood that it was an invitation to

24    negotiate, rather, an invitation to come out and be shot?

25       A.   Yes.  Yes.  That's it.  Well, there are practically two questions

Page 3287

 1    there.  What I think is that they wanted somebody to negotiate with

 2    supposedly some room leader --

 3       Q.   Well, I know --

 4       A.   -- so as to beat him up or something because the atmosphere was

 5    already rather tense and nobody could come out.  The room was very

 6    stuffy.

 7       Q.   What I'm suggesting, Witness, is that it was so ridiculous to even

 8    think that this was a negotiation situation, but what was happening was

 9    that the guard, the soldiers with the guns were trying to provoke the Room

10    3 residents to come out when they would be shot.  May that have been the

11    situation?

12       A.   Yes.

13       Q.   Can I move, please, to another matter very briefly.  You told us

14    about the incident of the calling out of the 20 the next day; do you

15    remember?

16       A.   I do, yes.

17       Q.   And that was not the same day as the shooting that had taken place

18    in the early morning and through the night.  It wasn't that day, it was

19    the day afterwards.  You told us that.

20       A.   I did.

21       Q.   Is it right that you were told that Fustar was the shift commander

22    when those 20 prisoners were called out?

23       A.   Yes.

24       Q.   You told us, and you didn't really need to tell us, what a

25    traumatic and horrifying event the shooting of the inmates of Room 3 was,

Page 3288

 1    and you've told us where you were in the room.

 2       A.   Yes.

 3       Q.   We've heard evidence that earlier on in the evening, there was

 4    singing in Room 3; do you recall that?

 5       A.   Yes, that selfsame Banovic made us do it, made us sing their

 6    songs.  And later on when the melee started, he demanded that we keep

 7    silent.

 8       Q.   Can you remember how long before the shooting roughly, because we

 9    know you didn't have watches, that singing took place?  Was it hours

10    before or minutes before or ...

11       A.   Well, it didn't last long because --

12       Q.   How long before, not how long it lasted?  If you can help us,

13    please, how long before the shooting was the singing?

14       A.   Well, perhaps two or three hours, thereabouts.  Two hours.  Two,

15    I'd say, two.

16       Q.   Might it have been longer than two?

17       A.   I cannot tell you exactly, but I'd say it was two hours.

18       Q.   My question is -- you're doing your best, but might it have been

19    longer than two hours before the shooting began?

20       A.   Yes.

21       Q.   Thank you.  Do you remember -- you've told us that there was a

22    shortage of water in Room 3 and were people in Room 3 crying out for

23    water, shouting out for water?

24       A.   Yes.

25       Q.   We've heard evidence that Kole was trying to get somebody to bring

Page 3289













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Page 3290

 1    a hose to Room 3.  Can you remember whether that happened or not?  Can you

 2    remember?  That's the point.

 3       A.   I don't remember that.

 4       Q.   Can you remember nearer to the shooting, and we've heard evidence,

 5    Kole shouting to the inmates of Room 3 to break the glass so that they

 6    could get more air?

 7       A.   Yes, but it was by then too late already.

 8       Q.   So your recollection was hearing Kole shouting that?

 9       A.   Yes, I heard him.

10       Q.   Thank you.  Did you hear Kole, and we've heard evidence about

11    this, shout to the residents of Room 3 not to come outside once the

12    shooting was starting?

13       A.   I did not.

14       Q.   Did you hear, and we've heard evidence about this, Kole shouting

15    to the soldiers to stop the shooting?

16       A.   I did not.

17       Q.   If it happened and you didn't hear it, might that be because there

18    was such a lot of noise going on inside Room 3?

19       A.   Yes, there was a lot of noise because our lives were in danger.

20       Q.   And you were down by the wash basin, I think you told us, and the

21    radiators.  Was that sort of low on the floor?

22       A.   No, like that, regularly.  A metre, a metre above the floor on the

23    wall just like any other wash basin.

24       Q.   But the atmosphere inside the room must have been appalling?

25       A.   Yes, it was.

Page 3291

 1       Q.   And you must have been very shocked and horrified?

 2       A.   We were very frightened.  We didn't know what was going on.  We

 3    knew what was going on because even before that shooting, there already

 4    were some dead and wounded, and there was confusion and disorder.

 5       Q.   And the memory of events that you've tried to drive out of your

 6    mind over the years?

 7       A.   Well, actually, you can't wipe it out.  You can't drive it out.

 8    That's impossible.

 9       Q.   But did you try?

10       A.   When I am doing something, then I tend to forget about it while

11    I'm doing something.

12       Q.   And I think you're not claiming, are you, Witness Q, that you

13    remember everything with total accuracy that happened that night?

14       A.   I don't claim that I remember everything with total accuracy, of

15    course not.

16       Q.   Thank you.

17            JUDGE ROBINSON:  Thank you, Sir Ivan.

18            Ms. Baly.

19                          Re-examined by Ms. Baly:

20       Q.   You said, Witness Q, that after the massacre, this commission came

21    at about 8.00 a.m. in the morning.  My question is, had the bodies and the

22    wounded been taken away by that time?

23       A.   No.

24       Q.   Had Room 3 been cleaned by that time?

25       A.   No, it hadn't.

Page 3292

 1            MS. BALY:  Thank you.  Those are my questions.

 2            JUDGE ROBINSON:  Witness Q, that completes your evidence, and you

 3    are released.

 4                          [The witness withdrew]

 5            JUDGE ROBINSON:  Yes, Mr. Ryneveld.

 6            MR. RYNEVELD:  Yes, Your Honour.  The Prosecution's next witness

 7    has presently been designated as Witness K33 with protective measures.

 8    It's possible, and I will not know until the witness takes the stand,

 9    whether or not he -- we have had a discussion about whether he will

10    continue with that, and I won't know until he takes the stand.  So perhaps

11    we can go into closed session very briefly once the witness has taken the

12    stand as to whether he wants to continue with protective measures, or

13    whether or not he will allow himself to be examined as an open witness.

14            JUDGE ROBINSON:  Yes, yes.

15            MR. RYNEVELD:  Thank you.

16                          [Closed session]

17    [redacted]

18    [redacted]

19    [redacted]

20    [redacted]

21    [redacted]

22    [redacted]

23    [redacted]

24    [redacted]

25    [redacted]

Page 3293













13  Page 3293 – redacted – closed session













Page 3294

 1                          [Open session]

 2            MR. RYNEVELD:  Sir -- I'm sorry, are we open?  Thank you.

 3       Q.   Sir, I understand that you were living in the town where you were

 4    born, at the outbreak of the war, with your wife and children; is that

 5    correct?

 6       A.   Yes.  I lived in Rakovcani, and that means Prijedor.

 7       Q.   Yes.  And prior to the war, sir, you had worked as a locksmith

 8    with the railway company; is that correct?

 9       A.   Yes, that's right.

10       Q.   Is it also true, sir, that you served your compulsory military

11    service and later you became a member of the reserve police?

12       A.   Yes.

13       Q.   Is it also true to say, sir, that you were not active in politics,

14    but that you had joined the communist party because you found it easier to

15    find a job at that time as a member of the communist party?

16       A.   Yes.

17       Q.   Now, sir, in May of 1992, is it fair to say that the company that

18    you worked for closed down, and as a result of that, you lost your job?

19       A.   Yes.

20       Q.   And during that period of time, May 1992, I understand that for

21    about a month before that, you noticed soldiers being stationed in the

22    area where you lived and you noticed some armoured vehicles or tanks in

23    the area as well; is that correct?

24       A.   Yes, that's right.

25       Q.   Sir, I understand that Radio Prijedor broadcast a message on the

Page 3295

 1    20th of May 1992 wherein you heard that people of certain Muslim villages

 2    including your village, Rakovcani, were to put white flags on your houses;

 3    is that correct?

 4       A.   [No audible response]

 5       Q.   What were your villages, sir, that were specifically mentioned in

 6    the radio broadcast?

 7       A.   We called them Brda, it was Rakovcani, Biscani, Carakovo, et

 8    cetera, the hills.

 9       Q.   What did you understand was the purpose of putting those white

10    flags on your houses?

11       A.   It was the sign of giving ourselves up, but to whom and why and

12    what, that wasn't clear to me.

13       Q.   At the time, sir, in May of 1992, are you able to give the Court

14    an estimate as to how many houses there would have been in Rakovcani and

15    about how many normal village inhabitants there would have been?

16       A.   Rakovcani numbered, I'm not quite sure, but between 500 and 600

17    households which means about 3.000 inhabitants.

18       Q.   And was Rakovcani ethnically mixed or was it predominantly one

19    ethnicity or religion, religious group?

20       A.   It was one religious group, Muslims, in the whole area of what we

21    call Brdo.  Rakovcani is there too.

22       Q.   Are you saying it was almost an exclusively Muslim area?

23       A.   Yes, exclusively Muslim area, Brdo, which is what we called it.

24       Q.   So Brdo was a name for a collection of villages; is that correct?

25    This is an area comprising a number of villages?  You're nodding your

Page 3296

 1    head.

 2       A.   Yes, that's right.  That's right.

 3       Q.   Sir, at one point, did you suddenly find that there were a number

 4    of other people that you refer to as refugees who came to your village?

 5       A.   Yes.  They came from Ljubija, from Hambarine, but they were --

 6    they fled to Ljubija first and some went to Rakovcani, Biscani,

 7    Rizvanovici, that kind of thing.  But they were mostly from Hambarine

 8    actually.

 9       Q.   Do you know what they were fleeing from?

10       A.   They fled to save their lives from, well, you know from whom.  On

11    the 22nd of May already, that had already started.  Now, they know that.

12    They can assess what they did and -- but on the 22nd of May was when this

13    started, when the refugees started moving out, taking different

14    directions.

15       Q.   Sir, unfortunately although you indicate that I know what it was,

16    we need to tell the Court what it was.  So I'm going to have to have you

17    tell us rather than assume that I already know what the reason for the

18    refugees fleeing from what danger.

19       A.   Well, they fled from the Serbian army which had taken over

20    Hambarine.

21       Q.   Sir, this Serbian army, did they ever visit your house?

22       A.   Yes, they did on a number of occasions.

23       Q.   When, and what sorts of things occurred when they arrived at your

24    house?

25       A.   Once they came into the house and I was present there, but on many

Page 3297













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Page 3298

 1    other times I fled from the house.  I had to flee because I was afraid and

 2    so were my wife and children.  But when I was present on one occasion, a

 3    civilian came in wearing a tracksuit, two soldiers with him, and they

 4    looked around, looked at our things, and they made a note of them.  And

 5    they said that nobody must touch this property and that they would come to

 6    fetch it later on, things like a television, a video recorder.  Things

 7    like that.

 8       Q.   And did they, in fact, return and take those items?

 9       A.   Yes, they did return.

10       Q.   And when they returned, did they take those items away?

11       A.   Yes, they took them away.  They took the items away, the

12    television set, the video recorder.

13       Q.   Were you given an explanation as to why?

14       A.   No.

15       Q.   You told us you lived with your wife and children at your home.

16    How old was your -- I take it you had a son; is that correct?

17       A.   Yes, his name was [redacted].

18       Q.   And how old was he?

19       A.   14.

20       Q.   Did the soldiers express any interest in him?

21       A.   Yes.  They asked how old he was, and as a parent, that was

22    suspicious.  Why did they have to ask him his age?  And as he looked

23    older, he was physically well-developed, well, he looked as if he might be

24    15 or 16 years old so I was afraid for him.

25       Q.   Now, the time that you've just talked about, the radio broadcast

Page 3299

 1    and the soldiers visiting your home, was that in the period of time

 2    between the 20th of May and the 19th of July 1992?

 3       A.   Could you repeat that question, please?

 4       Q.   Yes.  These events that you've just told us about, did they occur

 5    in the time period -- well, let me rephrase it.  Do you know approximately

 6    when those things happened?

 7       A.   Yes.

 8       Q.   Tell us, please.

 9       A.   From the 20th of May to the 20th of July when I was finally ...

10       Q.   Okay.  I don't know if you finished your sentence, when you were

11    finally what?

12       A.   Well, taken into custody, arrested in front of my own house.

13       Q.   All right.  Sir, I'd like you to turn your mind now, if you would,

14    to the 19th of July, 1992.  Can you tell us what was happening in the area

15    surrounding the village where you lived?

16       A.   What happened was shelling.  That lasted about two hours, although

17    for me it seemed to be an eternity because I had never encountered weapons

18    and shells or anything of that kind before, but it was exactly on the

19    19th.

20       Q.   Apart from shelling, did you see any troops?

21       A.   Yes.

22       Q.   And what, if anything, were they doing?

23       A.   They were passing by my house when I saw them.  My father's dead;

24    he's no longer living.  He shot at my father, but they missed, and perhaps

25    it would have been a better thing if he had died then than later on.

Page 3300

 1            But anyway, in Rizvanovici an incident occurred as well.

 2    Allegedly, what had happened was that they had lost a soldier, as they

 3    said, in that part of Rizvanovici.  However, they arrested I don't know

 4    how many people but a lot of them and took them off with them towards

 5    Ljubija.  And later on it was found that they had been killed.

 6       Q.   This incident you've just told us about, sir, that was a

 7    neighbouring village, Rizvanovici?

 8       A.   Yes, that's right.

 9       Q.   Did these troops eventually show up in your village, which was

10    Rakovcani?

11       A.   Well, whether they were the same ones or not, I don't know, but

12    they would appear often.  But when the cleansing, as they said -- that is

13    to say, on the 24th when that was to happen, I don't know where they were

14    from.  But yes they did appear frequently in that period, between the 20th

15    of May and, let's say -- or, rather, the 22nd of May when the attack on

16    Hambarine took place right up to the arrest itself.

17       Q.   All right.  Perhaps I have not been clear in my questioning.  I

18    thought we were talking about the 19th of July moving on to the 20th of

19    July.  You've told us that on the 19th of July that neighbouring villages

20    were being shelled, I believe, and --

21       A.   Yes.

22       Q.   Did the -- and that troops were doing certain things.  My question

23    now is, on the 19th or 20th of July, did troops, i.e., soldiers, Serbian

24    soldiers, end up in your village of Rakovcani?

25       A.   Well, they came -- they turned up at around 9.00 or 10.00 and

Page 3301

 1    started taking people out.  I personally at that particular moment had

 2    come to a neighbour's house, and I was listening to Radio Prijedor, the

 3    news through Radio Prijedor that day, and they announced that there would

 4    be a search taking place, and as they said, as they called it, this

 5    search.  And I came home.  When I came home, I saw my wife and children

 6    grouped together with their neighbour, a lady called Sefika.  However,

 7    just as I had entered, two soldiers turned up.  They were wearing

 8    uniforms, and they said that all the men were to come outside.  I looked

 9    at my wife and children, and I had to go out because if I were to resist

10    them, I would have got a bullet in my head or something like that.

11       Q.   Did they say anything else to you other than that all men were to

12    go outside?

13       A.   Yes.  One of them said -- told me to sit down, and he swore at

14    me.  He used derogatory terms.  He said, "Fuck you and Alija, your Alija,"

15    something along those lines.  And at one point he said that I should move

16    towards the group of people who were standing some 50 to 100 metres away

17    from my own house.  This was called Kuzno [phoen], and that's where my

18    neighbours had been gathered together.

19       Q.   Just let me ask you one question.  When he said -- he swore at you

20    and made some comment about your Alija, who was Alija?  What is that?  Who

21    was that?

22       A.   Alija Izetbegovic, the president.

23       Q.   Of?

24       A.   Of the then Bosnia-Herzegovina.

25       Q.   So that was reference to a political figurehead, was it?

Page 3302

 1       A.   Yes.  And they said, "Who did you vote for?"  They mistreated us,

 2    generally speaking.

 3       Q.   Well, sir, this gentleman who told you to sit down, was he armed?

 4       A.   Yes.  They had automatic rifles.  I didn't look to see what type;

 5    otherwise, I could have recognised an automatic rifle.  I was able to

 6    distinguish between this type of rifle and the other PAP type or whatever.

 7       Q.   At the time that you were arrested, sir, were you somehow

 8    associated with the military or were you a civilian?

 9       A.   Exclusively civilian.

10       Q.   What happened to you?

11       A.   When I left to -- went to the crossroads, my neighbours were

12    there.  Some soldiers waited for us there and asked for our IDs so that we

13    could join the other group, but at that particular point I didn't take out

14    my ID card, but I gave them some other papers.  I don't remember exactly

15    what, but some other papers.  And we moved off towards Rizvanovici.

16       Q.   This other group you refer to, other group of what?

17       A.   People.

18       Q.   What kind of people, and where were they from?

19       A.   They were exclusively from Rakovcani and some from Hambarine.

20    Where I was, thereabouts.  Rizvanovici.  Some other people were to join

21    us.

22       Q.   When you say people, were they male, female, adults, children, or

23    was it a more restricted group?

24       A.   Males.

25       Q.   What were their ages?

Page 3303

 1       A.   Exclusively men.  Between 14 and 80 years of age.

 2       Q.   What were these prisoners or what were this group of men to do?

 3    What did they do and why?

 4       A.   You mean the Serb army?

 5       Q.   No.  Let's back up.  You just told us that there was a group of

 6    exclusively men, and then I think you gave us an age range although I

 7    don't think that the transcript picked it up.  What was the age range?

 8       A.   From 14 to 80 years old.

 9       Q.   All right.  Now, this group of people, did they just stay there or

10    did they go somewhere or what -- what did they do and why did they do it?

11       A.   Well, they were standing around at that crossroads.  They were

12    just standing there.  And the numbers increased, more and more people came

13    up, and then at one point we moved off towards Rizvanovici.

14       Q.   How did you know to do that?

15       A.   Because we placed our hands on the shoulders of the person in

16    front of us, and we had to sing their songs.

17       Q.   When you say you had to do something, who was it who was giving

18    you the instructions to do that?

19       A.   I can't say exactly, but it was the Serb soldiers.

20       Q.   Thank you.  Now, sir, so you marched off into the direction of

21    Rizvanovici, if I have pronounced that correctly.  You are nodding your

22    head.  Yes?

23       A.   Yes.

24       Q.   And how far away was that?

25       A.   It was about a kilometre away, thereabouts.

Page 3304

 1       Q.   So the group of you just marched there under escort from the

 2    soldiers; do I understand that?

 3       A.   Yes, that's right.

 4       Q.   And when you got there, what happened?

 5       A.   An APC vehicle turned up and some soldiers came out of it; one of

 6    the soldiers had a Serbian flag, took a Serbian flag.  You could see that

 7    from the Rizvanovici place.  He went up to the mosque, the minaret of the

 8    mosque, took down the flag that was there, and raised the Serbian flag.

 9    And I noticed that he shot at someone with a sniper or another weapon, I'm

10    not sure whether it was actually a sniper, but I don't know whether he hit

11    his target or not.

12       Q.   When you say, "He shot at somebody with a sniper," are you

13    referring to a sniper as a weapon?

14       A.   Yes.  Yes, a weapon.

15       Q.   I see.  Now, sir -- and this may seem like a very stupid question

16    and it probably is but I'm going to ask you this anyway:  This mosque that

17    you referred to, is this a Muslim house of religious order?

18            JUDGE MAY:  I don't think we need to be told what that is.

19            MR. RYNEVELD:  Thank you.

20       Q.   In any event, sir, at some point, do I understand that a number of

21    buses arrived?

22       A.   Yes.

23       Q.   And what, if anything, happened when the buses arrived?

24       A.   Then they started yelling at us and cursing us, and told us to get

25    on to these buses.  They said, "You Turkish swine," something to that

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Page 3306

 1    effect, "Get in."  Once we got in, a man in uniform, one of them, entered

 2    and said, "The older people can get off."  And he personally pointed at

 3    the people who could get off the bus.

 4       Q.   Did he give a reason?

 5       A.   Allegedly they were not fit for the camp, that they should stay

 6    behind.  However later on, it was established that they tortured these

 7    older people and killed most of them.  This was to be learnt later.

 8       Q.   Did you know who it was that got on the bus and told the older

 9    people to get off?

10       A.   Yes.

11       Q.   Could you tell us?

12       A.   It was Rade Bilbija.  He lived about three kilometres, three to

13    four kilometres from my house.

14       Q.   Now, did the rest of you stay on the buses and where did the buses

15    go?

16       A.   I stayed in the bus.  It was packed full.  How many exactly there

17    were, five or six, that headed off towards the camps via Rakovcani and

18    Hambarine.

19       Q.   En route to wherever the buses were going, did it stop at

20    Hambarine, the bus you were on?

21       A.   Yes.  This was in the Hambarine Polje or field.

22       Q.   And what happened once the bus stopped at the Hambarine field?

23       A.   They took a man out who was about 30.  I knew him.  His name was

24    Selimovic, his nickname Baki.  I don't know his name.  They took him off,

25    and nothing is known about him since, whether he is alive or not.

Page 3307

 1       Q.   Who took him off the bus?

 2       A.   I noticed a colleague of mine from work next to the white Kombi

 3    van, a small van that was standing there.  I noticed Brane Krnata.  Now,

 4    who actually took him off and why, allegedly I heard from others that they

 5    had lost a soldier of their own and they wanted to make up for it.  This

 6    is something I heard later so I don't know whether it's true.

 7       Q.   These people that took him off the bus, one of which you

 8    recognised and have named, could you tell how they were dressed?

 9       A.   They were in uniform.

10       Q.   Do you remember what kind of uniform?

11       A.   We usually call it SMB, olive-grey.  They were the Yugoslav

12    military uniform.  I didn't really look closely so I'm not a hundred per

13    cent sure.

14       Q.   Once this man was taken off the bus, your bus continued on, did

15    it?

16       A.   Yes, along the road towards Prijedor.

17       Q.   Did you hear from other passengers on the bus what happened to

18    this man as your bus was driving away?

19       A.   Yes.  I heard that they were first playing around with him, and

20    then they started beating him.  The bus started.  What happened after

21    that, Brane Krnata probably knows.

22       Q.   Sir, in any event, your bus continued on and you ultimately

23    arrived at Keraterm camp later that morning; is that correct?

24       A.   Yes.

25       Q.   And when you arrived at Keraterm, sir, did the buses park inside

Page 3308

 1    of the compound?

 2       A.   No.

 3       Q.   Where?

 4       A.   In front of the camp, there was a gate there.

 5       Q.   Yes.  Did it go through the gate, or do you recall?

 6       A.   I'm not sure about that.

 7       Q.   But in any event --

 8       A.   There were other things I had on my mind.

 9       Q.   Certainly.  In any event, sir, when you got off the bus, did you

10    go through the gate into the camp at some point?

11       A.   Yes.

12       Q.   And when you were inside the gate, what happened to you?

13       A.   As I entered I reached a kiosk, and then a soldier, normally,

14    asked me for my ID.  I gave it to him.  He asked me my surname.  I said

15    what my name was -- can I mention my name?

16       Q.   Just, we will get to the point where I will have to ask that.  We

17    will go into the closed session.  At the moment just tell us that you gave

18    him your surname, please.  You gave him your surname, yes?

19            MR. RYNEVELD:  Perhaps this is a good time.  We should just deal

20    with this one issue that we need to go into closed session.  It is only

21    about three questions.  Just a minute.

22                          [Closed session]

23    [redacted]

24    [redacted]

25    [redacted]

Page 3309













13  Page 3309 redacted – closed session













Page 3310

 1     [redacted]

 2     [redacted]

 3     [redacted]

 4     [redacted]

 5     [redacted]

 6                          [Open session]

 7            MR. RYNEVELD:  Thank you.

 8       Q.   Now, sir, this gentleman that you had this conversation with, did

 9    he ask for your identification, or had you given it to the soldier?

10       A.   I gave it to this man who was the first one next to me, closest to

11    me.  And behind him was Sikirica, and he said this to me.

12       Q.   Yes.  And what happened with your identification card?  Did it

13    ever get into Sikirica's possession, and if so, how?

14       A.   He was already in the kiosk with this soldier.

15       Q.   Yes.

16       A.   And so he already had the ID.

17       Q.   And by "he," are you talking about the soldier or Sikirica?

18       A.   Sikirica.

19       Q.   Did he return the ID, or did he make any notation in your

20    presence?

21       A.   He took down my name, and he didn't return the ID to me.

22       Q.   All right, sir.  Now, do I understand correctly from your evidence

23    that you recognised this individual that you have now called Sikirica from

24    a previous incident involving the, shall we say, picking up of a body of a

25    woman?

Page 3311

 1       A.   No, I didn't recognise him by that.  I had noticed him, but I

 2    didn't pay much attention.  It was only later when I came to the camp that

 3    I realised that I had seen that person before, and that is at the

 4    checkpoint at Hambarine.

 5       Q.   How much earlier had this incident involving picking up the

 6    woman's body been before you were arrested and taken to Keraterm camp?

 7    How much time had passed between the time you had seen him there?

 8       A.   Not very much.  This was less than a month, I think.  Fifteen to

 9    twenty days previously.

10       Q.   Is it fair to say, sir, that at the time that you went to pick up

11    the woman's body, you did not know this man's name?

12       A.   It was a woman, not a man.  Her name was Causevic.

13       Q.   No, no, no, sorry.  Badly phrased my question.  Is it fair to say

14    that at the time you picked up this woman's body, you did not know the

15    name of the man that you now refer to as Sikirica?

16       A.   I did not know.

17       Q.   Is it also fair to say that you did not know this man's name at

18    the time you had a conversation with him and he recorded your ID?

19       A.   I didn't know, but the president, of the local community had

20    spoken to him, of the Red Cross, Camil Dedic.  And I, myself, was on the

21    tractor.  But I noticed him, of course.

22       Q.   Did the president of the Red Cross tell you what the name was of

23    the man that he spoke to?

24       A.   No, he didn't.

25       Q.   How did you learn that the man that you spoke to at Keraterm camp,

Page 3312

 1    and the man who had been in charge at the time that you picked up the

 2    woman's body was named Sikirica.  When did you learn his name?

 3       A.   I learnt it in the camp.

 4       Q.   From whom?

 5       A.   First, from his own colleague, Nurija Crljenkovic a good friend of

 6    mine.  Unfortunately, he is not alive.  And there were others who knew

 7    him, older detainees.

 8       Q.   Turning now just right to the very last paragraph, paragraph 22,

 9    I'll just follow up on this.  Sir, this Nurija Crljenkovic, you say was a

10    colleague of yours.  What did this individual, what information did this

11    individual have about Sikirica and his identity?

12       A.   Simply I didn't really inquire much, but he was saying that he was

13    his colleague from work.  I also know that he was never tortured.  He was

14    one of those who was in Room 3 who was not tortured.  But Nurija explained

15    it by saying that they had worked together and he knew him, and maybe that

16    is why he was not tortured.  And he also spoke to him now and then during

17    the day.

18       Q.   So this friend of yours who told you Sikirica's identity knew

19    Sikirica because he had worked with him; is that correct?

20       A.   Yes, certainly.

21       Q.   I see.  So the source of your information about who Sikirica was

22    was from someone who personally knew him?

23       A.   Yes.

24       Q.   All right.  Returning, if I may, Your Honours, to --

25       A.   May I also add that I had another encounter with Sikirica, but

Page 3313













13    Blank page inserted to ensure pagination corresponds between the French

14    and the English transcripts.












Page 3314

 1    maybe we'll come to that later.

 2       Q.   We'll get to that in a moment, sir.  For the moment, I'm just

 3    trying to find out it was that you knew that this man's name was Sikirica,

 4    all right?

 5            Now, sir, earlier in your evidence you referred to an individual

 6    by the name of "Banovic" and you referred to him in relation to the same

 7    incident when you and the president of the Red Cross went to pick up a

 8    woman's body; do you recall that?

 9       A.   Yes.  Yes, I do.  I remember.

10       Q.   Did you see this individual, Banovic, later in the camp, camp

11    Keraterm?

12       A.   Yes.

13       Q.   First of all, after you arrived at Keraterm, where were you

14    placed, what room?

15       A.   Room 3.

16       Q.   With how many other people and, if so, how do you know?

17       A.   We were placed there, somebody counted, I don't know exactly, but

18    about 400 people were in there.  They should know best how many because

19    they had the particulars.

20       Q.   But to your knowledge, somebody made a count of the people and

21    told you that it was about 400 people that were in that room; is that fair

22    to say?

23       A.   Yes.  Yes.

24       Q.   And the day that you arrived at Keraterm, sir, just so that I'm

25    correct, have I got the day correct, was this the 20th of July 1992?

Page 3315

 1       A.   Yes.

 2       Q.   And you had arrived in early morning; is that correct?  No, I'm

 3    sorry, late morning.

 4       A.   Yes.

 5       Q.   And what happened during the day, if anything, and when, if any

 6    time, were you locked down for the night?

 7       A.   Yes.

 8       Q.   There was a question in there, sir, so I should ask it again.

 9    What happened -- you were placed in Room 3.  Did anything happen during

10    the day before you were locked up at night?

11       A.   Yes, we went for lunch.  That was the first time I went to eat.

12    We were given two minutes to eat.  Of course you had to obey.  We reached

13    the room, this number 3, so-called.  Maybe later it would get another

14    name.  A group of men entered that room; however, 10 or so of us were the

15    last stayed behind.

16       Q.   I'm sorry, sir, I think -- I've got to back you up.  I'm talking

17    about the very first day you arrived at the camp, the very first day.

18       A.   Oh, I see.

19       Q.   We'll get to the incident you're talking about later, okay?  The

20    very first day, the 20th of July.

21       A.   I apologise.

22       Q.   Did you get fed the very first day?

23       A.   No.  Can I go on?

24       Q.   Yes, please.

25       A.   The first time I was given food was on the 24th.  That was the

Page 3316

 1    first meal I got.

 2       Q.   And I take it you were about to tell us about getting your first

 3    meal a moment ago when I indicated to you that I wanted you to talk about

 4    your first day of arrival; is that correct?  You are nodding your head

 5    meaning yes?

 6       A.   [No audible response]

 7       Q.   Let's make sure that we know what time frame we're talking about.

 8    We're talking about the 20th of July, the first day you arrived at

 9    Keraterm.  Was the door locked sometime that day?

10       A.   On the 20th of July, one of the soldiers locked the door about

11    8.00.

12       Q.   What happened after that, if anything?

13       A.   On the 20th of July, the night to the 21st, what time it was I

14    don't know, but anyway, a call-out started.  They called out first Avdic

15    Rasim.  How he fared, I don't know.  I know that I was taken out.

16       Q.   How was that?  How were you taken out?  Who called you out?

17       A.   I didn't know who it was, but I was to learn later who it was.

18    They said, "Come out, we need you."  However, there was a younger man,

19    [redacted], then me, and then the room chief Muharem said, [redacted]

20    [redacted]

21       Q.   If I can just stop you there, sir.  How -- by what reference or by

22    what name did you think you were being called out?  How did they refer to

23    you so that you knew you were being called out?  Was it by your name or by

24    some other term?

25       A.   It wasn't my name.  [redacted].

Page 3317

 1            THE INTERPRETER:  The interpreter apologises, didn't hear the

 2    word.

 3       A.   I was known as a [redacted].

 4            MR. RYNEVELD:

 5       Q.   All right.  [redacted]

 6    [redacted]?

 7       A.   Yes, yes.

 8       Q.   And if I understand what you were trying to explain earlier, there

 9    were other younger players [redacted]?

10       A.   Correct.

11       Q.   And how did you know that it was you they were referring to as

12    opposed to one of them who also were [redacted]?

13       A.   The man who was calling out said, "We need the [redacted]who

14    [redacted]," so I knew that he meant me.

15       Q.   And as a result of that, what, if anything, did you do?

16       A.   Nothing.  I knew that he wanted me, so I went out.

17       Q.   That's what I meant.

18       A.   A big man was there.  When I opened the door, I saw somebody who

19    looked familiar.  I didn't pay much attention.  He said, "Go over there,"

20    and it was Banovic, actually.  When I reached that room, it was a room for

21    torture.

22       Q.   All right.  I'm going to stop you there, sir.

23            MR. RYNEVELD:  Your Honours, we're about to launch on an area

24    that's going to take a few minutes, and I wonder if this is an appropriate

25    time for our lunch break.

Page 3318

 1            JUDGE ROBINSON:  Yes, it is.

 2            Witness R, Witness R, we are going to take a break of one hour and

 3    a half.  You will return at 2.30 p.m.  During the adjournment, you are not

 4    to discuss your evidence with anybody, and that includes members of the

 5    Prosecution team.

 6            We are adjourned.

 7                          --- Luncheon recess taken at 1.00 p.m.



















Page 3319

 1                          --- On resuming at 2.34 p.m.

 2            JUDGE ROBINSON:  Mr. Ryneveld, continue with your examination.

 3            MR. RYNEVELD:  Thank you, Your Honour.

 4       Q.   Now, Witness, just to remind you where we are, you had just told

 5    us that you had been called out of the room by virtue of the fact that

 6    they were looking for an [redacted]and you say that you recognised

 7    someone called Banovic; is that correct?

 8       A.   It is.

 9            THE INTERPRETER:  Could the witness please come closer to the

10    microphone.

11            MR. RYNEVELD:

12       Q.   Just come a little closer to the microphone, sir, so they can hear

13    you.

14            Now, sir, where did you go and what happened to you, if anything?

15       A.   When I came out, I moved towards a room which I later found out

16    was called number 5.  Before it, there was Room 4 and that one was the

17    torture chamber.  But when we got there, Banovic did not hit me right

18    there and then.  Well, there was some verbal abuses, but when I got there,

19    a woman met me with a hose and she said, "This is a good one," and hit me

20    with that hose and others joined her.

21       Q.   Do you know, when you say, "others joined her," what kind of

22    people were there that joined in when this woman hit you with the hose?

23       A.   They were all in uniforms.

24       Q.   How about the woman, was she in uniform?

25       A.   The woman was in a uniform too.

Page 3320

 1       Q.   Did you, at that time or -- were you able to identify any of the

 2    people who were involved in your beating other than this woman?

 3       A.   Not at that moment.  But later on when it was all over, I mean

 4    when I was already beaten up and battered, I heard somebody shout, I'm not

 5    sure who that was, "Off to that corner."  And I went to that corner and I

 6    crouched.  But how shall I put it, I apologise, but that's how it was,

 7    somebody had defecated and I stood in the middle of that and it really

 8    stank.

 9            And then Kondic came and hit me with his baton a couple of times

10    and said, "Look at this one, he can still stand."  But that is not true.

11    One of them -- "Excuse me, this one has shat," but that's not true, it

12    wasn't me.  It must have been one of them.  And then they sent me to

13    another corner.

14            And if I may add, Hasan Crljenkovic, he was already brought in

15    meanwhile.  Unfortunately, he is no longer among the living.  They beat

16    him and tortured him, and even though I knew I shouldn't look around me, I

17    did and some said, "You are looking around so as to identify," but that's

18    not what I wanted to do.  It was purely instinctive.

19            And then the so-called Faca came up to me.  At first he put his

20    pistol in my mouth, and then a knife, too.  And I was praying to God to

21    finish me off, not to torture me any more, but he said, "Balija, we're not

22    finished with you.  Now off be with you."

23            And I had to pass by them, and they beat me and at first with feet

24    as I was passing by.  They were beating me with their feet and their

25    fists.  And when I passed by, I thought I'd fall, but had I fallen I doubt

Page 3321













13    Blank page inserted to ensure pagination corresponds between the French

14    and the English transcripts.












Page 3322

 1    if I would have ever stood up again.

 2       Q.   All right, if I can just stop you there, Witness.  We're still

 3    talking about the same incident when you were called out the first night

 4    of your arrival, and you were taken into what was the room beyond Room 4;

 5    is that correct?  That's what we're talking about?

 6       A.   Yes.

 7       Q.   And --

 8       A.   That's right.

 9       Q.   -- there was a woman, a uniformed woman and other soldiers, and

10    you have just in the course of your evidence mentioned someone called

11    Kondic and someone called Faca.  Were there any others involved in this

12    beating that you suffered?

13       A.   Yes, Banovic.  Now, I don't know if he took part in that, but when

14    I was on my way back, when I had passed by them, the one who has said,

15    "Look at this one, he can run," that person, and I guess it was he who

16    said that, and he caught up with me because I was bent with a pen [as

17    interpreted] and he jumped on my back.  But I know he meant -- he couldn't

18    have had more than 50 kilograms, which is not much, so I managed to make

19    it into the room --

20       Q.   All right.

21       A.   -- and I know what they did to me, but why ...

22       Q.   Yes, you've told us some of the things they did to you.  You told

23    us about being hit with the hose and you were hit with various

24    instruments.  How long would you say this beating went on, sir?

25       A.   It's hard to say.  Between 10 and 15 minutes, not less than that.

Page 3323

 1       Q.   Sir, while you were being beaten, did they ask you any questions?

 2       A.   Yes, there were questions, those provocative.  Of course, they

 3    couldn't without four-letter words, "Fuck your balija.  Who did you

 4    support?"  When I supported Belgrade Partizan soccer club, they stopped to

 5    beat me, but that was in stages.  They beat me in all possible ways.

 6       Q.   Ultimately, sir, do I understand after the beating you managed to

 7    find your way back to your room, Room 3?

 8       A.   Yes.

 9       Q.   How badly had you been beaten?

10       A.   So much that my -- all my ribs were broken.  Well, I don't know if

11    all of them were broken, but my whole body hurt, the whole upper part of

12    my body.

13            And I forgot to say that at the time they beat me, that they

14    didn't beat me on the head but all over my body.  I do not know -- while I

15    was out, I do not know, they also hit me on my legs.  But I'm still

16    suffering consequences, I mean, the upper part of my body.

17       Q.   Over the next few days, sir, did further incidents occur?  When I

18    say incidents, were you beaten again on subsequent days, and if so, can

19    you tell us about the circumstances?

20       A.   Yes.  The next evening - I don't know at what time because we

21    didn't have watches, it's common knowledge that they had taken everything

22    - they called me out again.  I don't know which one I was, but I was

23    already beaten up, and so they said, "Well, if he calls me or doesn't call

24    me, kills me, doesn't kill me."  And they called me out like the previous

25    night, "[redacted], we need you."  And of course I knew they meant me, so of

Page 3324

 1    course I came out, and the same person then took me over there.

 2       Q.   When you say the same person -- just a minute, just a minute.

 3    When you say the same person, you've mentioned before four different

 4    people.  Which person took you out?

 5       A.   It was Banovic.

 6       Q.   And where were you taken this time?

 7       A.   I was walking towards the same room.

 8       Q.   And what happened on this second occasion in this same room?

 9       A.   Well, I didn't see that female, and there was some others whom I

10    could not recognise because I was taking, I was taking care of myself.  I

11    was trying to protect myself so I didn't pay much attention.

12            There were about eight to ten soldiers waiting for me, and they

13    started to beat me straight away with expletives and all the rest.  And

14    among other things, when I fell down to the ground, my arm was like this,

15    to the right, because my right arm had been broken.  And this one shouted

16    to remove it.  I'll never forget that.  And I heard it.  But instinct told

17    me or something to pretend that I couldn't hear him, but he removed my

18    arm.  And I could already see an iron rod prepared, that -- my head was

19    like this down on the concrete, and a blow ensued.  Whether I moved or

20    not, I don't know.  I don't know how long it lasted.  I could hear voices,

21    "Get up," but I was already ...

22       Q.   Sir, while you were being beaten the second time did anyone enter

23    the room?

24       A.   You mean one of the three civilians or ...

25       Q.   Let me rephrase my question, sir.  During the course of your stay

Page 3325

 1    at Keraterm, did you become familiar with someone with the name of Kajin?

 2            MR. PETROVIC: [Interpretation] Objection, Your Honour.  In this

 3    situation, this is a very leading question and it is insinuated to the

 4    witness whom he should mention in relation to the incident and this

 5    follows from the previous question.  This is a directly leading question

 6    whose name the witness should give.  I must object against this form of

 7    examination.

 8                          [Trial Chamber confers]

 9            JUDGE ROBINSON:  It does seem to the Chamber that this is leading,

10    Mr. Ryneveld and perhaps you would rephrase it.

11            MR. RYNEVELD:  Thank you.

12       Q.   Sir, you told us that on the second day of imprisonment you were

13    beaten again; is that correct?  You've just been telling us about that.

14    While you were being beaten, you say there was about 8 to 10 --

15            JUDGE MAY:  Just one moment.

16            MR. RYNEVELD:  Sorry.

17                          [Trial Chamber confers]

18            JUDGE MAY:  Mr. Ryneveld, the difficulty is this:  You've been

19    endeavoring to get some evidence from the witness who is in Court and has

20    heard all this discussion.  To ask your question in a neutral way would,

21    of course, be unobjectionable had it been not with reference to a

22    particular incident.  But since it was asked immediately after a question

23    about a particular incident, it must be doubtful whether the witness's

24    answer, if it comes, is unprompted.  And I think the fairer course would

25    be to move on.  You can ask about Kajin in a general way.

Page 3326

 1            MR. RYNEVELD:  I have Your Honour's point.  I will move on.  I

 2    suspect I will return to that individual at some later date, but not in

 3    relation to this incident.

 4       Q.   Now, sir, as a result of the beating that you sustained, did you

 5    receive any -- what can you tell us, was it of a fleeting nature or do you

 6    still suffer today from the injuries that you sustained?

 7       A.   I wish it was fleeting.  I suppose I shall suffer consequences to

 8    the end of my life.

 9       Q.   What kinds of difficulty do you have as a result of that beating

10    today?

11       A.   I have headaches, hemorrhoids, and that is another effect of it.

12    My back hurts.  I have to have massage.  But thanks to [redacted]authorities

13    who extended adequate assistance to me but it is of no avail.  Whenever

14    the weather changes, I hurt.  My arm is broken.  I've already told you

15    that.  I've undergone surgery.

16       Q.   Let me move on, sir, to an incident two days before what has been

17    referred to as a shooting incident in Room 3.  Can you tell us, sir,

18    whether there were any windows in Room 3 when you were in it?

19       A.   There were.

20       Q.   Were those windows open or closed, generally speaking, when you

21    first came into the room?

22       A.   When we came, they were closed.

23       Q.   Did that situation change at some point?

24       A.   Yes.  A detainee from another room came, I don't know whether from

25    number 1 or number 2.  I knew him.  "Sejho" was how they called him.  I

Page 3327

 1    don't know what his last name was.  So he came and removed the window and

 2    I thought it was good so we could have some fresh air and that that was

 3    the reason for it, but later on it turned out that it was in preparation

 4    for something else.

 5       Q.   Now, you've told us, sir, that when you were locked into the room

 6    on the 20th of July, that you did not receive any food; is that correct?

 7       A.   Yes, it is.

 8       Q.   How long did you go before you received your first meal?

 9       A.   I got my first meal at 1600 on the 24th of July.  So it was the

10    fourth or fifth day, from Monday to Friday.

11       Q.   And where was that meal served?

12       A.   Up there where they were distributing food next to Room 2.

13       Q.   And when you -- were you permitted out of the room in order to go

14    and get the food, I take it, I mean it's obvious you had to go from Room 3

15    to the area where the food was served; is that correct?

16       A.   It is.

17       Q.   When you were out, did you see anything that was different on the

18    pista?

19       A.   Well, I looked around mechanically not knowing what would happen,

20    and I saw this machine-gun nest and a machine-gun placed there, but I

21    thought, well, it's natural.  It's the army.  They are protecting us or

22    guarding us.  But later on, it turned out that it was something else.

23       Q.   Could you tell which direction the machine-gun was pointing?

24       A.   Room 3.

25       Q.   Where was the placement of this machine-gun in relation to Room

Page 3328

 1    3?

 2       A.   In the direction of Room 3.

 3       Q.   Had you seen that machine-gun on an earlier occasion like when you

 4    arrived or in the days between the 20th and the 24th of July?

 5       A.   No, I did not see it.

 6       Q.   Did you notice anything else unusual when you were allowed outside

 7    to get your food?

 8       A.   Yes.  They told us -- first they said, "You have two minutes to

 9    have your meal."  Well, two minutes is a very short time, and we had that

10    soup and went back to Room 3.  A group of men went inside, but a soldier

11    ordered -- or rather closed the door and told the rest of us to stop.

12       Q.   When you say "the rest of us," you and how many other people?

13       A.   About ten.

14       Q.   What happened next?

15       A.   Well, that soldier lined us up again, put us in a line and began

16    to interrogate who had weapons.  Of course, nobody responded.  Who didn't

17    have any will suffer no consequences; who did have some, we'll have a

18    special conversation with them.  And two -- and I'll never forget that.

19    Whether he knew them or not I don't know, but I don't think so, though,

20    and he said that he -- that they -- that one, that man's face was

21    familiar, that their faces were familiar, and they kept silent.  Had they

22    answered, perhaps it would have ended differently.

23       Q.   Do you know who that soldier was who told you to remain behind?

24       A.   Yes.  It was Kajin.  As a matter of fact, yes, it was Kajin who

25    also introduced himself, who said he was Kajin, who was not ashamed of his

Page 3329













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Page 3330

 1    name or, rather, his nickname.

 2       Q.   Had you seen this individual before the war?

 3       A.   No.

 4       Q.   How often would you have seen this individual during the course of

 5    your detention at Keraterm?

 6       A.   I can't give you an exact number of times, but on different

 7    occasions, three or four times, perhaps, but it was enough for me to see

 8    him once and to get frightened and to remember that face.

 9       Q.   Can you describe this individual to the Court?

10       A.   Yes.

11            MR. PETROVIC: [Interpretation] I object, Your Honour.  It is not

12    clear.  What is the question, when to describe this witness, to describe

13    him what he looks like today if the witness knows, or to describe him at

14    the time when he allegedly saw him in Keraterm?  I don't think the

15    question is precise, and I think it needs to be clarified.

16            JUDGE ROBINSON:  Generally, it's to the time when he saw him in

17    Keraterm.

18            MR. RYNEVELD:  Thank you, Your Honour.

19       Q.   The person that you refer to as Kajin who was speaking to you and

20    the other detainees, could you describe that individual to the Court, what

21    he then looked like?

22       A.   Yes.  Well, like this, he had short hair or, rather, dark hair.

23    While it was July and perhaps that is why he cut his hair so short, but

24    it's his business, really.  His face is stuck in my memory.  I can never

25    forget it because one cannot forget ever if one suffered such consequences

Page 3331

 1    in their hands.

 2       Q.   Can you tell us approximate age or height or weight or body build?

 3       A.   Well, a sportsman.  He was tall.  Now, as for weight, well, say

 4    about 80 kilograms.

 5       Q.   Approximate age?

 6       A.   Well, was he 30?  Thereabouts, 30-ish.

 7       Q.   You say that you would recall his face.  Was there something

 8    unique about his face that assists you to recall what he looks like?

 9       A.   He looked dark, dark and, if may say so, rather good-looking, but

10    something -- I didn't have any contact with him or against him, and that

11    is not why I'm testifying here against him.  Nor did I have any bad

12    experience with him, but I do not know if he did anything to others.

13       Q.   Yes.  That's not the issue, sir.  Do you -- did you ever see this

14    person's photograph shown to you since 1992?

15       A.   No, no.

16       Q.   Did you ever see his photograph or depiction on television since

17    1992 and coming to court today?

18       A.   No.

19       Q.   Sir, do you feel that you would recognise this individual if you

20    were to see him again?

21       A.   I think I would.  Quite certainly, yes, I would.

22       Q.   I would invite you, sir, to look around the courtroom today and

23    tell us if the person you say was Kajin is in the courtroom today, and if

24    so, where is he?

25       A.   I've already looked at him during the break.  I took a glance at

Page 3332

 1    him.  I don't want to act out anything.  I'm quite clear on who it is, and

 2    I can point to him.  He's in the middle over there next to the policeman.

 3       Q.   You're pointing to the back wall, are you, sir?

 4       A.   Yes.

 5       Q.   There appear to be six seats against the back wall, three of which

 6    are occupied by policemen.  Including the policemen, going from left to

 7    right, which seat is the person that you say is Kajin sitting in?

 8       A.   In the fourth place.

 9            MR. RYNEVELD:  For the record, the witness identified --

10       A.   From this side.

11            MR. RYNEVELD:

12       Q.   Yes.  From left to right, he's in the fourth seat; is that

13    correct?

14       A.   Yes, but the hair has done something to him, but yes, that's the

15    man.

16       Q.   Thank you.

17            MR. RYNEVELD:  For the record, the witness identifies --

18            MR. PETROVIC: [Interpretation] I apologise.  I have an objection

19    to the transcript.  He said, "But he has sort of changed a little bit."

20    That's what the witness said, generally speaking, and those words were not

21    translated.

22            JUDGE ROBINSON:  What line is that, Mr. Petrovic?

23            MR. PETROVIC: [Interpretation] The witness said it in B/C/S and it

24    was not introduced into the transcript, but it should have been in line 24

25    15:03:30.

Page 3333

 1            MR. RYNEVELD:  Thank you.

 2       Q.   Now, this individual that you say was Kajin, while he was speaking

 3    to you and the fellow detainees, can you tell us anything about his

 4    demeanour, how he appeared to you to be?

 5       A.   Well, whenever he would question us, in my opinion, he was tipsy,

 6    he was the under the effects of alcohol and he liked to show his strength

 7    with respect to us.  But he always repeated the same things over and over

 8    again, if anybody had weapons, that he would talk to them in his own way.

 9    If we didn't have weapons, we wouldn't have any problems, "I am so and

10    so.  Everybody knows me."  That kind of thing.

11       Q.   Sir, I'd like to move on, if I may.  After you had had this

12    conversation with this individual by the name of Kajin, were you returned

13    to your room?

14       A.   Yes, we went into Room 3.

15       Q.   And when you went into the room, sir, did you have a particular

16    spot where you were able to go?

17       A.   Yes, because I was beaten up, my friends made a little room for me

18    so that I could sit underneath the window to get some air, get some

19    more -- a little more air.  That kind of thing.

20       Q.   Was there any water in the room and, if so, what happened to it?

21       A.   There was a barrel, however, somebody had taken it out.  I don't

22    know who.  But the barrel was no longer there.  It had been taken out at

23    about 8.00.

24       Q.   And was -- were you locked in for the night at some point?

25       A.   Yes.  Somebody locked us in.  Who did, I don't know, but one of

Page 3334

 1    them did.

 2       Q.   Sir, what's the next thing that you recall happening that

 3    evening?

 4       A.   At one point, because there were mostly elderly people around me,

 5    I felt that there was something not quite all right with them.  They

 6    started saying some things.  They started praying to God to save them,

 7    things like that.  And I also felt some changes as if it was difficult,

 8    difficult for me to breathe and some of the people would murmur some

 9    words.

10            Amongst other things, they started arguing.  Some people started

11    to sort of command, issue orders when they were thrown in there.  I felt

12    this difference with the elderly people first, and then the rest of us who

13    were a bit younger.  We were all a bit younger there.

14       Q.   Could you tell why you felt different?

15       A.   Well, we knew that they had thrown something in.  I know -- knew

16    that they were sort of poisonous gas of some kind but I didn't know what

17    kind but I was in the army and I know something about that.  And I know

18    that I put the shirt that I had on as a sort of protection.  It helped me

19    to take this for longer.  I don't know ...

20       Q.   What happened eventually?

21       A.   Well, there was general panic and people entreated them not to

22    throw these things in, not to kill us.  I was lying down myself.  I wasn't

23    able to move.  And some of the people started fighting, the more

24    pressure.  There was and this affected them, these poor people who were

25    with me.  And they started storming the door, but --

Page 3335

 1       Q.   Who started storming the door?

 2       A.   The people started arguing amongst themselves, fighting amongst

 3    themselves.  Some even fought amongst themselves.

 4       Q.   Are you talking --

 5       A.   Yes, yes, the prisoners.  And then when I say "they," I mean the

 6    Serbs.  When I say "they," I mean the Serbs, the Serb army.  So they

 7    responded with a burst of gunfire and at one point, the people did manage

 8    to break down the door.  I don't know -- I know when Besim Fazlic a friend

 9    of mine and many others, he said, "[redacted], brother help me.  I've been

10    wounded in five different places."  So this is a dilemma for me.  I didn't

11    know what to do.  My life was in question.

12            At one point I sat down.  As I was sitting underneath the window,

13    I was all crouched up like this and I felt I couldn't take it any longer.

14    I said goodbye to my wife and children, and I don't remember the details

15    anymore but I know there was shooting, and let me repeat there was several

16    bursts of gunfire.  I heard that over here.  Now of course you can't -- we

17    were under the influence of all this, of everything that was going on.

18       Q.   Sir, did -- at some point, did you lose consciousness?

19       A.   Yes, I did lose consciousness, and what I remember and what I can

20    never forget is that I thought about my wife and children.  And that's

21    when I lost consciousness and I woke up afterwards.

22       Q.   When you woke up the next morning, where were you?

23       A.   I was in the corner by the window.

24       Q.   What's the first thing that you recall seeing or hearing upon

25    awaking?

Page 3336

 1       A.   Well nothing.  I got up and I saw -- I saw one corpse next to

 2    another.  And some people -- I saw some people taking something out, but I

 3    must say that for a moment when I came to, for a moment I thought that I

 4    was in Keraterm and then there was another moment when I thought that I

 5    was in my brother's cellar in Rakovcani.  But that was the result of the

 6    effects of probably those poisonous gases -- well, not probably but most

 7    certainly.  However ...

 8       Q.   Did you see anyone ministering to your fallen colleagues?

 9       A.   Yes, it was my neighbour who is a paramedic.  And unfortunately, I

10    am to say that he is no more.  He helped as best he could.  He would give

11    people water drop by drop on their lips, and their chests began to expand

12    and they began to breathe.  But as far as Senad Crljenkovic, I could say,

13    and we called him Senci is what had he called him, he gave him water drop

14    by drop.  I know that, but unfortunately he expired.  It wasn't enough.

15       Q.   Sir, I --

16       A.   And there were others.

17       Q.   Yes.  I'm not going to ask you to try to relive this incident at

18    this point.  I'm going to simply ask you by way of a summary question,

19    eventually, sir, did you see that there were piles of bodies as a result

20    of this shooting incident?

21       A.   Yes.  They were lives -- people who were alive.  They were alive

22    but wounded.  But all this was -- they were sort of in a drugged state.  I

23    don't know how to express myself better than saying that they were in sort

24    of a drugged state.  Some of them were taking out some of the dead.

25       Q.   Did you ultimately see what happened to the dead and the wounded?

Page 3337













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Page 3338

 1       A.   Well, I saw them being taken out of Room 3 through that aperture

 2    to the truck.

 3       Q.   And did the truck haul those bodies and wounded people away?

 4       A.   Yes.  It hauled the people away in an unknown direction.  And some

 5    people went off who were supposed to identify them because they said that

 6    these people would be identified and handed over to their families,

 7    whereas the wounded they said would be taken to hospital.  That was the

 8    information that reached us then.

 9       Q.   Do you know whether the people that were taken away were ever seen

10    again?

11       A.   Unfortunately not.

12       Q.   Sir, after the truck left, what happened to the remaining

13    prisoners in Room 3?

14       A.   As they sort of halved us, more or less, the first order was, "All

15    of you come out with your hands up behind your backs," and I still don't

16    know how I was able to put my beaten hand up behind my back, but that's

17    what I did.  I don't know how I managed to.  And we went for our morning

18    exercise, which is what they called it, and we knew what that was.  That

19    was mistreatment.

20            We went out of Room 3, and I still remember a voice, and that

21    voice saying -- a well-known voice, a voice that was familiar, he says,

22    "Look at [redacted].  He's still alive."  And that was the sign that I had

23    been condemned to death.  However, when we went outside, I didn't pay

24    attention, really, very much because I was still under the influence of

25    all this stress situation.  But when we did go outside, we laid down on

Page 3339

 1    the ground, lined up with our hands like this and our face was -- we were

 2    face downwards to the ground and turned towards Room 3.

 3       Q.   How long did you lay there?

 4       A.   It's difficult to say exactly, but about 4.00 or four hours.  It

 5    seemed an eternity to me.  It was July, and, you know, it's very hot at

 6    that time of the year in our country.

 7       Q.   What was happening to your room while you were lying outside?

 8       A.   Some of the people, I don't know who selected them, who picked

 9    them out, but they were washing the blood.  They were hosing down, washing

10    down the blood from the previous night in the room.  And on that day they

11    brought us in some pallets for the younger ones who had survived so that

12    they were given priority.  They could sort of sleep and sit down on these

13    pallets, wooden pallets.

14       Q.   Sir, moments ago you told us that you heard a voice referred to

15    you as [redacted]being still alive.  Did you recognise whose voice that was?

16       A.   Yes.

17       Q.   Are you able to tell us whose voice it was?

18       A.   I looked at that young man.  It was the voice of -- well, his

19    nickname was Pele.

20       Q.   Now, sir --

21       A.   I know him 'cause he played football, too, so that's how I

22    recognised him.

23       Q.   Sir, while you were lying outside, did you see if anything

24    happened to a neighbour of yours?

25       A.   Well, no, but I heard voices and moans and cries.  I knew that it

Page 3340

 1    was Adem Fazlic.

 2       Q.   And what --

 3       A.   Now, whether it was --

 4       Q.   What did you hear?

 5       A.   I heard the cries from that -- coming from that man whom they were

 6    torturing.

 7       Q.   That's the person you just named, Adem Fazlic?

 8       A.   Yes.  He's a neighbour of mine.  I knew him.  He's -- he was about

 9    55 at the time, 55 years old, thereabouts.

10       Q.   Now, sir, what happened next after you were lying there?

11       A.   We weren't allowed to raise our heads because if we opposed them

12    in anything, you knew what you would get.  They would kick our heads, and

13    that was the sign that you would have to get up, that the person being

14    kicked would have to get up to go up to the barrel, which was also

15    intended for torture.  They would place his head in the water for a time.

16            However, when my turn came, they kicked me, not very hard, but

17    they kicked me in the head a little, and I got up.  And just as I had

18    gotten up, they said, "Lie down," and I had to obey.  That's what you had

19    to do.  And then there was a hit, and I turned round and looked at the

20    person that I recognised - and you don't have to ask me who - and he hit

21    me again.  He tried to hit me, but I managed to avoid the blow, and I went

22    in to the dormitory so that I avoided that torture barrel on that

23    occasion.

24       Q.   You say that I don't have to ask you who.  Do you know who it was?

25       A.   Yes.  It was Sikirica.  I recognised him already when we had got

Page 3341

 1    up.  I tried to come out, but this gentleman told me to stand there a

 2    little longer.  I don't know the rules.  I looked round the hall, and of

 3    course I saw that -- the gentleman, if I can call him gentleman.

 4       Q.   I'm sorry, I'm a bit confused.  When are you talking about?  Are

 5    you talking about back in July of 1992, or are you talking about a more

 6    recent incident?

 7       A.   No.  When I said that I know the identity of that man if you were

 8    to ask me, I jumped the gun.  I looked at that Sikirica, and I saw him.

 9       Q.   When?

10       A.   When you said there would be a break.  I got up and I looked

11    round, and I know how I felt at that particular moment when I ...

12       Q.   I understand.  You're saying that when we broke for lunch, you

13    looked around and saw the person who -- is that what you're saying now,

14    and that was just earlier today?

15       A.   Yes, that's right.  Precisely that way.

16       Q.   So during the break, you saw an individual --

17       A.   That's what I'm saying now.  It was today when we were going to

18    take a break.

19       Q.   And I'm going to ask you to turn back to July of 1992.  When you

20    turned around then, this individual, what did he do?

21       A.   He hit me with a sort of wooden baton or truncheon.  We call it a

22    Palija.  It's this long, roughly.  I don't know how I managed to get up,

23    but I did and he wanted to strike me a second time but I managed to avoid

24    the blow.  And I avoided the barrel used for torturing us and they

25    screamed at me, "Stop.  Stop."  But I didn't pay any attention to them.

Page 3342

 1    And later on they didn't call for me that day.

 2       Q.   When you say you avoided the barrel, how did you do that?

 3       A.   Well, I dodged the barrel with the water.  There was a barrel with

 4    water as I said and it was used to torture those individuals, us, those of

 5    us who were there who were in Room 3.  But I managed to dodge that.

 6       Q.   All right, sir.  Now, I'm going to the point that you made

 7    earlier.  You said that during the break today, you recognised an

 8    individual that you say was Sikirica.  I'm going to ask you how often had

 9    you seen this individual during the course of your time at Keraterm?

10       A.   I would see him -- well, not very often.  He didn't come to Room 3

11    especially but when he walked around the compound, I would see him.  And I

12    think I've already said that I received information from Nurija

13    Crljenkovic, he was a friend of mine.

14            I don't know whether he was his friend, that that was that person,

15    a person that I knew from earlier on but I didn't know his

16    identification.  I didn't know his name.  But he didn't appear in Room 3

17    often.  I would see him in passing.  But I didn't dare look while I was

18    outside.  I just happened to glance under my eye if I was on my way to

19    lunch, then I happened to notice someone by taking a cursory glance or

20    people who came up like Banovic, Kajin, and so on.

21       Q.   Sir, this individual that you say struck you when you were in

22    front of Room 3 with a water barrel, was that the same person that you had

23    dealings with the morning you checked into Keraterm camp, the person that

24    you had a conversation about identification with?

25       A.   Yes.

Page 3343

 1       Q.   To the best of your recollection --

 2       A.   Yes.  That's that person on the 20th of June when I went in, and

 3    the incident at Hambarine where we went to fetch the woman.  That's that

 4    person.

 5       Q.   Now, you've already told us that you recognised him -- this

 6    individual in the courtroom today --

 7            MR. GREAVES:  Your Honour, in my submission, the evidence which

 8    he's given does not lay a sufficient foundation or sufficiently

 9    satisfactory for this type of identification to take place.  If Your

10    Honour looks at what he said, he doesn't appear to have seen him terribly

11    often in the camp and when he did, it was in a very sidelong sort of way

12    where he didn't want to look at him particularly closely, "I would just

13    glance under my eye if I was on my way to lunch."

14            In my submission, the tenure of that evidence is that it's not a

15    satisfactory foundation for this kind of identification.

16                          [Trial Chamber confers]

17            JUDGE ROBINSON:  Mr. Ryneveld, would you inquire how often he saw

18    Mr. Sikirica.

19            MR. RYNEVELD:  Yes.

20       Q.   Sir, during the time, how often would you say that over the whole

21    time from that first incident near Hambarine, to when you arrived at the

22    camp, to the time that you last saw this individual either before or after

23    the incident outside the Room 3, how often would you say you saw him?

24       A.   Three times.  I saw him directly three times.  In the course of

25    the day, when Nurija Crljenkovic told me that that was that person, and

Page 3344

 1    these other detainees knew about him and therefore there was no dilemma

 2    who Sikirica was.  When we knew quite naturally amongst ourselves, we were

 3    afraid for our lives and we would warn each other, "Take care of that one

 4    and mind the other one."  And I would see him around, but I underline that

 5    he didn't come into Room 3 often, but I did see him around in the course

 6    of the day and when I was passing outside.

 7       Q.   In addition to these three specific occasions that you mentioned,

 8    are you telling this Court that you saw him from time to time over the

 9    period of time that you were in custody?

10       A.   Yes, from time to time.

11       Q.   On those occasions, are you able to give the Court an idea of how

12    frequently in total, in addition to these three times that -- specific

13    occasions that you would have seen him?

14       A.   Three or four times.

15       Q.   So a total of three or four plus the three specific incidents; is

16    that correct?

17       A.   Correct.  Correct.

18       Q.   And on the day -- on the 20th of July when you checked into

19    Keraterm camp, did you have an opportunity to see him for longer than a

20    sidelong glance?

21       A.   That day?

22       Q.   Yes.

23    [redacted]

24    [redacted]

25    [redacted]

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Page 3346

 1       Q.   So this incident you say that you are relying on in order to say

 2    today that you can identify that man?

 3       A.   Yes.

 4            JUDGE ROBINSON:  Thank you, Mr. Ryneveld.

 5            MR. RYNEVELD:  Might we just edit that last comment because he

 6    repeated something that was said in closed session.

 7            JUDGE ROBINSON:  Yes, that will be edited.  Thank you.

 8                          [Trial Chamber confers]

 9            JUDGE ROBINSON:  The Chamber holds there is a sufficient basis for

10    the identification to be made.

11            MR. RYNEVELD:  Thank you, Your Honour.

12       Q.   Sir, would you indicate if this individual that you say was

13    Sikirica is in the room today and, if so, where is he?

14       A.   Yes.  He's the second in order.

15       Q.   And what you're saying is the back row, there are six seats

16    starting from the left to right, he is in the second seat?

17       A.   From this side --

18       Q.   Yes.

19       A.   -- as I'm looking?

20       Q.   Yes.

21       A.   There's the policeman and then Sikirica.

22       Q.   Thank you.

23            MR. RYNEVELD:  Might the record reflect that the witness has

24    identified the accused.

25            JUDGE ROBINSON:  Yes.

Page 3347

 1            MR. RYNEVELD:

 2       Q.   Sir, when you -- when this incident outside Room 3 was finished,

 3    were you returned to Room 3?

 4       A.   On the 24th?  Yes.

 5       Q.   And when you went back in, was there more room inside?

 6       A.   This was the night between the 24th and the 25th.  It was on the

 7    25th when we were halved.  There was room to lie down, to stretch your

 8    legs.  No one was standing.  There was enough room.  And unfortunately, we

 9    had to relieve ourselves there.  That was the orders we got later.

10       Q.   Sir, did you know someone by the name of Ismet Duratovic?

11       A.   Very well.  [redacted].

12       Q.   And what, if anything, did you see in relation to him at Keraterm?

13       A.   First of all, I think that evening they brought in the barrel with

14    the water, and then they threw some bread through the window for us.  Of

15    course, we grabbed it immediately, the bread, and we drank the water.  We

16    ate the bread and drank the water, and as we did so, some of us lay down

17    and fell asleep.

18            Later on I saw Ismet Duratovic taking his clothes off.  He was

19    naked.  There was Husnija Duratovic there, too.  He was from Tukovi.  He

20    was also naked.  That is the effect that this had on us, the water and the

21    bread they gave us.  So that's how we behaved.  We had to fall asleep.

22       Q.   Did something happen the following day in relation to your

23    [redacted]?

24       A.   Yes.  In the morning, I don't know what time it was, they asked --

25    somebody opened the door and said, "Who is Ismet Duratovic?"  But most

Page 3348

 1    probably they knew.  I don't know how because we were all sort of dazed.

 2    "Who is Ismet Duratovic?"  And he was still naked.  This Ismet Duratovic

 3    who was supposed to be the extremist leader.  "And who is the accomplice?"

 4    I wondered of what, but that is what they said.  And whoever finger was

 5    pointed at had to go out.

 6       Q.   Who did the finger pointing?

 7       A.   Ismet Duratovic as his accomplice, in connection with what I don't

 8    know, but those people who gave those orders know what they meant and what

 9    they did to us.

10       Q.   How many people did he point to?

11       A.   About 15.

12       Q.   And what happened to them?

13       A.   I know among the last of them was a retarded man from Hambarine.

14    I think he was in his 30s.  I remember his voice, "Not me, not me," and I

15    heard a burst of fire.

16       Q.   Do you remember his name?

17       A.   Behzar, Behzar is his name.  Behzo, everyone called him Behzo

18    Pehlic.  That's the name.

19       Q.   And what happened to these 15 mean?

20       A.   I didn't see them being killed, but obviously I heard the burst of

21    fire and, after that, single shots.  I couldn't really count how many

22    there were.  I was frightened for myself.

23       Q.   Did those men return?

24       A.   No, never.

25       Q.   Could you tell how far away from your room the shots were?  I

Page 3349

 1    mean, were the sounds of the shooting close by or far away, or what?

 2       A.   Close by the room.  One could hear it, both the burst of fire and

 3    the single shots that were fired.

 4       Q.   Now, sir, I understand that ultimately you went to the hospital on

 5    the 4th of August, 1992; is that correct?

 6       A.   Yes, correct.

 7       Q.   What can you say about your physical condition and your bodily

 8    functions in the interim period before you went to hospital?

 9       A.   Yes.  I had pain all the time.  I didn't report that because those

10    who did would go away the next day, apparently for examination, but they

11    didn't come back as far as I know.  At least, not to Room 3.

12            So on the 3rd -- no, on the 4th -- actually, on the 3rd, the

13    so-called Zizin - he also had a nickname, he's a Bosniak from Prijedor -

14    he came up to me and asked me personally, "Do you need any assistance?

15    Will you apply?"  And I said "no, thank you" because I knew what was

16    happening.

17            Then the next day in the morning, my arm had been infected.  It

18    had swollen up.  I had mental problems, which was quite normal, so I

19    decided to apply, for better or for worse.  However, when I went to apply

20    in the morning, a soldier met me there, a bearded one - I have to say that

21    because that's how he was - and he asked me for my name.  I told him my

22    name, and then he said, "Who are you fucking around with," and he cursed

23    my mother.  But there was a medical technician there without an arm, and

24    then I showed him my hand, my arm, and he was surprised when he saw it,

25    and he said, "Stand to one side."

Page 3350

 1       Q.   All right.  I'm going to just back you up for a little bit, sir.

 2    During your time at Keraterm, did you lose any body weight?

 3       A.   Yes.  I weighed myself the second day in hospital, and I saw that

 4    I had lost 26 kilograms.  I had had 95 and then I had 69, which is very

 5    hard to imagine, but that's the truth.

 6       Q.   And sir, between the incidents of the Room 3 incident, shall we

 7    say, the shooting incident that you've told us about, and going to the

 8    hospital, had you left your room at all, the room, Room 3?

 9       A.   Before the shooting?

10       Q.   No, after the shooting before going to the hospital.

11       A.   Yes.  Occasionally I would go for lunch, and if I had to -- and

12    you could feel it in the air, that some shifts were better than others,

13    that you could go out and look around.  And I once went up to Room 1.  I

14    didn't perhaps mention that.  From a guy I got a tomato and a piece of

15    loaf, and I've maybe forgot to mention that.

16       Q.   Now, sir, did they bring any new prisoners into Room 3 after the

17    Room 3 incident that you've told us about?

18       A.   Yes.  Yes.  They would regularly take out 10 to 15 men.  It is

19    difficult to tell you the exact number.  They can -- they will know that.

20    People were coming from Carakovo and Ljubija, Rizvanovici, yes.  Carakovo,

21    of course.

22       Q.   When they brought these new people to Room 3, did they also take

23    them out and do things to them?

24       A.   When they brought these people from Ljubija -- anyway, they opened

25    the door.  We recognised those persons.  I think there were about 12 of

Page 3351

 1    them.  We had to sing those songs like, "Who is talking, who is lying,"

 2    and others.  And they beat them.  Then some soldiers were going back to

 3    Gradacac, and they thought this was something nice like a sports match.

 4    They tortured those poor people and then about an hour later -- anyway,

 5    sometime later they would shove them into our room.

 6            They would stay there for about an hour, and that is how I learned

 7    that my brother had been killed at the Rudar stadium where I use today

 8    play football.

 9       Q.   This is information you got from the new arrivals; is that

10    correct?

11       A.   What information?

12    [redacted]

13    [redacted]

14    [redacted]

15    [redacted]

16    [redacted]

17    [redacted]

18    [redacted]

19    [redacted].  Now, you started to tell us about being

20    taken to the hospital and you told us some of the details of that and

21    you've told us that they saw that your arm was infected and told you to

22    stand to one side.  Were you ultimately taken to the hospital in Prijedor?

23       A.   Yes.  We waited --

24       Q.   Were you the only one?

25       A.   No, there were 25 of us.  We waited there for about half an hour

Page 3352

 1    to one hour.  I don't know what it was.  No examination was needed.  They

 2    were talking amongst themselves.  I don't know what.  We went to the

 3    hospital.  This took about 10 minutes roughly.

 4            When we got off, I saw the hospital.  I was glad to see the

 5    hospital.  And five or six of the soldiers got off, Sikirica was among

 6    them.  He was the most important as far as that was concerned.  He took us

 7    with a rifle pointed at us and we reached the doctor and were examined.

 8            Dr. Resic examined us.  He decided that the three of us should be

 9    hospitalised.  When the examination was over, the rest went back and we

10    went, I think it was to Room 7 on the second floor.  We were accompanied

11    all the time by Sikirica.  These others were making remarks to the effect

12    that we were extremists, that we shouldn't go to hospital but somewhere

13    else.

14       Q.   What others made those comments?

15       A.   Soldiers who had come with Sikirica, who had actually escorted us

16    there.

17       Q.   Now --

18            JUDGE ROBINSON:  Mr. Ryneveld, we are coming up to the time for

19    the break.

20            MR. RYNEVELD:  Yes.  I'm not quite finished with this paragraph,

21    but certainly right after the break I will continue.

22            JUDGE ROBINSON:  Mr. Greaves.

23            MR. GREAVES:  Your Honour, there is a matter I'd like to raise

24    before you have your break so that it's possible for you to discuss it

25    during your break.

Page 3353













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14    and the English transcripts.












Page 3354

 1            JUDGE ROBINSON:  Yes.

 2            MR. GREAVES:  Your Honour, after my learned friend started -- the

 3    passage where my client was to be identified, if you remember, it took a

 4    little while to do it because of something which was said, perhaps

 5    unexpectedly, by the witness.

 6            Between then and when the identification was actually made, I

 7    received a note from my client, and I'm going to read it because it's

 8    self-explanatory and to the point. "Ask the Prosecutor or the Judges why

 9    does the technician always put our pictures on the monitor about the

10    identification?  It's not fair."

11            I assume from that that when the issue of identification is being

12    raised, a picture of that particular defendant is being broadcast on the

13    monitor.  Bearing in mind, if that's correct, bearing in mind that there

14    is a monitor in front of the witness, I would respectfully suggest that

15    that is both a dangerous and objectionable thing for the technicians to do

16    if the question of identity is being raised.

17            THE WITNESS:  [Interpretation] It's not true.  I apologise.

18            JUDGE ROBINSON:  I am told that those representations are not

19    shown on the screen in front of the witness.

20            MR. GREAVES:  I'm anxious to be reassured as to how that is to be

21    guaranteed.  You can see my concern.  There plainly is a monitor there.

22    I'm anxious to know that there is no possibility of any witness being able

23    to see those things being done.

24            JUDGE ROBINSON:  We will investigate this.  Mr. Ryneveld.

25            MR. RYNEVELD:  Yes, I have no way of knowing what my friend --

Page 3355

 1    whether there's anything to it because my monitor is to the transcript.

 2    So I am not able to see it at the time.

 3            MR. GREAVES:  Mine too.  I always watch the transcript rather than

 4    pictures that are being broadcast.  So I would have raised it earlier had

 5    I known about it.

 6            JUDGE ROBINSON:  The Chamber will investigate it during the

 7    break.

 8            MR. LAWRENCE:  May I raise a matter which is tangential to that.

 9    It may be that the witness doesn't see the pictures on the monitor, but I

10    think the witness sees the text, and I have noticed as the case has gone

11    on in the last few days --

12            THE WITNESS:  [No interpretation]

13            JUDGE ROBINSON:  Please do not interrupt, Witness.

14            MR. LAWRENCE:  Not this witness, be it said but last week, I

15    noticed that one or two of the witnesses when being challenged about

16    something that they had said looked down to see what it was they had said

17    on the monitor.  Now, that seems to me to be somewhat undesirable, and I

18    wonder if that is a matter which the Court could think about and look

19    into.  It may be that it's not necessary, in the normal course of events,

20    for the witness to have the monitor in front of him on at all.  It's to

21    assist the Court.  It's to assist counsel, but it shouldn't affect the way

22    a witness gives his evidence.  And if it was decided that the monitor

23    should not, in general, be on when the witness is giving his evidence,

24    then maybe that would deal with both my learned friend's problem and what

25    I think may be something that shouldn't be happening anyway with regard to

Page 3356

 1    the printed text.

 2            JUDGE ROBINSON:  Thank you.  We'll take note of your submissions.

 3            Witness R, we are now going to take a break until a quarter past

 4    4.00.  During the adjournment, you are not to discuss your evidence with

 5    anybody and that includes the members of the Prosecution.  We are

 6    adjourned until quarter past 4.00.

 7                          --- Recess taken at 3.55 p.m.

 8                          --- On resuming at 4.22 p.m.

 9            JUDGE ROBINSON:  I should say that the Chamber has carried out an

10    investigation into the matters that were raised prior to the adjournment.

11    We are satisfied that the technical arrangements are such that the witness

12    will not see the photograph of the accused when the accused sees it at the

13    particular time that has been mentioned.  We have satisfied ourselves

14    about that.

15            As for the transcript, the witness ordinarily does not have a

16    transcript.  He has no transcript on the, on the screen.  There is a

17    transcript on the ELMO, but of course the witness does not see that unless

18    the Chamber has reason for the use of the ELMO or unless the Chamber

19    requires that the transcript be placed on the screen for the witness,

20    which would be a rarity considering that the -- considering the difference

21    in language.

22            Mr. Ryneveld.

23            MR. RYNEVELD:  Thank you, Your Honour.

24       Q.   Witness, just before the break you told us that you had been

25    escorted to the hospital in Prijedor, and was this yet another occasion

Page 3357

 1    when you had an opportunity to see Mr. Sikirica for a period of time?

 2       A.   Yes, precisely, as we were entering the hospital with another five

 3    or six soldiers, and he was present there.  And he took us into the

 4    hospital, all of us, and then we waited in the passage to be examined, and

 5    we were examined there by Dr. Resic.

 6       Q.   Yes, I think you've told us that.  I don't need you to repeat

 7    that, sir.

 8            Eventually you and three other -- you were one of three patients

 9    who was permitted to stay behind in the hospital; is that correct?

10       A.   Yes, yes.

11       Q.   And your escort, which included Mr. Sikirica and others, left; is

12    that correct?

13       A.   That's right.

14       Q.   Did you ever return to Keraterm after being taken to hospital, or

15    did you go right from hospital to another location?

16       A.   I went to the Trnopolje camp on the 18th of August.

17       Q.   So had you been in hospital, then, for 14 days, sir, upon being

18    admitted there on the 4th of August?

19       A.   Yes, that is correct.

20       Q.   And you were discharged from hospital on the 18th of August and

21    you were transferred to Trnopolje; is that correct?

22       A.   It is.

23       Q.   While you were at hospital, did you hear about the closing of the

24    Keraterm camp?

25       A.   Yes, we did.  Soldiers also came, and I have to mention a page who

Page 3358

 1    came and gave us his name.  One of those present knew him, and we asked

 2    that page, "Well, and what are further prospects?"  And he said, "The

 3    worse that can happen to you is that you will go to third countries."

 4            We then -- and somebody called Spaga also came, but all they asked

 5    us was about weapons.  And there were also my people whom I used to work

 6    with, they also came.

 7       Q.   This is while you were in hospital?

 8       A.   That's right.

 9       Q.   While you were in hospital, did you hear from other sources what

10    happened to the inmates at Keraterm?

11       A.   Yes, I heard that the Keraterm camp was closed down on the 5th of

12    August.

13       Q.   And what happened to its inmates?

14       A.   Much later, I learned that on the 5th of August, men were called

15    out from Room 3 and put into buses.  I was to be amongst them too, that

16    is, I was called out.  That is what people told me.  I couldn't know that

17    because I was in hospital.  And that is how I escaped, avoided my death

18    because two buses left the Keraterm camp.

19       Q.   And you heard your name was read out for those who were to get on

20    those buses to go; is that correct?

21       A.   It is, yes.

22       Q.   I see.  Moving on then, sir, when you were at Trnopolje, did you

23    see anyone during your stay at Trnopolje who you had seen at Keraterm?

24       A.   I did.  I saw Mr. Banovic.  He would come in a Mercedes to bring

25    some people, Muslims.  Why he did that, he knows.  I didn't come close.

Page 3359

 1            I saw, among other people Faca, so-called Faca whose face I don't

 2    know -- whose name I don't know but his face.  And he stood near my tent

 3    so I couldn't really walk by without seeing him.  And I thought something

 4    and I told myself I'll ask him for a cigarette and make as if I didn't

 5    know him at all.  So I did come up to him and asked him for a cigarette

 6    but he said he was a non-smoker and he didn't have any.  And he said that

 7    he'd been around there for a long time and that I should ask other inmates

 8    who would tell me how -- what a good man he was and that he would give me

 9    a cigarette if he had any.

10       Q.   All right, sir.  And is it fair to say that you were finally

11    released from Trnopolje on the 1st of October 1992 and left that

12    particular area; is that correct?

13       A.   It is.  It is correct.  74 days later.

14       Q.   74 days after you were originally arrested on the 19th or 20th of

15    July; is that correct?

16       A.   The 20th of July.

17            MR. RYNEVELD:  Would you answer my learned friends, please.  Thank

18    you.

19            THE WITNESS: [Interpretation] Thank you.

20            JUDGE ROBINSON:  Thank you Mr. Ryneveld.  Mr. Greaves.

21                          Cross-examined by Mr. Greaves:

22       Q.   Witness R, could you help me, please, about this:  Before June

23    1992, did you -- were you involved in politics in any way in your country

24    whether as an activist or as a political party member?

25       A.   Yes, I was a member of the League of Communists from 1976 until

Page 3360

 1    1985 and -- but that is a different matter.  I was also on the reserve

 2    police force if that means -- if that is what you wanted to ask me.

 3       Q.   No, I'm not going to ask you about that just for the moment.  If

 4    we can deal with other matters, please.  Did you do your national service,

 5    I think, around 1972 in the JNA?

 6       A.   That's right, in Kikinda.  I can give you the garrison if you

 7    wanted.

 8       Q.   What branch of the service did you serve in, Witness R?

 9       A.   Infantry, mechanised infantry.  And I worked at the gate as a

10    guard.  Now why that is again ...

11       Q.   Witness R, after your release from Trnopolje, did you serve at all

12    in the army of Bosnia-Herzegovina?

13       A.   No.

14       Q.   And at any stage, have you had or do you continue to have any sort

15    of relationship with the intelligence and security services of

16    Bosnia-Herzegovina?

17       A.   No.

18       Q.   I'm now going to ask you about the police reserve.  After you had

19    completed your compulsory military service, you joined, as you've told us,

20    the reserve police.  It's right, isn't it, that that was something that

21    you could opt to do instead of going on to the ordinary JNA reserve; do

22    you accept that?

23       A.   Yes.  Yes.

24       Q.   What was behind your personal decision to opt for the police

25    reserve as opposed to the ordinary JNA reserve?

Page 3361













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14    and the English transcripts.












Page 3362

 1       A.   Oh, what was it?  Well, I suppose because I was fit, because I was

 2    a sportsman.  Also, I was a rather calm person, poised person, and that is

 3    the kind of people they needed.  People who enjoyed priority, those were

 4    selected people; not everybody could join the reserve police force.  And I

 5    was with that special unit.  Later on, I was assigned to a manoeuvreing

 6    unit.

 7       Q.   Was the commitment, in other words, the amount of time that you

 8    had to spend each year, was that less than you would have had to spend in

 9    the JNA?

10       A.   I was with the police force as -- with a specialised unit, that

11    manoeuvreing unit for some years.  I don't know how long.  And then I was

12    assigned to duty in my company.  In the company I was the responsible

13    clerk, but that I never -- that is, once I was there on duty, but that

14    was ...

15       Q.   And when you describe yourself as being part of a manoeuvreing

16    unit, may we take it from that that it was a quasi-military kind of unit

17    that you were assigned to?

18       A.   Not to my mind.  No, not then, no.  No.  At that time, no.

19       Q.   What kind of manoeuvres were you carrying out?

20       A.   We mostly went to Mrakovica, underwent some drills with active

21    policemen who were my superiors, mostly of Muslim, Islamic religion.  I

22    can tell you the name of my superior if you want me to.  And when we had

23    those drills, then a military police came from somewhere.  And I heard

24    that somebody -- Vikic came, and there was those special police when that

25    Vikic - and Vikic is quite well known, I think - when he came.

Page 3363

 1       Q.   Thank you, Witness R.

 2            MR. GREAVES:  May we go into private session, Your Honour.

 3            JUDGE ROBINSON:  Yes.

 4                          [Private session]

 5   [redacted]

 6   [redacted]

 7   [redacted]

 8   [redacted]

 9   [redacted]

10   [redacted]

11   [redacted]

12   [redacted]

13   [redacted]

14   [redacted]

15   [redacted]

16   [redacted]

17   [redacted]

18   [redacted]

19   [redacted]

20   [redacted]

21   [redacted]

22   [redacted]

23   [redacted]

24   [redacted]

25   [redacted]

Page 3364

 1   [redacted]

 2   [redacted]

 3   [redacted]

 4   [redacted]

 5   [redacted]

 6   [redacted]

 7                          [Open session]

 8            MR. GREAVES:

 9       Q.   Witness R, I want to ask you very briefly about matters which

10    occurred between May and the date of your arrest in your area.  I think

11    it's right that on occasions soldiers would come to the village, and they

12    would have as a motive for their visit stealing property and houses.  Is

13    that correct?

14       A.   Well, not houses in Rakovcani, I wouldn't say that, but property,

15    yes.

16       Q.   On one occasion some of the soldiers spoke briefly with your son

17    and asked him about his age.  It's right, isn't it, that your son was not

18    taken away or arrested on that occasion?

19       A.   He was not, no.  He was not taken away or arrested, but I was

20    afraid that something might happen because all sorts of things were going

21    on.  At that time, I was afraid.

22       Q.   Of course.  We understand that.  When you yourself were arrested,

23    again, your wife and your children were left at home.  That is right,

24    isn't it?

25       A.   They did stay at home.  They did not leave.  In the second part of

Page 3365

 1    the house away from the road where the kitchen was and we usually spent

 2    our time, she moved over to a smaller room with children and with a

 3    neighbour, Sefika.

 4       Q.   The people who arrested you were soldiers, and by that do you mean

 5    soldiers from the JNA or the army of Republika Srpska?

 6       A.   I don't have to think about that.  Those men were in uniforms, in

 7    olive-green/gray, the colour that the Yugoslav People's Army used.

 8    Whether they were of the reserve force or what, but be that as it may,

 9    they did what they did.

10       Q.   And would this be correct that effectively the men who were

11    detained along with you were essentially men of military age; do you

12    accept that?

13       A.   Mostly, yes, militarily-able, adult.

14       Q.   And it's right also that you, and indeed the majority of the

15    people who were with you, whilst you were on your way to Rizvanovici, you

16    were not beaten; is that correct?

17       A.   No, but we sang songs, I mean they did not beat me.  I don't know

18    about others.  Because I did not look around so I don't know, because it

19    was a very long haul.

20       Q.   You had been searched upon your arrest, had you not?

21       A.   Yes, but I did not hand over my identity card, that is, I handed

22    over some papers, but I kept the identity card.

23       Q.   I didn't ask you that.  What personal documents, as you put in one

24    of your newspaper articles, what personal documents were taken from you at

25    that time?

Page 3366

 1       A.   Documents, well, I didn't really think much about that, but let me

 2    try to remember.  I remember I had some razor blades which I put in my

 3    pocket but they mostly -- they were mostly asking for personal documents,

 4    that is right, but I think I didn't give them the identity card then.

 5       Q.   The buses which were used to transport you to Keraterm, were they

 6    full, all of the buses, when they were sent off to Keraterm?

 7       A.   I can't know that.  I can only tell you about the bus I was in.

 8       Q.   What about the bus that you were in?

 9       A.   Yes, it was full.

10       Q.   How many buses in all, Witness R?

11       A.   Five or six buses.  I didn't feel like counting them, but that was

12    roughly how it was.  We got on, and then we turned around near

13    Rizvanovici.

14       Q.   And all the buses arrived at Keraterm at about the same time; is

15    that right?

16       A.   I can't claim that either, whether they arrived.  I know that when

17    I entered Keraterm, I know what happened to me and where I went and that I

18    went to Room 3.  I was terrified, and I can tell you today that I

19    regretted going but I'll come back to that later.  That's beside the point

20    now.

21       Q.   On the way, one particular man was taken off the bus.  It's right,

22    isn't it, that his selection was apparently completely random; is that

23    right?

24       A.   Baki Selimovic, yes.

25       Q.   I'd like to ask you now, please, Witness R, about the occasion

Page 3367

 1    when you saw the man Sikirica at a checkpoint.  It's right, isn't it, that

 2    that was about 10 days before you were arrested; do you accept that?

 3       A.   I think about 20 days.

 4       Q.   Do you recall that you, in connection with these matters, made a

 5    statement to the Office of the Prosecutor on the 23rd of September of last

 6    year, Witness R?

 7       A.   I did make a statement.

 8       Q.   And did you not say in that statement, Witness R, that you had

 9    "... previously worked for the Prijedor Red Cross about 10 days before my

10    arrest," and that you recalled at that time seeing Sikirica at a

11    checkpoint?  Does that refresh your memory, Witness R?

12       A.   Sir, you are insulting me.  I told you that I worked for the Red

13    Cross and I don't know exactly, because the presiding officer chose me and

14    I was probably the suitable person, and I joined him and I worked with

15    him.  And if I had known what would have -- what was going to happen to

16    me, I never would have gone there no matter what.

17       Q.   I certainly don't mean to insult you in any way.  Please would you

18    be so kind as to deal with the question which I have asked you.  It's

19    quite simple.  When you told the Office of the Prosecutor that it was

20    about 10 days before your arrest, does that help you to refresh your

21    memory as to when that incident of seeing Sikirica at a checkpoint took

22    place?

23       A.   I didn't specify exactly when that was.  I always said "about that

24    time."  I didn't know what was going to happen and what would happen to me

25    in the -- would happen to me in the future.  But when I see a person once,

Page 3368

 1    and especially if you experience something bad or in fear, then you don't

 2    forget such a person.

 3       Q.   What it comes to is this, isn't it, Witness R, that you are unsure

 4    of when it was that you saw this man at the checkpoint and that it may

 5    have been as little as 10 days before your arrest or it may have been a

 6    bit more.  Isn't that what it comes to?

 7       A.   10 to 20 days.

 8       Q.   Thank you.  The location of the checkpoint, please, Witness R,

 9    would this be correct that it was at a fork in the road which leads

10    between Prijedor and Ljubija and the fork to the road leads to Rizvanovici

11    and Rakovcani; is that right?

12       A.   The checkpoint was where people were sleeping.  Some were to the

13    side, to the left side, others to were to the right.  I think it is Ramo

14    Fikic's house where they had their checkpoint, between Kasim Fikic and

15    Ramo Fikic, that is where they met us, and Banovic went with us in the

16    trailer.

17       Q.   You will appreciate, I am sure, Witness R that those of us in this

18    courtroom do not have the advantage you do of knowing where everybody

19    lives.  So please help us.  Is it right that the checkpoint was situated

20    on the road between Prijedor and Ljubija at the point where it forks, and

21    the fork road leads to Rizvanovici and Rakovcani and it may otherwise be

22    known as the checkpoint at Hambarine.

23       A.   For me, that day when I noticed him, the checkpoint was between

24    Ramo Fikic and Kasim Fikic's house.  That is where I saw those soldiers

25    who were talking to my superior.  For me, the checkpoint was on the

Page 3369













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14    and the English transcripts.












Page 3370

 1    asphalt -- Ljubija to Prijedor road.

 2            When we were returning with the corpse, they were shooting at us

 3    from there.  So it wasn't on the side towards Rizvanovici, this

 4    checkpoint.  And when they shot at us, we turned to this side, towards the

 5    right.

 6       Q.   Do the two gentlemen you have mentioned, Ramo Fikic and Kasim

 7    Fikic, do they leave near to the junction of that main road and the road

 8    that leads to Rizvanovici?

 9       A.   Yes.

10       Q.   Was it manned by soldiers, soldiers and police, or police only?

11       A.   They were uniformed.  For me, they were soldiers.  At the time, I

12    didn't think about it, whether it is this or that.  They were all in

13    uniform.

14       Q.   Had you passed through that checkpoint many times, Witness R?

15       A.   Through Hambarine?

16       Q.   Yes, we've been talking about that particular checkpoint, Witness

17    R.  Did you pass through that checkpoint many times or not?

18       A.   No.

19       Q.   So is this the only occasion when you were there, or were there

20    others?

21       A.   You see -- just a moment, let me try to recollect.  We were going

22    for the body.  We were to pick up this body.  The bad man was called

23    Nedzad, I think his surname was Zec, or that was his nickname.  We were

24    looking for him.  Banovic went with us in the tractor.  I can't forget

25    that.  He was standing on the tractor like a show-off.  We didn't question

Page 3371

 1    him or anything.  We were just carrying this body, and we turned back.  We

 2    returned.

 3       Q.   Yes.  But apart from this occasion, were there others, be they few

 4    in number, when you had been through this particular checkpoint,

 5    Witness R?

 6       A.   I think with the convoy we passed there.

 7       Q.   Did you have an opportunity on those occasions to observe what

 8    function the checkpoint was performing?  For example, were they simply

 9    stopping vehicles and checking identities or doing anything else?

10       A.   I was not in such a position.

11       Q.   Did you go through other checkpoints in the area between May and

12    the time of your arrest, Witness R?

13       A.   Yes, I did go to Prijedor to get my salary of 50 Deutschmarks, in

14    Prijedor.

15       Q.   And was the function of those checkpoints --

16       A.   In that period.

17       Q.   -- principally to check the identity of those passing through

18    them?

19       A.   It should have been.

20       Q.   Do you know, please, I want to ask about two people.  Somebody

21    called Karanfil Aliskovic?

22       A.   Yes.

23       Q.   Was he at Keraterm with you?

24       A.   Known as Stanko.  He was.

25       Q.   In Room 3?

Page 3372

 1       A.   Yes.

 2       Q.   Thank you.  You have to remember to keep your voice up because

 3    the -- and sit up close to the microphones; otherwise, it wouldn't pick

 4    you up.  All right?

 5            The second name about which I wish to ask you is Nihad Karadzic,

 6    was he with you in Keraterm?  Karagic, sorry.

 7       A.   Nihad Karagic?  Karadzic?

 8       Q.   Karagic.

 9       A.   Karagic.

10       Q.   My pronunciation has failed me on this occasion.

11       A.   No, the name doesn't ring a bell.

12       Q.   I'd like to turn now, please, to the incident of the killings in

13    Room 3, Witness R, please.  Something happened, some substance was

14    introduced into the room which caused people to behave in a strange way.

15    Is that right?

16       A.   Yes, that is right.  Now, whether there was just one thing that

17    was thrown in or more, I don't understand those things, but I know that

18    there was something.

19       Q.   And is this correct, that some of the outward symptoms of that

20    substance being introduced, some people became drowsy and sleepy?  Is that

21    right?

22       A.   That evening on the 24th of July, after all that, I, too, became

23    drowsy.  Now, what the effect was on others, I can't say.

24       Q.   You were able to observe that many of your fellow detainees were

25    behaving in a very strange manner, were you not?

Page 3373

 1       A.   Yes.  And that they were crying and moaning and praying to God and

 2    begging those over the fence - I am referring to the Serbs - not to kill

 3    us, but they seemed to be intensifying the tempo.

 4       Q.   Some people started to have hallucinations and claimed that they

 5    were seeing devils and things like that, isn't that right?

 6       A.   Yes.  They started saying things, praying to God in a way.  This

 7    was probably -- but not probably, certainly the result of those poisonous

 8    gases.

 9       Q.   And others began to talk in a nonsensical fashion; isn't that

10    right?

11       A.   There was instances of that, too.

12       Q.   And still others started to fight one with another, did they not?

13       A.   Yes, but this was already later when the effect started.  That is

14    correct, yes, but it would never have occurred to them to fight amongst

15    themselves if they were not under the effect of something.

16       Q.   That may well be right, but the fact is that they were indeed

17    fighting themselves.  And the situation at this time inside Room 3 was

18    completely chaotic, wasn't it?

19       A.   Yes.  The men rushed to the door, but this was later when they

20    were overcome.  I felt this, too.  They dashed the door and they broke it

21    down.

22            And it must be the effect of those poisonous gases.

23       Q.   And there were a large number of people trying to break through

24    the door, were there not?

25       A.   I don't know whether there were a large number of people, but

Page 3374

 1    anyway, we heard the bursts of fire.  I heard the fire.  I don't know who

 2    was hitting with his head and his hands, but somebody was, and they

 3    obviously broke down the door.  When we saw, I think it was the left

 4    part.  I don't think, I'm sure.  The left part of the door was broken

 5    down, and that is through that opening that they found the killed and

 6    wounded.

 7       Q.   It was only when the door was forced open that the shooting began;

 8    isn't that right?

 9       A.   No.  I don't know when the door was broken down.  I couldn't say

10    that when I was under the window, to the right where the window was.  When

11    it was broken down, I don't know.  Bursts of fire were heard several

12    times.  When the door was broken down, I don't know.

13       Q.   You see on the 23rd of September last year, Witness R, you told

14    the Office of the Prosecutor this:  "The detainees finally forced the door

15    open and the bursts of fire started."  So that was your position last

16    year; isn't that right?

17       A.   Finally, that I had said "finally"?  I don't believe I said

18    finally.

19       Q.   That's what I'm putting to you from your statement which you

20    signed as being correct and true to the best of your knowledge and

21    recollection.

22       A.   Maybe it's a mistake in the translation.

23       Q.   The substance which had been put into the room and which caused

24    everybody to behave in this bizarre fashion, that substance had a

25    long-lasting effect, did it not, Witness R?

Page 3375

 1       A.   Yes.

 2       Q.   Indeed many people were still affected by it the following day and

 3    in the days which followed; is that correct?

 4       A.   I know how I behaved.  As for others, I don't know.

 5       Q.   Did you observe anything which told you that others were still

 6    suffering from the effects of this substance, whatever it was, Witness R?

 7       A.   Would you repeat the question, please?

 8       Q.   Yes.  Did you observe anything in other people which told you that

 9    they were still suffering, a long time after the substance had come into

10    the room, still suffering from its effects?  In other words, behaving in a

11    bizarre fashion.

12       A.   As far as that day is concerned, the 25th, the 25th, if you're

13    talking about that day, we went outside as I have explained, the order was

14    hands behind your head and go to the grass facing Room 3.  What could we

15    expect?  The man next to me, grey-haired, was saying, "[redacted], it seems to

16    me that beans are being cooked somewhere in Rizvanovici."  I thought of

17    that too but I tried to console him, he and myself at the same time, that

18    things would be better and words to that effect.  But the next evening or

19    that evening or rather the next day, I didn't see that man anymore in Room

20    3.  Now how they behaved, I -- but it's only natural that they should

21    behave like that because they were tortured.

22            Just imagine lying there for five minutes, let alone hours, and

23    then to be hosed down with water.  I thought that the hose was meant to

24    assist us, but later I realised it was the system they applied:  Hot,

25    cold.

Page 3376

 1       Q.   The following morning, you, yourself, still felt as if you were

 2    drugged and you watched the scene lethargically as nothing was going on;

 3    isn't that right?

 4       A.   The next, you mean the 25th, when the truck came and when I woke

 5    up?

 6       Q.   On the morning of the 25th.

 7       A.   Or are you referring to -- I was talking about the night of the

 8    25th to the 26th.  You are confusing me with your questions.  The 25th in

 9    the morning, and what I was saying a moment ago was on the 26th.  You are

10    confusing me with these questions.  We are talking about one thing and

11    later on you ask me that morning.  You have to tell me what you mean.

12       Q.   Thank you for clarifying that you were talking about this

13    gentleman talking about beans being cooked in Rizvanovici on the 26th.

14    That's helpful.  I am now talking about how you felt on the 25th, and if I

15    confused you, I apologise to you.

16       A.   No, this was on the 25th, that day.

17       Q.   Now, in addition, there were quite a lot of people, weren't there,

18    hallucinating about food at this time; do you accept that?

19       A.   About food, I know I was hungry and the others were hungry too.

20    As to how people behaved, they know, you and Your Honours can imagine how

21    we felt on the 26th.

22       Q.   You see what you put into your newspaper article is that

23    "... because they did not give us any food, we," in other words, you and

24    other prisoners, "started hallucinating about food," didn't you, on the

25    25th?

Page 3377

 1       A.   Yes.  That is correct that one started imagining things, that this

 2    man Hasan Ramastagic, known as Sidi, he said that.  And he was to the

 3    right and this other one was to the left.  These are things that cannot be

 4    forgotten, you see.

 5       Q.   Did other people indicate, say things to you which told you that

 6    they also were hallucinating about things?

 7       A.   To me, you mean?

 8       Q.   To you or in your hearing.

 9       A.   Yes.  There were some who were talking about that night, that they

10    had a good fight and they were wondering why I know those people were sort

11    of peace-loving.  They are sportsmen.  They were from my club who were

12    saying that.

13            MR. GREAVES:  I'm moving on to another topic and I see the time.

14    Is that a convenient moment, please?

15            JUDGE ROBINSON:  This afternoon, we will, with the cooperation of

16    the interpreters, go a little longer.

17            MR. GREAVES:  I was rather hoping you wouldn't say that.  I have

18    an appointment that I have arranged for just after 5.30 and -- obviously

19    it's a personal matter, and I would defer to Your Honour if it's thought

20    to be right.

21                          [Trial Chamber confers]

22            JUDGE ROBINSON:  In the view of the fact we did announce 5.15, we

23    will stop.

24            MR. GREAVES:  Thank you.  I've got to move home in the next couple

25    of months and I'm now looking for a home to live in so it's to do with

Page 3378

 1    that.  You'll understand that's quite important.

 2            JUDGE ROBINSON:  Yes.  We don't want you to be homeless,

 3    Mr. Greaves.

 4            Witness R, we are going to adjourn until tomorrow morning at

 5    9.30.  During the adjournment, you are not to discuss the evidence with

 6    anybody and that includes the members of the Prosecution team.

 7            THE WITNESS: [Interpretation] Thank you.

 8                          --- Whereupon the hearing adjourned

 9                          at 5.15 p.m., to be reconvened on Tuesday

10                          the 22nd day of May, 2001, at

11                          9.30 a.m.