Tribunal Criminal Tribunal for the Former Yugoslavia

Page 4562

1 Monday, 2 July 2001

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 9.37 a.m.

5 JUDGE ROBINSON: Mr. Greaves, I understand you have an application

6 of a particular kind.

7 MR. GREAVES: Yes. What I was going to propose as far as this

8 week was concerned, I was hoping to be able to call and complete a total

9 of five witnesses today. At the conclusion of that fifth witness, I then

10 have two other witnesses to call. What I would like to be able to do, and

11 I understand that the Trial Chamber has other duties about tomorrow, is to

12 invite Your Honours to then adjourn to Wednesday morning because these

13 two -- last two witnesses are two important witnesses whom we want to

14 re-interview and go through a number of things with. They will be

15 finished by, I think, probably Thursday, at the close of business on

16 Thursday, probably trickling over into, trickling over into Friday

17 morning, and so I will finish my case this week.

18 With that assurance, I hope that that proposition would find

19 favour with Your Honour.

20 JUDGE ROBINSON: Yes. We'll discuss it, yes.

21 [Trial Chamber confers]

22 JUDGE ROBINSON: Very well, Mr. Greaves. I think your proposal is

23 acceptable, so that tomorrow the Chamber will not sit in the afternoon,

24 and in fact, we will not sit in the morning, either, because we have other

25 duties. So in the result, there will be no sitting tomorrow, and we will

Page 4563

1 resume on Wednesday.

2 I want to take this opportunity before the witness comes in to

3 make some announcements of a procedural nature.

4 As far as the accused Dosen is concerned, I remind counsel that

5 you must file your list of witnesses by Friday, the 6th of July. And as

6 far as Kolundzija is concerned, I remind counsel that that list should be

7 filed before the recess on the 3rd of August.

8 There will be no sitting on Friday, July 20th, and Monday, the

9 23rd, and there will be no sitting on Thursday, September 13th and Friday

10 the 14th. The accused Kolundzija will be given two extra days, if that is

11 necessary. We would still urge the closing of Kolundzija's case on

12 Wednesday, September 12th, but if that is not possible, then two more days

13 will be allowed, and that will take Kolundzija's case to Tuesday, the 18th

14 of September; the rebuttal and rejoinder on Wednesday the 19th to Friday

15 the 21st; final briefs by Wednesday, the 26th of September; and closing

16 arguments on Thursday the 4th and Friday the 5th.

17 I do not wish to have a discussion of this now. The senior legal

18 officer will distribute the new schedule, and such questions as you may

19 have may be raised at a subsequent occasion.

20 So may we have your witness now.

21 MR. GREAVES: Yes. Can we just go into private session whilst I

22 make an application in respect of protective measures, please.

23 JUDGE ROBINSON: Yes, private session, please.

24 [Private session]

25 [redacted].

Page 4564













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21 [Open session]


23 Q. Witness DF, can you help us about this, please: Have you known

24 Dusko Sikirica for a considerable period of time?

25 A. Yes; since we were children, from our school days.

Page 4576

1 Q. And during that time, have you become friends with Dusko Sikirica?

2 A. Yes. We would go to cafes together, discos. We worked together

3 in the factory, the cellulose factory.

4 Q. And when did you start work at the cellulose factory?

5 A. I can't remember exactly what year it was. I think 1993, 1994.

6 No, 1983, 1983, I'm sorry, thereabouts. 1983, 1984.

7 Q. In his social life and in his work life, did he mix freely with

8 people from other nationalities?

9 A. Yes, and often.

10 Q. During such occasions as you were able to observe, did you see or

11 notice anything which would indicate to you that he held extremist views,

12 nationalist views that were hostile to other nationalities?

13 A. No. He was an exceptionally fine man.

14 Q. Was he ever in charge of your section at Celpak?

15 A. Yes.

16 Q. And when he was in charge of the section, how did he treat the

17 workers who were -- formed that section?

18 A. He was always very proper in his conduct.

19 Q. And did the section in which you worked and of which he was the

20 head, did that contain people from all the nationalities in Prijedor?

21 A. Yes; Serbs, Croats, Muslims.

22 Q. During the period before the events of 1992, did you have occasion

23 to help him in some building work at his home?

24 A. Yes, fairly often. I helped him build the family house.

25 Q. And did he return the favour to you by assisting in the building

Page 4577

1 of your home?

2 A. Well, he didn't actually help me because I didn't have a house to

3 build, but he did help me in the company I worked in. I liked to take an

4 extra drink now and again, and I would be -- this alcohol intake would

5 mean that I slept late and I wasn't always at work in my shift, so he

6 helped me get through that period.

7 Q. As events moved towards the clashes of 1992, Witness DF, did you

8 observe any change in the attitude of Dusko Sikirica towards people of

9 other nationalities?

10 A. No. He was the way he had always been.

11 Q. Were you close enough to Dusko Sikirica to know anything of his

12 political affiliations, if any?

13 A. Well, yes. I was close to him, but he wasn't interested in

14 politics.

15 Q. Do you know if he ever joined or was interested in the politics of

16 the SDS?

17 A. No.

18 Q. If Dusko Sikirica had ever begun to exhibit nationalist or racist

19 or extremist views towards members of other nationalities, would he have

20 continued to be your friend, or would you have ceased your friendship with

21 him?

22 A. I would cease to have been friends with him, quite certainly.

23 Q. In 1991, did you volunteer to join the JNA, the Yugoslav national

24 army?

25 A. Yes, I did.

Page 4578

1 Q. Why -- can you help us about this? Are you a Muslim yourself?

2 A. I'm a Yugoslav.

3 Q. And why exactly did you join the JNA in 1991?

4 A. I decided to join because I wanted to retain what had been

5 acquired after Comrade Tito.

6 Q. Did you at any time support the nationalist and extremist politics

7 that were exhibited on the Muslim side?

8 A. No, I did not. I didn't support that and I always condemned it.

9 Q. How long did you remain in the JNA?

10 A. From 1991 up until the end of December 1992. I can't remember the

11 exact date.

12 Q. Did you then return to work at Celpak?

13 A. Yes. I went in my work assignment.

14 Q. When you returned to Celpak, did you find that there was still any

15 Muslims working there?

16 A. Yes, that's right. I can't remember the names of all the people.

17 Q. In March 1993, did you suffer in some way from an assault?

18 A. Yes. In front of my house, two men were lying in wait for me, and

19 they hit me with their fists from behind, put me into a car, and I was

20 transferred to the cattle market, and they finished off beating me up

21 there.

22 Q. The two men, were they people that you knew, either by name or by

23 sight?

24 A. I knew them -- I remember one of the two -- the surname of one of

25 the two, and I knew them by sight.

Page 4579

1 Q. As a result of being assaulted, did you suffer injuries?

2 A. Yes. I had some broken ribs, three or four ribs, in fact, and

3 then my eye was all beaten up.

4 Q. Did you manage to get yourself home?

5 A. Yes, but with difficulty.

6 Q. Did you go to work the following day?

7 A. I couldn't go to work, so I rang up to say that I wouldn't be

8 coming in. I explained why, what had happened to me.

9 Q. Did you see Dusko Sikirica shortly after that?

10 A. Yes. He came to visit me in my home, and he took me off to see a

11 doctor in the company, the company doctor.

12 Q. And thereafter, did he continue to take you for medical

13 treatment?

14 A. Yes. He did that for six months until I was completely cured, and

15 he helped me throughout that time financially as much as he was able. He

16 would give me coffee, sugar, cigarettes too.

17 Q. In your opinion of Dusko Sikirica, if he had heard of a similar

18 event happening to other Muslim people, do you think he would have given

19 similar assistance to them?

20 A. He would. Knowing him, the kind of person he was, he would, yes.

21 Q. The Dusko Sikirica whom you knew after the war, was he the same

22 person that you have known from before the war?

23 A. Yes.

24 Q. And again, in that period of six months when he was taking you for

25 medical treatment, did he ever express to you or to any other person any

Page 4580

1 sentiment which could be described as hostile to other nationalities?

2 A. No. I've described him to you. He wouldn't have behaved as he

3 did towards me had he been a different person.

4 MR. GREAVES: Yes, Witness DF, would you wait there, please, and

5 answer any questions.

6 JUDGE ROBINSON: Any cross-examination, Mr. Petrovic?

7 MR. PETROVIC: [Interpretation] No, Your Honour.

8 MR. LAWRENCE: No questions.

9 JUDGE ROBINSON: Mr. Ryneveld?

10 MR. RYNEVELD: Thank you, Your Honour

11 Cross-examined by Mr. Ryneveld:

12 Q. Now, witness, as I understand your evidence, you're saying that

13 you were a childhood friend with Mr. Sikirica; is that correct?

14 A. Yes.

15 Q. And so before you started work at Celpak, you had been friends for

16 close to 30 years; is that correct?

17 A. Well, not quite 30, but I've known him, let's say, for 25 years.

18 Since we were children, since he started walking as an infant.

19 Q. Okay. Now, sir, you've told us that while you were working at

20 Celpak, you found that Mr. Sikirica got along with all of the employees,

21 regardless of race or ethnicity. Is that what you're telling us?

22 A. That's right.

23 Q. Isn't it fair to say, sir, that prior to 1990 or thereabouts, that

24 is not uncommon in the Prijedor area? People got along of all

25 ethnicities; isn't that true?

Page 4581

1 A. That's true, yes.

2 Q. In other words, this wasn't particularly unusual that Muslims and

3 Serbs and Croats would get along in the workplace or in the marketplace or

4 would socialise? That wasn't unusual, was it, sir?

5 A. No, it wasn't unusual.

6 Q. Would it be fair to say, sir, that after the political parties

7 formed and the outbreak of the war, that there was a sudden change in

8 that?

9 A. Well, yes, with the Muslims, because they wouldn't say hello to

10 you or good evening to you. They would say "selam aleykum."

11 Q. Is it fair to say, sir, that the ethnic tensions ran throughout

12 between Serbs and Muslims and Croats? Suddenly people who before got

13 along suddenly weren't getting along; is that fair to say?

14 A. Well, with some individuals, yes.

15 Q. Sir, surely you don't disagree with me that you could not have

16 predicted that people who you saw in the 1980s would suddenly turn to be

17 showing nationalistic tendencies in the early 1990s; isn't that true?

18 People changed.

19 A. Yes.

20 Q. Did you associate with Mr. Sikirica in 1992?

21 A. Well, I saw him several times in town. We'd go off for a drink

22 when I came back from the front.

23 Q. So you were on the front, and you would come into town. Did you

24 discuss what your job was at the time, or did you discuss what you were

25 doing at the front?

Page 4582

1 A. No.

2 Q. Would you discuss --

3 A. We weren't interested in politics.

4 Q. No, sir. I'm not really talking about politics now, I'm talking

5 about, "So, what have you been up to the last few months? Oh, I've been

6 up at the front. How's it going?" Were there conversations like that?

7 A. No, not really.

8 Q. And would you have asked him what he was doing?

9 A. Well, I didn't ask him because I knew that he was in the reserve

10 force of the civilian police force.

11 Q. All right, so you knew that. Did you ask him specifically what he

12 was doing or where he was or how things were going?

13 A. No. I wasn't interested.

14 Q. Did you know that he was camp commander at Keraterm?

15 A. No.

16 Q. You didn't know that?

17 A. No.

18 Q. You didn't know that he had any capacity at Keraterm?

19 A. No.

20 Q. So during this period of time, you had no idea that your childhood

21 friend was involved in a detention camp where Muslim prisoners were being

22 detained; you had no idea?

23 A. I knew he was in the camp there, but in what capacity, I didn't

24 know 'cause usually -- well, he was a policeman.

25 Q. So you didn't know --

Page 4583













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Page 4584

1 A. What kind of function would he have?

2 Q. So you did know that he was at the camp?

3 A. Yes.

4 Q. Did you know the kind of people who were detained at the camp?

5 A. Of course I knew.

6 Q. And you knew that there weren't any Serbs at the camp; is that

7 right? You knew there were Muslims and Croats, largely Muslims.

8 MR. GREAVES: Your Honour, the Prosecution's own witnesses have

9 spoken of Serb detainees at the camp. That's an improper question, if I

10 may say so.

11 MR. RYNEVELD: Let me rephrase my question.

12 Q. You knew that the large majority of people at the Keraterm camp

13 were Muslim civilians and some Croat civilians; isn't that right?

14 A. Yes.

15 Q. All right.

16 A. Yes. There were Serbs, too.

17 Q. Now, sir, counsel asked you about you helped Mr. Sikirica build

18 his house, but he didn't help you build your house because you didn't have

19 a house to build; is that correct?

20 A. Yes, in a way.

21 Q. But he did other favours for you; is that correct?

22 A. Yes.

23 Q. And I'm not quite sure what you meant that you liked to take an

24 extra drink so that you could sleep late the next morning, and he'd let

25 you get away with that. Is that one of the examples you're giving, that

Page 4585

1 he wouldn't report you when you came in late?

2 A. Yes.

3 Q. So is it fair to say, sir, that Mr. Sikirica showed favours to

4 you?

5 A. No.

6 Q. Or anybody --

7 A. It wasn't a favour.

8 Q. Well, then, I guess I failed to appreciate why it is you mentioned

9 that. Was everybody entitled to come in late?

10 A. I didn't have the right myself, but occasionally it would happen.

11 But it wouldn't only happen to me, that is, it wasn't only me to whom he

12 did this kind of favour.

13 Q. But you listed it as an example of things he would do for you; is

14 that right? He would let you come in late. You were his friend. Is that

15 right?

16 A. Yes.

17 Q. If you weren't his friend, he wouldn't have let you come in late

18 without some consequences?

19 A. Well, he would.

20 Q. Now, sir, I only have a few more questions. I believe the

21 question was, in 1992, whether or not you knew if Mr. Sikirica was

22 politically active, and you said that you did not think he was; is that

23 correct?

24 A. He wasn't active.

25 Q. Do you know if he joined the SDS?

Page 4586

1 A. No.

2 Q. Let me rephrase my question because I think that's the same

3 question my friend asked. You do not know, or do you know that he did

4 not?

5 A. I know that he did not.

6 Q. You know that he did not join the SDS. And how would you know

7 that? Did you discuss politics with him?

8 A. No, I did not talk, because at the company, while we worked

9 together, politics was something that, if it was addressed as a topic, he

10 would just walk away from it.

11 Q. But how would you then know that he was not a member of the SDS,

12 if you didn't discuss it?

13 A. I know because he stayed away from -- he would leave this group

14 that would talk about it.

15 Q. Would it surprise you, sir, if I were to tell you that your friend

16 Mr. Sikirica was a member of the SDS?

17 A. I don't believe it.

18 Q. Well, then, let me show you, if I may, a document which has

19 already been marked as Exhibit 9.1, but I have another copy of it.

20 MR. RYNEVELD: Mr. Registrar, could you show this document,

21 please, to the witness. And I have copies for the Bench and for my

22 learned friends. Six copies there; one for each Defence team and one for

23 the Bench.

24 Q. Now, sir, this document has not been translated but it's just a

25 list of names and numbers. On the right-hand corner, it says 8221. You

Page 4587

1 see that number in the top right-hand corner of this document?

2 A. Yes.

3 Q. There is also a phrase above the list on page 1, above the list of

4 names. Can you tell us -- can you read that to us, please, and tell us

5 what that says.

6 A. "List of SDS member in Urije Prijedor."

7 Q. And, sir, I would like -- invite you, if you would, please, to

8 look at number 69 on that list. You see the number 69 in the second

9 column?

10 A. Yes.

11 Q. Could you read that name to us, please.

12 A. "Dusko Sikirica."

13 Q. I see. Do you read Cyrillic, sir? Are you able to read the

14 Russian Cyrillic script?

15 A. I'm not very good at it. I can, but I'm not very good at it.

16 Q. Perhaps you could try for us. I'm only going to ask you to read a

17 name.

18 MR. RYNEVELD: Again, I have copies of a document which was 9.2,

19 Your Honours, in the Prosecution's list of documents filed, and again I

20 have copies for the witness, counsel and the Court.

21 Q. This appears to be a handwritten list. First of all, sir, there

22 is a phrase at the top of page 1 in handwriting. Are you able to read

23 what that says?

24 A. "SDS members, Prijedor, Urije."

25 Q. Would you please look at the number 71 and tell us whether you're

Page 4588

1 able to read that name. That's in the second column on the first page.

2 A. "Dusko Sikirica."

3 MR. RYNEVELD: Thank you. Might those documents be marked as two

4 consecutive numbers in the Prosecution's case, please?


6 THE REGISTRAR: These documents are already admitted as

7 documentary evidence and are already in our exhibit list.

8 MR. RYNEVELD: Thank you.

9 Q. Now, sir, you joined -- in 1991, you joined the JNA, the Yugoslav

10 army; is that correct?

11 A. Yes.

12 Q. And do I understand you correctly to say to counsel that you were

13 opposed -- you did so for various reasons, but did I get from your

14 evidence that you were opposed to the policies of the SDA?

15 A. Yes.

16 Q. Did you consider them to be extremists, sir?

17 A. Yes, they were.

18 Q. I see. So you personally had very little sympathy for any Muslim

19 SDA members; is that correct?

20 A. Yeah -- no.

21 Q. Better find out -- it's no, you had no sympathy? Maybe I should

22 rephrase my question. Double negatives are not good. Did you have

23 sympathy for Muslim SDA members?

24 A. No, I did not have that either.

25 Q. Okay. Now, sir, you said that after you were assaulted in March

Page 4589

1 of 1993 by two men, you called into work the next day and reported your

2 inability to come to work. I got that right, did I?

3 A. I would call in by phone.

4 Q. Yes. Was Dusko Sikirica back at work at Celpak in March of 1993?

5 A. No.

6 Q. Do you know how it is that he knew that, of your unfortunate

7 assault?

8 A. I wouldn't be able to tell you that.

9 Q. Sir, at the time you were assaulted, they stole 10.000 dinars from

10 you, did they not? You were robbed.

11 A. No. Where did you get that?

12 Q. The answer to my question is simply no; is that correct?

13 A. Yes.

14 MR. RYNEVELD: Excuse me one moment.

15 [Prosecution counsel confer]

16 MR. RYNEVELD: Sorry, unless Your Honour has any questions, those

17 are likely mine.

18 Questioned by the Court:

19 JUDGE ROBINSON: Witness DF, do you have any idea why you were

20 assaulted?

21 A. I think simply because my name was Sead.

22 JUDGE ROBINSON: That being a name of what ethnicity?

23 A. Muslim.

24 MR. RYNEVELD: There is something arising from that, if I may.

25 JUDGE ROBINSON: Yes, Mr. Ryneveld.

Page 4590

1 Further cross-examined by Mr. Ryneveld:

2 Q. Counsel asked you if you knew the individuals who assaulted you.

3 You said, if I remember correctly, that you recognised them both by face

4 and knew one by name. Were you able to determine what ethnicity your

5 assaulters were?

6 A. They were Serbs.

7 Q. Thank you.

8 JUDGE ROBINSON: Mr. Greaves?

9 Re-examined by Mr. Greaves:

10 MR. GREAVES: Yes, you've been asked about Dusko Sikirica's

11 membership in the SDS, Witness DF. I'd like you to have a look at two

12 documents, please.

13 JUDGE ROBINSON: The documents are to be distributed.

14 MR. GREAVES: There are copies of two originals which are in

15 Cyrillic and translations in English -- perhaps you could give them to the

16 registrar first so they could be distributed. The French translation

17 follows. One of each document for the witness, please. Not the English

18 translation.

19 Q. Witness DF, would you look at the document which does not have a

20 coat of arms at the top of it, please. Thank you. Does that bear at the

21 top left-hand corner the name Londrovic Veselin, and indicate that he's

22 Defence counsel for the accused Dusko Sikirica, giving his address? Is

23 that correct?

24 A. Yes.

25 Q. And is that a request to the SDS in Prijedor, requesting

Page 4591

1 information as to whether or not Dusko Sikirica was a member of the SDS

2 and asking them to consult their records in respect of that, and it's

3 dated the 12th of October, 2000; is that right?

4 A. Yes.

5 Q. Would you look at the second document, please. Would you look at

6 the section containing the coat of arms. Is that the SDS coat of arms,

7 and does it have the name "Serb Democratic Party, Municipal Board

8 Prijedor," at the top?

9 A. Yes.

10 Q. And is that addressed to Veselin Londrovic, a lawyer at Bijeljina,

11 and does it say, in effect, that, "In relation to your written request

12 dated 12th of October regarding membership in the Serb Democratic Party of

13 Sikirica Dusko from Prijedor, we inform you that the person in question

14 never was a member of this party"? Is that what it says?

15 A. Yes.

16 Q. And that document is dated the 12th of October, 2000; is that

17 right?

18 A. Yes.

19 Q. And does the original bear a stamp over the signature of I think

20 it's Mr. Dusan Beric, the director?

21 A. Yes, it does.

22 MR. GREAVES: Your Honours, just give me a moment, please.

23 [Defence counsel confer]

24 MR. GREAVES: Do Your Honours have any further questions for the

25 witness?

Page 4592


2 Witness DF, that concludes your testimony and you are released.

3 THE WITNESS: [Interpretation] Thank you.

4 MR. GREAVES: Your Honour, the next two witnesses I intend to call

5 are both witnesses for whom voice distortion is going to be requested.

6 Because of the technical problem that appears still to be in existence, on

7 the face of it, that's going to have to be done in closed session. I'm

8 reluctant to allow these two witnesses in particular to have their

9 evidence unheard by the public at large, and I wonder whether we can

10 perhaps adjourn now for the morning break to see whether we can get the

11 voice distortion operating properly by the time they are recalled.

12 JUDGE ROBINSON: Yes. We will take the break now and resume at 20

13 minutes after 11.

14 MR. GREAVES: May the documents I've just produced acquire exhibit

15 numbers, please?


17 THE REGISTRAR: D36/1 and D37/1.

18 JUDGE ROBINSON: Witness DF, we are going to adjourn for half an

19 hour. Please have the witness sit so he can hear what I'm saying.

20 Witness DF, we will adjourn for half an hour. During the adjournment, you

21 are not to discuss your evidence with anybody. That includes the members

22 of the Defence team.

23 Mr. Ryneveld?

24 MR. RYNEVELD: Yes, Your Honour. Maybe I'm wrong but was this

25 witness -- are we not finished with him? I believe he can be excused. I

Page 4593













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Page 4594

1 don't know if he needs to be -- I'm sorry, I may be wrong.

2 JUDGE ROBINSON: Yes, I think you are right. Witness DF, your

3 testimony has been concluded and you are released.

4 THE WITNESS: [Interpretation] Thank you.

5 [The witness withdrew]

6 --- Recess taken at 10.53 a.m.

7 --- On resuming at 11.30 a.m.

8 JUDGE ROBINSON: Yes, Mr. Greaves?

9 MR. GREAVES: Your Honour, I'd like to start this session by

10 producing some photographic exhibits and going through them with you very

11 briefly just to explain what they are and how they are assembled, please.

12 Copies have already been distributed to other Defence teams and the

13 Prosecution.

14 Could I ask Your Honours, please, to turn to the first two

15 photographs, number 1 and number 2. Your Honour, the first one is a view

16 along the main Prijedor-Banja Luka road with the Keraterm perimeter fence

17 on the left, showing also, I just notice, the weigh hut in the very left,

18 middle ground.

19 JUDGE MAY: When were these taken?

20 MR. GREAVES: 16th of June, Your Honour. It may be possible to

21 view the date stamp on some of them. Your Honour, these are the fruits of

22 our visit to Prijedor during the break. Photograph number 2 is taken from

23 the same position but shows Keraterm camp outside the perimeter fence,

24 looking towards the left-hand end of the building, and you can see, just

25 behind a tree and a lamp post, Room 1 and Room 2. And the figure of 60

Page 4595

1 metres is derived in this way: It is by me pacing it out. So it is

2 approximately 60 metres to that point.

3 Photograph number 3, taken again from outside the camp, from the

4 side road leading to the entrance to Keraterm, and that photograph shows

5 the entrance gate and the -- how the road diverges in front of the weigh

6 hut, which you can see just in the centre middle ground.

7 Photograph below that, number 4, is a photograph looking back

8 towards the main gate, again with the weigh hut and a small storage shed,

9 which I think appears on one of the sketches that was produced in the

10 middle ground.

11 Photograph number 5 was taken from a position similar to the one

12 in number two but just inside the fence and, therefore, approximately 50

13 metres from the building. Again, done by pacing it out.

14 Number 6, self-explanatory: A view of Keraterm building showing

15 the present doors to Room 1 and 2, because it is understood that they have

16 been changed since 1992, and the area in the corner there where the food

17 was served.

18 Then we took a series of photographs, and I hope I'll be forgiven

19 for appearing to give evidence, but I was present during the taking of

20 these photographs and supervised it. Photograph number 7 shows the

21 position at which the photographer took the next series of photographs.

22 It is the door of Room 1, and it is, as you look at it, the left-hand side

23 thereof. And what we did in respect of each position was to take a

24 photograph 90 degrees to the right, approximately 45 degrees to the right,

25 straight ahead, 45 degrees -- sorry, not straight ahead, 45 degrees left,

Page 4596

1 and 90 degrees left. And Your Honours will see those from position -- of

2 the photographer appearing in photographs 8, 9, 10, and then 11.

3 Number 12 shows the second position for the photographer,

4 approximately the centre of the door of Room 1, and then a similar series

5 of photographs taken 90 degrees right, 45 degrees right, 45 left, and 90

6 degrees left, and that takes us to photograph 16.

7 Then a photograph at number 17 showing the position of the

8 photographer for the next series of photographs. That's the, as you look

9 at it, the right-hand door lintel of Room 1, and then four photographs

10 taken at similar angles to the ones I've already described.

11 Photograph 22 is the door of Room 2. That's the position of the

12 photographer for a similar series of photographs in the same, same

13 panoramic views that I've described.

14 Photograph 27 shows the position of the photographer for a similar

15 series from the centre of the door of Room 2.

16 Photograph 32 shows position of the photographer on the other door

17 lintel of Room 2, again, with the succeeding series of photographs with

18 panoramic views as before.

19 Photograph 37 shows Mr. Londrovic standing on a group of -- set of

20 pallets, and he's holding in his hand a piece of wood with a piece of

21 cloth on the end of it. That is so as we can identify for those

22 photographs where you cannot see him personally to indicate what his

23 position is, and so that if you look at photograph 38, that is a view from

24 the door of Room 1 at its left-hand extremity, so that you cannot see the

25 person standing on the pallets, but you can see the end of the plank of

Page 4597

1 wood with the cloth on it.

2 And what we then did was to take a photograph at each of the

3 former positions - left-hand side of Room 1, centre of Room 1, right-hand

4 side of Room 1, left-hand side of Room 2, centre of Room 2, right-hand

5 side of Room 2 - so as to indicate what you can see of the person standing

6 on the pallets. That takes us through to photograph 43.

7 Forty-four shows Mr. Londrovic standing approximately ten metres

8 from the door of Room 3, and we conducted the same exercise from the same

9 positions at each of the doors so that that can indicate what may be seen

10 of Mr. Londrovic at approximately ten metres from the door of Room 3.

11 That takes us through to photograph number 50.

12 51, 52, 53 concern a witness who will be giving evidence later on

13 during the course of today, and we'll deal with those in due course.

14 JUDGE ROBINSON: Yes, Mr. Ryneveld.

15 MR. RYNEVELD: It may also be of assistance if my learned friend

16 could in due course provide an indication as to whether this is with a 35

17 millilitre -- not millilitre, millimetre camera, whether it had a wide

18 angle. And we acknowledge, I take it, that this is assuming the doors

19 shown today are in the same place that they were in the relevant time

20 period in 1992. If those are different, then everything else is

21 different.

22 MR. GREAVES: As I understand it, the doors are plainly different

23 doors from the ones which existed in 1992. I do not know one way or the

24 other whether the position of the doors has been changed, but I think it's

25 highly unlikely.

Page 4598

1 JUDGE ROBINSON: What about the camera?

2 MR. GREAVES: The answer to that is, I don't know, but I can find

3 out. That's a matter of a telephone call.

4 If my learned friend requires it, I have a handwritten statement

5 from the person who took the photographs and the originals. I see him

6 shake his head.

7 MR. RYNEVELD: No. All I'm asking for is if my friend can make

8 inquiries and inform the Court and the Prosecution in due course what kind

9 of angle or lens that we've got because it affects perspectives and

10 distances and all that sort of thing.

11 MR. GREAVES: Of course. If he gives us the same information

12 about his photographs that he produced at the beginning of the case, I'm

13 sure we can accommodate him.

14 May this document acquire an exhibit number, please.

15 THE REGISTRAR: Defence Exhibit D38/1.

16 [Trial Chamber confers]

17 MR. GREAVES: Your Honour, may we -- I'm sorry.

18 JUDGE ROBINSON: Yes, Mr. Greaves.

19 MR. GREAVES: May we go into private session whilst I make an

20 application in respect of protective measures, please.


22 [Private session]

23 [redacted]

24 [redacted]

25 [redacted]

Page 4599













13 page 4599 redacted private session.













Page 4600

1 [redacted]

2 [redacted]

3 [redacted]

4 [redacted]

5 [redacted]

6 [redacted]

7 [redacted]

8 [redacted]

9 [redacted]

10 [redacted]

11 [redacted]

12 [redacted]

13 MR. GREAVES: May we go back into open session, please?


15 [Open session]


17 Q. Witness DG, from 1969 onwards, did you work outside the former

18 Yugoslavia, in [redacted]?

19 A. [redacted].

20 Q. [redacted]

21 A. Yes.

22 Q. And did you continue to travel thereafter to various countries, in

23 [redacted]?

24 A. Yes, yes.

25 Q. On the 30th of April 1992, were you in Prijedor?

Page 4601

1 A. I came from Russia to go to Rijeka to settle some business deals,

2 and then I had a rest at home for two days and then I went to Rijeka, I

3 struck the business deals, but I couldn't go back. I don't know the exact

4 dates, but I wasn't able to return via Zagreb to Russia because I had five

5 people -- five of my people in Zagreb and five others in Russia.

6 Q. Is it right that at the end of May 1992, you were in Prijedor, and

7 in particular on the 31st of May 1992, were you in Prijedor?

8 A. I think I was. I'm not quite sure.

9 Q. At around that time, did some people come to your home and detain

10 you?

11 A. Well, yes. When there was a commotion of some kind and the army

12 turned up, yes, they did come to my house and street and they said, I

13 don't know from what age, a younger age up to the age of 80, that we

14 shouldn't leave our homes, and that we should gather together at the main

15 road at about 3.00 p.m.

16 Q. The -- did eventually some people come to the street at 3.00

17 p.m.?

18 A. Yes, in the afternoon, yes, we did, the whole street, all my

19 neighbours, we all went out and collected at that point.

20 Q. Were some of you taken away at that point?

21 A. Not from there, from the buses.

22 Q. Where did the buses go to?

23 A. We were boarded into the bus and we went to the barracks, and then

24 we stopped -- the Urije barracks, and then we stopped and then we

25 continued, I don't know where exactly. We arrived at Omarska and we found

Page 4602

1 some buses there too. There were another four or five buses in front of

2 us. Otherwise, there were people sitting out there on the pista in

3 Omarska. However, I don't know how long we stopped there for. All the

4 people got off and sat down on the pista. This went on for some time. I

5 sat there for some time on the pista too. And then they called the same

6 people back into the bus and we reached Keraterm.

7 Q. At what time did you reach Keraterm, approximately?

8 A. I don't know exactly. It was night-time. It was night.

9 Q. When you arrived there, where were you placed upon arrival?

10 A. Number 1, Room number 1, Keraterm, a big hall.

11 Q. And can you remember what the date it was upon which you were

12 detained firstly at Keraterm and then -- firstly at Omarska and then at

13 Keraterm?

14 A. No, I don't remember.

15 Q. How long did you remain in Keraterm?

16 A. It was a Sunday when we were taken there, and I left on a Friday.

17 I don't know exactly, but I left after 12 noon on Friday, six days later.

18 Q. When you were placed in Room 1, how many other men -- how many

19 other people were in the room with you?

20 A. There were a lot of us. I was next to the door. Not only me, the

21 room was full, so I don't know the exact number, but there were a lot of

22 us, a great many.

23 Q. And were all the people who were detained, were they all Muslim,

24 or were they of mixed race?

25 A. There were Croats. They were my neighbours, some of my Croat

Page 4603













13 Blank page inserted to ensure pagination corresponds between the French

14 and the English transcripts.












Page 4604

1 neighbours, in fact.

2 Q. During the time that you were in Keraterm, were you in any way

3 ill-treated by any person at the facility?

4 A. No.

5 Q. Did you observe any other, any other person being ill-treated by

6 the guards?

7 A. Well, no. Two or three days went by. I know that just one young

8 man was when some people stormed the room and beat him up. He went

9 outside. And nothing else happened, nor did anybody mistreat me or

10 others.

11 Q. Were you, were you interrogated in Keraterm, Witness DG?

12 A. Yes, I was on the Friday when I left.

13 Q. And can you remember what the date was when you were -- when you

14 left Keraterm?

15 A. I couldn't say. All I know is that we were collected up into the

16 bus on a Sunday and went to Keraterm, and on the sixth day, which was a

17 Friday, we left.

18 Q. When you were interrogated, who was it who carried out the

19 interrogation?

20 A. I don't know. I didn't know the people. I can't say, really.

21 All I do know is who took me up for the interrogation.

22 Q. What was the subject of the interrogation? What were the

23 questions about?

24 A. Well, they asked me if I was in any organisation, whether this,

25 whether that, whether I had any arms, weapons. I said no. My answer was

Page 4605

1 no. And everything was all right. Their conduct was proper so that I was

2 there -- I was interrogated for a very short time, actually.

3 Q. After you had been interrogated, were you kept in Keraterm or were

4 you released?

5 A. I don't know how much time went by, an hour or two, but the person

6 that took us for the interrogation -- I don't know how much time went past

7 -- by, as I say. He brought in some certificates and then called out our

8 names, the five of us, all five of us neighbours from my street. We were

9 all born in 1946. He questioned us up there, and then he brought these

10 certificates and said, "You can take your jackets or your belongings and

11 you can go home. We would drive you home, but we haven't got any vehicles

12 at our disposal at the moment." So that's what he said, and he said that

13 we shouldn't turn around or go back until we had come to our part of the

14 street, and go on home.

15 Q. You've mentioned being given a certificate. Do you still have the

16 certificate that you were given?

17 A. No. I had some refugees with me, and all -- I haven't got the

18 certificates. No, none of those documents.

19 Q. What was the nature of the certificate that you were given?

20 A. Well, it was just a small one. Perhaps a little bigger than this

21 piece of paper here.

22 Q. And what was the effect of the certificate?

23 A. I apologise, but I don't understand. You mean what was written on

24 the certificate; is that what you mean?

25 Q. Yes. What did the certificate permit you to do or what was it

Page 4606

1 about?

2 A. Well, it enabled us to go home so that the army, some other

3 soldiers, wouldn't capture us. And had we not had that certificate,

4 perhaps they would have sent us back, but with that certificate we were

5 able to leave.

6 And when we received those certificates, the man who took us up

7 for interrogation told us to go to the SUP building on Monday, any of us

8 who had any land to till, that we were to go to SUP and get another permit

9 to be able to move around. So it wasn't the same certificate but some

10 sort of permit allowing us to move around and cultivate our land, those of

11 us who owned land.

12 Q. And what time of day was it that you were released?

13 A. Well, about 12, little before 12 noon. Perhaps 15 minutes later.

14 But I arrived home sometime in the afternoon, and I don't live very far

15 away so I was able to go on foot. It's perhaps a kilometre or so away.

16 Q. Can you help us about this, please: During the period from Sunday

17 to Friday when you were in Keraterm, did you receive food during that

18 period?

19 A. Not by the soldiers, no. We got food from home. When they heard

20 where we were and what was happening to us, our families would bring in

21 the food. But I told my family to bring food in during the day, so that

22 was not a problem, and we would get cigarettes and food. It wasn't that

23 this couldn't be brought in to the place.

24 Q. And what about water; was there a supply of water at Keraterm

25 during this period?

Page 4607

1 A. Yes, there was. There was a cistern, and they would bring in

2 fresh water and open the big, big doors, and we were able to wash

3 ourselves and so on. And their conduct was proper, at least, while I was

4 there.

5 Q. Help me about this: During the period that you were at Keraterm

6 from the Sunday to the Friday, did you hear of or see a man called Dusko

7 Sikirica?

8 A. No.

9 Q. Do you know that person at all?

10 A. No.

11 Q. Just see if you can help me again to try and fix the date when you

12 were at Keraterm. Do you recall fighting taking place in the centre of

13 Prijedor during the course of May 1992?

14 A. I can't remember because, as I say, I came there, and then I went

15 to help my neighbour put a roof on his shed, so I wasn't really informed

16 of that kind of thing. I didn't hear about anything like that and wasn't

17 interested in things like that. I just worked on my place and his. So I

18 can't remember the date, no.

19 Q. Can you put a month on it? Are we talking about the beginning of

20 June or end of June or end of May? What are we talking about?

21 A. I don't know.

22 Q. Yes. Wait there, please.

23 JUDGE ROBINSON: Thank you, Mr. Greaves.

24 Mr. Petrovic?

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

Page 4608

1 Cross-examined by Mr. Petrovic:

2 Q. Witness DG, is it true that you did not know a person named Kajin

3 before the war?

4 A. No.

5 Q. Is it true that several days after your arrival in Keraterm, you

6 learned from the people who were detained there that there is a guard

7 there named Kajin?

8 A. Yes.

9 Q. Is it true that Kajin was one of the guards at Keraterm?

10 A. Of course he was, because he was the one who took me up to the

11 interrogation, so I got to know him a little bit. There were three

12 occasions, I think, that three persons were taken to be interrogated on

13 that Friday.

14 Q. Can you hold on, please? I will come to that point. But is it

15 true that you don't know whether Kajin had any other role in Keraterm

16 except for being a guard?

17 A. No.

18 Q. Let us clarify this, please. You know that Kajin was only and

19 exclusively a guard?

20 A. Yes.

21 Q. Was Kajin the one who escorted you to be interrogated that Friday

22 when you went there?

23 A. Yes.

24 Q. This interrogation, is it true that it was conducted on the top

25 floor of the administration building?

Page 4609

1 A. Yes.

2 Q. Is it true that Kajin escorted you to the door of the room where

3 the interrogators were and then remained in front of the door?

4 A. Yes.

5 Q. Is it true that Kajin was not in the room where you were

6 interrogated?

7 A. No.

8 Q. What you're trying to say, he was not in that room; is that

9 correct?

10 A. Yes.

11 Q. And you're trying to tell us that he remained in front of the

12 door?

13 A. Yes.

14 Q. When you went for interrogation, is it true that no one mistreated

15 you in any way?

16 A. They did not.

17 Q. We may have a problem with your answers. You just gave evidence

18 that no one mistreated you from the room where you were staying to the

19 room where the investigators were and back. Is the answer to that yes?

20 A. Yes, but just a moment, please; nobody mistreated us.

21 Q. Also no one mistreated you during the interrogation?

22 A. No.

23 Q. Did anyone mistreat you during interrogation?

24 A. No.

25 Q. Do you know a person named Duraj Sejdi?

Page 4610

1 A. No.

2 Q. The certificates that you used to get out of Keraterm was brought

3 to you by Kajin?

4 A. Yes.

5 Q. So far as you know, these certificates was drafted by the

6 interrogators that interrogated you?

7 A. Yes.

8 Q. Kajin advised you how to proceed to your home in order to avoid

9 any problems that the person of your ethnic background could have faced in

10 Prijedor?

11 A. Yes.

12 Q. He did so in order to help you?

13 A. Yes.

14 Q. He did it in order to prevent that anything would happen to you on

15 your way home?

16 A. Yes.

17 Q. Kajin always treated you in a correct and friendly way?

18 A. Correct.

19 Q. The event you mentioned a little while ago took place when Zigic

20 was working?

21 A. Yes.

22 Q. When Kajin was working, you could freely receive food from your

23 families?

24 A. Yes. We were able to receive it in a normal way.

25 Q. When Kajin was working, you could freely bring in the food brought

Page 4611

1 in by your families, share it with your fellow inmates and eat it?

2 A. Yes. We shared it freely, normally, and we also were able to eat

3 it.

4 Q. When Kajin was working, you could -- you were free to use the

5 water that was brought in in water tanks and drink whenever you wanted?

6 A. Yes, whenever everybody was thirsty, one could go and serve

7 themselves. We also had some plastic container and bottles from juices

8 that we also used.

9 MR. PETROVIC: [Interpretation] No more questions, Your Honour.

10 JUDGE ROBINSON: Thank you, Mr. Petrovic. Any cross-examination?

11 MR. LAWRENCE: No questions, thank you.


13 Cross-examined by Ms. Baly:

14 Q. So, Witness DG, was it difficult when Kajin wasn't working to get

15 access to water?

16 A. Well, it was a little bit, but Zigic did allow it, so one could

17 get to water but, for the most part, people avoided asking for it.

18 Q. Why was that?

19 A. Well, I don't know. What do I know? I had not known Zigic even

20 until then. I got to know him then. He did not mistreat me. But I don't

21 know why the other people did not -- even then people could receive food,

22 but it seems -- I don't know. I wouldn't be able to say anything else.

23 Q. Wasn't it the case that people were afraid to ask because they

24 were afraid of being mistreated?

25 A. I wouldn't be able to say. As I said, I did not want to ask, but

Page 4612

1 while Kajin was there, there were no problems. He would open the door and

2 anybody could come out when they were thirsty or whatever.

3 Q. And you said that the food could get in when Kajin was working.

4 Does that mean when Kajin wasn't working, it was difficult to get food

5 in?

6 A. Well, people avoided it. People were getting it, but those who

7 knew Zigic, so then they could get it through him. For instance, my

8 family -- a colleague who knew Zigic and who was on good terms with Zigic,

9 my wife would give food to him so that the food could get in that way.

10 Q. So that if Kajin wasn't working and Zigic didn't know you, it's

11 possible you wouldn't get any food in; is that correct?

12 A. Yes, that is correct.

13 Q. And at that time, the authorities in the camp were not supplying

14 the detainees with any food whatsoever. That's correct, isn't it?

15 A. In those six days, no, nothing. We may have received some

16 biscuits, those round ones. I think that was on a Wednesday or a

17 Thursday. And even that we split into three or four parts because there

18 wasn't enough, so we only received a little bit of that.

19 Q. May I ask you, Witness DG, what party you voted for in the general

20 elections in November of 1991?

21 A. For Fikret Abdic. I don't know what party that was, but I voted

22 for him.

23 Q. What was your -- did you vote for -- no, I withdraw that.

24 Did you participate in the plebiscite in February of 1992?

25 A. I'm sorry, I don't know what that -- the question means, the one

Page 4613













13 Blank page inserted to ensure pagination corresponds between the French

14 and the English transcripts.












Page 4614

1 you just asked me. I'm sorry.

2 Q. I won't repeat the question; I won't ask that question again of

3 you.

4 What was your view at that time, that is late 1991, early 1992, of

5 the SDA party? Did you have a view regarding the SDA party?

6 A. To be honest, I had -- I didn't join any party. I had very strong

7 family. I had a large family. I had to work a lot. I had no interest in

8 any of that whatsoever.

9 Q. Would you look, please -- will you look, please, at this document

10 which is Exhibit 54. It's a slightly different document so I'll just show

11 you this document, please, and I'm having copies obtained.

12 A. If I could only read this now.

13 Q. Witness DG, do you have difficulty reading that document,

14 particularly the heading of that document?

15 A. Yes. I have a little difficulty with reading, and the problem

16 also is I didn't bring my glasses with me, so there's a problem.

17 Q. Would you recognise your name if you saw it?

18 A. I think that I would recognise it if I did see it.

19 Q. All right. Can you turn to the second page of the document. Can

20 you look, please, in the first column at about halfway down. Can you see

21 your name there and your date of birth, or the year of your birth? [redacted]

22 [redacted].

23 A. This? Here. Yes, yes.

24 Q. All right.

25 A. Now I see it. I recognise it.

Page 4615

1 Q. Well, Witness DG, do you accept from me that that is a list of

2 persons who responded to the military call-up on behalf of the JNA army?

3 JUDGE ROBINSON: Ms. Baly, why don't you have it put on the ELMO?

4 MS. BALY: Yes, please, Mr. Usher. Can you put the document on

5 the ELMO, please.

6 MR. GREAVES: Could we go into private session if that is done,

7 because it will reveal his name.

8 JUDGE ROBINSON: Yes, private session, yes. Closed session.

9 [Closed session]

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 4616

1 [redacted]

2 [redacted]

3 [redacted]

4 [redacted]

5 [redacted]

6 [redacted]

7 [redacted]

8 [redacted]

9 [redacted]

10 [redacted]

11 [Open session]

12 MS. BALY:

13 Q. Was it the VRS army for whom you worked?

14 A. Yes.

15 Q. That was the Army of the Republika Srpska, correct?

16 A. That's correct, yes.

17 Q. Just getting back to the time period for a moment, you said it was

18 after the 1992 conflict. Just doing the best you can, please, how many

19 months or years after? Just give us an approximate date, please.

20 A. I wouldn't be able to recall, but I know that I spent quite a bit

21 of time on this work duty, until the Dayton Accord. Then we came back

22 from Gradacac. Then I spent another 3 months in Prijedor, working for the

23 army, for those who were killed. We went to log and that's what went on.

24 Q. In 1992, during the conflict, would you agree that you had an

25 allegiance to the Serb army?

Page 4617

1 A. Yes, I was, because when the army came, they told us to put up

2 white flags on our homes, and that's what we did.

3 Q. And that indicated, did it, that you were aligned to the Serb

4 army?

5 A. Of course I was there. I stayed there. I remained there. Of

6 course I put out the white flag, and so there it was.

7 Q. In any event, you were -- you were arrested and detained at

8 Keraterm camp sometime after you'd put up your white flag; that's correct,

9 isn't it?

10 A. That is correct.

11 Q. And it was members of the Serb army who arrested you; that's

12 correct, isn't it?

13 A. Yes. The army came and rounded us up and put us in buses and so

14 on.

15 Q. And they rounded up those who were non-Serbs; that's correct,

16 isn't it?

17 A. Yes, yes.

18 Q. And so would you agree with the proposition that you were arrested

19 because you were non- -- a non-Serb?

20 A. Well, I don't know how and what -- of course that's how it was.

21 Q. In any event, you were taken to the camp and you were placed in

22 Room 1 where you said there were many other men; that's correct?

23 A. That's correct.

24 Q. In fact, the conditions were very overcrowded; would you agree

25 with that?

Page 4618

1 A. I agree.

2 Q. And you didn't have any bedding at all, did you? You had to sleep

3 on wooden pallets; that's correct, isn't it?

4 A. That's correct.

5 Q. And you've already indicated, you've already told us that there

6 was no food organised by the authorities. What was the situation --

7 A. That's correct.

8 Q. What was the situation in relation to the hygiene conditions?

9 They were very poor, weren't they?

10 A. Yes. It was poor in those six days. It was very hot and so on.

11 Q. And then you were interrogated; that's correct?

12 A. Yes. On the sixth day, I was taken for interrogation.

13 Q. And you've indicated that it was Mr. Kajin who took you there.

14 Did he take a number of other persons as well for interrogation that day?

15 A. On that day before we were interrogated -- in fact, on Monday it

16 started, so the older men went first, and it went on through Friday when

17 it was my turn, because on that day I think three groups of five were

18 released on that day. That's when we were released, also in a group of

19 five, but there were three groups, I think, before me.

20 So this is when I inquired and I found out that it was Kajin who

21 was taking people to be interrogated, and that's how I met him. He took

22 me and all these neighbours from the same street, and everything was all

23 right and it all sort of went in the best way.

24 Q. Was he using a list or something when he took the persons to be

25 interrogated? Was he calling people out from a list?

Page 4619

1 A. He did call out, but he did have a notebook. Actually, he had

2 ordered, and one of our -- from our own made a list with the dates of

3 birth, and he called people out by their, by their birth year, and that's

4 how we all went.

5 Q. And he was the person who ordered that list to be created; is that

6 right?

7 A. Yes, yes.

8 Q. And you were interrogated and released on the same day, correct?

9 A. Yes, the same day.

10 Q. And again, it was Mr. Kajin who issued the certificate to you,

11 correct?

12 A. That's right.

13 MR. PETROVIC: Apologies, regarding the interpretation. In B/C/S

14 he said, "Who gave you the paper," and if --

15 JUDGE ROBINSON: Yes, I agree.

16 MR. PETROVIC: [Interpretation] Not "issued," and that is a crucial

17 difference.

18 MS. BALY: Yes, I apologise. That is indeed the case.

19 Q. In any event, he gave you this certificate, and you say it was a

20 fairly small document. Did you ever have that certificate read to you?

21 A. I did not read it. I just put it in my pocket. And he said,

22 "Just go down the main road and then go to the SUP on Monday for those of

23 you who have some land so you can move about." So this document was only

24 from Keraterm to the house. I think that that's what it was saying.

25 Q. Witness DG, did you ever -- ever that is, not at that time, but

Page 4620

1 ever have that certificate read to you? Do you know what it said?

2 A. I don't know, no.

3 Q. Mr. Kajin was a shift commander in the camp; would you agree with

4 that? A shift commander who had authority over a number of subordinate

5 guards; would you agree with that?

6 A. I don't know what he was. I only know that he was there a few

7 times while I was there, a guard. I don't know what his position was. I

8 don't know anything about that.

9 Q. When you were interrogated, one of the first questions you were

10 asked was about your politics. Would you agree with that?

11 A. They asked about weapons and things like that. I said that I

12 didn't own any, and basically I had no problems when I was up there being

13 interrogated.

14 Q. But Witness DG, weren't you asked about your political allegiances

15 at that time, during the interrogation?

16 A. They mostly asked whether I knew if some of the neighbours had

17 weapons. They mostly asked me about weapons, and they asked me -- they

18 said, "You're working abroad. You had money. Perhaps you were buying

19 things for people." And I said no, and I stand by it.

20 At that time, I was building a house. I had a large family, and I

21 said I had nothing to do with that. I had no interest in any of that.

22 Q. [redacted]?

23 A. Yes, I did work there, yes.

24 Q. The question is, you told -- did you tell the interrogators that

25 you'd worked there?

Page 4621

1 A. Yes.

2 Q. And did they ask you -- putting aside the questions about weapons

3 for a moment, did they ask you about your personal politics?

4 A. No.

5 Q. Did they ask you whether you were loyal to the Serbian army?

6 A. They didn't ask me that up there while they were interrogating me.

7 Q. Well, did you tell them that?

8 A. Well, I didn't say that, and they didn't ask me. I didn't take

9 care about things like that. I don't know.

10 Q. Did they ask you what you'd voted for, who you'd voted for?

11 A. No.

12 Q. In any event, as soon as you'd been interrogated, or on precisely

13 the same day, you were released?

14 A. The same day, yes.

15 Q. Now, you indicated that you didn't know who Dusko Sikirica was;

16 that's correct?

17 A. I didn't, that's right, yes.

18 Q. So it's possible that he was in the camp when you were there and

19 that you just didn't know who he was; that's correct?

20 A. I didn't know, no, nor did I hear his name Sikirica, at least

21 while I was there.

22 MS. BALY: Thank you.

23 JUDGE ROBINSON: Thank you, Ms. Baly. Mr. Greaves?

24 Re-examined by Mr. Greaves:

25 Q. Witness, can you help me about this, please: When you were asked

Page 4622

1 by the authorities to put up a white flag from your home, what did you

2 understand you were indicating by putting such a flag up?

3 A. Well, all of us put up the flag, not only my street, in all of

4 them, we all did that, to show that we were loyal towards that army, I

5 think, and that's the kind of thing that it was about.

6 Q. And look again, please, at the names on the list.

7 MR. GREAVES: I don't think he has the list with him any more.

8 Q. Would you look again at the names, and if you can read it

9 properly, can you tell us, are all those names Muslim names?

10 A. Well, I can't see well enough to read.

11 MR. GREAVES: No doubt the Prosecution will make an admission to

12 that effect.

13 A. I can't read it.

14 MS. BALY: Not without having them checked at this stage.

15 MR. GREAVES: Thank you. I have no further questions. Do Your

16 Honours have any questions for the witness, please?

17 JUDGE ROBINSON: Witness DG, that concludes your testimony and you

18 are released.

19 [The witness withdrew]

20 MS. BALY: May I have the document moved into evidence?


22 MR. PETROVIC: [Interpretation] I apologise, Your Honour, with

23 respect to the request made by the Prosecutor to have this document moved

24 into evidence. I don't object; the only thing that I would like to ask

25 for would be additional information, the first of which is what date this

Page 4623













13 Blank page inserted to ensure pagination corresponds between the French

14 and the English transcripts.












Page 4624

1 document is from - of course, if the Prosecution has that information -

2 and from what source.

3 And the other matter is that the document we admitted as document

4 54, it has several pages, it says page 1 of 5 and 1 of 15. Now, if the

5 Prosecutor has the integral text of this document, could it present an

6 integral document and that document be introduced into evidence, rather

7 than looking at just excerpts from a document which make it inauthentic?

8 So if the document is the integral document, then we could state our

9 opinions as to the document as evidence and its admission into evidence,

10 rather than having just part of the document.

11 JUDGE ROBINSON: Yes, Ms. Baly?

12 MS. BALY: I don't have a date for the document. I can see if I

13 can obtain the full document at some stage. I don't have it with me now.

14 It's only the excerpts that I wish to have moved into evidence.

15 JUDGE MAY: The rest of it's relevant, though, so you ought to

16 produce the whole document, not just a bit of it.

17 MS. BALY: I accept that, Your Honour, and I will endeavour to

18 obtain the entire document.

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

20 I would like to respond to the question of how the document was come by.

21 And I would like to assist the Prosecutor as well, perhaps, in view of the

22 numbers we see in the upper right-hand corner of the document. Quite

23 obviously, it is a document whose integral version probably exists, in

24 view of the fact that the difference between the numbers, the first and

25 last number, is equal to the number of pages that are missing. So we have

Page 4625

1 52741, and then on page 13 is 52753. So we see that 12 pages are missing

2 from that document, from 41 to 53. I assume that those pages exist; at

3 least, that is my assumption. Perhaps I'm wrong. Thank you, Your

4 Honour.

5 JUDGE ROBINSON: We'll postpone the admission of these documents

6 until the additional information is obtained.

7 Mr. Greaves?

8 MR. GREAVES: Your Honour, may we move into private session for my

9 application for witness protection, please.


11 [Private session]

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]


Page 4626













13 page 4626 redacted private session.













Page 4627

1 [redacted]

2 [redacted]

3 [redacted]

4 [redacted]

5 [redacted]

6 [redacted]

7 [redacted]

8 [redacted]

9 [redacted]

10 [redacted]

11 [redacted]

12 [redacted]

13 [Open session]


15 Q. Witness DH, in 1992, where were you living?

16 A. In Prijedor.

17 Q. Did there come a time during the summer of 1992 when you learnt

18 that the person who had been the kum at your wedding was detained at

19 Keraterm?

20 A. Yes.

21 Q. As a result of that, did you take something to Keraterm?

22 A. Yes, I did.

23 Q. What was it that you took to Keraterm?

24 A. Mostly food. Not "mostly," only food, actually. Tins, tin food,

25 and I know that there was some honey. The tins we found in the fridge

Page 4628

1 because there wasn't enough food. At the time when I left, I put it in a

2 plastic bag and took it with me.

3 Q. Can you recall which month in the summer of 1992 it was that you

4 visited Keraterm with this food?

5 A. It was July. I don't remember the exact date. I think it was

6 mid-July.

7 Q. When you went to Keraterm, did you go in a car or on foot or by

8 bicycle, or how did you get there?

9 A. By car.

10 Q. And did you go alone or were you accompanied by other people?

11 A. My wife and two children were in the car with me.

12 Q. And when you got to Keraterm, where did you put your car?

13 A. I parked the car on a byroad before you get to the fence and the

14 entrance to Keraterm.

15 MR. GREAVES: May he look, please, at Exhibit D38/1. It's the

16 bundle of photographs.

17 Q. Would you look at the last photograph in that bundle, please,

18 Witness DH, number 53.

19 MR. GREAVES: Don't put it on the ELMO.

20 Q. Would you --

21 A. Yes.

22 Q. -- look that the photograph, please. Witness DH, is that a

23 photograph that was taken of you on the 16th of June, 2001, just a couple

24 of weeks ago?

25 A. Yes, it is. Yes, that's the photograph, yes.

Page 4629

1 Q. The position in which you are standing in that photograph, is that

2 approximately where you parked your vehicle on the occasion about which

3 you are telling us?

4 A. That's the position roughly where I parked the car, give or take a

5 metre or ten metres. I can't remember exactly but it was round that point

6 there, on the road.

7 Q. Was this the only visit that you paid to Keraterm in 1992?

8 A. Yes, yes.

9 Q. Thank you. I have finished with the photographs for the moment.

10 Witness DH, having arrived at Keraterm with the food, what did you do?

11 A. I [redacted]

12 [redacted]

13 [redacted]

14 [redacted]


16 Q. Witness DH, if you can remember not to deal with the name that

17 you've just mentioned, if you could just say your kum, please? Thank you

18 very much.

19 And having asked for that person, did someone go to fetch him?

20 A. Yes, they did. I don't know whether they went to fetch him or

21 whether they called on the phone, but a connection was established with

22 him and he was told that he had a visitor.

23 Q. And did that person then come to meet you?

24 A. Yes.

25 Q. Did you remain at the weigh hut or did you go somewhere else on

Page 4630

1 the premises of Keraterm in order to meet with that person?

2 A. Several metres inside -- I went inside several metres to meet him

3 as he was coming towards me.

4 Q. And by that, do you mean between the weigh hut and the main

5 building of Keraterm?

6 A. That's right, yes.

7 Q. Would you look at the photographs again, please. Would you look

8 at photograph number 51, please, which is a couple of pages before the

9 last one that you looked at. Is -- again, is that you, Witness DH?

10 A. Yes, it is. That's me.

11 Q. And the position in which you're standing, what does that

12 represent?

13 A. Well, on this photograph, I can't see the weigh hut and the

14 Keraterm building, but I think that's the place we met, the two of us.

15 Q. If you would look at the next photograph, number 52, please.

16 A. Yes.

17 Q. Perhaps you can just confirm that was taken on the 16th of June of

18 this year and that's again a picture of you. Can you see the weigh hut in

19 that photograph?

20 A. I can see it, yes, I see the weigh hut, and the photograph was

21 indeed taken on the date you mentioned.

22 Q. And what can you say about the position in which you're standing

23 in that photograph?

24 A. I didn't understand your question. What do you mean exactly?

25 Could you repeat it, please, and explain what you mean?

Page 4631

1 Q. Are you in the same position as the photograph -- the photograph

2 previous, number 51?

3 A. Well, I can't determine that by looking at it. It wasn't taken

4 from the same angle, so I really can't say.

5 Q. Again, is that -- does that photograph show approximately where

6 you were standing when you met the person we've been discussing?

7 A. Photograph 52, yes.

8 Q. Thank you. You can just close the photographs up for a moment,

9 please. Did you speak with the person we've been discussing?

10 A. Yes, I did.

11 Q. For how long did you speak with him?

12 A. Well, very -- just briefly; five minutes at the longest.

13 Q. Having completed your conversation, what did you then do?

14 A. I handed over the things I'd brought with me, turned around and

15 walked towards the car.

16 Q. And in returning to your car, did you walk at your normal pace?

17 A. Yes, I did.

18 Q. And when you got to your car, what did you do?

19 A. I got into the car, turned it round, and went off. I went to see

20 my father-in-law, my wife's father.

21 MR. GREAVES: Yes. Your Honour, I've got a short piece of video

22 which I wish to show. Since it shows a protected witness, it will have to

23 be done in, I think, closed session, I suspect.

24 JUDGE ROBINSON: Yes, closed session.

25 [Closed session]

Page 4632













13 page 4632 redacted closed session.













Page 4633













13 Blank page inserted to ensure pagination corresponds between the French

14 and the English transcripts.












Page 4634

1 [redacted]

2 [redacted]

3 [redacted]

4 [redacted]

5 [redacted]

6 [redacted]

7 [redacted]

8 [Open session]


10 Q. Witness DH, during the time when you were standing with the man

11 about whom we've been talking about, did you see anybody on the grass

12 which is close to that spot?

13 A. No.

14 Q. In particular, did you see any reserve police officers close to

15 that spot, in particular on the grass?

16 A. No, except for the police officers who were at the gate.

17 Q. Witness DH, did you serve -- do your national service in the JNA?

18 A. Yes, I did.

19 Q. In what branch of the service did you serve?

20 A. Anti-aircraft defence or air defence.

21 Q. As a result of your service in the JNA, are you familiar with the

22 sound of pistols and semi-automatic rifles being discharged?

23 A. Yes.

24 Q. At any time during your visit to Keraterm on the occasion which

25 you have described, did you hear the discharge of either a pistol or

Page 4635

1 semi-automatic weapon or indeed of any firearm of any kind?

2 A. No, I did not.

3 Q. At any time during visit to Keraterm, did you observe any person

4 preparing to ill-treat or shoot any of the detainees?

5 A. No.

6 Q. Is it right that at some stage you used to work at Celpak as an

7 engineer?

8 A. Yes, and I still do. My work document is still at Celpak.

9 Q. During the time that you worked at Celpak, did you ever meet or

10 know Dusko Sikirica?

11 A. No. I neither knew him nor did I meet him.

12 Q. During the time when you were either standing with the person we

13 have been discussing, or at any time during your visit to Keraterm, did

14 you ever hear anybody, a reserve police officer or anybody else, shouting

15 about what would happen to people if they tried to escape? Did you hear

16 anything like that?

17 A. No, I did not.

18 MR. GREAVES: Yes. Would you wait there, please, and answer any

19 questions.

20 JUDGE ROBINSON: Thank you, Mr. Greaves. Any cross-examination,

21 Mr. Petrovic?

22 MR. PETROVIC: [Interpretation] No, Your Honour.

23 JUDGE ROBINSON: Any questions, Sir Lawrence?



Page 4636

1 Cross-examined by Ms. Baly:

2 Q. How many police officers were there at this gate?

3 A. At the gate? I don't remember. Five or six. I wouldn't be able

4 to tell you the exact number.

5 Q. And there were numerous other persons at the camp, being detainees

6 and guards, weren't there?

7 A. At that moment, I did not see any detainees. There may have been

8 some in front of the door, but I did not pay any attention to them.

9 Q. And after your meeting with your kum, you turned your back toward

10 him and you walked away and then left the camp, correct?

11 A. Yes, yes.

12 Q. You have no idea what your kum did behind your back, do you?

13 A. No.

14 Q. And indeed, you have no idea what went on in the camp behind your

15 back and after you left, do you?

16 A. No.

17 Q. Thank you.

18 JUDGE ROBINSON: Thank you, Ms. Baly.

19 Any re-examination?

20 MR. GREAVES: No, I don't think I can get anything out of

21 something as short as that. Your Honours have no questions of the

22 witness?

23 JUDGE ROBINSON: Witness DH, that concludes your testimony and you

24 are released.

25 MR. GREAVES: May the video become an exhibit, please.

Page 4637


2 THE REGISTRAR: Exhibit D39/1.

3 [The witness withdrew]

4 MR. GREAVES: May we go into closed session -- private session so

5 I can make an application in respect of the next witness, please, who is

6 at 9263.


8 [Private session]

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]


Page 4638

1 [redacted]

2 [redacted]

3 [redacted]

4 [redacted]

5 [redacted]

6 [redacted]

7 [redacted]

8 [redacted]

9 [redacted]

10 [redacted]

11 [redacted]

12 [redacted]

13 [Open session]


15 Q. Witness DI, is it right that you were arrested on the 26th of May

16 1992 and taken to Omarska, where you were detained until the 5th of August

17 1992?

18 A. Yes.

19 Q. During that time, did you spend some of your period of

20 incarceration in what was known as the "white house"?

21 A. Yes, the latter part of my detention.

22 Q. And at some time during that period -- well, sorry, I'll go back a

23 bit. Do you know or did you know somebody by the name of Bajazit

24 Jakupovic?

25 A. Yes, I did.

Page 4639

1 Q. Was he someone who had a nickname, and if so, what was it?

2 A. At first, while we were still young, we called him Beljo, and

3 later on, after he finished his pilot training, we called him Pilot.

4 Q. And was he a military or a civilian pilot?

5 A. I think he was a military pilot. He did his training in Serbia.

6 Q. Did there come a time during your period in the "white house" when

7 you saw Bajazit Jakupovic?

8 A. Yes, he came to my room.

9 Q. Can you say approximately when it was that you saw him?

10 A. That was in early July. I think maybe before the 15th of July.

11 Q. And when Bajazit Jakupovic was brought to the "white house," in

12 what condition was he at that time?

13 A. He was beaten up. This is sometime towards the evening.

14 Q. And as far as his mental state was concerned, was he

15 well-adjusted, or was he disorientated, or how would you describe him?

16 A. I think he had some kind of a condition, which is why he was

17 retired, and when he came to our room, he went out on several occasions

18 and he ended up in the hole anyway.

19 Q. Did the fact of his going out of the building, did that cause any

20 problems between him and the guards?

21 A. Yes, that is correct. They beat him up in a room two or three

22 times. But he wouldn't sit down among us. He would go out to the

23 hallway. Our door, the door to our room, did not have a lock, so you

24 could open it, so he would go out.

25 Q. And Witness DI, what eventually happened to Bajazit Jakupovic?

Page 4640

1 A. They kicked him in the -- in the hallway, and that's where he

2 remained lying for half an hour or more. Then the guys from our room

3 carried him out. To me, he didn't look like he was showing any signs of

4 life, and that's how it was. He was in the hallway near the door, and the

5 door was open, so we could see him.

6 Q. And did you later hear what had happened to him, whether he was

7 alive or not?

8 A. Later, we heard nothing more about him.

9 Q. Was his body moved from the building?

10 A. Yes. The guys, two guys, took him out.

11 Q. And at the time when he was taken out again, was he showing signs

12 of life, or did he appear to be dead?

13 A. As I said, he came in a police van, he was beaten up several

14 times, and he didn't sit down among us, and then he would leave, then they

15 would bring him back to the room, and then he would all again leave. And

16 I think on the third time around, they beat him up again, there were

17 several guards there, the soldiers, and he remained lying there for, I'd

18 say, over half an hour on the tile floor in the "white house."

19 Q. And Witness DI, have you ever heard of Bajazit Jakupovic again?

20 A. No, I did not.

21 Q. Would you wait there, please, Witness DI.

22 MR. GREAVES: I'm sorry, I won't -- just give me a minute.

23 [Defence counsel confer]

24 MR. GREAVES: Yes.

25 Q. Witness DI, do you know where Bajazit Jakupovic had come from that

Page 4641

1 day?

2 A. At that time, I did not know exactly.

3 Q. Did you subsequently learn where he had come from?

4 A. Later we learned because there were new arrivals every day.

5 Q. And where was it that you learned he had come from?

6 A. When somebody would come from outside, people would comment

7 always, and the comment was that he was in Keraterm, that he had come from

8 Keraterm. There were other Jakupovics there. There was Kemal Jakupovic.

9 He was right there with me while we were there.

10 Q. How was he dressed when he came to Omarska?

11 A. He had cut off blue jean shorts and a multi-colour T-shirt, short

12 sleeved.

13 Q. Yes. Thank you, would you wait there, please.

14 JUDGE ROBINSON: Cross-examination? No. Sir Ivan? No.

15 Mr. Ryneveld.

16 MR. RYNEVELD: Thank you, Your Honour

17 Cross-examined by Mr. Ryneveld:

18 Q. Very briefly, sir. It's safe to say that when this friend of

19 yours arrived, he was a new arrival to Omarska; is that correct?

20 A. Yes.

21 Q. And the first day that he came into your room, did he arrive in a

22 beaten-up condition? Was he already suffering injuries?

23 A. Yes, he was. Yes, he did.

24 Q. And subsequent to that, he suffered further injuries on an almost

25 daily basis until he died. Is that what I understand your evidence to be?

Page 4642

1 A. No, it wasn't like that. It went on for about half an hour. He

2 came to our room, and then he would go out on his own. The door did not

3 have a lock. Then in the hallway he would be beaten up, and then he would

4 be brought back and then again he would leave. And the second or the

5 third time, they finished him off, as we would say. And he lay there for

6 half an hour, maybe longer. We saw him because the door was open.

7 Q. Thank you for clarifying that. So I understand there were a

8 series of beatings, but all of those occurred on the same day of his

9 arrival, correct?

10 A. I think that it did not all last for more than half an hour on

11 that day.

12 Q. So just so that I'm clear about the time frame that you've been

13 discussing, would he have arrived and died on the same day?

14 A. The same day, within one hour.

15 Q. Thank you. A couple of other questions, sir. Were you ever at

16 Keraterm between May and August 1992?

17 A. No. I was at Omarska and then subsequently at Manjaca.

18 Q. So you wouldn't have any knowledge as to what occurred at

19 Keraterm?

20 A. I wasn't there.

21 Q. So you don't know if people were -- there were other pilots at

22 Keraterm?

23 A. There were several pilots who had come, and they were in the

24 "white house." There was a Samir and his group, but that was earlier. I

25 had -- I knew Samir. He -- I think he was one or two years younger, and

Page 4643













13 Blank page inserted to ensure pagination corresponds between the French

14 and the English transcripts.












Page 4644

1 we went to school together.

2 Q. I believe you're answering about several pilots being at Omarska.

3 Do you know whether there were any pilots at Keraterm, or do you have any

4 way of knowing?

5 A. I don't know because I was not there.

6 Q. Right. And you wouldn't know if there were people who were

7 disoriented and wandering around, would you, at Keraterm?

8 A. There was Keraterm, it was a camp. There were people there, but I

9 cannot say anything about it because I wasn't there. But there were

10 people from Keraterm who came to Omarska who were at the "white house."

11 Q. And my final question, sir: You wouldn't know if people were shot

12 at Keraterm, would you?

13 A. I cannot say that because I didn't see it.

14 MR. RYNEVELD: Those are my questions, thank you.

15 MR. GREAVES: No re-examination. Do Your Honours have any

16 questions for Witness DI?

17 JUDGE ROBINSON: Witness DI, that concludes your testimony and you

18 are released.

19 [The witness withdrew]

20 MR. GREAVES: Your Honour, that brings me to the natural break I

21 advertised to you this morning.

22 JUDGE ROBINSON: Yes, it does.

23 [Trial Chamber confers]

24 JUDGE ROBINSON: Yes, we'll adjourn, then, until Wednesday morning

25 at 9.30.

Page 4645

1 --- Whereupon the hearing adjourned at 3.07 p.m., to

2 be reconvened on Wednesday, the 4th day of July,

3 2001, at 9.30 a.m.