1 Friday, 7 February 2003

3 [The witness entered]

4 --- Upon commencing at 9.03 a.m.

5 PRESIDING OFFICER: Good morning, Mr. Lazic. Could you please

6 stand and take the solemn declaration.

7 WITNESS: DJOKO LAZIC

8 [Witness answered through interpreter]

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

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

11 PRESIDING OFFICER: Defence for Mr. Tadic.

12 Examined by Mr. Krgovic:

13 Q. [Interpretation] Good morning, sir. Please tell us your name.

14 A. My first name is Djoko.

15 Q. What about your last name?

16 A. It's Lazic.

17 Q. When were you born, sir?

18 A. I was born on the 3rd of April, 1955.

19 Q. Where were you born, sir?

20 A. I was born in the village of Tutnjevac, municipality of Ugljevik,

21 Bosnia and Herzegovina.

22 Q. Mr. Lazic, please tell us: What schooling do you have?

23 A. I've completed secondary religious school in the monastery in

24 1975, and then I graduated from the faculty of theology in 1982, in

25 Belgrade.

1 Q. Father, please tell us: Are you married?

2 A. Yes, I'm married, and I believe myself to be happily married, and

3 I have three children.

4 Q. Did you serve your military service?

5 A. I completed my military service in 1981 in Pristina.

6 Q. Tell us about your work. Where are you employed?

7 A. The first employment was in Tuzla, and starting on the 4th

8 November of 1985, I've been working in Milosevac in Modrica municipality.

9 Q. How far is Milosevac from Samac?

10 A. Milosevac is a village in Posavina, somewhere halfway between

11 Modrica and Samac, so eight kilometres to Samac and eight kilometres to

12 Modrica.

13 Q. Please tell us: Prior to April 1992, what area did your parish

14 cover?

15 A. My parish covered two villages: Kruskovo Polje, which belonged to

16 Samac municipality; and village of Milosevac, which belonged to Modrica

17 municipality.

18 Q. As I understood it, you are residing in the village of Milosevac.

19 A. Yes. I've been residing there since 1985.

20 Q. Father, please tell us: Do you know Miroslav Tadic?

21 A. Upon my arrival from Tuzla to work in Milosevac as a priest, one

22 of the first people I met in Samac -- in the very early days of my arrival

23 to that parish, I felt great attachment to Samac, and one of the first

24 people I met there was Mr. Miroslav Tadic.

25 Q. Father, please tell us: Immediately prior to April of 1992, and

1 throughout 1991, did you frequent Cafe AS?

2 A. I have to say that two establishments that I used to frequent in

3 Samac were Cafe AS and a seafood restaurant whose owner was a Muslim, a

4 Bosniak, named Hamid. And the reason I went to Cafe AS was that it has

5 been recommended to me by my neighbour. Mr. Miroslav Tadic was a teacher

6 and was a renowned intellectual in the area, and he was quite popular with

7 his students. All of the students, to this day, speak very favourably

8 about him. And this neighbour of mine was also his student, and he

9 recommended that I go there. I always felt very comfortable there and I

10 frequent that place even nowadays.

11 Q. Please tell me how frequently, prior to the conflict, you went to

12 Cafe AS.

13 A. At least twice a week, on a Wednesday and on a Saturday, because

14 there was a green market held on Wednesday and we used to gather there.

15 We had a company of people that gathered there. And then there were some

16 weeks when I would go there several times a week.

17 Q. Father, please tell me: What was the ethnic composition of

18 patrons of the Cafe AS at the time when you used to go there?

19 A. With your permission, let me just say something else. Before me,

20 another priest worked in Samac. His name is Djoko as well. He's a

21 relative of mine and he's in Belgrade now. And when I came to Samac, some

22 people confused me with the other priest Djoko. And when I came there, I

23 said that I was a different Father Djoko. People accepted me, welcomed

24 me, in that area. There were Serbs and Croats and Muslims there, and they

25 said that I needed to continue the tradition of the previous priest, my

1 relative, who was very friendly with them, and that I needed to continue

2 socialising with them, which I did. And there were many young people in

3 that company, and there were many Serbs and Muslims and Croats among them.

4 Q. Sir, please tell us: Prior to April 1992, were there any premises

5 in Cafe AS which were not accessible to all patrons? Or rather, can you

6 tell us: How many rooms with the Cafe AS have?

7 A. I know this for a fact, that there were never any rooms which were

8 off limits. There was a total of two rooms. One was for the pool. I

9 personally don't shoot pool, but I used to cheer people playing there. So

10 there were two rooms. One was for the pool, and the other room was where

11 they played cards, various card games and so on. And never once did it

12 occur to anyone to put any of the rooms off limits to anybody. Everybody

13 could go into any of the two rooms whenever they wanted.

14 Q. Please tell us, sir: What was the atmosphere like in the Cafe AS

15 while you went there? Were there any incidents?

16 A. I can assure you that while I was present there, there were no

17 incidents whatsoever. People were just joking while shooting pool,

18 playing cards. We joked. It was a very friendly atmosphere. People

19 enjoyed being together, laughed together, and so on.

20 Q. Sir, please tell us whether you heard, prior to April 1992, about

21 the existence of the 4th Detachment.

22 A. No, I did not.

23 Q. What about the time after April 1992? Have you heard of its

24 existence after that?

25 A. Later on, I heard from some of my friends from Milosevac that

1 there had been such a detachment, the 4th Detachment, which had a mixed

2 ethnic composition.

3 Q. Please tell us: Do you know where the headquarters of the 4th

4 Detachment was?

5 A. I don't know.

6 Q. Please tell us: While you went to Cafe AS prior to April 1992,

7 did you see any military meetings being held at the Cafe AS?

8 A. No. As a priest, I can assure you - and I claim this with full

9 certainty - that at least while I was there, there were no political or

10 military meetings held there. There were no uniformed people -- members

11 of units in uniform assembling there. People simply had a good time

12 shooting pool, drinking, joking, and so on.

13 Q. Please tell us: During the night between the 16th and 17th of

14 April, did you meet or did you perhaps hear of any members of the special

15 units from Serbia wearing camouflage uniforms?

16 A. After the conflict broke out, I heard about that, and I later even

17 had an occasion to meet the late Lugar. But prior to that, I have never

18 seen them, nor did I know that they existed.

19 Q. After the 17th of April, some of the people that you later learned

20 were members of special units, did you see them ever at the Cafe AS?

21 A. No. I claim with full certainty that I would have known of those

22 people had they frequented Cafe AS. All of the people that I met at the

23 Cafe AS were the people familiar to me.

24 Q. Can you tell me whether a certain Hasan Ibralic used to come to

25 Cafe AS?

1 A. I don't know that man. I didn't used to see him at the Cafe AS.

2 And since I didn't work at the state-owned companies, nor did I go there,

3 I don't know the man. I don't know what his job was. I just don't know

4 him.

5 Q. Did you perhaps ever see Enes and Nijaz Alatovic?

6 A. No. I never saw them at the Cafe AS. I don't even know those

7 people.

8 Q. Did you perhaps see Mehmed Vukovic there?

9 A. No. I don't know him either.

10 Q. Do you know that Mr. Miroslav Tadic was a kum at the church in

11 Dubica prior to the breakout of conflict in Samac municipality?

12 A. Yes, I'm aware of that. I was present, together with the priest

13 Bogdan Tolic from Modrica, and I collected donations when Patriarch Pavle

14 blessed that church. And after the completion of the church service, I

15 congratulated him, and I was very pleased to see him, as a friend of mine,

16 at the church.

17 Q. Can you explain to us: What does it mean to be a kum of the

18 church?

19 A. That means that he, by donating a certain amount of money, becomes

20 a kum to the church, or rather, a patron of the church, and thereby he has

21 a duty to bring a special religious cake and to bring a candle to the

22 church, in order to celebrate the patron saint of that church.

23 Q. So this is some kind of a distinction, isn't it?

24 A. Yes. That's a very special distinction that he held. Our people

25 usually say that sacred are the people who are kums to the church.

1 Q. So you are telling us that when that church was sanctified,

2 Patriarch Pavle was there as well?

3 A. Yes, that's right. He attended that ceremony as well. All of us

4 had our duties during that ceremony, and I, together with the priest from

5 Modrica, collected donations and a very solemn church service was held

6 during that time.

7 Q. Thank you, Father. I have no further questions.

8 PRESIDING OFFICER: Thank you.

9 Cross-examination.

10 Cross-examined by Mr. Di Fazio:

11 Q. Mr. Lazic, my name is Di Fazio. I've got just a few questions for

12 you.

13 How long had you been living in Bosanski Samac, or in the area, I

14 should say, prior to April of 1992?

15 A. I've just said a minute ago that I came to the Posavina region

16 from Tuzla on the 4th of November, 1985.

17 Q. And from that time, had you been frequenting Cafe AS?

18 A. Yes, as early as 1986. I have said that, owing to my neighbour,

19 who was a student of Miroslav Tadic, I had the pleasure to meet him, and

20 he's an intellectual, a good Christian. And because of that, I went to

21 his cafe. I also went to this other restaurant, which was a seafood

22 restaurant, and it's very good seafood, and I used to go to that place,

23 especially during Lent time.

24 Q. Thank you. And you kept abreast of events in Bosanski Samac,

25 particularly in early 1992, trying to keep yourself informed of what was

1 going on in the community?

2 A. No. I was not informed, either about the political or any other

3 situations. I simply went to Samac as a guest, in order to play cards and

4 have a drink with my friends, hear a joke, laugh a little bit. And then

5 following that, I would return to my parish in Milosevac.

6 Q. Right. So your sole connection with Bosanski Samac was to go

7 along to Cafe AS and entertain yourself there?

8 A. Yes.

9 Q. And in all the time that you were doing that, your evidence is

10 that you never heard of and you never saw any members of any organisation

11 called the 4th Detachment?

12 A. No. I claim this with full responsibility, that as far as the

13 military organisations are concerned, I heard, neither in Modrica or in

14 Samac, where the headquarters were, I didn't hear anything about how it

15 was organised. I am a priest. I had a lot of work. And when I had some

16 free time, I would go and spend some time with my friends, have a drink,

17 and that would be it.

18 Q. Thank you. Did you continue to frequent Cafe AS after the 16th

19 and 17th of April, 1992?

20 A. It so happened that I was, on the 16th of April, at the AS cafe.

21 I had my coffee, and then following that, I went to the seafood

22 restaurant, because it was Lent time and people were fasting. Upon the

23 breakout of the conflict, I had to attend a funeral, on the 17th, and on

24 the 16th, in the afternoon, I had a traffic accident. And my car remained

25 in Samac, with Tomo Zarak. I didn't know about this. And then on the

1 17th, people woke me up because there was a funeral in Milosevac. The

2 late Milija [phoen] Tomic had died and I had to attend and hold a service

3 at the funeral. And then there I heard that there had been a conflict in

4 Samac.

5 Q. Thank you. I was actually concerned with more the weeks and

6 months after the 16th of April, 1992. In the weeks and months after that

7 period of time, did you still go to Cafe AS from time to time?

8 A. Immediately after the 16th of April, the cafes were not open.

9 They were not operating, because there had been an order, both in Modrica

10 and in my village, Milosevac, and in Samac, and therefore, cafes and

11 restaurants did not work. And it wasn't until later that I went there

12 from time to time, because there was shelling and it was quite dangerous.

13 But I still went there, and I do so nowadays as well.

14 Q. Thank you. What period of time was it that you started going

15 there again?

16 A. Well, in 1992, in the autumn -- or rather, starting in May, when

17 the cafe -- from May, the cafe would be open from time to time, and I used

18 to go occasionally, but not as often as I did before the breakout of the

19 conflict.

20 Q. Fine. Of course. And in those troubled times, was it still

21 possible to get a drink at the Cafe AS, post-April 1992?

22 A. Yes, it was possible. One could get a drink at a cafe.

23 Q. So you're not aware of any order prohibiting the sale of alcohol

24 or consumption of alcohol in the municipality of Bosanski Samac after

25 April of 1992?

1 A. You said a drink, and I consider juice to be a drink as well, at

2 least in my language. I am a teetotaller. I don't drink.

3 Q. You may not. What about others?

4 A. I socialised mostly with people who drink exclusively juices or

5 colas.

6 Q. Okay.

7 A. I beg your pardon, but the favourite drink of some of my friends

8 was the homemade plum brandy, slivovitz, so I saw two of my friends

9 drinking that.

10 Q. Okay. Thank you. And in the period of time after the 16th and

11 17th of April, on these occasions when you started to go back to Cafe AS

12 from time to time, did you then become aware of the existence of the 4th

13 Detachment?

14 A. I heard later that the 4th Detachment -- and I learned of it after

15 the end of April.

16 Q. Thank you.

17 MR. DI FAZIO: I've got no further questions.

18 PRESIDING OFFICER: Thank you.

19 Any re-examination?

20 Re-examined by Mr. Krgovic:

21 Q. [Interpretation] I just wish to ask you something in connection

22 with what the Prosecutor asked you. When you spoke about your visit to

23 the Cafe AS after the 16th and 17th of April, if I understood you well,

24 you said that you used to go there after -- or rather, in the fall, in the

25 autumn, but then you also mentioned the month of May. So can you just

1 please be more specific and clarify: When did you actually start going to

2 Cafe AS again, and when was the prohibition in force?

3 A. I was not clear, perhaps. I said that on the 16th, in the

4 afternoon, I had a traffic accident with my car, a Lada, and I left my car

5 in Samac. And then after five days I regained my car, or I went to get my

6 car, and the first stop in Samac was Cafe AS. And I asked Mr. Tadic to

7 show me where the auto mechanic shop was, because this is where my car had

8 been. So after the 16th of April, I went to Cafe AS, not frequently, but

9 I still went to that place. Even though the cafe itself was closed, it

10 wasn't working. There was a spot or a platform in front of it where

11 one -- where people gathered. So the cafe itself wasn't, strictly

12 speaking, working, but I would go to the spot in front of the cafe and see

13 people there and have a drink there.

14 Q. So during that period of time -- May, June, April - Cafe AS, in

15 fact, wasn't working?

16 A. No, it wasn't working at the time, because there had been an order

17 issued to that effect. But I still went there to see my friends.

18 Q. And the people that you mentioned, did you see them in autumn,

19 after Cafe AS started working again, or was it at a different time?

20 A. What do you mean? Other people, my friends?

21 Q. Well, you mentioned some friends and you spoke about two of your

22 friends who liked plum brandy. When did you start seeing them again? Was

23 it in the fall, on that fall of 1992?

24 A. Yes, that's correct, in the fall of 1992.

25 Q. I have no further questions.

1 PRESIDING OFFICER: Thank you, Mr. Lazic, for coming today. Your

2 deposition is concluded. You may go now.

3 THE WITNESS: [Interpretation] Thank you.

4 [The witness withdrew]

5 PRESIDING OFFICER: Ten minutes' break.

6 --- Break taken at 9.28 a.m.

7 --- Upon resuming at 9.43 a.m.

8 [The witness entered]

9 WITNESS: LJUBOMIR CORDASEVIC

10 [Witness answered through interpreter]

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

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

13 PRESIDING OFFICER: Mr. Vukovic.

14 MR. VUKOVIC: [Interpretation] Thank you.

15 Examined by Mr. Vukovic:

16 Q. [Interpretation] Good morning, Mr. Cordasevic. Will you please

17 tell us your full name, first and last.

18 A. My name is Ljubo Cordasevic, born on the 12th of May, 1946, Velika

19 Obarska [phoen], near Bijeljina.

20 Q. Tell me: Where are you living now?

21 A. I'm living in Samac now.

22 Q. Are you married?

23 A. Yes, I'm happily married and the father of two daughters.

24 Q. Tell me, please: What is your ethnicity?

25 A. I'm a Serb.

1 Q. For how long have your ancestors been living in the territory of

2 Samac?

3 A. I'm in Samac since 1986, and before that, within the territory of

4 Samac municipality, since the 1960s.

5 Q. Yes, but I meant your parents, your grandparents.

6 A. I was born in Bijeljina, and that is where I was educated. I got

7 married in 1967, and since then my whole family has been living in the

8 territory of Samac municipality.

9 Q. Mr. Cordasevic, you completed your secondary education in

10 Bijeljina, and higher school for teachers' training in Tuzla, and the

11 faculty of philosophy, in 1982, in Sarajevo; is that right?

12 A. Yes.

13 Q. And your occupation is teacher of psychology and pedagogy?

14 A. Yes.

15 Q. After 1967, you worked as a teacher in the village of Gornja

16 Slatina, and after 1986, you started working in the centre for social

17 welfare in Samac, and as a psychologist, pedagogist?

18 A. Yes.

19 Q. Also, in the period after 1980, you worked as a part-time

20 correspond for the newspaper Sport and for other newspapers, such as

21 Oslobodjenje, Sportske Novosti, and others?

22 A. Yes.

23 Q. Tell me: Were you a member of any party?

24 A. I was a member of the League of Communists of Yugoslavia.

25 Q. Until when?

1 A. Until the beginning of the armed conflict, which means about 1991,

2 up to 1991.

3 Q. And after that?

4 A. After that, after the beginning of the armed conflict, I was a

5 member of the Serbian Democratic Party.

6 Q. Do you have a position now in that party?

7 A. Just now, not a very significant one. I'm a member of the

8 municipal board of the Serbian Democratic Party of Samac municipality.

9 Q. Would you be kind enough and tell us whether you have any position

10 in the field of sports.

11 A. Just now, I'm a member of the highest-level bodies of the football

12 association of Bosnia-Herzegovina and Republika Srpska.

13 Q. Mr. Cordasevic, you served in the Yugoslav People's Army in 1971,

14 in Nasice, that is right, and you completed your military service in Banja

15 Luka?

16 A. That's right.

17 Q. Mr. Cordasevic, there's no dispute that at the end of 1991 and the

18 beginning of 1992, there was a heightening of tension in Samac

19 municipality between members of different ethnic groups. Tell us,

20 please: What is your understanding of that situation? What is your

21 knowledge as to how this occurred and what you experienced yourself?

22 A. In very brief terms: Being of the profession that I am, that is,

23 a pedagogue and a psychologist, it was not difficult to conclude that

24 people in town were not socialising and conversing in the way they used to

25 before. Secondly, I think that these tensions, in my view, were increased

1 and climaxed after the beginning of the war in neighbouring Croatia. And

2 after the multiparty elections, and in the process of the formation of

3 parties, contributed to this atmosphere, and one could conclude from all

4 this that something would soon be happening in the area.

5 Q. I assume that, as a social worker, you moved around all the places

6 within the territory of Samac. Immediately prior to the outbreak of

7 conflict, did you see patrols in villages held by people of different

8 ethnicities, depending on the population of the village?

9 A. My job was such that I was busy day and night, so I spent a lot of

10 time visiting families to provide care and social welfare. And true that

11 as I moved around, I came across unknown persons, particularly passing

12 through certain villages, such as Hrasnica, Grebnice.

13 I remember well, one night as I was travelling, I was stopped.

14 They asked for my documents. People were not in uniform. They were

15 civilians. I was not mistreated; I was just checked out - that is, my

16 identity was checked out - and the reason that I had no problems is

17 certainly the fact that I was very well known in the area.

18 Q. Let us now move on to a different topic.

19 Tell us, please: Where were you in the night between the 16th and

20 17th of April, 1992?

21 A. In that, let us call it, critical night, I was in my own apartment

22 in Samac.

23 Q. Thank you.

24 A. I was in my apartment in Samac, and without expecting anything

25 special to happen. I wasn't informed that anything was in the offing, and

1 I stayed in the apartment for four or five days, without anyone calling me

2 or disturbing me, and this applies to all the other inhabitants in the

3 town of Samac. I noticed that something was going on, that something was

4 changing, nevertheless.

5 Q. But did you hear shooting that night, that something was actually

6 happening?

7 A. Could you repeat your question? I didn't hear you too well, I'm

8 afraid.

9 Q. What did you hear during the night between the 16th and the 17th?

10 Did you hear arms fire or something like that?

11 A. Around 4.00 or 5.00, I did hear some shooting, and this was a sign

12 that something unusual was happening.

13 Q. Could you please put your headphones on your ears, because in that

14 case you will hear us better. Like that, yes. Thank you. Thank you.

15 So please explain what happened. You spent a couple of days in

16 your apartment, and then what happened?

17 A. Four or five days later, from the editor of the then radio

18 station, Vaso Antic, I was informed by telephone that I needed to go to

19 the radio station to act as a journalist, as a person who would keep the

20 population informed, because I already had some experience as a stringer,

21 especially specialising in sports reporting. So when I was called in, of

22 course I responded, and from that day on, for the following year and a

23 half, I worked as a reporter in the Samac radio station.

24 Q. And that was your work obligation, was it not?

25 A. Yes, it was.

1 Q. And you received a decision to that effect from the local defence

2 ministry department, that that was your work obligation?

3 A. Yes. Shortly after that, I received a decision that that was my

4 work obligation, and like everyone else, I accepted it.

5 Q. And when you went to the Radio Samac premises, what did you find

6 there? What was the situation like? Who was there present? And what

7 were you told regarding your future tasks under your work obligation duty?

8 A. Just as anyone else starting work somewhere, I was familiarised

9 with the conditions of work. I found the editor, Vaso Antic, there; the

10 sound engineer, or radio technician, whose name was Pasaga Tihic, who had

11 also come there under the work obligation. In the studio there was the

12 announcer, a lady - I don't remember her name now - and the other workers

13 who were employed there. And then I was told by the editor what my tasks

14 would be, and they were as follows --

15 Q. Could you please slow down a little for the interpreters.

16 A. I was told that my tasks would be to inform the entire population

17 about civilian life, to give them information that affected all civilians

18 in the area; that I would also be going into the field, that I would be a

19 reporter from the field; that I would truly and frankly keep the citizens

20 of Samac and the surrounding villages informed regarding many matters of

21 vital importance, and what was meant was distribution of food,

22 distribution of humanitarian aid, the cases when there would be

23 electricity cuts and water supply cuts and other matters of interest to

24 the citizens; also other crucial issues in those days, and that was,

25 despite the difficult conditions, the need to organise the education of

1 children, vaccination of children; then also that I would have to go to

2 various institutions, such as the health centre, the hospital. In other

3 words, that I would simply inform the listeners of all matters of interest

4 to the population on which their life depended. And these were the broad

5 lines, but generally, it meant keeping them informed so that the

6 population would feel well informed and protected and be able to continue

7 living as best they could.

8 Q. Tell me, please: Did you also carry reports about developments on

9 the front and the needs of the army?

10 A. Yes. Yes. In addition to the other duties I had was this one, to

11 report from the front, because the relatives of the people in the military

12 had a keen interest as to where they were, how they were doing, and so on.

13 Q. I see. So you were a reporter. You mostly worked in the field,

14 collecting information from the whole of the Samac municipality, what the

15 needs of the population were, what could be done, what was the situation

16 on the battlefield. Then you brought those reports to the offices and

17 these were broadcast?

18 A. Yes, that was my job. In those days, every inhabitant living in

19 the territory of Samac municipality, be it in town or in the rural areas,

20 couldn't wait to hear my voice with reports from the field, and the

21 territory I covered was very large. Maybe I won't be exaggerating. But

22 it covered an area of some 120 and 130 kilometres. It was a border region

23 towards the neighbouring municipalities of Gradacac, Orasje, and Odzak, on

24 the other side. Because Samac municipality had a quite specific

25 geographic position.

1 Q. Will you please explain: What were people complaining of most?

2 What kind of information did they give you when you interviewed them?

3 A. It was the kind of information that I would have given them if

4 they had asked me, and that is the following: They were condemning

5 everything that was going on at the time, because for many people this had

6 caught them by surprise. Also, the difficulties that the people, the

7 locals, the citizens, whatever you like to call them, were confronting,

8 and there was a wide spectrum of difficulties that the people had to

9 contend with, very difficult conditions of life. And of course, there was

10 always a ray of hope that all this would blow over soon, and everyone said

11 that they couldn't wait for it all to be over for them to go back to their

12 normal life.

13 Q. Was that the kind of information you received from members of all

14 nationalities?

15 A. What kind of a journalist would I be if I were to provide

16 information to one group and not to others? The information was addressed

17 to all the population in town and in the villages and local communes of

18 Samac municipality, and wherever, in fact, Radio Samac could be heard. So

19 whatever I did, whatever I said, I did for the benefit of the entire

20 population living there at the time.

21 Q. You said that you frequently visited the front lines, that you

22 were in contact with the troops. Of what ethnicity were the army members?

23 A. I was in direct contact with all of them, so I'm well informed

24 about that. Understandably, the largest group were Serbs, but there were

25 also soldiers of other nationalities or ethnicities, both Muslims and

1 Croats. I do not have the numbers, but I'm quite sure and I can claim

2 that there were men of all ethnic groups who wanted to be where they were.

3 Q. Mr. Cordasevic, tell us: Did you, during those first days, see

4 anyone wearing white armbands, be they soldiers or civilians?

5 A. Yes, I did. This was at the very beginning. The first few days,

6 these bands were worn - or ribbons - on the shoulder. These ribbons were

7 worn by members of the army, that is, men in uniform. They were worn also

8 by a certain number of civilians. I was one of them who had this ribbon

9 on either one or other shoulder, depending on what the army determined.

10 We wore these ribbons - and I am quite sure of that, because that is the

11 reason why I wore it - so that people could tell that I belonged to the

12 area, that I wasn't some outside element. Very briefly, it was a sign of

13 identification.

14 Q. Since the situation was difficult - the town was shelled

15 frequently, there was a shortage of electricity and water - how did the

16 population find food? Where did you have your meals?

17 A. The greatest difficulties were, in fact, in the field of food,

18 because that is one of the essential needs. The people did as best they

19 could, but most of them fared like I did. There was a public canteen in

20 the premises of Tekstilac plant. It was a public canteen where the troops

21 were fed, as well as the civilian population. I went there too, and many

22 of us ate there, and it was most welcome in those days. Whoever needed

23 food would come to the canteen, so (canteen. )

24 Q. So this means members of Croatian and Muslim ethnicity as well?

25 A. Yes, of course.

1 Q. And in view of this very difficult situation with electricity,

2 water, shelling, how did Radio Samac manage under those conditions?

3 A. It is not difficult to assume how it managed. In such

4 circumstances, because of the aggravated situation, it was normal to

5 expect that there were frequent interruptions in the airing of

6 programmes. But we didn't just sit and wait, but we went on with our

7 work, waiting for more favourable conditions. And these interruptions in

8 broadcasts occurred primarily because of electricity cuts, then also

9 because of certain other changes in the location of the radio. Then also,

10 one must admit, the equipment was outdated, so there would be frequent

11 failures, and sometimes, if we could get hold of a generator, they were

12 not powerful enough. So that, in view of all these things, according to

13 my assessment, I think that we were more off the air than on the air, and

14 we were even criticised by the population for them not being able to hear

15 us.

16 Q. Will you please tell us whether there was a report aired on Radio

17 Samac that Muslims and Croats had to wear white ribbons.

18 A. You mean by the radio, on the radio. No. No. I never heard any

19 such announcement. I never made such an announcement, nor did I ever hear

20 about it, nor did I write such an announcement.

21 Q. And was there a report announced on prohibiting more than three

22 Muslims or Croats forming a group?

23 A. No. No such item was broadcast by the radio station in which I

24 worked.

25 Q. And was any kind of report broadcast, or an order, for Muslims and

1 Croats, any kind of order that would be discriminatory in relation to the

2 population?

3 A. No, no such report was ever aired. We continued living together

4 in Samac, all of us, those of us who wanted to stay on. We would meet and

5 sit together and walk around together. So who would ever think of

6 announcing any such thing?

7 Q. In the period while you were a reporter working for Radio Samac in

8 1992 and 1993, did you receive any remuneration for your work?

9 A. I shared the fate of all others that had work obligation, which

10 meant that I was happy to have the essentials I needed, that is, food.

11 And under those difficult conditions, I did have some remuneration, which,

12 true enough, was symbolic because of the devaluation of the currency in

13 those days. I can't remember the exact amount - the value of the currency

14 changed - but the amounts were minimal and very modest, but they were

15 welcome. So I did receive remuneration.

16 Q. Sir, tell us, please: In that period of time, who determined the

17 editorial policies of the radio? And also, tell us at the same time who

18 financed the work of Radio Samac.

19 A. I've already said that I was a reporter working in the field. The

20 programme structure is normally up to the editor of the radio, and I was

21 involved in implementing that programme schedule. As for the financing,

22 since we belonged to the Secretariat for Social Affairs of the Municipal

23 Assembly, then naturally, the finances came from them, in simplest terms.

24 Q. The Secretariat for Social Affairs, was it under the Executive

25 Council, that is, the government, or the Municipal Assembly?

1 A. I don't know. I didn't have much contact with the secretariat.

2 My duty was to do my part of the work properly. I just know that the

3 Secretariat for Social Affairs is within the Municipal Assembly. Now, how

4 it's regulated, probably the Executive Council is a higher-level body than

5 the secretariat.

6 Q. Sir, did Mr. Blagoje Simic ever give you any orders as to what

7 should be broadcast over the radio?

8 A. No. As far as I, as a journalist, am concerned, no, because I had

9 my own job description, and I've already told you what that was. I didn't

10 make interviews of prominent figures. If that was necessary, someone else

11 would do that. I was also just a journalist, and the editor is the

12 editor, and he is the one who decides who would be interviewed and by

13 whom. So I was not the person who did that.

14 Q. But you were a journalist, a reporter. Do you have any knowledge

15 as to certain people being detained in Samac?

16 A. I do, and I do know that. I am aware of three locations in town

17 where men were detained, probably because of investigations and

18 interrogations. I don't know what exactly was being done there, but I do

19 know that they existed.

20 Q. Do you know anything about a tragic event that happened in

21 Crkvina?

22 A. I heard of it. True, I learnt about it later, subsequent to the

23 event itself. As this was the affair of the army, and as I was not

24 engaged as a soldier, it is understandable that I didn't get any detailed

25 information about it, but I heard about it, as did many other citizens

1 living in the territory of the municipality. Samac is a small town, and

2 reports spread very fast, even without the radio.

3 Q. Are you familiar with a location called Zasavica, within Samac

4 municipality?

5 A. Yes. It's about six or seven kilometres from Samac. It's a

6 village.

7 Q. What do you know about who was living there in that period of time

8 and what was going on there?

9 A. I know that before the armed conflict, the village was mostly

10 inhabited by Croats. I know that in this period of time, that there were

11 also others living there in addition to Croats. There were Muslims and

12 Croats, but also some Serbs who had come from some other areas. I know

13 they lived there. I don't have a lot of information about it. The only

14 thing I really do know, because this was of vital importance for all of

15 us, was that there was a farm there where livestock was bred, and I know

16 that this farm was the basis for the food that was provided in the public

17 canteen where I had my meals. So it was a part of an agriculturalist

18 state that existed there. That is as much as I know about Zasavica.

19 Q. Did you ever go to Zasavica in that period of time?

20 A. No, I didn't in that period of time. I didn't have any need to go

21 there. I had no relatives staying there for me to go and visit them. So

22 I didn't.

23 Q. And do you know, or had you heard rumours, that it was a kind of

24 camp?

25 A. No, I don't know that there were any such rumours. I already said

1 that it was inhabited by the people that I have described and that there

2 was a farm there. I don't know anything about a camp.

3 Q. Sir, you joined the SDS after the outbreak of armed conflict.

4 Tell me: In that period of time, that is, 1992 and 1993, did your party,

5 at the local level, implement a policy of ethnic cleansing?

6 A. No. No.

7 Q. Or a policy of discrimination, or anything like that?

8 A. No.

9 MR. VUKOVIC: [Interpretation] Thank you. I have no further

10 questions.

11 PRESIDING OFFICER: Thank you.

12 Cross-examination for the Prosecution.

13 Cross-examined by Mr. Re:

14 Q. Mr. Cordasevic, my name is David Re, a Prosecutor at The Hague.

15 I'm going to ask you some questions about your testimony. You understand

16 that?

17 A. Yes.

18 Q. As journalist working both before and during the war, it was your

19 job to be informed about what was going on, wasn't it?

20 A. My job was to broadcast news about the civilian life, the life in

21 the area, to transmit information which pertained to and affected all the

22 population, which would benefit the entire population. I have already

23 enumerated what my job -- the tasks contained within my job.

24 Q. When giving your answers, could I ask you, please, to be as brief

25 as possible and to respond to the question I ask, and not answer another

1 one.

2 As a journalist, you have to be informed to broadcast the

3 information, don't you? It's a very simple question.

4 A. So within the ambit of the work which I did --

5 Q. You have to gather information, don't you?

6 A. Yes. Yes. I went to different institutions. I went to

7 basements, shelters, public canteens, to the front line. I talked to

8 people in the streets, I went to schools, to establishments, to all places

9 where I could gather information which would be of interest and benefit to

10 the population.

11 Q. Of course. You wouldn't be doing your job as a journalist

12 otherwise, would you?

13 A. Yes.

14 Q. And of course, as a journalist, you also make contacts or use

15 contacts? Yes or no.

16 A. Yes, with the civilian population, as well as with the army.

17 Q. In your job -- you told us earlier your job was to provide

18 information over Radio Samac about what was happening in the war and in

19 the town. Your contacts -- you would have needed contacts with the

20 government, the military, and the police?

21 A. Well, to a lesser extent with them, because this was up to the

22 editor and not up to me, because I was a field reporter, and I reported

23 from the field.

24 Q. Journalists, Mr. Cordasevic, prize their contacts, don't they, the

25 people who provide them with information on matters about which they're

1 reporting?

2 A. Yes, they do.

3 Q. Because these contacts can give you valuable information which you

4 can use to report, or can give you leads; correct?

5 A. Yes.

6 Q. In your job in reporting from the front line, you had contacts

7 with members of the military, didn't you?

8 A. Yes.

9 Q. You relied upon those people to give you information?

10 A. I did.

11 Q. Did you have contacts in the 2nd Posavina Brigade command? Yes or

12 no, please.

13 A. No.

14 Q. Who were your main military contacts during 1992 and 1993? Just

15 the names, please.

16 A. I had none. I didn't have any contacts of that kind. I was a

17 journalist in the field, putting together programmes aimed at informing

18 the people.

19 Q. Just please stick to the point. I'm asking you about your

20 contacts in the military. You've already told us you needed contacts to

21 obtain information to compile your reports. You must have got the

22 information from people in the military. Who were the people in the

23 military - just their names, please - who were your main sources of

24 information during 1992 and 1993?

25 A. I just had talks with soldiers on the front line.

1 Q. Including, of course, officers?

2 A. The commanding officers were with their troops. The petty [phoen]

3 officers were with their troops on the front line then, yes.

4 Q. You also broadcast information about what was -- about civilian

5 activities, and to do so, you would have needed to obtain accurate

6 information from the civilian authorities; correct?

7 A. No. This is also up to the editor.

8 Q. You said you had worked as a psychologist in Samac before the

9 war. Did I hear that correctly?

10 A. Yes. Pedagogist and psychologist. That's right. Yes.

11 Q. Blagoje Simic was a medical practitioner in the town. Did you

12 have professional contacts with him as another -- as a health professional

13 working in the same area?

14 A. Yes.

15 Q. Did you know him quite well?

16 A. Well, to the extent which was necessary, because, after all, he

17 was a doctor and we worked together in a humanitarian association. It was

18 an association to control, to combat, alcoholism and drug addiction.

19 Q. You weren't the only announcer working at the radio station, were

20 you?

21 A. No, I was not the only one.

22 Q. You didn't listen to Radio Samac all the time when it was

23 broadcasting, did you?

24 A. No. I didn't have occasion -- much occasion for that, because I

25 was in the field most of the time preparing my material for the programme,

1 for the broadcast.

2 Q. So, of course, you can't tell us what was broadcast about anything

3 when you were in the field gathering your reports, because you didn't hear

4 it.

5 A. Yes.

6 Q. You know Simeon Simic, don't you?

7 A. Yes, I do.

8 Q. Milan Simic?

9 A. Yes.

10 Q. Stevan Todorovic?

11 A. Yes.

12 Q. Simo Zaric?

13 A. Yes.

14 Q. Miroslav Tadic?

15 A. Yes.

16 Q. Bozo Ninkovic?

17 A. Yes.

18 Q. The radio station was socially owned during the war, wasn't it?

19 A. Yes, it was. Yes, by -- it was a fixed asset of the Municipal

20 Assembly.

21 Q. And the director of the radio station was appointed by the

22 Municipal Assembly, or the Executive Board or Council of the Municipal

23 Assembly?

24 A. I suppose so, yes.

25 Q. And in the war, war period, that was -- the function of the

1 Municipal Assembly was taken by the Crisis Staff and the War Presidency,

2 wasn't it?

3 A. This social affairs department was within the framework of the

4 Municipal Assembly.

5 Q. The Municipal Assembly was replaced by the -- its functions were

6 carried out by the Crisis Staff and the War Presidency during the war,

7 1992 and 1993, weren't they?

8 A. Yes. Yes, probably.

9 Q. And they -- and you, of course, knew that Blagoje Simic was

10 president of the Crisis Staff, didn't you, and War Presidency?

11 A. Yes.

12 Q. Who were the other members of the Crisis Staff? Was Milan Simic

13 on the Crisis Staff?

14 A. I don't know who was on the Crisis Staff or in the War

15 Presidency. I repeat: I did my work in the field. I was not interested

16 in that part.

17 Q. You were able to leave Samac and return to Samac for the purposes

18 of your war reporting, weren't you?

19 A. Yes.

20 Q. You were able to leave freely and return freely, weren't you?

21 A. I had a pass issued to me by the army. I also had a sticker on my

22 car. And of course, I was subject to check-ups wherever I went, and that

23 was that.

24 Q. Did you work at the radio station before the war, that's before

25 April 17th, 1992?

1 A. From 1970, from the beginning of that radio, but only in the

2 sports programme.

3 Q. There were Croat and Muslim employees of Radio Samac, or Bosanski

4 Samac, before the war, weren't there?

5 A. Yes.

6 Q. After April 17th, 1992, the municipality of Samac came under Serb

7 control, didn't it?

8 A. Yes.

9 Q. The radio station was then -- from then on was under Serb

10 management, wasn't it?

11 A. I don't know exactly how that segment was organised, but it was in

12 the service of the people who lived there.

13 Q. The Crisis Staff and War Presidency were a Serb Crisis Staff and

14 Serb War Presidency, weren't they?

15 A. Probably.

16 Q. And as the highest civilian officials or authority in Samac during

17 the war, they ultimately controlled the radio station, didn't they?

18 A. We were within the framework of the civilian authorities of the

19 Municipal Assembly, that is, civilian authorities.

20 Q. Which were Serb controlled; correct?

21 A. Well, it is true that the majority of the people who remained

22 there were Serbs, but also others remained there, of the other

23 ethnicities, and they all listened to the radio.

24 Q. Were there any Croat or Muslim announcers on Radio Samac after the

25 17th of April, 1992?

1 A. No. Well, initially, yes, but later, no.

2 Q. How much later? Are we talking days here, days after the 17th of

3 April?

4 A. Perhaps two or three months. There was a technician working, as

5 part of his work obligation.

6 Q. The only non-Serb employee was this technician after that time; is

7 that correct?

8 A. Yes.

9 Q. Serb forces, in fact, seized control of the radio station on about

10 the 17th of April, 1992, didn't they?

11 A. Yes.

12 Q. And the radio station was guarded by soldiers, wasn't it, or armed

13 police?

14 A. I saw a soldier, soldiers, but whether it was guarded, and in

15 which way it was guarded, I don't know.

16 Q. There were armed people outside the radio station to prevent

17 unauthorised people from gaining entry, weren't there?

18 A. Well, control and check-ups had been intensified at all points,

19 which was only logical.

20 Q. I'm asking you about the radio station. The answer to my question

21 was yes, wasn't it?

22 A. There was heightened security all over the place.

23 Q. I'm asking you about the radio station. There were armed people

24 outside the radio station stopping unauthorised people gaining entry,

25 weren't there?

1 A. Yes, heightened control there.

2 Q. And the editor, was he a member of the SDS as well? That's Vaso

3 Antic.

4 A. Yes, I think so, initially.

5 Q. Were the other announcers SDS members?

6 A. You might find it hard to believe, but that is something I wasn't

7 interested in at all. I just went about doing my job properly.

8 Q. Can you answer my question? Were they SDS members or not?

9 A. They were probably sympathisers. I don't know who were actual

10 members. I was a member.

11 Q. Radio Samac broadcast local government or local civilian

12 announcements, didn't it, announcements of the Crisis Staff, War

13 Presidency, and Executive Board, didn't it?

14 A. I don't know much about that. I worked in the field gathering

15 what was within the purview of my job. As to different announcements and

16 warnings, and if those were of vital importance, this was not something

17 which was within my ambit.

18 Q. Were you involved in the broadcasting or the announcement of the

19 declaration of the state of emergency over Radio Samac after the 17th of

20 April, 1992?

21 A. No. That is also up to the editor and for the announcer to do.

22 Q. Because that was certainly broadcast over Radio Samac, wasn't it,

23 the declaration of the state of emergency in Samac?

24 A. Well, it had to be within the context of the worsened situation

25 that attained, but I had no occasion to hear it in detail or in full.

1 Q. Did Radio Samac broadcast to the citizens of Samac that Serb

2 forces had taken control of Radio Samac?

3 A. I don't know that.

4 Q. How often did Simeon Simic visit Radio Samac when you were there?

5 A. Perhaps -- well, I worked with him for only a couple of months,

6 and I only saw him two or three times. Mine was to work in the field, and

7 his was to work at the office.

8 Q. One of the functions of Radio Samac during the war was to boost

9 the morale of the civilian population, wasn't it?

10 A. Yes.

11 Q. And it did that by giving them information and entertaining them,

12 didn't it?

13 A. Yes.

14 Q. It played music too, didn't it?

15 A. Yes. That was welcome, in the circumstances, everything which was

16 popular before and during the war, and they had music at all these

17 stations with that view in mind.

18 Q. It played Serb patriotic songs, didn't it?

19 A. Well, yes, occasionally, those too.

20 Q. It didn't play Croat patriotic songs, did it?

21 A. Well, much less, much less or never, perhaps.

22 Q. I think "never" is the right answer, isn't it?

23 A. I can't claim that, because I didn't listen much to the radio. I

24 didn't have much chance to listen to the radio. I can't claim that with

25 certainty.

1 Q. You never heard Radio Samac play Croat patriotic songs after

2 the ... END OF RECORDING.

3 A. I don't remember.

4 Q. It played what could be called Chetnik songs, didn't it?

5 A. No.

6 Q. You never heard Chetnik songs being played?

7 A. Yes, patriotic songs from time to time, but there was also other

8 kind of music which did not -- not necessarily of an ethnic character.

9 There were just nice songs, all sorts of nice music.

10 MR. PANTELIC: [Previous translation continues]... for

11 interrupting. Maybe my learned friend can give a few examples, because

12 it's rather, you know, maybe a matter of interpretation. For one it's a

13 patriotic song, for the other it's a folk song or -- you know. So maybe

14 my learned friend can -- if we have some names of these songs, maybe he

15 can ask this witness and then he can get -- obtain the answer. Thank you.

16 PRESIDING OFFICER: So, Mr. Pantelic, you're seeking a

17 clarification; right?

18 MR. PANTELIC: A clarification, yes, Madam Presiding Officer.

19 PRESIDING OFFICER: Thank you.

20 MR. PANTELIC: That's correct.

21 MR. RE: And could I have a minute out for that very detailed

22 clarification, please, Madam Presiding Officer?

23 PRESIDING OFFICER: Yes, and you have 17 minutes on your bank

24 account of minutes.

25 MR. RE: Thank you, Madam Presiding Officer.

1 Q. Mr. Cordasevic, was "From Topola to Ravna Gora," what that one of

2 the songs that you heard played on the radio, "From Topola to Ravna

3 Gora"?

4 A. It's hard to remember whether I heard that particular song.

5 Q. What about "General Drazic's Troops Are Everywhere"? Was that one

6 of the songs that you heard played on Radio Samac?

7 A. I can't recall now what songs I listened to.

8 Q. It's quite possible that those were the types of songs that were

9 played; you would agree with that, wouldn't you?

10 A. Patriotic songs were played occasionally; I will agree with that.

11 Now, as to playing Chetnik and nationalistic songs, I didn't hear those.

12 Q. And Stevan Todorovic used to come into the radio station, didn't

13 he?

14 A. I spent the least of my time at the radio station. Perhaps I can

15 remember one or two of his visits. Others would be able to tell you more

16 about that.

17 Q. But you certainly heard -- you saw him there a couple of times,

18 but you heard that he used to come in quite regularly, didn't you?

19 A. No. I didn't hear that he used to come regularly. The journalist

20 did not inform me about visits and the frequency of visits of other

21 people. I wasn't important enough for that.

22 Q. Simo Zaric came to the radio station, didn't he?

23 A. I don't that. I didn't see him there.

24 Q. Todorovic would come and order the radio station staff to play

25 Chetnik songs, wouldn't he?

1 MR. PANTELIC: Objection. Calling for speculation. Maybe the

2 question could be rephrased. Thank you.

3 MR. RE: I don't intend to rephrase the question.

4 Q. The question was: Stevan Todorovic used to come to the radio

5 station and order the staff to play Chetnik songs, didn't he?

6 A. I don't know about that.

7 Q. You went to the municipal building to meet Blagoje Simic during

8 1992 and 1993, didn't you?

9 A. I had no reason to go. It was up to the editor to talk to

10 others. My job was to work on the ground with civilian population,

11 because I knew the area well.

12 Q. Your job, you said in your evidence earlier to Mr. Vukovic, was to

13 truly and frankly keep the citizens of Samac informed.

14 A. About the material that I had prepared, and pursuant to the

15 information that was available to me.

16 Q. Radio Samac could be heard by troops on the front line, couldn't

17 it?

18 A. It most of the areas, yes.

19 Q. You've already agreed that one of the things that Radio Samac was

20 doing -- or one of its roles was to keep -- was to boost civilian morale.

21 It also attempted to boost military morale too, didn't it?

22 A. It's hard to distinguish; therefore, yes.

23 Q. The enemy you were fighting, that is, the Serb forces were

24 fighting at the time, were Croats and Muslims, weren't they? You would

25 know that from your job on the front line.

1 A. Yes.

2 Q. And information was broadcast over Radio Samac, intended to

3 demoralise the enemy, wasn't it?

4 A. Yes. Partially, yes.

5 Q. And Radio Samac reported on war crimes against Serb forces and

6 civilians, didn't it?

7 A. I apologise. I didn't quite get your question.

8 Q. Radio Samac reported on war crimes committed by Croat and Muslim

9 forces against Serb forces and Serb civilians, didn't it?

10 A. There were cases of that too, within the scope of what was

11 available.

12 Q. Radio Samac reported on those things, didn't it, broadcast it;

13 correct?

14 A. To the extent that it was available, that there was information

15 about that.

16 Q. Radio Samac also reported on genocide against the Serbian people,

17 didn't it?

18 A. Yes.

19 Q. Radio Samac didn't report on alleged war crimes committed by Serb

20 troops or civilians against Croats or Muslims, did it?

21 A. No, it didn't.

22 Q. When Radio Samac was referring to the Croats, it referred to them

23 as the Ustasha forces, didn't it?

24 A. During that critical period of time, all of the media used

25 occasionally those terms, as it Radio Samac.

1 Q. When referring to the forces of the Bosnian government, the

2 central government, it referred to -- it called them the Muslim forces or

3 the Muslim army, didn't it? That's Radio Samac?

4 A. Well, yes.

5 Q. It referred to the Bosnian government as Muslim extremists, and

6 their army as Muslim extremists, didn't it?

7 A. There were certainly cases of that as well too.

8 Q. In your job of truly and frankly keeping the citizens of Samac

9 informed, did Radio Samac report on the detention of hundreds of non-Croat

10 - sorry - non-Serbs in the facilities, the four facilities around the

11 town? Yes or no.

12 A. No.

13 Q. Did it -- did Radio Samac report on the isolation of Croats in

14 Zasavica in its job of keeping the citizens --

15 A. No.

16 Q. No?

17 A. No.

18 Q. Did it report on bribes being paid to officials to allow people to

19 be exchanged from Samac to other places?

20 A. No.

21 Q. In keeping the citizens of Samac truly and frankly informed, did

22 it report upon the beating and torture of detainees in the SUP, MUP,

23 primary and elementary schools?

24 A. No.

25 Q. Did it report upon the massacre of 16 Croats by Serb

1 paramilitaries in May 1992 at Crkvina?

2 A. No.

3 Q. Did it report, in its reports on the work obligation, on

4 civilians, non-Serb civilians, being forced to dig trenches at the front

5 lines while under enemy fire?

6 A. No.

7 Q. Did it report upon the looting of non-Serb property by

8 non-Serbo-Croats and Muslims who were forced to do so by Serb --

9 A. No.

10 Q. -- armed guards? The answer is no?

11 A. I don't know about that.

12 Q. Did it report upon the isolation of Croats or the order of the

13 Crisis Staff ordering Croats to be isolated and taken to vital facilities

14 in the town?

15 A. No.

16 Q. Those things would have been of interest to the Croats and Muslims

17 in town, who were part of your audience, wouldn't it?

18 A. The programme of the department for information is something that

19 is decided upon by the editor, not a person reporting from the ground.

20 Q. The mass arrest of non-Serbs only because they were non-Serbs;

21 their isolation, their detention, beating, torture, only because they were

22 non-Serbs; the taking of their houses because they were non-Serbs; the

23 looting of their property because they were non-Serbs; and the deportation

24 from Samac because they were non-Serbs, would amount to ethnic cleansing,

25 wouldn't it?

1 A. I was not involved in the political aspect of it. You can put

2 questions to me that have to do with my job.

3 Q. You were asked by Mr. Vukovic about SDS local policies. I just

4 put a number of things to you in relation to ethnic cleansing. The things

5 I put to you, you have to agree, would amount to ethnic cleansing,

6 wouldn't they? I can list them again if you like.

7 A. I'm not aware of the fact that the SDS participated in that.

8 Q. I was asking you if those things - the mass arrest of non-Serbs

9 because they were non-Serbs, their detention because they were non-Serbs,

10 their torture, their beating, because they were non-Serbs, the isolation

11 of Croats because they were not Serbs, the taking of their houses because

12 they were not Serbs, the expulsion of these people from Bosanski Samac

13 because they weren't Serbs - that would amount to ethnic cleansing,

14 wouldn't it, and you, as a psychologist and educated man, would have to

15 agree with that, wouldn't you?

16 MR. PANTELIC: Objection. Calling for speculation. This is a

17 legal matter. This is a legal issue, and this witness is not a legal

18 professional, so I don't know how he can answer to that question.

19 MR. RE: I press the question on the basis "ethnic cleansing"

20 isn't a legal term, and it was put to the witness by the counsel who

21 called him.

22 Q. Again I ask the question: All those things would amount to ethnic

23 cleansing, as you understand the term, wouldn't they?

24 A. Everything you listed would amount to bad things. Now, as to

25 where exactly it happened, what happened, I had no information concerning

1 that.

2 Q. You were asked about ethnic cleansing by Mr. Vukovic. I'm asking

3 you, simply: The things I've just listed, you can agree, would amount to

4 ethnic cleansing if they occurred? Yes or no. I'm not asking you whether

5 they occurred; I'm just asking you whether, if they did occur, they would

6 amount to ethnic cleansing, in the commonly understood definition of the

7 term. Yes or no.

8 A. I never studied the definition of ethnic cleansing.

9 Q. Sir, you, of course, joined the SDS because you agreed with its

10 policies; is that right?

11 A. I agreed with their policies, yes, I did. How else would I become

12 their member?

13 Q. You, of course, agreed with its leadership as well, didn't you?

14 A. Not always, but in the majority of cases.

15 Q. One of its published policies in May 1992 was to establish state

16 borders separating the Serbian people from the other two ethnic

17 communities. The leaders of the SDS - Krajisnik, Plavsic, and Karadzic -

18 have been indicted for persecution. You understand and you know that,

19 don't you?

20 A. I know that they had been indicted, but I don't know the details

21 of it. That is too political for me.

22 Q. Mrs. Plavsic has pleaded guilty to persecuting non-Serbs

23 throughout Bosnia and Herzegovina, and one of the things she has agreed

24 with SDS policy, which amounted to persecution, was establishing state

25 borders separating the Serbian people from the other two ethnic

1 communities. You're aware of that?

2 A. I'm only aware of the plea agreement of Mrs. Plavsic, but I have

3 no clue as to the details of it.

4 Q. One of the Serb -- one of the SDS policies was to "establish state

5 borders separating the Serbian people from the other two ethnic

6 communities," published on the 12th of -- promulgated by the Bosnian Serb

7 Assembly on the 12th of May, 1992. That was the policy of the party you

8 joined in 1992.

9 A. I don't know about that particular conclusion.

10 Q. You have remained in the party, despite the indictment of its

11 three leaders for persecution and crimes against humanity, haven't you?

12 A. I remained in the party, yes.

13 Q. You remained in the party even after the massacre of thousands of

14 Muslim men in Srebrenica in 1995, didn't you?

15 A. I will repeat again that I am a member of the party, yes. Now, as

16 to the details, I don't know much about that.

17 Q. You remained in the party despite its carrying out of ethnic

18 cleansing and persecution of non-Serbs across the Republika Srpska, didn't

19 you?

20 A. I'm not aware of the ethnic cleansing committed by this party.

21 Nobody discussed that in my presence, nor was I asked to participate in

22 ethnic cleansing, nor did my party participate in ethnic cleansing.

23 Q. So you're seriously telling the Trial Chamber that, as a

24 journalist, you are unaware of ethnic cleansing committed by the SDS

25 leadership or the VRS? Is that your serious evidence here?

1 A. I'm not aware of that.

2 PRESIDING OFFICER: Thank you.

3 Any re-examination?

4 Re-examined by Mr. Vukovic:

5 Q. [Interpretation] Sir, do you know: After the breakout of

6 hostilities, when was the first session of the Municipal Assembly of Samac

7 held following that?

8 A. No, I don't know.

9 Q. The Prosecutor asked you whether you knew -- or rather, whether it

10 was announced on the radio that non-Serbs were leaving Samac. Do you know

11 the reasons for certain non-Serb families to leave Samac, not only after

12 the breakout of the war but also before that and during it?

13 A. I know that some people were leaving town due to specific

14 geographical location of the place itself. All of those who believed they

15 would be better off in town remained, and all of those who believed that

16 they would be better off leaving left from the area where there was

17 fighting going on. It is true that there were more Croats and Muslims

18 leaving, but there was also a significant number of Serbs that left.

19 Q. And did a certain number of non-Serbs remain there during the war?

20 A. Yes, and nobody knows that better than me, because they remained

21 living there with us, working with us, and there were Muslims in some

22 associations, in some clubs. There were Muslims playing in the football

23 club Borac during that period of time.

24 Q. You said to the Prosecutor, when asked about the programme that

25 was aired, you said that there had been certain warnings announced.

1 A. Yes.

2 Q. What kind of warnings were those?

3 A. Warnings, announcements to the residents concerning power outages,

4 water outages, vaccinations, school enrollment for children, distribution

5 of food to the population, warnings about possible shellings, going to

6 shelters, all of those things that residents were interested in.

7 Q. Now, please tell us: How long did you remain as a journalist in

8 Radio Samac?

9 A. Until 1993, basically for a year and a half, and then I went on to

10 another job.

11 Q. When was Mr. Simo Simic appointed director of Radio Samac?

12 A. I believe that it was just prior to my departure from the radio

13 station, some three months before that.

14 Q. So in 1993?

15 A. Yeah, thereabouts, towards the end of 1993.

16 Q. I'd like to ask you this as well: The warnings that you have just

17 mentioned, did they pertain to all of the residents?

18 A. I've already said so several times. They pertain to all of the

19 residents, because they were of interest to all of the people living

20 there.

21 Q. Regardless of their ethnicity?

22 A. Ethnicity is of no consequence here.

23 Q. Sir, in the vicinity of Samac, or rather, across from it, is

24 Slavonski Samac, even nowadays. Were you able to listen to Croatian radio

25 station?

1 A. Yes, one could listen to them, but I don't know whether it was

2 Djakovo or Osijek radio stations. It might have been even Orasje radio

3 stations. Yes, from the neighbouring areas.

4 Q. And did you hear some Serbian songs played on those Croatian radio

5 stations?

6 A. No. No.

7 Q. And can you tell us about their vocabulary, what terms they used

8 referring to Serbs?

9 A. We adopted from them some of our terminology.

10 Q. Tell us what kind of terminology.

11 A. To call the opposing side the enemy side. They referred to us as

12 Chetniks. Those are the terms they used, nationalistically coloured, and

13 they used such terms as "Muslims," "balijas," "Ustashas," and so on. But,

14 rather, we used these terms much less frequently than they did.

15 Q. Tell me, please: Are you aware of the fact that Croats and

16 Muslims were sequestered in Zasavica?

17 A. No, I'm not aware of that, but I know that there were different

18 kinds of people living there. However, they had not been isolated there.

19 Q. I have just one further question for you. Do you know or do you

20 have any information that there had been a decision of the Crisis Staff

21 concerning isolation?

22 A. No, I'm not aware of that.

23 Q. Do you know whether there had been any kind of order on forcing

24 out non-Serb population from Samac?

25 A. No.

1 Q. Do you know whether there was an order on imprisoning non-Serbs,

2 on torturing them?

3 A. No, I don't know about that. I believe that there was no such

4 decision; however, I was only concerned with doing my work.

5 MR. VUKOVIC: [Interpretation] Thank you. I have no further

6 questions.

7 PRESIDING OFFICER: Thank you, Mr. Cordasevic, for coming here

8 today to give your deposition. It's concluded now and you can go. Thank

9 you.

10 Ten minutes' break.

11 [The witness withdrew]

12 --- Break taken at 11.12 a.m.

13 --- On resuming at 11.32 a.m.

14 [The witness entered]

15 WITNESS: MILOS SAVIC

16 [Witness answered through interpreter]

17 PRESIDING OFFICER: Good morning, Mr. Savic. Could you please

18 stand and read the solemn declaration in front of you.

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

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

21 PRESIDING OFFICER: You may sit down.

22 Mr. Pantelic.

23 MR. PANTELIC: Yes. Thank you.

24 Examined by Mr. Pantelic:

25 Q. [Interpretation] Good morning. For the record, please tell us

1 your first and last name.

2 A. My name is Milos Savic.

3 Q. Do you have a nickname?

4 A. Yes, I do. Mrki.

5 Q. Mr. Savic, you will be explaining that later on, but since you are

6 a very seriously war-disabled person, to the extent of 90 per cent

7 disabled, should, at any point in time during your testimony, should you

8 not feel well or need a break, please feel free to ask for one. We won't

9 hurry. We'll adjust to your physical abilities. So please feel quite at

10 ease, and if at any point in time you feel you're unwell, please let us

11 know, and Madam Presiding Officer will take care of it.

12 When were you born, Mr. Savic?

13 A. I was born on the 9th of January, 1957.

14 Q. And where were you born?

15 A. In the village of Gajevi.

16 Q. That is Samac municipality?

17 A. Yes, it is.

18 Q. Are you married?

19 A. Yes, I am.

20 Q. Where are you residing now?

21 A. In Bajevo [phoen].

22 Q. Could you repeat the name, please.

23 A. In Gajevi. I'm currently living in Gajevi.

24 Q. Your current occupation is a farmer, is it not?

25 A. Yes. I'm working on my own land. I'm tilling my own land.

1 Q. But you have a secondary-school degree and you are a mechanic by

2 occupation?

3 A. Yes.

4 Q. You did your national military service when?

5 A. In 1976, 1977.

6 Q. And what branch of the army did you serve in?

7 A. In a motorised unit. I was a driver.

8 Q. Up until 1990, you were not politically active?

9 A. No, I was not.

10 Q. And in 1990, you became a member of which party?

11 A. Of the SDS.

12 Q. Are you still a member of the SDS?

13 A. Yes, I am.

14 Q. Will you please explain whether, at the end of 1991, you received

15 a call-up paper, that is, whether you were mobilised to units of the JNA?

16 A. At the end of October/beginning of November 1991, I was called up

17 by the Territorial Defence of Samac and I was mobilised to a company in

18 the village, in the village I lived in.

19 Q. Your village unit belonged to which larger unit?

20 A. It was part of the 1st Detachment of the Tactical Group 17,

21 Pelagicevo, under the command of the JNA.

22 Q. Tell me, Mr. Savic: What was your duty in the 1st Detachment when

23 you were mobilised?

24 A. I was a courier in my company.

25 Q. Describe for us briefly what your military engagement in that

1 period meant, what kind of military duties you had during the day, whether

2 you were accommodated in a barracks or in a camp, or anything like that.

3 A. In those days, I stayed on in my own house. During the day, the

4 commanders would call if there was any need to distribute call-up papers,

5 to tell people to come to a meeting, to be familiarised with weapons, and

6 things like that.

7 Q. Tell me, Mr. Savic: The other members of the 1st Detachment from

8 your village had also been mobilised, like you?

9 A. Yes. The whole village had been mobilised. Everyone had received

10 call-up papers, and more or less everyone had responded to them.

11 Q. But your village and the environs, how would you describe it

12 ethnically? Was it a mixed community or a Serb-dominated community?

13 A. My village is a Serb village. There were only some five or six

14 Muslim households in it.

15 Q. Within the 1st Detachment, of which you were a member, were there

16 members of other nationalities in addition to Serbs?

17 A. Yes, there were.

18 Q. What nationalities were they?

19 A. Muslims, and I think there were some Croats as well. I know those

20 people from the street, but it's difficult to tell all of them.

21 Q. So you were mostly at home, and if need be, you performed these

22 military duties as a kind of reserve force?

23 A. Yes, precisely so. All I did was what I did at home. I farmed

24 the land, I looked after the livestock, and I did this courier work when

25 necessary, and in the evening I worked in a restaurant called Zvijezda, as

1 a waiter.

2 Q. Could you briefly explain for us the atmosphere in the territory

3 of Samac municipality, and of course in your village itself and around it,

4 regarding interethnic relations in the period from January 1992 to April

5 1992. What are your personal impressions and memories of that period?

6 A. As far as I can remember, the situation was rather tense there was

7 a lot of coming and going through the villages, there were barricades in

8 some villages that we didn't go into much, but we had reliable information

9 about them. We were -- this psychosis had spread from Croatia, so that

10 over here where we were, we expected something like that to happen too.

11 Q. If I'm not mistaken, when we discussed your testimony in these

12 proceedings, you mentioned that towards the end of March 1992 you went to

13 attend a course, some kind of military training in handling certain

14 weapons and so on.

15 A. Yes.

16 Q. Tell us a little about that, how it came about that you went to

17 this course, upon whose orders, where it was held, and how long it lasted,

18 and what you were taught. You tell us in your own words, and if

19 necessary, I will put some additional questions to you.

20 A. Towards the end of March, a report arrived to my company, from the

21 battalion, that our company - that is, four younger men, who were ready

22 and willing to learn about weapons - should go, and the deputy company

23 commander -- actually, in the company, they agreed, pursuant to the orders

24 of the 1st Battalion of the 17th Tactical Group, who the four men would

25 be, and the company commander read out those four names. I was among

1 them. Savic Milos, Lukic Petar, Lukic Cedo [phoen], and Duzic Zeljko

2 [phoen]. And from the village of Gajevo, we went in a private vehicle to

3 Batkusa, and then, with the others, we moved on. There were about 15 to

4 18 of us. We didn't know exactly where we were going, but knowing the

5 surroundings, I realised we were close to Ilok. We were travelling in

6 civilian clothes, without weapons, because around Orasje and Brcko there

7 were barricades, searches of passengers, and to facilitate our trip, we

8 travelled as civilians.

9 We got to somewhere close to Ilok, to a camp there. We found a

10 group of inspectors there, people we hadn't known. They were wearing

11 camouflage uniforms and they addressed us officially. They never

12 mentioned any names, only nicknames, and I don't even remember those

13 nicknames now. They called each other by nickname. And when we arrived

14 there, they told us that the training would be quite strenuous, a lot of

15 physical, hard work, physical fitness training, that we would be some sort

16 of an intervention unit. We didn't really know what that meant.

17 We stayed there 12 to 15 days, then we returned home. We had

18 learnt as much as we could regarding the handling of those rifles,

19 hand-held rocket launchers, grenades, and suchlike.

20 Q. Very well. If I am right, you must have returned to your unit,

21 that is, the 1st Detachment, if my calculations are right, around perhaps

22 the 13th or 14th of April, something like that.

23 A. I'm not quite sure. I think it was around the 12th. I never took

24 note of those dates anywhere, but it was thereabouts.

25 Q. When you returned, what kind of military assignment did you have?

1 A. Of course, when we returned, we went back to our detachment and we

2 tried to pass on some of the knowledge we had been taught by our

3 instructors to our friends and comrades in the village. That was our job.

4 Q. Tell me, Mr. Savic, whether you are aware of the arrival of a

5 group from Serbia, around about that time, in the territory of Samac.

6 What do you know about that?

7 A. I didn't have any direct knowledge. I heard from others that a

8 group of some 30 guys had arrived. We didn't know who they were or what

9 they were, but we heard that they had arrived.

10 Q. What do you know about them? Were they independent in their

11 activities or did they come under the control of a unit or a command?

12 A. They were independent of us, but they were under the command of

13 the 17th Tactical Group.

14 Q. Tell me, Mr. Savic: In your unit, and on the basis of your

15 personal knowledge at that time, was there an information about the

16 military situation in the Samac area? Because, after all, you were a

17 military man at the time. You ... END OF RECORDING ... at that time you

18 were a soldier?

19 A. As far as I can remember, the situation was rather tense. There

20 was some information, either through intelligence people or informers. We

21 were told that an action was being prepared on the other side of the Sava

22 River from Prud, which was inhabited mostly by Croats. And during our

23 training period, there had been barricades, and it had not been possible

24 to enter or leave Samac. And as far as I was informed, apparently this

25 had been done, these barricades had been erected by the Muslims.

1 Q. Will you please describe to us now, to the best of your

2 recollection: What did you, as a soldier, as a member of the 1st

3 Detachment, do, or rather, what were your assignments and duties in the

4 night between the 16th and 17th of April, 1992? Slowly and clearly, from

5 beginning to end.

6 A. On the 16th of April, I was in the village, in my own village, at

7 home, when a courier arrived from Batkusa, where the command of the 1st

8 Detachment was. He came to tell me that we should go to Batkusa

9 immediately. It was late afternoon/early evening. We went there. That

10 is where the command was. We spent an hour, two or three there, and then

11 we were told that we had to go to Samac, that is, a group of us who had

12 undergone training, that we should go to Samac to assist in protecting the

13 silos where food was stored, the wheat, the grain was stored.

14 Q. Who told you that, that you should go there?

15 A. The commander, and he received orders from his superiors.

16 Q. Now tell me: Around what time was this that you went to the silo

17 in Samac, to that position?

18 A. We went to that position at the silo just before midnight, I

19 think. I think it was before midnight. And when we arrived there, we

20 found men from the 4th Detachment who were already there. So we climbed

21 onto the silo, which is about 20 or 30 metres high, and we took our

22 positions there. And then our commander, Aco Jankovic, was in

23 communication, and we heard that their communications were operating.

24 Now, whether he intercepted that communication or not, I don't know. But

25 anyway, he told us that they were not allowing any civilian vehicles from

1 Babina Greda or Sikirevci to move towards the Samac bridge. And around

2 2.00 a.m., we were able to see a large line of headlights moving towards

3 the Samac bridge. These were not civilian vehicles; these were ATCs or

4 tanks. They made a lot of noise. Ordinary vehicles would not make such a

5 noise.

6 Q. And where was this coming from?

7 A. It was coming from the Croatian side. We couldn't see the

8 vehicles, but we could see their lights, because it was night-time, and we

9 were positioned high up.

10 Q. And around what time -- did an armed operation begin, and around

11 what time?

12 A. What happened was that they opened fire at us at the silo. Shells

13 hit the silo where I was, and in town there was a bit of shooting from

14 infantry weapons.

15 MR. WEINER: Madam Presiding Officer, this witness -- according to

16 the summary, Mr. Savic was born on January 9th, 1959 -- and you can remove

17 this time that I'm speaking from your time of direct examination. I have

18 no objection to that. He now lives in Samac. He was a member of the

19 reserve JNA unit in 1992. He attended the military course in the village

20 near Ilok, and afterwards he joined the special battalion in Samac. He

21 will testify on the following facts and events related to the defendant:

22 The defendant was not in charge of recruiting volunteers for

23 special training, and defendant never organised such activity. Half of

24 his -- more than half; three quarters of his testimony has been outside of

25 this summary. 1) We have not received any proper discovery or notice of

1 any of this man's testimony so far today; and 2) it's totally outside the

2 scope of the summary that was provided to us. I have allowed him to go on

3 a bit. I've given them some latitude. But now this is well beyond any

4 type of notice that we've been provided. This is another notice violation

5 and discovery violation on behalf of the defendant Blagoje Simic, and I

6 want the record to note that.

7 MR. PANTELIC: Yes. Maybe that's the position of the Prosecution,

8 but the interpretation of the Defence is very simple. We are speaking

9 about the personal involvement of this witness in the training outside of

10 territory of Samac, then his membership in a special battalion, and

11 inevitably, all events when he was a member of the special battalion,

12 including the night of 16th to 17th of April. So everything is linked and

13 connected to his personal involvement and his personal knowledge. And I

14 think that this objection from the Prosecution side is unfounded, and I

15 will proceed, and I will leave to Trial Chamber to finally decide about

16 the objections.

17 MR. WEINER: I understand that, and it would be very nice if you

18 gave us notice. You list one particular event that this person is going

19 to testify to. The rest of it, we've had no notice of.

20 MR. PANTELIC: In fact --

21 MR. WEINER: Here it is. Do you want to read it? Do you want to

22 read it for the record?

23 MR. PANTELIC: Yes, yes, but in fact it is not in dispute that

24 there was an armed conflict on the night of 16th or 17th of April.

25 MR. WEINER: It's not in dispute; however, there was a conflict --

1 MR. PANTELIC: That's a well-known fact in these proceedings.

2 MR. WEINER: However, if you want to discuss it, you have to list

3 it in your summary, to give proper notice for the other side.

4 MR. PANTELIC: That's a background of the events where this

5 witness was involved.

6 MR. WEINER: It's a summary of the facts, and we've had no notice

7 of these facts. That's for the record.

8 MR. PANTELIC: We don't have to put any kind of -- you have that

9 in your indictment, all these facts, so that's very simple. We are

10 speaking about the indictment.

11 PRESIDING OFFICER: You can proceed now.

12 MR. PANTELIC: Yes. And I kindly ask to have additional five

13 minutes because of this --

14 PRESIDING OFFICER: It's not five minutes --

15 MR. PANTELIC: Give me three -- give me three --

16 PRESIDING OFFICER: Three.

17 MR. PANTELIC: Okay.

18 PRESIDING OFFICER: Three. Three. It's three minutes, actually.

19 MR. PANTELIC: I ask more to get what --

20 PRESIDING OFFICER: Yeah, yeah, sure. It's three minutes.

21 MR. PANTELIC: Okay.

22 Q. [Interpretation] So, Mr. Savic, please describe, in brief: When

23 you were on top of the silo, what -- how did this military operation go?

24 What happened? Did anyone shoot at the silo, or what?

25 A. A shell was fired from the Croatian side at the silo and hit the

1 silo, on which I was. And also in town we could hear some skirmishes,

2 some shooting. Whether these were smaller groups or not, we couldn't

3 tell, because it was night and we couldn't see, in fact, and we had no

4 reports coming from town at all.

5 Q. All right. Let me ask you this, because in some of the notes

6 which I jotted down when we talked, when I talked to you, perhaps you

7 recollected some things wrong. You said that when your detachment came

8 and was assigned to the silo, that you met members of the 4th Detachment.

9 Do you still stick to this, or was it perhaps something else?

10 A. I think they were members of the 4th Detachment.

11 MR. WEINER: Are you impeaching your own witness, Counsel?

12 MR. PANTELIC: No, no, no. I'm just -- there was a problem with

13 the interpretation. I mean, not from interpreters' booth; it's a problem

14 with his explanation of that. So I just tried to clarify that. Because

15 he mentioned 1st Detachment and then the other one.

16 Q. [Interpretation] Okay, Mr. Savic. What happened at dawn on April

17 17th?

18 A. At dawn on the 17th of April, there were JNA units in town who

19 were, in fact, our lads who had been mobilised, who had been called up.

20 They moved around town disarming these smaller groups and manning all the

21 vital facilities in town, and this was the information that was available

22 to us up there on the silo.

23 Q. And where was your group at dawn on the 17th of April?

24 A. Our group remained on the silo.

25 Q. So you spent the whole day on the 17th of April on the silo?

1 A. Yes, we were there all day on the silo. All the reports or the

2 information that we received, what we could hear, was -- what I could hear

3 when I went to the artesian well to fetch water in town, when I heard that

4 they were handing over their weapons there, that people were bringing

5 their weapons and surrendering them over at the police station. This I

6 heard from people I know, from people I knew.

7 Q. Another question regarding this group which went for training:

8 Were members of this group elected on the basis of party affiliation or

9 was this strictly a matter of military categorisation or military

10 principle?

11 A. This group which went there for training was there on a purely

12 military principle basis.

13 Q. And what happened afterwards? Where were you wounded?

14 A. I was wounded on the 25th of May, 1992. We spent some time

15 there upon the silo, and we spent the time until I was wounded, or rather,

16 we were there three or four days; and from there, we went to a part of

17 Grebnice. Our unit was standing by there in order to intervene in case of

18 any casualties which needed to be pulled out, the dead, wounded needed to

19 be pulled out, so that we were there in the Grebnice and Novo Selo, Samac

20 area, and Obudovac and that area, generally, with that task.

21 So we stayed there for two to three days and were transferred to

22 the centre of Obudovac from there. There, an intervention unit was

23 established consisting of young men, mostly lads from the unit in which I

24 had been trained. We were there, and the military police. Also was there

25 from these companies, i.e. battalions.

1 Q. Tell me: Did Dr. Blagoje Simic play any role whatsoever in

2 sending you personally to that training?

3 MR. WEINER: Objection. This is direct examination. This is not

4 cross-examination. You can't ask leading questions like that.

5 MR. PANTELIC: Okay.

6 Q. Tell me, Mr. Savic: What is your personal knowledge as regards

7 Blagoje Simic, in connection with the training that you underwent? What

8 do you know about that?

9 A. My personal knowledge -- to my personal knowledge, Blagoje Simic

10 and the SDS had nothing to do with the sending of these lads to that

11 particular training course.

12 Q. Did you talk to the other young men who underwent this training?

13 Did you ask them about the phases on which they had been sent there?

14 A. Well, I did not -- I hadn't known all these guys before we arrived

15 at this camp. There, of course, we met, because we worked together, we

16 were accommodated together. And as we had not much contact with the

17 instructor other than during the training, we talked among each other. So

18 they told me that they had been summoned for training within the framework

19 of a call-up. You couldn't very well refuse a military summons at that

20 time.

21 Q. Did any one of these people who were with you mention Blagoje

22 Simic?

23 A. No, no one made any reference to Blagoje Simic, or mentioned

24 anyone else, for that matter.

25 Q. And in the end, Mr. Savic, please tell us, because you yourself

1 were severely wounded and spent a long period in hospital with treatment

2 and recovery: How many of your friends got wounded or killed during these

3 military operations at the Samac front line? Do you have an approximate

4 number?

5 A. Are you referring to the period which I spent there, until the

6 25th of May?

7 Q. No. Generally, if you know.

8 A. I know that it is a large number, but I don't know what number it

9 is.

10 Q. And until the time of your wounding, do you know how many people

11 had been wounded or killed?

12 A. I don't know. I know that we went there to pull out the dead and

13 the wounded, but as to the exact number, I don't know. I can't tell you

14 that.

15 Q. That is quite okay. Thank you.

16 PRESIDING OFFICER: Cross-examination.

17 Cross-examined by Mr. Weiner:

18 Q. Good afternoon, Mr. Savic. My name is Phillip Weiner. I'm with

19 the Office of the Prosecutor, and I'm going to ask you some questions over

20 the next 25 minutes. Okay? Do you understand that? Okay.

21 Sir, let's talk about the selection process of the soldiers, like

22 yourself, for training. You were not in charge of that training, first;

23 isn't that correct?

24 A. I have not understood the question. I'm sorry.

25 Q. You were not in charge of the training in Ilok?

1 A. No, I wasn't.

2 Q. You were not involved in selecting any of the persons to be

3 trained?

4 A. No, I wasn't.

5 Q. You were not involved in making recommendations of the persons to

6 be trained?

7 A. No, no, I was not involved in that.

8 Q. Basically, you had no responsibilities in the decision-making

9 process as to those persons who would be trained? You were just a

10 trainee. You had no decision-making -- you weren't involved in the

11 decision-making process of who would be sent to training. Correct?

12 A. Yes. I had nothing to do with that. I went there with these

13 other lads on orders.

14 Q. Okay. Now, you indicated you were a member of the SDS. Did you

15 know the defendant Blagoje Simic?

16 A. I did not know Blagoje Simic before.

17 Q. But you knew he was a leader in the SDS, local SDS leader?

18 A. I had heard this from people, because people said that he was the

19 elected president.

20 Q. Now, having not known him at the time, you weren't present with

21 Dr. Simic in any meetings that he was involved in?

22 A. I was not at a single meeting, because I was not politically

23 affiliated. I was just a plain party member.

24 Q. You weren't present with Dr. Simic in any meetings where there

25 were discussions about potential trainees; correct?

1 A. I did not attend a single meeting.

2 Q. You weren't present with Dr. Simic during any conversations that

3 he had with others, be it political leaders or military, concerning the

4 training programme or the selection of trainees; you weren't present for

5 any of those types of meetings or conversations?

6 A. I told you that I was not politically active. I was just in my

7 unit.

8 Q. My question is, if you listen to my question carefully: You

9 weren't present when Dr. Simic had any conversations with anyone else,

10 whether it's military personnel or political leaders, concerning that

11 training or the selection of trainees; you weren't present for any of

12 those conversations. Isn't that correct? Correct?

13 MR. PANTELIC: Objection. This is --

14 A. I wasn't --

15 MR. PANTELIC: -- misleading question, and this witness is trying

16 to be confused, because certain assumptions that Blagoje Simic was at

17 certain meetings with certain people in order to make this kind of

18 mobilisation is absolutely unfounded. So maybe you could rephrase your

19 question in order not to mislead this witness. Thank you.

20 MR. WEINER: There's no misleading of the witness.

21 Q. The question is: Were you present for any conversations Blagoje

22 Simic had relating to the training or trainees -- or the selection of

23 trainees? Yes or no.

24 A. No.

25 Q. And obviously, you were never present for any telephone calls

1 Blagoje Simic made relating to the training or trainees.

2 MR. PANTELIC: Objection. Calling for speculation.

3 MR. WEINER: Whether he was present or not is not speculation.

4 Q. The question is: Were you present --

5 MR. PANTELIC: The speculation is whether Mr. Blagoje Simic was

6 speaking about that or calling someone with that regard. That's

7 speculation.

8 MR. WEINER:

9 Q. Were you present, sir, for any telephone calls which Blagoje Simic

10 made relating to the training or the selection of trainees? Were you

11 present while he made any telephone calls in relation to that subject?

12 A. No, I wasn't present, because I had no opportunity to be near him

13 at all, and I don't think that he had anything to do with the assignment

14 of that group for training.

15 Q. Sir, were you present during conversations between Blagoje Simic

16 and SDS officials? Yes or no.

17 MR. PANTELIC: Objection. On which occasion? Which period?

18 With -- who was present there? What -- it's absolutely irrelevant

19 question. You have to be more specific. What is the personal knowledge

20 of this witness of such-and-such meeting where these people were present,

21 at which time, et cetera. Otherwise, it's absolutely irrelevant

22 MR. WEINER:

23 Q. Sir, were you present, prior to the notice of training, for any

24 meetings between -- or meetings or conversations between Dr. Blagoje Simic

25 and SDS officials?

1 A. I was not present at any consultation meeting, at any meeting of

2 any kind, because I was in my village. I didn't even know Blagoje Simic.

3 I only met him after I had been wounded and after I returned from hospital

4 and the recovery at hospital. The only thing which I had heard was that I

5 had heard that this man was the president of the SDA [sic]. I didn't know

6 him at all. We live several -- or were some several kilometres away. He

7 did his job at a school and I was doing mine. I had no occasion to meet

8 him.

9 Q. You said in your testimony a second ago - and I think it's a

10 mistake, and I just want to clarify the record - you said president of the

11 SDA. Do you mean president of the SDS?

12 A. My mistake. Sorry. SDS. SDS.

13 Q. Thank you. Finally, one last question on this same subject. You

14 were never present for any conversation or meeting between Dr. Blagoje

15 Simic and any military officials? And once again, this is prior to your

16 receiving notice. You weren't present for any of that; correct? You were

17 not; correct?

18 A. No, I wasn't present.

19 Q. Now, you went for training in Ilok? Am I pronouncing that right:

20 Ilok? And where is that located? Is that in Serbia?

21 A. In Croatia. It's more or less at the border.

22 Q. And who conducted this training?

23 A. The training was conducted by some instructors, by men, members of

24 special units, in camouflage uniforms, men whom we didn't know, and we

25 couldn't learn what unit was actually involved.

1 Q. Now, sir, let's continue on units. You indicated you were a

2 member of the 1st Detachment. You were aware that there were four

3 detachments until the area; correct?

4 A. Yes.

5 Q. These four detachments were part of the 17th Tactical Group?

6 A. Yes.

7 Q. Stevan Nikolic was the commander of that group?

8 A. Yes, he was.

9 Q. And there were other units in that group, including a tank or APC

10 unit from Brcko, a small tank or APC unit, and various other units in that

11 group; correct? If you know.

12 A. I don't remember.

13 Q. Now, you heard that there were volunteers from Serbia which came

14 and was added to that 17th Tactical Group, the volunteers from Serbia

15 came, about April 11th or so?

16 A. Yes.

17 Q. And were you aware that they arrived in Batkusa?

18 A. I heard in the village that they had arrived, some sort of a group

19 of about 30-odd people.

20 Q. And were you aware that they had arrived by JNA helicopters?

21 A. I didn't -- I wasn't aware, but I heard.

22 Q. And had you also heard that they were met by JNA personnel and

23 that Colonel Nikolic saw to it that they were given housing, food,

24 transportation? Were you aware of that or did you hear that?

25 A. No.

1 Q. But you didn't know where they were staying or who was providing

2 for their food or housing or any of that?

3 A. No, I didn't know. We didn't know.

4 Q. And when you talk about these Serb volunteers, you're talking

5 about the ones Crni, Debeli, Lugar, that group of Serb volunteers?

6 A. I don't know. I know that this is the group that I later heard

7 among whom were men with these nicknames that you are now mentioning, but

8 whose volunteers these were, I don't know. I know that they were there

9 and that they were under the command of the 17th Tactical Group.

10 Q. And they were brought in to assist the 17th Tactical Group?

11 A. I don't know that.

12 Q. Well, they didn't come in to fight the 17th Tactical Group; they

13 came in to be part of the 17th Tactical Group.

14 A. Well, that is probably so, but I had nothing to do with it. I was

15 not there in the command. This was not information that I was privy to.

16 Q. Okay. Now, the 17th Tactical Group was involved, as you

17 testified, in war operations or military operations early morning hours

18 April 16th, April 17th, April 18th and 19th, is that correct, including

19 the detachments, these special groups, involved in military operations

20 during those days; correct?

21 A. The 17th Tactical Group was the command, and they did the

22 commanding. It was at their orders that I went to the silo.

23 Q. And your small group wasn't the only group that was out there;

24 there were other groups that apparently had been ordered out, because you

25 saw 4th Detachment people. There were other groups of people from the

1 17th Command [sic] also out there during the 16th, 17th, and 18th and

2 19th?

3 A. Yes.

4 Q. Now, did you see these camouflage people, while you were up in

5 these silos, moving around, the 16th, 17th, 18th? Does it come -- these

6 camouflage people, did they come from Serbia, moving around the city,

7 during those days?

8 A. Are you referring to these camouflage uniforms?

9 Q. Like the Serbs from Serbia were wearing, that special group with

10 the camouflage uniforms, did you see them moving through the city from --

11 that were part of the 17th Tactical Group, on the 16th, 17th, 18th, and

12 19th of April?

13 A. Yes.

14 Q. And would you agree with me that the various groups within the

15 17th Tactical Unit were coordinating their activities? Such as your

16 group, the 1st Detachment, was up in the silos; another group was guarding

17 the bridge; another group was on the waterfront. So the various units

18 were being coordinated by the commanders. Or you were told what to do by

19 your commander --

20 A. Yes.

21 Q. -- and you relieved the 4th Detachment that was at the silo, or

22 did you work together with them at the silo?

23 A. I think that we were together, as far as I can recollect.

24 Q. So your commander sent you to the silo. So the 1st Detachment --

25 members of the 1st Detachment were sent to the silo, and whoever was in

1 command of the 4th Detachment sent some of their people to the silo;

2 correct?

3 A. That's correct, because I saw them there.

4 Q. And obviously, you have to do what your commanders tell you to

5 do.

6 A. Naturally.

7 Q. And as you know, in the JNA army, there's a chain of command, or

8 there was at that time -- while the JNA was in Bosnia, there was a chain

9 of command.

10 A. Yes.

11 Q. And you had Colonel Nikolic, of the 17th Tactical Group, in

12 charge. He had -- correct? Colonel Nikolic was in charge of the 17th

13 Tactical Group and he gave orders downward and eventually got to the

14 soldiers, like yourself, and you were told what to do; correct?

15 A. Yes.

16 Q. And you couldn't just disobey the orders of the commander; you did

17 what you were told to do, obviously.

18 A. Yes.

19 Q. And even the group that came in from Serbia was part of the 17th

20 Tactical Group, which answered to Colonel Nikolic?

21 A. Yes. There were -- yes, they were there under that command.

22 Q. Okay. Then eventually the military unit changed because the JNA

23 was ordered out, in May, and the army of the Republika Srpska was

24 established; isn't that correct? If you know.

25 A. Yes.

1 Q. And those groups that were part of the 17th Tactical Group became

2 part of the 2nd Posavina Brigade -- I'm sorry. 2nd Posavina -- yes, 2nd

3 Posavina Brigade.

4 A. Yes.

5 Q. And that also had a chain of command, or a disciplined order to

6 it, as any army would?

7 A. Yes.

8 Q. And it ran from, in the chain of command, from the soldiers, or

9 privates, all the way up to the top, to General Mladic, who was the chief

10 commander, or the general in charge?

11 A. Yes.

12 Q. And between General Mladic and the soldiers, you had people of

13 various ranks?

14 A. Yes.

15 Q. And within this 2nd Posavina Corps [sic], you had -- were the four

16 detachments - the 1st Detachment, 2nd Detachment, 3rd, and the 4th - from

17 Samac?

18 A. There were already battalions in existence then.

19 Q. But you had -- what used to be those detachments were now in that

20 2nd Posavina Brigade. And were you aware that Crni, or Dragan Djordjevic,

21 was even made commander in May, of that whole brigade, of the 2nd Posavina

22 Brigade, Dragan Djordjevic, whose nickname was Crni; one of the people

23 from Serbia was named the commander?

24 A. I heard that he had been nominated, and then immediately following

25 his nomination, I was wounded and I left. So I'm not fully familiar with

1 that, because I sort of skipped over that period.

2 Q. But before you were injured, you had heard that he had in fact

3 been nominated to be the commander of the brigade?

4 A. Yes.

5 Q. As a result, all the soldiers within the brigade had to answer up

6 the line, eventually to Crni, or Dragan Djordjevic, if he took that

7 position. Because he was the commander, you would have to do what he

8 said.

9 A. We had to carry out those tasks.

10 Q. And in carrying out those tasks, the different soldiers in,

11 whether it was the 17th Posavina Group - I'm sorry - the 2nd Posavina or

12 the 17th Tactical Group, had to work -- had to follow their orders and

13 work together, had to coordinate their activities when they're told to do

14 so?

15 A. Yes.

16 Q. And as part of the coordination, you all had radios so you could

17 communicate with each, or different groups had radios so you could

18 communicate; isn't that true?

19 A. Yes.

20 Q. And let's just finish off with that one period of April 16th,

21 17th, 18th, and 19th. You said you saw the camouflage people out there.

22 A. Yes.

23 Q. You saw the tanks arrive, the JNA tanks?

24 A. We saw one tank in the morning, after the dawn, by the silos.

25 That's where it was.

1 Q. You saw one JNA tank, and as I said, you had radios. The radios,

2 you used them with the same frequency so you could talk with each other?

3 A. I didn't have it, because I was not involved in establishing

4 communication. I heard it from our commander.

5 Q. The radios that the commanders were using had the same frequency

6 so they could talk with each other and coordinate their activities?

7 A. Probably so, but I had nothing to do with communications.

8 Q. I know you had nothing to do with it. I'm just saying that

9 because -- for an army to function, you have to use the same radio

10 frequency, obviously, as you know, having been in the military. Correct?

11 A. Probably so. I was a driver in the army, and again, had nothing

12 to do with communications.

13 Q. And all these different groups, whether it was the tank, the 1st

14 Detachment, the 17th Detachment, the specials from Serbia, you were all

15 coordinating and working together to fight the enemy; correct?

16 A. We did not command; we were issued orders, and we fought the

17 enemy.

18 Q. You were issued orders and you were all working together, after

19 being issued orders, to fight the enemy; correct?

20 A. There was no combat there.

21 Q. Well, you were working together, or you were coordinated to defend

22 the city and be prepared to fight, then; isn't that correct?

23 A. In order to defend the city.

24 Q. And, like any other army, you got your orders and everyone was

25 working together in a coordinated effort, which is the plan of operation

1 of any army; correct?

2 A. I don't know how the planning is done. I suppose that the

3 Superior Command does the planning, and we simply had to carry out the

4 orders.

5 Q. Well, following the orders, everyone had certain assignments to

6 do, and they're coordinated, because everyone's doing a certain job or

7 chore or assignment; isn't that correct?

8 A. Yes.

9 Q. Thank you very much.

10 PRESIDING OFFICER: Re-examination.

11 MR. PANTELIC: Yes. Thank you.

12 Re-examined by Mr. Pantelic:

13 Q. [Interpretation] Mr. Savic, perhaps there's a misunderstanding

14 here or the question was not quite specific, the question of my colleague

15 Prosecutor which had to do with combat. You said that on the -- that from

16 the Croatian side, a shell was fired at the silo.

17 A. Yes.

18 Q. You also said there were skirmishes and occasional firing during

19 the night between the 16th and 17th of April, in Samac.

20 A. Yes.

21 Q. Do you know where the bunker was located by the bridge? Was there

22 any firing from there directed at Samac?

23 MR. WEINER: Madam Presiding Officer --

24 MR. PANTELIC: I withdraw.

25 MR. WEINER: -- I did not raise --

1 MR. PANTELIC: I withdraw. I withdraw.

2 Q. [Interpretation] So this is what we mentioned. Is this your

3 understanding of a combat operation? Is this combat?

4 A. Yes.

5 Q. Just one more question. From the 17th on, was Samac shelled?

6 Were shells landing?

7 A. Yes, they were. There was firing from Slavonia and from Prud.

8 Q. From the 17th on, was the front line established, the defensive

9 front line around Samac? Or rather, were ... END OF RECORDING ...

10 positions there set, facing enemy lines?

11 A. Yes.

12 Q. What do you personally know regarding the link between the SDS and

13 the 17th Tactical Group? I would like to know whether the SDS in any way

14 participated in operations of the 17th Tactical Group.

15 A. According to what I know, the SDS did not cooperate with the 17th

16 Tactical Group.

17 Q. What do you know about whether Blagoje Simic, as an individual,

18 acted in cooperation with the 17th Tactical Group?

19 A. I have no knowledge about that, but this was never mentioned.

20 There were no rumours to this effect either.

21 Q. Thank you, Mr. Savic. We've completed our examination.

22 PRESIDING OFFICER: Thank you, Mr. Savic, for coming. You can go

23 now.

24 THE WITNESS: [Interpretation] Thank you.

25 PRESIDING OFFICER: We'll start again at 10 to 2.00.

1 [The witness withdrew]

2 --- Luncheon recess taken at 12.34 p.m

3 --- On resuming at 2.16 p.m.

4 [The witness entered]

5 WITNESS: MITAR NIJEMCEVIC

6 [Witness answered through interpreter]

7 PRESIDING OFFICER: Good afternoon, Mr. Nijemcevic. Would you

8 please stand and take the solemn declaration.

9 THE WITNESS: [Interpretation] Good afternoon.

10 I solemnly declare that I will speak the truth, the whole truth,

11 and nothing but the truth.

12 PRESIDING OFFICER: Mr. Pantelic.

13 Examined by Mr. Pantelic:

14 Q. [Interpretation] Good afternoon. For the record, please tell us

15 your full name.

16 A. Good afternoon. My name is Mitar, father's name Stojan, surname

17 Nijemcevic. I was born on January 1st, 1963, in Samac.

18 Q. Are you married, and do you have any children?

19 A. I am married. I have two children.

20 Q. What is your ethnicity?

21 A. I am a Serb.

22 Q. Have you completed secondary school of mechanical engineering in

23 Samac?

24 A. Yes, I did.

25 Q. You did your military service in the JNA, and you were in

1 artillery rocket units and anti-air defences?

2 A. Yes, I served in Kraljevo.

3 Q. Having completed your military service, you became a reservist,

4 and your rank in the reserve is lieutenant, second lieutenant?

5 A. Yes. That is from the former JNA, and I have not been promoted

6 since.

7 Q. Immediately prior to the outbreak of armed conflict in the

8 territory of Samac municipality in April 1992, you were the head of a

9 building material warehouse in the village of Struke, near Prud? That is

10 where your family home is too, in Struke, isn't it; that is where you

11 lived?

12 A. Yes, until the outbreak of the conflict I was there, and then in

13 Samac.

14 Q. During the state of war, having left Struke, just before the

15 beginning of the conflict, or round about then - but you will explain that

16 later for us - your house was destroyed, so actually, you're no longer

17 living in Struke?

18 A. That's right. My house was destroyed, so I'm now living in Samac,

19 yes.

20 Q. You're living with your family and your wife's parents, if I'm not

21 mistaken.

22 A. Yes, that's right.

23 Q. What is your current occupation?

24 A. I'm working in a metal farm called Njegos, in Samac, producing

25 metal, electrical equipment, boilers and things like that.

1 Q. In the period from mid-April 1992 up until the end of May 1992,

2 you were a member of an intervention unit within the 17th Tactical Group?

3 A. Yes, I was, briefly.

4 Q. You were wounded for the first time on the 27th of May, 1992?

5 A. Yes, I was.

6 Q. And for the second time, on the 12th of December, 1992?

7 A. Yes.

8 Q. After treatment was completed, you were found to be 70 per cent

9 war disabled; is that right?

10 A. Yes.

11 Q. Mr. Nijemcevic, before we move on to your testimony linked to a

12 meeting that took place in your home, will you please, in a few sentences

13 only, give us some background to this event and describe for us the

14 situation in your village of Struke in the month of March, with respect to

15 relations between Serbs and Croats, and so on.

16 A. Struke is a very small place, consisting of some 20 households.

17 There were about 18 households and 20 houses -- no. I'm sorry. There

18 were 20 households, of which two were Croat, 18 Serb. There was some

19 tension between the parties, so that I felt that we were in jeopardy. On

20 the one hand there was Odzak, and to the other side there was Prud, so

21 that we were sort of closed in on both sides, so that two or three times a

22 conflict occurred amongst us; actually, between the inhabitants of Struke

23 and those of Dubica and Prud.

24 Q. Did you notice any fortifications, weapons, on the river banks and

25 in the immediate surroundings of Struke, in March?

1 A. Yes. Since my house was right next to the main road, there was an

2 embankment which protected the village from the flooding of the Bosna

3 River, and along that embankment, just before the war, that is, in March,

4 there were artillery weapons dug in by the Croat or Muslim forces.

5 MR. DI FAZIO: Madam Presiding Officer, I just need to register my

6 objection to this evidence. We are now straying. I've been waiting for

7 us to get to the two topics that are clearly delineated in the filing that

8 was the joint defence motion in respect of Rule 71. The filing was very

9 specific. There are two topics mentioned, namely, whether or not Blagoje

10 Simic discussed or mentioned the division of the municipality; and

11 secondly, the presence of one of the Prosecution witnesses at a particular

12 meeting and the circumstances under which the defendant Blagoje Simic

13 appeared at that meeting. Those two topics have not yet been reached.

14 We're now moving into an area regarding the fortifications and placing of

15 arms by the Croatian forces. That is well outside, well outside, of the

16 two topics, and I object to this evidence and submit that Mr. Pantelic

17 should now direct the witness, having settled the witness and obtained the

18 necessary personal details, directly into those two topics that are

19 clearly delineated in the joint defence motion made in respect of Rule 71.

20 MR. PANTELIC: Just for the record, in response to the

21 Prosecution's submission, I believe that this short evidence with regard

22 to the atmosphere in the village of Struke immediately prior to the

23 meeting, which is actually the topic that we shall discuss in a few

24 seconds, is necessary in order to know background of the situation by

25 itself, and then we shall hear the explanation of this witness with regard

1 to the discussion, so that meeting, presence of various persons,

2 et cetera. So just for the record, that is my suggestion.

3 MR. DI FAZIO: Very well, Mr. Pantelic. If we could get on to the

4 establishment of the checkpoints. We all know the evidence of the witness

5 and how the meetings came about and the reason for the meetings. And then

6 we can go directly to those two topics, and that will save time and also

7 mean that the Prosecution won't be standing up and objecting.

8 MR. PANTELIC: That is indeed my intention, and in fact my next

9 question after this explanation will be strictly focused to this

10 particular meeting. So it's just an introduction, as I would say.

11 PRESIDING OFFICER: Mr. Di Fazio, are you moving to strike these

12 portions you've just mentioned, or ...

13 MR. DI FAZIO: No.

14 MR. PANTELIC: Okay.

15 Q. [Interpretation] So, Mr. Nijemcevic, we are coming now to the

16 event for which you have been called here to testify in the defence case

17 for Blagoje Simic. During these proceedings, a certain episode was

18 interpreted in a particular way. We would now like to hear from you what

19 happened.

20 My first question is: Could you tell us whether, in March - and

21 you will tell us which part of March - in your house, in the village of

22 Struke, a meeting was held. Was a meeting held in your house?

23 A. Yes, it was, around mid-March 1992.

24 Q. What was the reason for convening that meeting?

25 A. At the beginning of March, we had some unfortunate incidents

1 caused by inhabitants of Dubica and some inhabitants of Prud. We are a

2 very small locality. So they were afraid of the army, and we were a

3 buffer for them. So they feared that if we left, the army would come in.

4 And on two occasions, we had negotiated with them, but there was one

5 access after another, and it became more and more difficult. And then

6 this meeting was convened to calm the situation down.

7 Q. When you say "they," do you mean the Croats?

8 A. Yes. Yes.

9 Q. And when you say "we," you mean the Serbs from Struke?

10 A. Yes, some ten inhabitants. It's a very small hamlet, in fact. It

11 was a hamlet attached to Prud.

12 Q. Mr. Nijemcevic, in that period of 1992, were you a member of any

13 political party?

14 A. No, I was not, and I am not a member of any party today, nor do I

15 intend to become one.

16 Q. So you have never been a member of any party?

17 A. That's right, and I believe I never will be a member.

18 Q. Tell me: What was the motive for that meeting to be held in your

19 house?

20 A. My house has a rather specific position. It is somehow in a

21 neutral position, along the line separating Prud and Dubica. And because

22 there was a large enough room to receive several participants, or a number

23 of participants. That was the reason.

24 Q. Please tell me now: If I understood you correctly - but please

25 correct me if you feel I'm wrong - so you and the others decided to hold

1 this joint meeting in order to deal with these ethnic tensions and

2 problems that were present between the Serb and Croat populations?

3 A. It wasn't I who decided about that meeting, but somebody else,

4 Milan Rakic, a man who was killed, probably in agreement with somebody

5 called Matanovic. I think he was from Odzak. And there were also

6 representatives of the Croats and of the Serbs, that means of Prud,

7 Dubica, Vojskova, and Struke.

8 Q. So you were a kind of host of the meeting and not the initiator?

9 A. Yes, of course I was the host, yes, but I was really serving my

10 guests with coffee and drinks.

11 Q. Mr. Nijemcevic, will you try, though I know it was a long time

12 ago, try and tell us now, with regard to the Serb representatives from the

13 area, which persons attended that meeting. Slowly, for the record, so we

14 can note down the surnames, if you remember, of course.

15 A. Yes, I remember some surnames. I remember this Milan Rakic, from

16 Novi Grad; I remember Rajko Djuric, I think his surname was.

17 Q. Did he have a nickname?

18 A. Yes. Truman, Truman. That was his nickname. He very briefly --

19 Miro --

20 Q. We'll come to that.

21 A. -- came in very briefly.

22 Q. But among those who attended the meeting -- so you told us these

23 two names. Can you remember anyone else?

24 A. Milic from Dubica, Ljubisa Djuric, and I think Sreten, and another

25 man. I can't remember his name.

1 Q. So those were representing the Serbs?

2 A. Yes, but for the purpose of an agreement, of an easing of

3 tensions, things like that. The meeting itself was organised by this

4 Milan Rakic.

5 Q. Very well. Now tell us, please: On the Croatian side, who do you

6 remember attending that meeting?

7 A. From Vojskova, there was this Matanovic. Actually, I think he's

8 from Odzak. I think his name was Ivica and I think he was an officer.

9 Then from Vojskova, Caktas [phoen]; and another one, Bono, known as Guda

10 [phoen]. I don't know his surname. From Prud, there was Zoran Obrenovic;

11 and another man, I think it was Anto Pepic. But these were more or less

12 observers, actually. Because Ivica Matanovic, he really represented them

13 at that meeting, probably.

14 Q. Was he an officer? Did he have a military position?

15 A. I think he was an officer, yes.

16 Q. Tell me: And from Prud, did anyone attend?

17 A. This Zoran Obrenovic and Anto Pepic.

18 Q. Was a Mijo, known as Mis, present too?

19 A. Yes, he was there too.

20 Q. Who was this Mijo?

21 A. I think he was an officer in reserve too. I didn't know him very

22 well, really. We were neighbours, that's true, but we didn't really know

23 each other; we just said hello. I think the man is an active military man

24 in the army of the Federation now.

25 Q. So those were the persons that you listed as Croats, representing

1 the other side; is that right?

2 A. Yes.

3 Q. Tell me, please: Do you know a person by the name of Blaz

4 Paradzik?

5 A. Yes, I do.

6 Q. Where is he from?

7 A. The man is from Prud.

8 Q. Did you know him personally? Would you see him often?

9 A. I would see him. We didn't socialise, we didn't have any

10 particular contacts, but I do know the man. Why? Why? Has he done

11 anything?

12 Q. Well, he says that he attended that meeting. That's why I'm

13 asking you.

14 A. Blaz? No. No, no.

15 Q. So my question now: Did Blaz Paradzik attend the meeting that you

16 are now describing, held in March 1992, in the presence of all these

17 people?

18 A. No, he did not.

19 Q. Could you explain briefly the topics discussed at that meeting.

20 What did you talk about, and what conclusions were reached, if any?

21 A. The main and only topic, in fact, was to ease tensions and avoid

22 excesses, and for us to be allowed passage from our village to Samac, and

23 vice versa, to Odzak, because we couldn't get out anywhere.

24 Q. When you say "we," who do you mean?

25 A. I mean the Serb side. I mean the villagers of Struke.

1 Q. And what was the position of the Croatian side?

2 A. The Croatian side kept repeating that if the villagers of Struke

3 move out, the army would come in, and they were afraid of the army. And

4 in the end, the agreement was that they would allow women and children to

5 leave, and some 10 to 12 men that there were, aged between 15 and 70,

6 those 12 of them, should stay behind as some sort of guarantors. And

7 that's how it was.

8 Q. So I understand that the women, children, and the elderly Serbs

9 from the village were allowed by the Croats to cross to Samac.

10 A. Yes, but they succeeded the third time they tried.

11 Q. So how long did this take, roughly?

12 A. From the beginning of March until sometime at the end of March.

13 MR. DI FAZIO: I don't object, but that evidence is unclear, and I

14 suggest it should be clarified. Is the witness saying that these

15 negotiations were ongoing throughout March, leading to the departure of

16 these people throughout the period of March, on frequent occasions? That

17 will be necessary for the Trial Chamber to have a good understanding of

18 what this witness is saying.

19 MR. PANTELIC: Yes, yes. I'll clarify that.

20 Q. [Interpretation] Mr. Nijemcevic, I understood you to say that

21 after two attempts -- at the third attempt it was agreed that the women

22 and children could leave. Did they all leave in different periods or all

23 in one group? Could you indicate that? When you said the third time

24 round --

25 A. The meeting that was held at my home was the meeting at which it

1 was agreed that the children and the elderly and women could leave. There

2 were some sort of informal meetings and discussions on the road two or

3 three times, and after two or three attempts, the women and children were

4 still not allowed to leave. And throughout the month of March, there were

5 no more meetings, but simply two men from Prud, who were very fair and

6 correct, they had the greatest merit for the final permission that was

7 given to the women and children to leave.

8 Q. Tell me, please: And when did this happen in relation to the

9 meeting? When did they actually leave? After the meeting?

10 A. Yes, after the meeting.

11 Q. Talking about that, your wife and children -- I don't know whether

12 you had children in those days.

13 A. Yes, I did.

14 Q. When did they cross over into Samac?

15 A. Before the meeting. Before the meeting, across the Bosna River,

16 by boat.

17 Q. In a boat. Why didn't they use the bridge leading to Samac?

18 A. It was not possible to reach the bridge, because there were

19 checkpoints along the river.

20 Q. Who held those checkpoints?

21 A. The so-called reserve policemen, that is, the locals from Prud.

22 We reached the bridge; however, they turned us back, on the pretext that

23 if we left, this army would come in. That was their excuse all the time.

24 Q. Did you consider yourself to be some sort of hostages?

25 A. Well, something to that effect. When you don't have freedom of

1 passage and you can't leave, that's what it is, isn't it?

2 MR. DI FAZIO: Madam Presiding Officer, I object to that last --

3 the content of that last answer. I'd move for that to be struck out.

4 We're now moving beyond attendance at the meetings that are described in

5 the summary and to the actual substance of events in the area of Prud and

6 Bosanski Samac during the month of March. The summary is very specific,

7 very, very clear and very specific: It's those two meetings in the

8 presence of people. That's what we're -- that's what the summary is about

9 and that's the areas that I submit that Mr. Pantelic should confine

10 himself to.

11 MR. PANTELIC: No comment from the Defence side. I will proceed

12 with the other topics.

13 Q. [Interpretation] Mr. Nijemcevic, in your previous answer you

14 mentioned Miro Tadic as having come by. Tell me first: Do you know Mr.

15 Miroslav Tadic, known as Brko?

16 A. Yes, I do. He was my teacher in secondary school. He taught --

17 he gave practical training lessons.

18 Q. Tell us, in connection with that meeting, what his role was. Did

19 he attend the meeting?

20 A. Very briefly, Mr. Tadic dropped in for five to ten minutes. He

21 said hello to Rakic and Matanovic, he had his coffee and left. Now, where

22 he went, I don't know.

23 Q. Who did he come with to your home? Did he come alone or in

24 somebody's company?

25 A. No. He came alone.

1 Q. Do you know Dr. Blagoje Simic?

2 A. Yes, I do.

3 Q. What can you say about his presence at that meeting, Blagoje

4 Simic?

5 A. Dr. Simic came maybe five or six hours after Tadic, in the

6 afternoon. He stayed 15 to 20 minutes. The talks were almost over.

7 Again, the man exchanged greetings, had his coffee, and left. Now, where

8 he left, I don't know.

9 Q. While he was present in your house, did Dr. Blagoje Simic say

10 anything to the effect that Samac municipality needed to be divided: a

11 part should belong to the Serbs and another part to other peoples? Did he

12 say something like that at that meeting?

13 A. No, he didn't. Dr. Simic, when he arrived, he said hello and he

14 said, jokingly, that we should come to some sort of agreement so that

15 problems should be avoided. But there was no mention of any divisions.

16 Q. Did Dr. Blagoje Simic on that occasion mention the founding of the

17 Serbian Municipality of Bosanski Samac?

18 A. No, though I'm not in any party, but on that occasion, no such

19 things were mentioned.

20 Q. Did Dr. Blagoje Simic at that meeting speak about the expulsion of

21 non-Serbs from Samac on the part of the Serbs and as a result of their

22 policies?

23 A. First of all, we wouldn't have let him say anything like that,

24 because of the position we were in, and he didn't.

25 Q. Did Dr. Blagoje Simic on that occasion speak of discrimination

1 towards other ethnic groups, towards Croats and Muslims?

2 A. No, that was not the topic of discussion at all.

3 PRESIDING OFFICER: Mr. Pantelic, you have two more minutes to

4 finish, because of the objections.

5 MR. PANTELIC: I just finished my examination-in-chief. Thank

6 you, Madam Presiding Officer.

7 [Interpretation] Thank you, Mr. Nijemcevic. I've finished my

8 examination. The Prosecutor will have a few questions for you now, after

9 which I will have some more. Thank you.

10 Cross-examined by Mr. Di Fazio:

11 Q. Mr. Nijemcevic, my name is Di Fazio. I've just got a few

12 questions for you. I won't be long.

13 A. Yes. No problem.

14 Q. Because of the position of your house, it was a good idea to hold

15 these meetings there, between Croatians who lived in Prud and Serbs who

16 lived in Struke?

17 A. Yes.

18 Q. And in fact, I believe Struke and Prud are, although separate

19 villages, or small towns, are in fact -- they looked as if they're linked

20 because the buildings are clustered close together. To someone who didn't

21 know the ethnicity of the inhabitants, it might look as if it's all part

22 of the one small town; is that a fair assessment of the way it looks?

23 A. No. Prud and Struke are along the border dividing two places, and

24 there is an interspace of about 1.000 or 1.500 metres, dividing Struke and

25 Prud.

1 Q. I see. Okay. Thank you. But in any event, the best place to

2 hold the meeting was at your house?

3 A. Not the best place, but this was some sort of a crossroads, of a

4 rallying point centre, and everybody came there, so it was the most

5 favourable spot from that point of view.

6 Q. Right. You say it was a rallying point and a centre and everyone

7 came there. Do I take it that in those troubled times, in early 1992,

8 quite a few meetings were held there?

9 A. No. One meeting was held in my house, and there was a sort of an

10 informal meeting which was held outside, in the street, on the road, as it

11 were.

12 Q. Near your house?

13 A. Yes, some 100 or 200 metres away from my house, practically in the

14 street.

15 Q. Thank you. You spoke of the attempts to reach agreement with the

16 Croats from Prud regarding the departure of Serbs from Struke, and you

17 said that on the third attempt there was an agreement reached. Does that

18 mean that on at least three occasions you spoke to each other, the groups,

19 the Serbs and the Croats, regarding this issue?

20 A. Mr. Rakic talked with them on our behalf. We personally did not.

21 It was Mr. Rakic who conducted this talk with Mr. Matanovic, who probably

22 was the representative of the Croats.

23 Q. And meetings were held in other houses in the area of Struke, and

24 maybe even Prud, regarding this issue, this matter?

25 A. No, not in Struke. No other meetings were held at Struke.

1 Probably somewhere in the area or some other area, some other houses.

2 This is something that I don't know about.

3 Q. Now, on the day of this meeting that you've given detailed

4 evidence about, how many men in all would you say were present in your

5 house?

6 A. Well, a rough estimate would be about 20 people.

7 Q. Right. And that would -- I assume all made up of either Struke

8 residents or Prud residents.

9 A. From Struke, there were four or five people. From Odzak, Dubica,

10 Prud, Vojskova, there were more of them. There were more people from the

11 Croatian and Muslim side. There were two men from the Croat side, from

12 Odzak, whom I didn't know, but there were more people from the Croatian

13 side.

14 Q. And no doubt this was a reasonably tense time for you because you

15 had to host them, look after these men, make sure that they were all

16 looked after and they could carry on the business of trying to sort out

17 this issue.

18 A. I don't know what you mean. Perhaps I don't understand the

19 question.

20 Q. You were hosting the meeting and you had to look after the needs

21 of these men who were gathered there?

22 A. I didn't have any specific needs to look after. I just made them

23 coffee and served a drink, as I would entertain any other guests in my

24 house, whether I was the host or anybody else in the household.

25 Q. Thank you. And the house, I take it, was crowded with 20 or so

1 men?

2 A. Yes, roughly.

3 Q. And Blaz Paradzik, you didn't know him very well, did you?

4 A. No, I did know him.

5 Q. I know. I've heard your evidence. I know that you knew him. But

6 you didn't know him very well, did you?

7 A. Yes. I don't know what you mean exactly when you say "very

8 well." We didn't socialise. We would just say hello to each other,

9 nothing more than that. We didn't have a -- we were not on close terms,

10 but I know his face and I know how he looks.

11 Q. I'm not suggesting you don't. And those times were fairly

12 troubled times, weren't they, fairly tense times, for you personally and

13 also for the inhabitants of Prud and Struke, and in fact the whole area?

14 A. I think that the times were much harder of the villagers of the

15 village of Struke than those in Prud because we were only 10 or 12

16 households. The tensions were mounting, as is normal in war conditions.

17 Q. You can't tell us the names of each and every one of those 20

18 men. You can tell us some of the men who were there. Is that a fair

19 assessment?

20 A. Well, as regards those from the villages which were near my own

21 village, I know those people. And also on the Odzak municipality and the

22 Posavska Mahala area and Svilaj.

23 Q. [Previous translation continues] ...

24 A. Well, I didn't know the people well enough, and I couldn't

25 remember their names. This is an area which is a bit off. It is some 20

1 kilometres away from my own village, and I didn't go there much, so I

2 didn't know the people well.

3 Q. Right. And it seems that the people who were present at the

4 meeting, it wasn't a static group; it was -- people were coming and going;

5 at least, Miro Tadic and Blagoje Simic came briefly and left?

6 A. Nobody came in a compact group. These two men, Matanovic and

7 Rakic, were negotiating each on behalf of their people, and others came

8 and went. And no, they did not come in compact groups.

9 Q. That's right. People were coming and going, and coming to see how

10 the meeting was going and how it was proceeding. It's not as if 20 men

11 arrived all at once and left all at once; people were coming and going.

12 A. No, no. It wasn't that 20 of them came together. They kept

13 coming within a space of perhaps an hour. But they did all leave

14 together. Dr. Blagoje just dropped in for a while, and he left before the

15 meeting ended. There was a slight incident between Mr. Rajko Djuric and

16 Mr. Matanovic. They had an altercation of sorts. And the meeting was

17 over at that point, so that everybody dispersed. And afterwards, Mile

18 Rakic, after a couple of days, that is, came and told us that the

19 vulnerable categories of people - women and children - could go, could

20 leave.

21 Q. Okay. Thanks for explaining that. Well, in those circumstances,

22 do you think you might be mistaken when you say that Blaz Paradzik wasn't

23 there, if people are coming and going and some of the people are

24 strangers, and it's 10 or 11 years ago? Do you think you might have made

25 a mistake?

1 A. No. No. I know exactly who was there from Prud, because these

2 were people that I went to school to accept for this papage [phoen]. And

3 I know my generation well. Blaz is a bit older than me or perhaps my

4 age. I'm not quite sure. But I knew him. I couldn't have made that

5 mistake, because I was right by the door, so I saw practically everyone

6 who came in and went out, and I was also there to be near the kitchen, in

7 order to be able to serve the coffee, so I saw all the going in and out.

8 Q. Right. Very well. What did Miro Tadic do at the meeting? I know

9 he came and had coffee and was only there for five to ten minutes. That's

10 what you said. Is that all that he did at the meeting?

11 A. That is all. In fact, we didn't know that Miro Tadic had come.

12 We were surprised. He just dropped in for 10 to 15 minutes, had a coffee

13 and a glass of brandy, and he left. I think that Miro Tadic either went

14 to stay with his family down in Novi Grad, for lunch or -- I don't know

15 where he went from there. But it is possible, seeing that that house is

16 by the road, by the main road, it is possible that he went down there to

17 stay with his relatives.

18 Q. Do you know him very well, or did you know him very well in 1992?

19 A. I knew him from school as a teacher. He was a practical

20 instruction teacher. We were not on very close terms, nor did we meet

21 often, or socialise. I just knew the man by sight, but not -- we were not

22 very close. I know that he was a good teacher, that he liked to crack a

23 joke; not much more than that.

24 Q. Sure. And in those circumstances, of course, he obviously,

25 plainly, was not coming to visit you; he was coming to see what was

1 happening at the meeting. Right?

2 A. I really don't know what was the reason why he came to the

3 meeting. As I said before, we were surprised to see him there, because

4 that man had never even dropped in my store before, let alone my house.

5 So we were really surprised.

6 Q. Of course. Of course. Naturally. And that must mean, therefore,

7 that he knew of the meeting going on, and he came to the meeting to see

8 what was happening at the meeting, not to visit you. He wasn't a friend

9 of yours who would drop in at the house.

10 MR. PANTELIC: Objection. Calling for speculation.

11 MR. DI FAZIO: Madam Presiding Officer, I think the witness is in

12 a position to comment on the purpose of the -- of Mr. Tadic's presence at

13 the meeting, or at least to be able to negate personal visit as a reason

14 for his attendance at the meeting, and it's that negation that I'm

15 interested in, and I'll therefore proceed with the question, and the Trial

16 Chamber will eventually rule on the matter.

17 MR. PANTELIC: Just for the record, this witness cannot know why

18 the other person is coming or what was the reasons. Maybe the proper way

19 would be to rephrase questions or to follow some more appropriate

20 questions.

21 MR. DI FAZIO: I'll approach it in the negative.

22 Q. You can be sure, can't you, that he wasn't coming there to visit

23 you personally; he had never done that before?

24 A. Well, I tell you: I don't know why he came there, why Miro came

25 there. I cannot give you a reply, because I really don't know the answer

1 to that question.

2 Q. Now, what about Blagoje Simic? Was he a close personal friend of

3 yours?

4 A. No, he wasn't.

5 Q. Had he ever visited you at your house?

6 A. No, he hadn't, not ever before. That was the only time that he

7 came by, and that was late in the afternoon. He -- Miro was there for 10

8 to 15 minutes, and the meeting -- which was about 10.00 or 11.00, and

9 Blagoje then dropped in sometime in the afternoon, about 5.00 or 6.00 p.m.

10 And he talked more to Mr. Rakic and Mr. Matanovic than anybody else; what

11 about, I don't know. And as for territorial divisions or a Serbian

12 municipality, I can guarantee you with my life that that was not a topic

13 of this meeting, and Blagoje contributed nothing of the sort to the

14 meeting. After Blagoje had left, there was this small falling out between

15 Mr. Rajko [phoen] and Mr. Matanovic, and the meeting ended abruptly the

16 way it did.

17 Q. You are absolutely certain, aren't you - this is your position,

18 cast-iron, guaranteed, clear certainty - that they arrived at different

19 times, even though, of course, the meeting happened 11 years ago and

20 people were coming and going all day long?

21 A. I am, precisely. Miro came first, there for 10 to 15 minutes,

22 roughly about 10.00 or 11.00, and Blagoje came later, in the afternoon, as

23 I've described.

24 Q. Right. And of course, no doubt you could tell us the precise

25 times of all the other people who dropped in as well.

1 A. No, not the precise times, but I could tell you who arrived

2 first. Mr. Matanovic and Mr. Rakic, for instance, arrived first, the two

3 of them. They were up there by my store, and after a meeting of a group

4 of about ten people had assembled, then they all came to the house. And

5 then all of the rest came in intervals, from the morning hours -- in

6 intervals, from the morning hours, about 10.00 or 11.00 in the morning, to

7 4.00 or 5.00 or 6.00 in the afternoon. I don't know when the meeting

8 exactly ended, but it was in the afternoon hours.

9 Q. However, one thing is absolutely certain: You have perfect

10 clarity of memory as far as the fact that both Tadic and Simic, Blagoje

11 Simic, arrived separately?

12 A. Yes. That is 1.000 per cent so.

13 Q. That's very impressive. Thank you very much.

14 Now, Mr. Blagoje Simic was, of course, at that time a leading

15 community figure, wasn't he, because he was the president of the SDS in

16 the area? He was a politician of some rank, wouldn't you say?

17 A. First of all, I primarily know Blagoje as a doctor, and I'm not

18 engaged in politics or involved in it in any way. I'm not affiliated to

19 any party. I'm not interested in the subject, in politics, at all.

20 Q. Thank you. Thank you for letting us know that. However, I'm not

21 actually asking you about your interests, whether you're interested in

22 politics or not. I'm not asking you that. What I'm asking you is this:

23 Blagoje Simic was a well-known political figure in the area. He was

24 president of the SDS, wasn't he?

25 A. Well, I know Blagoje Simic as a physician. Whether he was the SDS

1 president, that I'm unable to tell you. I don't know.

2 Q. Okay. Now --

3 A. His party affiliation was of no interest to me. That's what I'm

4 saying. So I don't know whether he was the president of the party.

5 Q. So your evidence is that you don't know what reputation he held in

6 the community, you don't know how well known he was. All you know is that

7 he was a doctor, is that right, a doctor who lived in Bosanski Samac, a

8 simple country doctor living in Bosanski Samac? Is that your evidence?

9 A. Yes. That is how I view him. And whether he wielded any

10 authority with other people, that I don't know. For me, he was just an

11 ordinary person, an ordinary doctor. As for authority, I hold him in high

12 esteem as a professional and as a physician, and not as a political

13 personage. I don't know him as a political personage, as a political

14 figure, because I was myself a member of no party, so -- and I thereby was

15 not interested in that.

16 Q. Were you concerned - sorry - were you surprised at the presence of

17 this doctor at this meeting involving politics and local tensions? I

18 mean, he was just a doctor who worked in Bosanski Samac. You didn't know

19 anything about his political background and you didn't know him

20 personally. You must have been bewildered as to what he was doing in your

21 house.

22 A. I was bewildered, because -- and he probably had relations with

23 other people that he had to discuss. It was just by dint of circumstances

24 that this happened to be in my house. I was surprised myself to see him,

25 because I had never had any contact with the man.

1 Q. So if I suggested to you that, in fact, Blagoje Simic was an

2 extremely well-known politician in the area, that the fact that he was

3 known to be president of the SDS in the area was a fact known to everyone

4 in that house, including yourself, and that he was an influential man, you

5 would disagree with me?

6 A. I cannot agree with your contention as regards politics and the

7 SDS. I'm in no party. I'm not in politics. Whether he was held in high

8 esteem or not, I don't know that. That depends on the viewer, on whose

9 eyes were involved.

10 Q. Okay. And as far as the creation of the Serbian municipality of

11 Bosanski Samac, at the time of the meeting, were you aware that it had

12 been created and declared?

13 A. No. No, really not.

14 Q. So you can't tell us if that was a fact that was widely known, at

15 least in the Serb community?

16 A. It was a fact that was not known to me.

17 Q. Very well. Thank you very much. And just finally: If I

18 suggested to you that you're not being truthful when you say that Blaz

19 Paradzik was not there, you would disagree with me?

20 A. I told you. I told you that that man was not present at the

21 meeting, and I listed the people who attended it. So I see no connection

22 between Blaz Paradzik and this whole thing.

23 Q. But you know what my position is, so you can tell me if you agree

24 or disagree. That's all I'm doing. And I suggest to you that, in fact,

25 Blaz Paradzik was there; I suggest to you that Truman and Tadic and

1 Blagoje Simic arrived together; and I suggest to you that Blagoje Simic

2 did address the meeting on the dismemberment of the existing

3 municipalities. Would you agree with that?

4 A. I disagree. I do not agree at all. This was not at all the topic

5 of the meeting. I told you: Tadic, Professor Blagoje, and Truman did not

6 come together. Mr. Matanovic and Mr. Rakic arrived, and Truman came a bit

7 before Miro, and Blagoje arrived the last. Truman was somewhere,

8 reportedly in Samac, and I don't know where exactly, and he was a bit

9 drunk. This is actually what caused the incident, because he said that he

10 was sorry that the meeting had started before him, and then Rakic start

11 quarrelling with him, and there was a row, and then he started quarrelling

12 with Matanovic, so that the meeting ended abruptly, in the way I've

13 described.

14 Q. Thank you very much.

15 MR. DI FAZIO: I have no further questions.

16 PRESIDING OFFICER: Re-examination.

17 Re-examined by Mr. Pantelic:

18 Q. [Interpretation] Mr. Nijemcevic, let's clarify just a few things

19 for the sake of the record. You've mentioned, both when examined by me

20 and by the Prosecutor, that there was a certain Matanovic present there.

21 However, when answering the Prosecutor's questions, you did not indicate

22 Matanovic's first name so let us just state clearly first and last name of

23 that person attending the meeting.

24 A. Ivica Matanovic.

25 Q. The following question: Did you spend your entire childhood and

1 youth in Struke?

2 A. Yes, 80 per cent of it.

3 Q. You know Blaz Paradzik from Prud?

4 A. Yes.

5 Q. Since what time have you known him?

6 A. I've known him since I was 15 or 18, roughly speaking, but I know

7 him well. I know him well. We were not very close, we didn't socialise,

8 but I know the man.

9 Q. How old were you in March of 1992?

10 A. 29.

11 Q. Thank you.

12 MR. PANTELIC: [Interpretation] I have no further questions.

13 PRESIDING OFFICER: Thank you, Mr. Nijemcevic, for coming and

14 giving your deposition today. It's concluded and you can go. Thank you.

15 THE WITNESS: [Interpretation] You're welcome. Thank you.

16 DEFENCE COUNSEL: [Interpretation] I would like to suggest the

17 following: We have two witnesses left for Monday, and could we perhaps

18 start at 10.00? Because of the witness who is coming in the morning, I

19 would need to speak to Mr. Pantelic, and since we have only two witnesses,

20 I believe it wouldn't be a problem if we started at 10.00.

21 PRESIDING OFFICER: That's what I wanted to suggest. We'll start

22 at 10.00 on Monday.

23 --- Whereupon the Depositions hearing concluded

24 at 3.16 p.m., to be followed by the Trial which will

25 reconvene on Monday, the 10th day of February, 2003,

1 at 10.00 a.m.

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