Tribunal Criminal Tribunal for the Former Yugoslavia

Page 18011

1 Thursday, 3 April 2003

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 9.01 a.m.

6 JUDGE MUMBA: Good morning. Please call the case.

7 THE REGISTRAR: Good morning. Case number IT-95-9-T, the

8 Prosecutor versus Blagoje Simic, Miroslav Tadic and Simo Zaric.

9 JUDGE MUMBA: Yes. Good morning. Can the witness please make the

10 solemn declaration?

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

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


14 [Witness answered through interpreter]

15 JUDGE MUMBA: Thank you. Please sit down. Yes, Mr. Lazarevic?

16 MR. LAZAREVIC: Thank you, Your Honour. And good morning.

17 Examined by Mr. Lazarevic:

18 Q. [Interpretation] Mrs. Zaric, good morning.

19 A. Good morning.

20 Q. Mrs. Zaric, I'm going to examine you very briefly with regard to

21 certain details from your statement. The Court decided that you should

22 come here and speak viva voce about these details. We have already talked

23 about the way in which you should give evidence here, that you should wait

24 for me to put my question, that you should then, after a few seconds,

25 answer the questions so please make a pause so that the transcript would

Page 18012

1 reflect everything that we've said.

2 Let me just tell you one more thing. Everybody here is aware of

3 your health condition, so if you do not feel well at any point, please do

4 not hesitate to tell us. Just tell us, please.

5 Could you please tell me your name and surname for the

6 transcript?

7 A. Fatima Zaric.

8 MR. LAZAREVIC: Your Honours I provided a sufficient number of

9 redacted copies of witness's statement so maybe this can be distributed to

10 the Trial Chamber. I already gave one copy to the Prosecution so --

11 JUDGE MUMBA: All right.

12 MR. LAZAREVIC: [Interpretation]

13 Q. Mrs. Zaric, you have already given your statement. It is already

14 part of the case file. I would like to ask you something now. Let us

15 restrict your statement, your testimony, to the 16th of April, 1992 only.

16 You already said that you were at your friend's birthday party. After

17 that, you went to close your shop, and take care of the books there. Then

18 you went home. After that, your two sons came. After that, your husband

19 also came, Mr. Zaric?

20 A. Yes.

21 Q. So sometime around 11.30, you went to bed. Can you tell us what

22 happened then, in your apartment, whether there were any telephone calls,

23 who called? Could you please tell the Court about this?

24 A. Yes. That's true. That night, that evening, I was at a

25 restaurant. We were celebrating the birthday of my friend Nusreta

Page 18013

1 Besirevic. I stayed perhaps until 8.00. The other members of the party

2 remained and I went to the shop where my son Denis worked. I completed

3 the paper work that I was supposed to take care of that day. I put all

4 the money together. I tidied the store and around 9.00 I went home, which

5 was the usual thing I did every day.

6 Perhaps a few minutes later, or a few minutes before 9.00, my sons

7 returned home. It was a bit strange. I found it a bit strange why they

8 came so early. When I asked them how come they were being so nice and

9 good and how come they came home so early, they said the cafes are half

10 empty, there were very few people in town. While I chatted with my sons,

11 not much time went by, my husband also came, Simo Zaric. We watched TV.

12 Simo was in a very good mood. He said that although he never drinks

13 alcohol he said to me, "Wife, I've had a glass of brandy." We laughed.

14 Our sons went to bed. Simo and I stayed up some more. I don't know what

15 we talked about. The telephone rang and I answered it. Nobody said

16 anything to me from the other side of the line. That didn't surprise me,

17 because at that time, before that, I had been receiving anonymous calls,

18 even threats.

19 Q. Thank you, Mrs. Zaric. Now, tell me, nobody spoke to you over the

20 phone and did you go to bed after that?

21 A. We went to bed after that. We didn't even fall asleep. It was

22 perhaps about 11.30, we didn't even fall asleep. Again, the phone rang.

23 Simo went to the phone. When he returned, I asked him who it was, and he

24 said to me that they were calling him from the SUP, the duty policeman,

25 Luka, who I knew from before, because he had been a policeman for quite a

Page 18014

1 while in Samac before the war. I asked what he wanted, and he said that

2 he had asked Simo whether he knew that they had received information that

3 some military personnel with white ribbons were moving about Tisina, a

4 village near Samac. Simo immediately called Stanko Djurdjevic who lived

5 in Tisina, and he talked to him. I asked him what did he say to you? He

6 said that nothing was going on and that they'd see in the morning.

7 Simo called the SUP again, and informed the duty policeman about

8 what Stanko Djurdjevic had told him. We went to bed.

9 Q. Thank you. So let me summarise. First Mr. Gregurevic called your

10 husband?

11 A. Yes.

12 Q. After that, he called this --

13 A. Stanko Djurdjevic.

14 Q. Stanko Djurdjevic and then again he called Luka Gregurevic and

15 informed him about what he learned from this man Stanko?

16 A. Yes.

17 Q. Thank you, Madam. Now, tell me, did you go back to bed?

18 A. Yes, we went back to bed and we fell asleep. I was already

19 nervous because I knew that I had to get up early to go to work. Again,

20 the phone rang. It woke us up. It woke me up actually and I was trying

21 to wake Simo up and I was saying, "Simo this could only be a call for

22 you."

23 Q. I beg your pardon. I didn't want to interrupt you but did

24 Mr. Zaric answer the phone then again?

25 A. Yes, he did, he did. I was angry. I didn't know what was going

Page 18015

1 on in Samac. He didn't know either. He said that this call was from the

2 command of the 4th Detachment. It was the person who was on duty there

3 who called him. I don't know. And that he informed him that some gun

4 fire could be heard in town but in a different part of town, not near our

5 building. I got up. We went to the terrace or actually Simo was already

6 on the terrace. And I stood at the door. Shooting could be heard.

7 Nothing different from what could have been heard before that, because

8 there had been times when there had been shooting. He said that he had to

9 call Radovan Antic and he did. I panicked. I was afraid. After having

10 talked to Antic, he said to me, "I have to go." He put on his suit. He

11 took his weapons --

12 Q. Excuse me, just a moment, Mrs. Zaric. A suit can mean in our

13 language different things. When you say "suit" are you referring to

14 military clothing or civilian clothing?

15 A. I'm referring to military clothing, a military type suit, olive

16 grey, and he took his weapon and he took the car keys. I saw him off. I

17 heard him ignite the car and off he went from the yard. When he left, it

18 was only then that I really panicked. I didn't know anything. I tried to

19 phone my mother's house. The phone wasn't working.

20 Q. If I understood you correctly, after these conversations that

21 Mr. Zaric had with Antic, and the people at the command of the detachment,

22 at one point, the telephone ceased to operate?

23 A. Yes, yes. The telephone was my only means of communication with

24 my family and I have a lot of family members in Samac. However, it was

25 not working. Around 5.00, the phone rang. Perhaps it was after 5.00. I

Page 18016

1 cannot give you the exact time because a lot of time has gone by in the

2 meantime. The phone rang so I was really happy to hear that it meant that

3 the phone started working again.

4 THE INTERPRETER: The interpreter cannot hear this.

5 MR. LAZAREVIC: [Interpretation]

6 Q. I beg your pardon, Madam. Because of my coughing, the

7 interpreters could not hear the end of what you were saying. They could

8 not hear the end of your answer. I do apologise. The last thing that was

9 recorded in the transcript was that you were actually pleased and happy

10 that you heard the telephone ring because it meant that it started working

11 again.

12 A. Yes.

13 Q. Tell me, so when the phone rang that morning around 5.00, around

14 5.00, tell me who was on the telephone?

15 A. It was Simo. He said to me, "Wife, the situation in town is

16 complicated. I have to go with Radovan to Pelagicevo. Don't go anywhere

17 from the house. I'll call when I get back."

18 Q. Tell me now, did you go by what your husband said? Did you stay

19 at home? Did you not leave the house?

20 A. Yes, I did not. I stayed at home.

21 Q. Tell me now, around 8.00 approximately or perhaps a bit earlier, a

22 bit later, did you receive a telephone call again?

23 A. Yes, Simo called me and said that he had returned, that he was at

24 the command, that the children and I should not leave the house, and that

25 he would come home when he could.

Page 18017

1 Q. Tell me, Madam, we have now come to the 17th of April, the morning

2 of the 17th of April, did your husband come home?

3 A. Yes. Simo came, the children were already up, they did not know

4 what was going on. They don't -- they didn't know that Simo and I were

5 getting up, that he spoke on the telephone, and that he was on the

6 terrace, et cetera. I told them about all of that and I was very serious

7 about it and I said we are going to wait for Daddy to come and then we are

8 going to discuss it. He did indeed come. It was about 9.00 or 10.00. He

9 was uneasy, upset. I asked him whether he wanted to eat something and he

10 said, "No, I don't have time. I have to go back to the command." And

11 then he said to me that that day, that morning, a Crisis Staff was being

12 established. I didn't even know what a Crisis Staff was, because I had

13 never been in a war. I had no idea what kind of formation this was, what

14 its tasks were. He spent very little time at the house, and he said, "Do

15 not leave the house at all." And we went by that.

16 I was afraid for my older son because he was older, he was already

17 of age, whereas the younger one, Miran [as interpreted], was under age.

18 We stayed. The only means of communication with Simo was the telephone.

19 Q. Just a moment, please. Let's just correct one thing in the

20 transcript. Your younger son's name is Mirel, right?

21 A. Yes, his name is Mirel and my other son's name is Denis.

22 Q. Fine. Madam, we are still on the 17th of April. You said that

23 your husband stayed at the house for a while and that then he left again.

24 Did he tell you where he was going?

25 A. He told me that he had the task of assigning the members of the

Page 18018

1 4th Detachment next to the bank of the Sava River and Bosna River. And

2 again, he emphasised that we should not leave the house.

3 Q. Thank you very much. Can you tell me whether on the 17th of

4 April, apart from this arrival in the early morning hours, whether

5 Mr. Zaric came by the house during the day at a certain point?

6 A. No. He did not. He did not even spend the night at home.

7 Q. Let us now talk about the 18th of April. We have already covered

8 this part in your statement so we don't want to repeat saying that the

9 military came in front of your house, members of the 4th Detachment,

10 asking for illegal weapons to be surrendered. We will skip that part. We

11 just want to know whether you saw your husband on the 18th of April,

12 whether he came, if he did how long did he stay?

13 A. Well, yes. That morning, members of the 4th Detachment came. The

14 apartment next to mine was empty. My neighbour Biljana, a Serb, left for

15 Serbia earlier on. So that it was only me with my children who was there

16 on that particular floor.

17 Q. Did they knock at your door as well?

18 A. Yes. First they knocked at the door of Biljana's apartment but

19 nobody answered so they knocked at my door. I didn't allow my children to

20 open the door. I went out. They asked us whether we had any weapons, and

21 I said, yes, my husband has weapons but he is not at home, he took all the

22 weapons with him.

23 Q. Did you tell them that your husband is the assistant commander of

24 the detachment?

25 A. Yes, I did.

Page 18019

1 Q. Could you tell the Chamber what their reaction was?

2 A. Well, they were very polite, they weren't violent. They didn't go

3 into the house. I spoke to the other neighbours, they didn't enter

4 anyone's apartments. Those who had weapons and who weren't members of the

5 4th Detachment volunteered and surrendered their weapons of their own

6 will.

7 Q. Thank you very much. Did Mr. Zaric come home sometime during the

8 18th of April?

9 A. He telephoned me on the 18th and he said that their headquarters

10 would no longer be in the building where they were situated earlier on.

11 The command of the 4th Detachment. But that they would be relocated close

12 to our building with our neighbour who had this very fine house, next to

13 Jovo Dusanovic.

14 Q. Is this Mrs. Zaric the part called the plum orchard, Sljivak?

15 A. Yes.

16 Q. We -- on the 19th and the 20th of April, did you see your husband

17 and, if so, how often, how would he arrive? Did he spend the home at

18 night -- did he spend the night at home?

19 A. Yes. He came. He was very tired. I told him, "Well, you should

20 lie down. Look, you look very tired." So he did not spend the nights

21 there. He spent the nights at home.

22 Q. Thank you. Did he tell you about what was going on in the town?

23 A. Yes. But he spoke very little about it because I am quite fearful

24 by nature and I was very afraid. I was afraid for my children.

25 Q. Can you tell us what he told you to the extent that he told you

Page 18020

1 anything?

2 A. Well, he told me that the Crisis Staff was formed, that now we had

3 the Serbian Municipality of Samac, that some Special Forces arrived. We

4 called them the many-coloured ones. That the 4th Detachment did not have

5 the role that was originally envisaged. They started rounding up people.

6 Q. Excuse me, when you said they started up rounding people, you were

7 speaking of the 4th Detachment first?

8 A. No, no. It was the police who started rounding up people,

9 arresting them. I don't know what the criteria was but I know that these

10 were people who were of non-Serbian ethnicity and Simo took it -- it was

11 very difficult for him.

12 Q. Can you tell me whether Simo told you something to the effect that

13 some of the members of the 4th Detachment were also arrested by the

14 police?

15 A. Yes, yes. They arrested people who had weapons belonging to the

16 4th Detachment, even though they were in possession of papers for these

17 weapons and I don't know who gave them these papers, how they came by

18 these papers but these people ended up in prison. Among them was the

19 husband of Simo's sister. He's a Muslim.

20 Q. Thank you. Madam, let us now turn to another event, which took

21 place I think on the 21st of April, when your husband came home. Can you

22 tell us why is -- why was this particular day different from the others?

23 A. Yes. On this day, this was a day of both fortune and misfortune.

24 My husband suffered a great deal, for the fact that he did not side with

25 or sympathise any national party, political party, and he suffered also

Page 18021

1 for the fact that he did not distinguish people by their ethnicities. He

2 also suffered for the fact that he had me as a wife, a Muslim, who was

3 later on called Balinkura, a Turk, everything else that they called me all

4 sorts of different names but never used my own name, never called me for

5 what I was. He arrived and he was visibly upset. He was almost malformed

6 in his face.

7 Q. Are you feeling fine, Madam?

8 A. Yes, yes, I am.

9 Q. Please continue, then.

10 A. I asked Simo what is going on? He told me, "Today, you have to

11 leave Samac with the children." I said no. We will share our destiny.

12 He said, "No, you have to go. Stevan Todorovic and the Special Forces

13 which arrived from Serbia were harassing him at SUP, swearing him, his

14 communist mother, his wife, Balinkura, they were telling him to forget all

15 about brotherhood and unity. They were pushing the gun barrels into his

16 mouth. By nature, he was courageous, honest and proud. That particular

17 day he was humiliated by the very people who wanted to destroy everything

18 and everyone who did not share their opinion. They humiliated all people

19 from all different ethnicities, Croats, Serbs and Muslims. This threat

20 that was given to my Simo by Stevan Todorovic and by those of his yes-men,

21 I took it very seriously, they said that they would kill me and my

22 children and everything that was -- and everyone who were members of my

23 family, and Simo's family.

24 I had no choice. I decided, although with great difficulty, to

25 leave my husband behind, to leave my brother behind, my family, and I have

Page 18022

1 many members of my family in Samac, my friends, and my neighbours. And

2 secretively, it was just before nightfall, with my friend Mico Vidovic, I

3 literally disappeared from Samac with my two sons. It was very, very

4 difficult for me. I cried. I was sorry to leave my brother, who had

5 suffered a lot in this war, because we were brought up by a family, by

6 parents, who never taught us to hate other people for the mere fact that

7 they were not members of our ethnic group. My parents taught us to

8 respect people by what they were -- by their worth and not by their

9 ethnicity.

10 Q. Mrs. Zaric, you said, I disappeared from Samac, literally

11 disappeared. Can you tell us how you actually left Samac with the help

12 of this friend?

13 A. He came with his car in front of our house. No one knew. It

14 was -- they took us to Tisina, where there were other refugees. It was in

15 the evening. It was dark. It was cold. I didn't take any of my clothes

16 with me. I opened the cupboards and I saw -- closets and I realised that

17 whatever I did take would be just too much. So I just took off in my gym

18 suit which was a bit torn, and I didn't even take any of the diplomas,

19 school certificates of my children, myself, because I thought that I would

20 come back, which didn't help. There were other people there who I didn't

21 know. It was dark there. This was a closed-type truck, where I sat with

22 my children and perhaps it was -- I was lucky to have left that day

23 because on that particular day, the border was still open for all

24 ethnicities. Everyone could cross the border. Had it been a few days

25 later, I am positive I would not have been able to leave.

Page 18023

1 We arrived late in Belgrade, at my sister's, and my

2 brother-in-law's. This encounter -- this encounter of ours was really

3 terrible because we cried, all of us. I cried, my sister, my

4 brother-in-law, and I don't know what these tears actually meant, whether

5 they meant happiness or sadness. I think both actually. My mother was in

6 Gradacac. My sister was in Gradacac, where she lived. My brother

7 remained in Samac. I didn't know what happened to Simo's parents [as

8 interpreted]. Everyone was leaving any way they could and the family

9 literally disintegrated in a few days' time. This was terrible.

10 MR. LAZAREVIC: Your Honour I believe I need one small

11 clarification for the transcript because here on page 13, line 7, the

12 witness said I didn't know what happened to Simo's family. Because here

13 it says parents and Mr. Zaric's father was already dead by that time.

14 This was just that small intervention.

15 JUDGE MUMBA: All right. It will be corrected.

16 MR. LAZAREVIC: [Interpretation]

17 Q. Mrs. Zaric, in your statement, which is already part of the case

18 file, you said that already on the 23rd of April, 1992, you were

19 registered as a refugee?

20 A. Yes. I was -- I was registered at the insistence of my

21 brother-in-law. We went to the Red Cross. He drove us in his car and my

22 two sons as well, and we were registered with the Red Cross in Belgrade.

23 Q. Could you just wait a moment, please?

24 MR. LAZAREVIC: Your Honours, while proofing with this witness

25 yesterday, she informed me that she brought her refugee ID. So I would

Page 18024

1 like to be tendered into evidence.

2 MR. DI FAZIO: No objection.

3 MR. LAZAREVIC: Now we do have only B/C/S version. It is already

4 given -- it is already given for translation.

5 JUDGE MUMBA: The point is let me ask the Prosecution, is it

6 contested that she registered as a refugee by the Prosecution?


8 JUDGE MUMBA: There is no need then for us to produce this

9 certificate of registration.

10 MR. LAZAREVIC: All right. Thank you, Your Honour.

11 MR. LAZAREVIC: [Interpretation]

12 Q. Mrs. Zaric, in the rest of your statement, it's clear from what

13 you say when you returned to Samac, so we will not go into those details

14 again. I would just like to put a few questions to you now that refer to

15 some previous testimonies before this Tribunal.

16 First of all, for the sake of clarification, when you said that

17 your mother remained in Gradacac, and your sister too, can you tell us

18 where Gradacac is?

19 A. Gradacac is some 18 or 20 kilometres away from Samac. My sister

20 lived in Gradacac. My mother was visiting her. We didn't know that war

21 would break out. Had we known, we would not have separated. We would

22 have stayed together. We tried very hard to get my mother out, for

23 several months, but she was unable to return to Samac.

24 Q. Madam, during the war, which side of the warring parties was in

25 control of Gradacac?

Page 18025

1 A. It was the Muslims, Gradacac was a predominantly Muslim town.

2 Q. Thank you very much. I will now put a few questions to you

3 following from the testimonies of some other witnesses before this

4 Tribunal. Tell me, in brief, whether Mr. Blagoje Simic and Mr. Miroslav

5 Tadic ever came to your apartment before the war, before hostilities broke

6 out?

7 A. No, never.

8 Q. Madam, in the shop you owned, did you sell automatic weapons?

9 A. No.

10 Q. I may conclude from your reply that you did not sell a Kalashnikov

11 to a certain Bahrija Vajzovic?

12 A. I don't like weapons. I have never held a weapon in my hand. I

13 don't know anything about weapons. I can only distinguish between a rifle

14 and a pistol, and that's all. And if my lawyer hadn't asked me, I

15 wouldn't have known who this man was. I know that he comes from Samac but

16 I never knew his name. His real name, I only knew his nickname. In

17 Samac, everybody had a nickname, and that's what we knew each other by.

18 Q. Madam, I will ask you another question that has to do with your

19 statement. Does the name Jevrosima mean anything to you?

20 A. I read in Dragan Lukac's book -- I read in a book -- he didn't

21 want to attack me, he wanted to represent my husband as a Serb

22 nationalist.

23 Q. But did you change your name Fatima into Jevrosima?

24 A. I never changed my name. I'm not ashamed of my name. And my Simo

25 would never want to do that. I'm proud of my name. I'm proud of my

Page 18026

1 family. I'm proud of my parents and my ancestors.

2 Q. Thank you very much. I would now like to ask a few more questions

3 and then we will conclude. In Belgrade, you were a refugee staying with

4 your sister and your brother in law?

5 A. Yes.

6 Q. During this period, while you were a refugee, did somebody else

7 from Bosanski Samac come and stay in that flat?

8 A. Yes.

9 Q. Can you tell us, as far as you can recall, who lived in that

10 apartment during the war?

11 A. There were 16 of us in a one-room flat. We slept on the floor.

12 We were very crowded. And we had no idea how people from Samac got hold

13 of our address, looking for a place to stay.

14 Q. Tell us the names of the people who stayed there, as far as you

15 can remember.

16 A. The people who spent the longest time there were Satka Jasarevic;

17 her daughter, Fata; Salko Ceribasic; Fadil Mustafic; Fatka Mustafic; Adin

18 Mustafic, their son; Jasna Mustafic, their daughter in law; and Anja

19 Mustafic, their daughter, Jasna and Dina's daughter.

20 Q. Thank you. Judging by the last names, I would say that these were

21 all Muslims?

22 A. Yes.

23 Q. The Jasarevic family that you mentioned, the lady and her

24 daughter, were there related to Osman Jasarevic, also known as Roma?

25 A. Yes, Satka Mustafic was his mother, Roma's mother and Fata was

Page 18027

1 Roma's sister.

2 Q. You said Mustafic, did you mean Jasarevic?

3 A. Yes, I meant Jasarevic, I apologise.

4 Q. Thank you.

5 MR. LAZAREVIC: Could we have a brief period in private session

6 and I will complete my examination-in-chief.

7 JUDGE MUMBA: Yes. Can we move into private session?

8 [Private session]

9 [redacted]

10 [redacted]

11 [redacted]

12 [redacted]

13 [redacted]

14 [redacted]

15 [redacted]

16 [redacted]

17 [redacted]

18 [redacted]

19 [redacted]

20 [redacted]

21 [redacted]

22 [redacted]

23 [redacted]

24 [redacted]

25 [redacted]

Page 18028













13 Page 18028 redacted private session













Page 18029













13 Page 18029 redacted private session













Page 18030

1 [redacted]

2 [redacted]

3 [redacted]

4 [redacted]

5 [redacted]

6 [redacted]

7 [redacted]

8 [redacted]

9 [redacted]

10 [redacted]

11 [redacted]

12 [redacted]

13 [redacted]

14 [redacted]

15 [redacted]

16 [redacted]

17 [Open session]

18 THE REGISTRAR: We are in open session.

19 MR. LAZAREVIC: [Interpretation]

20 Q. Mrs. Zaric, I have concluded your examination-in-chief. My

21 learned friend will now put questions to you.

22 MR. LAZAREVIC: I have finished examination-in-chief.

23 JUDGE MUMBA: Yes, the Prosecution?

24 MR. DI FAZIO: Thank you, Your Honours.

25 Cross-examined by Mr. Di Fazio:

Page 18031

1 Q. Good morning, Mrs. Zaric, my name is Di Fazio, I will ask you some

2 questions on behalf of the Prosecution?

3 A. Good morning.

4 Q. I hope I won't be too long in my questions. We can speed it up if

5 you give brief answers as well.

6 Mrs. Zaric, your husband has had long experience as a policeman

7 and in the security services, hasn't he?

8 A. Yes.

9 Q. In fact, he was chief of the SUP in Bosanski Samac, I believe, for

10 four years, from 1975?

11 A. Yes.

12 Q. There followed a period of his involvement in private enterprise,

13 working for companies, and then in 1985, I believe, he became a senior

14 inspector in the state security service? Am I correct?

15 A. He wasn't involved in private business. He continued working in a

16 state-owned company, in the business sector, but not as a private

17 entrepreneur.

18 Q. I'm sorry, I didn't get that correct. I'm not interested in that

19 period. But in fact, after that period of working with the companies, he

20 became a senior inspector in the state security, and that was in September

21 of 1985, I believe. Am I correct? I'm sorry, I didn't hear your answer.

22 A. Yes, yes.

23 Q. Thank you. And he rose from the position of senior inspector in

24 the state security to the position of chief of the state security in

25 Modrica and he was responsible for the areas of Modrica, Odzak and Samac,

Page 18032

1 correct?

2 A. Yes.

3 Q. And he only retired from that job as chief of security -- state

4 security, in September of 1991?

5 A. Yes.

6 Q. So some six years in charge of the state security services

7 covering an area which included of course the municipality of Bosanski

8 Samac?

9 A. Yes.

10 Q. And in that position, right up until about seven months before the

11 outbreak of hostilities in Bosanski Samac, if my calendar calculations are

12 correct?

13 A. Yes.

14 Q. And of course, in that position as chief of state security, he had

15 access to good, high level intelligence relating to all sorts of

16 activities in those areas that I just mentioned?

17 A. I don't know how much he knew and who he contacted because this is

18 a secret service and people don't talk about things like that at home.

19 Q. I appreciate that. I understand that you weren't doing his job

20 and you were not in state security and I'm not suggesting that you had

21 access, chapter and verse, to everything that he knew. However, from your

22 discussions with him, it was apparent to you, wasn't it, that he had good

23 access to good intelligence for those areas?

24 A. I don't know about that.

25 Q. Okay. Your husband was also a man who was interested in politics

Page 18033

1 and in fact had joined, for a long period of time, the League of

2 Communists?

3 A. Yes. He was a member of the League of Communists. I was too.

4 Q. Of course. And many other people in the former Yugoslavia were

5 members of the League of Communists?

6 A. Precisely.

7 Q. Exactly, precisely. But he was also interested in politics, was

8 he not?

9 A. It's not only that he liked politics. He liked sports too. He

10 liked folklore.

11 Q. I know about that. I've read his interviews and I understand that

12 he's a man of wide interests but my question is?

13 A. Yes, yes, yes.

14 Q. He was interested in politics as well, was he not?

15 A. Politics was an integral part of his job. He was supposed to be

16 informed about many things, and he could only know about these things from

17 these meetings.

18 Q. That makes good sense, with respect, Mrs. Zaric. In -- it would

19 be fair to say that he followed politics at a national level and also

20 followed politics at a local or municipal level?

21 A. What do you mean at a national level? I don't understand that.

22 Q. Well, he kept abreast of political developments in Yugoslavia, he

23 kept abreast of political developments within the municipality, within the

24 areas of Odzak and Samac and the other -- the third area that he was

25 responsible for.

Page 18034

1 A. Well, he followed Bosnia and Herzegovina more than Yugoslavia,

2 because his headquarters were in Sarajevo, not in Belgrade.

3 Q. Okay. Thank you. And he -- sorry, I withdraw that. Let me

4 rephrase it. In your discussions, in your talks with your husband, it was

5 clear, wasn't it, that he was a man who was well aware and following

6 carefully the activities of the national parties in Yugoslavia and in

7 particular Bosnia and Herzegovina, the HDZ, the SDA and the SDS?

8 A. It's not that he only followed that. Ordinary people followed it

9 too. The establishment of national parties, I think that already at that

10 time there came a period of uncertainty when coexistence became more

11 difficult among us who lived there.

12 Q. I'm not suggesting that he was in some way obsessed with the

13 politics of the national parties. All I'm suggesting is that your husband

14 was a man who was right up to date, right up to date, well informed, about

15 the policies and developments of the national parties, the Croatian --

16 HDZ, the Muslim SDA and the Serb SDS. Would that be correct?

17 A. Yes.

18 Q. Thank you. Your husband was also a man who was well known in

19 Bosanski Samac and in -- indeed in the other municipalities close to the

20 municipality of Bosanski Samac?

21 A. Yes.

22 Q. He knew a lot of local politicians, including members of the SDA,

23 the SDS and the HDZ?

24 A. Yes. We socialised with people, with individuals, we paid no

25 attention to ethnic or religious background. We were not interested in

Page 18035

1 that. Neither he nor I had any sympathy for the national parties.

2 Q. Fair enough but that's not really with respect my question. My

3 question is that he socialised and knew well many members of these

4 national parties, am I correct?

5 A. I don't know which period you're referring to.

6 Q. I'm talking about the period in late 1991 and early 1992.

7 A. Yes. He had contacts with them. He didn't have any points in

8 common, but he said hello to them. He didn't turn his head away from

9 anyone, no, but he didn't socialise with them.

10 Q. Right. Okay. And he particularly in early 1992, he attended many

11 meetings in the municipality, meetings at which local politicians from

12 those national parties were present? Am I correct?

13 A. I don't know where and when he attended meetings with people. It

14 would be too much for me to know that.

15 Q. I understand that and I'm not asking you to provide details of

16 each and every meeting, nor dates, nor occasions. My question is a

17 general one. In early 1992, he attended many meetings, didn't he, at

18 which local politicians were present, to discuss local politics and other

19 issues?

20 A. I cannot give you an accurate answer to that question. It's not

21 that I don't want to. I simply don't know.

22 Q. Your husband, in early part of 1992, spoke on behalf of the 4th

23 Detachment and spoke of -- at meetings, of -- well, I'll restrict my

24 question to that. Spoke on behalf of the 4th Detachment at meetings, am I

25 correct?

Page 18036

1 A. He probably did.

2 Q. Does that mean that you don't actually know, you're speculating or

3 that you do know that he attended --

4 A. I think he did, I think he did. I think he did speak on behalf of

5 the 4th Detachment because wherever he would appear, he could only speak

6 that way because he was assistant commander for information, security and

7 information. So if he was invited anywhere, he certainly went, and he

8 could not speak on behalf of any national party. He could only speak on

9 behalf of the 4th Detachment.

10 Q. Thank you. And there were growing ethnic tensions in Bosanski

11 Samac in -- well, in late 1991 and early 1992; is that correct?

12 A. Yes.

13 Q. So all of that meant that he had to have an extremely clear, good

14 idea of the -- knowledge, I should say, of the policies of the national

15 parties, including the policies of the SDS?

16 A. Certainly. We as a family, my husband, we all had to pay a price

17 for this. He retired prematurely because he did not want to become a

18 member of the SDS although offers were made to him to that effect and he

19 had to retire prematurely, although he was still capable of working hard.

20 Q. Thank you. And in his work in 1992, in the 4th Detachment, he was

21 responsible for matters relating to security and intelligence; is that

22 correct?

23 A. Yes.

24 Q. And again, that was another reason that made it imperative for him

25 to have the clearest and best possible picture of the plans and policies

Page 18037

1 and intentions of the national parties, including the SDS?

2 A. Yes. He was worried. He probably had a lot of information about

3 the work of the SDS and the work of the SDS, and of the HDZ and the SDA,

4 the national parties, that cooperated before the war, during the war and

5 at the present day, they agree amongst themselves very well. We do not

6 belong to these parties.

7 Q. Thank you. And so developments in February and March of 1992,

8 when the SDS was instrumental in declaring a Serbian Municipality of

9 Bosanski Samac, was a matter that was obviously extremely well known to

10 your husband, and you as well?

11 A. I didn't find all of this very clear. I was born in Bosanski

12 Samac. I lived in Bosanski Samac, and all of a sudden, overnight, this

13 Samac is no longer Bosanski Samac. It's just Samac.

14 Q. Thank you. It's uncontested that in February and March of 1992,

15 the SDS was instrumental in setting up a Serbian Municipality of Bosanski

16 Samac, they held meetings, they appointed people to various positions.

17 Did your husband ever discuss that development with you?

18 A. We talked about many things. He was always unsatisfied. The

19 concept of the 4th Detachment was to safeguard all the citizens in the

20 town of Bosanski Samac.

21 Q. Thank you, Mrs. Zaric, but what I'm really interested in was -- is

22 this: That's the announcement in February and March of 1992, of the

23 creation of a Serbian Municipality of Bosanski Samac. Was that topic ever

24 the subject of discussion between you and your husband?

25 A. No.

Page 18038

1 Q. Were you aware of the appointment of various people to various

2 posts in this new Serbian Municipality of Bosanski Samac? For example,

3 the appointment of Stevan Todorovic as police chief?

4 A. Yes.

5 Q. Was that a matter that was well known throughout Bosanski Samac or

6 was it not so well known?

7 MR. LAZAREVIC: If I may just have one correction, it would be

8 much more helpful if we would -- if my colleague would ask the witness

9 when she learned about that, that Stevan Todorovic was appointed as Chief

10 of Police.

11 MR. DI FAZIO: Certainly, I'm happy to oblige Mr. Lazarevic if he

12 wants that question asked.

13 Q. When did you find out about the appointment of Stevan Todorovic?

14 A. I found out about that in the month of April.

15 Q. Pre or post 16th of April?

16 A. After the 16th of April.

17 Q. Okay. All right. Thank you. We'll leave that topic and move on

18 to another one. You mentioned in your evidence a telephone call that took

19 place late on the 16th of April, in which your husband spoke with Luka

20 Gregurevic. Do you recall that testimony?

21 A. Yes.

22 Q. And your husband, after the phone call, told you what had been

23 said?

24 A. Yes.

25 Q. One of the things he said was that men had been -- men had been

Page 18039

1 seen walking around Tisina with white ribbons?

2 A. Yes.

3 Q. That night, the -- at about that time, late, on the 16th, before

4 midnight, your husband was at home, not obviously not engaged -- obviously

5 not engaged in any 4th Detachment activities of any particular importance?

6 A. Yes.

7 Q. And you're not aware of the 4th Detachment being on any particular

8 manoeuvres at about that time on late on the 16th?

9 A. I don't think that any such thing was going on, because if it

10 were, Simo would have been with them.

11 Q. With respect that makes sense, doesn't it? All right. So these

12 men with white ribbons were not -- couldn't have been or very unlikely to

13 have been members of the 4th Detachment in Tisina?

14 A. Yes.

15 Q. The men who came to your apartment and sought weapons, were they

16 wearing white ribbons?

17 A. No.

18 Q. You stayed in the town until, I think, the 24th of April?

19 A. No. Until the 21st.

20 Q. Okay. 21st. Did you see in that period of time any members of

21 the 4th Detachment wearing white ribbons?

22 A. No. I did not leave the house at all throughout that time.

23 Q. Okay. When your husband came home in that period of time,

24 whenever it may have been, during the day or at night, was he wearing a

25 white ribbon?

Page 18040

1 A. I don't think so. No, no, no, he wasn't.

2 Q. Okay. All right. Let's move to another topic. You said that

3 Mr. Zaric, your husband, explained to you that a Crisis Staff was being

4 formed. You recall giving that evidence this morning?

5 A. Yes.

6 Q. When did he provide you with that information?

7 A. This was on the following day or -- the 17th, rather, in the

8 morning.

9 Q. Right. Okay. Thank you. After his return from Pelagicevo?

10 A. Yes.

11 Q. Okay. Now, in fact, he gave you a little more information than

12 simply a Crisis Staff had been formed. Isn't it the case that he came

13 home and told you that a police station had been occupied by some

14 paramilitary formations and police?

15 A. Yes. He said to me that vital facilities in Bosanski Samac had

16 been taken by the police, and the paramilitary formations that had come

17 from Serbia.

18 Q. Right. Thank you. And that buildings had been occupied? Did he

19 tell you that?

20 A. I don't know which buildings you mean.

21 Q. No, no. The buildings aren't important. Did he tell you, did

22 your husband tell you, that some buildings had been occupied by these

23 paramilitary formations and the police?

24 A. Yes. He said that the vital facilities in Bosanski Samac, the

25 police station, and the other vital facilities, were taken over, occupied,

Page 18041

1 by the paramilitary formations in cooperation with the police, the Serb

2 police.

3 Q. Okay. Thank you. And did he also tell you that a government was

4 being set up by a Serbian -- Serbian Crisis Staff?

5 A. Yes.

6 Q. Thank you. And in addition, it wasn't just your husband who had

7 access to that information but also other people in the building?

8 A. We gathered at the entrance and somebody had always heard

9 something, somebody would go out to get bread and they would find out

10 about things. Some of this was misinformation but some of it was genuine

11 information. However, I didn't dare go out. I was afraid. I was in the

12 apartment all the time.

13 Q. Thank you. Your husband did not mention anything to the effect

14 that the 4th Detachment was going to remove this paramilitary group, did

15 he?

16 A. No.

17 Q. Your husband did not mention anything to the effect that the 4th

18 Detachment was going to liberate the police station from the seizure by

19 this paramilitary group, did he?

20 A. No.

21 MR. VUKOVIC: [Interpretation] Objection, Your Honour.


23 MR. VUKOVIC: [Interpretation] The witness decidedly said that she

24 did not know anything about the information that her husband collected and

25 he said -- and she said that it was highly confidential, highly secret, so

Page 18042

1 this line of questioning isn't leading us anywhere.

2 MR. DI FAZIO: I'm asking what Mr. Zaric said to this witness or

3 what he did not say to this witness, words that he did or did not utter.

4 It's a pure question of fact.

5 JUDGE MUMBA: Yes, Mr. Di Fazio is right. You can proceed.


7 Q. He did not say anything to you to the effect that the 4th

8 Detachment was going to remove this illegal Serbian municipality, this new

9 administration? Sorry, am I correct?

10 A. Yes.

11 Q. What he did explain to you, however, was that the 4th Detachment

12 was going to set up positions on the river banks and guard those river

13 banks which face Croatia, well, at least the Sava, the Sava does?

14 A. Yes.

15 Q. And to protect from any outside attack, that's what he did say to

16 you?

17 A. Yes.

18 Q. All right. In the period of time up until the 21st, when you

19 eventually left for Belgrade, the new civilian authorities in Bosanski

20 Samac started to consolidate their power, did they not, by declaring

21 curfews, introducing state of emergency, and various other edicts and

22 decrees?

23 A. Yes.

24 Q. Thank you. Just returning for one moment to the conversation I

25 was asking you about earlier, when your husband told you that positions

Page 18043

1 were going to be taken up on the Sava and the Bosna, did he also mention

2 to you anything about the intended collection of weapons?

3 A. I cannot recall.

4 Q. All right. Thank you.

5 MR. DI FAZIO: I'm sorry, it's 10.30, it's time for our break, if

6 Your Honours please.

7 JUDGE MUMBA: Yes, we will take our break and come back at 1100

8 hours.

9 --- Recess taken at 10.30 a.m.

10 --- On resuming at 11.02 a.m.

11 JUDGE MUMBA: Yes, Mr. Di Fazio?

12 MR. DI FAZIO: Thank you, Your Honours.

13 Q. Mrs. Zaric, I was asking you about the consolidation of power by

14 the new civilian authorities and you told us that they introduced a state

15 of emergency and did other things, such as imposing curfews and

16 strengthening their grip on power, correct?

17 A. Yes.

18 Q. In addition, were you able to see from your home, or indeed

19 anywhere in Bosanski Samac or did you hear of paramilitaries going about

20 the town seizing weapons?

21 A. Yes.

22 Q. And this was apparent to you even before you left Bosanski Samac,

23 even before the 21st, that that's what they were doing?

24 A. Yes, yes.

25 Q. Plainly what they were doing was also participating in the seizure

Page 18044

1 of power?

2 A. Yes.

3 Q. At the same time that this seizure of power was going on, the 4th

4 Detachment, as far as you could tell, was setting up its positions on the

5 embankments of the Sava and Bosna rivers?

6 A. I know Simo told me the next day that the 4th Detachment has set

7 its position on the embankment of the Sava River and in the evening these

8 Special Forces came into Samac. This is what Simo told me, together with

9 the police. And only the next day did the 4th Detachment set its

10 positions along the Sava River.

11 MR. DI FAZIO: I'm sorry, would Your Honours just bear with me for

12 one moment?


14 MR. DI FAZIO: Thank you.

15 Q. Just a bit concerned about your sequence, okay? Tell me if this

16 is correct: On the night of the 16th and 17th, the commencement of the

17 seizure of power began, which involved the paramilitaries coming in, the

18 seizure of buildings and so on. Then on the 17th, during the day, the 4th

19 Detachment started setting up its positions? Is that a -- is that the

20 correct sequence?

21 A. Yes.

22 Q. Okay. And the seizure -- sorry, the collection, if you -- call it

23 what you will, of weapons by the 4th Detachment, the part that you saw,

24 that happened on the 18th, is that your position?

25 A. Yes, yes.

Page 18045

1 Q. Were you concerned that the 4th Detachment was assisting this

2 seizure of power by its actions in setting up positions on the embankment

3 and collecting weapons?

4 MR. LAZAREVIC: I object. I object to this question, concerned

5 that stating that the 4th Detachment assisted the seizure of power. This

6 is not what this witness could answer.

7 MR. DI FAZIO: All right. I'll rephrase it.

8 Q. The 4th Detachment was assisting the seizure of power by setting

9 up this perimeter around the town and by collecting weapons from the

10 citizenry. That's correct, or am I incorrect?

11 A. I think that this is not correct. This is not the way I see it.

12 If they stood by the River Sava, which we are actually bordering the

13 Republic of Croatia, so they were -- they were protecting

14 Bosnia-Herzegovina, that is Bosanski Samac, from another country, now, the

15 extent to which they could actually help people, well probably they could

16 only help those people who remained in Bosanski Samac.

17 Q. Yes. Okay. They may -- your position is that they were defending

18 the town, the -- from attack from another country. However, they did

19 nothing, did they, to remove the insurgents in the town, the

20 paramilitaries and this new Serbian Crisis Staff that has -- that had

21 taken power?

22 A. I don't know what else they could have done, even they -- if they

23 had raised their voice against it, I don't think anyone of them would have

24 remained alive.

25 Q. Did you ever get an idea of how many paramilitaries there were in

Page 18046

1 the town? This is in the period of time between the 17th and 21st, when

2 you left.

3 A. We all called them by the same name, we called them the

4 many-coloured, because we -- they stopped me, they asked me to -- they

5 asked us to look at the car, and this was terrible for me. This was

6 already before the war, and I didn't know who they were. Afterwards, it

7 transpired, actually it turned out, it became quite clear what sort of an

8 evil they represented. They were prepared to do everything, to kill, to

9 rape, and who knows what else.

10 Q. Fair enough but did you have any idea between the 17th and the

11 21st, when you left, of the numbers of sareni or paramilitaries who had

12 come into the town, the numbers who had been involved in the takeover?

13 A. No, no.

14 Q. Were you aware who brought in these paramilitaries or sareni and

15 the Serbian police who took over the town?

16 A. I heard, I read about it, that they were brought by Stevan

17 Todorovic.

18 Q. Okay. But apart from your subsequent readings in that period of

19 time between the 17th and the 21st, did you obtain from anywhere, any

20 information of who was involved in bringing in these paramilitaries and

21 Serbian police to accomplish this takeover?

22 A. No, no.

23 Q. Okay. You described an episode in your evidence this morning of

24 an occasion when your husband complained of an episode where a gun had

25 been pushed into his mouth and how he had been humiliated and so on. You

Page 18047

1 recall that evidence?

2 A. Yes.

3 Q. You --

4 A. Yes, very well.

5 Q. You made the comment that this was done by people who wanted to

6 destroy everything?

7 A. Yes.

8 Q. Was that something that your husband told you?

9 A. Well, he did talk about them in the -- as the worst people, it was

10 at the time while I was still there, that they were the ones who dominated

11 everything in the town.

12 Q. Okay. I realise that this is -- these are events that took place

13 11 years ago, it's a long time ago, and that they're emotional times and

14 that your recollection cannot be absolutely precise?

15 A. Yes.

16 Q. But what I'm interested in is this: Did your husband make it

17 clear to you that his view was that these people wanted to destroy

18 everything when he was talking to you about the episode of the gun in the

19 mouth?

20 A. Yes.

21 Q. And by that, he meant the destruction of the existing ethnic

22 order, the destruction of the existing institutions, the destruction of

23 coexistence? Is that how you understood his comment?

24 MR. LAZAREVIC: If I may, okay. Now it's all right, because when

25 I read the last sentence of the question, now it's all right. I wanted to

Page 18048

1 object.


3 Q. Am I correct that when he said that these were people who wanted

4 to destroy everything, he was talking about people who wanted to destroy

5 the institutions of ethnic tolerance and togetherness? Is that a fair

6 summary of how you understood it?

7 A. Yes, yes, yes. They would not accept coexistence and whoever

8 decided to oppose them would end up in jail, perhaps even be killed.

9 Q. Okay. I've got no quarrel with that. I understand that but what

10 I'm asking you is this: When your husband spoke to you, when he came back

11 after that emotional episode, and he said these are people who want to

12 destroy everything, you understood him to be talking about the destruction

13 of existing institutions that allowed for ethnic tolerance and

14 cohabitation?

15 A. Precisely.

16 MR. DI FAZIO: Again will Your Honours just bear with me?


18 [Prosecution counsel confer]

19 MR. DI FAZIO: Thank you.

20 Q. So -- and when he spoke about these people, he was talking, wasn't

21 he, as far as you could tell, about all of the people involved in the

22 seizure of power, the Serbian Crisis Staff, the paramilitaries, the

23 Serbian police, all of them who were acting together to take over control

24 of the town?

25 A. Yes.

Page 18049

1 MR. LAZAREVIC: Maybe I -- the witness already answered but I

2 believe that it was unfair question for this witness because first he

3 referred to the paramilitaries and the event that Mr. Zaric had with

4 paramilitaries and Mr. Todorovic who threatened him and she understood

5 after this event that Mr. Zaric when talking about this -- referring

6 to this, to this person, so to Mr. Todorovic and the paramilitaries. Now

7 the witness is asking about others taking control of the town so maybe

8 this could be clarified, what -- who are the persons that Mr. Zaric was

9 referring when he talked to his wife.

10 JUDGE MUMBA: Yes, Mr. Di Fazio, I think Mr. Lazarevic is right to

11 the extent that the other people included -- the other institutions

12 included in your question could have misled the witness.

13 MR. DI FAZIO: If you just give me a moment to read the

14 transcript, if Your Honours please?


16 MR. DI FAZIO: All right.

17 Q. Let me ask you this way. When your husband said these people want

18 to destroy everything, who did you understand him to be talking about?

19 A. I meant non-Serbs, people who wanted to live together, who are

20 honest, who were in favour of cohabitation.

21 Q. Again, perhaps I've -- my question wasn't that clear. I'll try

22 again. What I meant was when your husband told you, came back and said to

23 you these people want to destroy everything --

24 A. Yes.

25 Q. What people was he talking about?

Page 18050

1 A. Well, if they arrested only Muslims and Croats, and took them to

2 jail, sometimes they would even take a Serb who was disobedient. I guess

3 he was referring to those.

4 Q. Did he make any reference, when he was talking about the

5 destruction of everything and talking about these issues, to the Serb --

6 the new Serb Crisis Staff?

7 A. He wasn't a member of the Crisis Staff, so that he didn't have

8 anything to talk to me about that.

9 Q. No, no. I understand that. All I'm interested in is your

10 understanding of what he meant when he told you that there were people who

11 wanted to destroy everything or said words to that effect, okay? Who was

12 he talking about? Was he talking about just the paramilitaries? Was he

13 talking about the Serb Crisis Staff? The new civilian administration? Or

14 you don't know? If you don't know, tell us but see if you can clarify

15 that for us.

16 A. Well, he -- it was Stevan Todorovic who was very rude to him and

17 his paramilitaries, and then he said, well, they will destroy everything,

18 and he meant including himself, and that's what he said. He disagreed

19 with them. He didn't know them. He didn't know who these people were.

20 Q. Did he ever tell you of his appointment by the Serb Crisis Staff

21 as the director of national security? I believe it was appointment he

22 held for --

23 A. No.

24 Q. You know nothing of that?

25 A. No.

Page 18051

1 Q. Would you approve of his working in any position offered to him by

2 the Serbian Crisis Staff?

3 JUDGE MUMBA: No, Mr. Di Fazio. That's not a fair question for

4 the witness.

5 MR. DI FAZIO: All right. I'll withdraw it. Thank you, Your

6 Honours.

7 Q. Your husband gave a statement to officers of the OTP on June the

8 3rd, 1998. And in that statement, he said that Blagoje Simic and Stevan

9 Todorovic brought the paramilitaries into Bosanski Samac. Did he ever

10 give you any such information at any time now, not just between the 17th

11 and the 21st. At any time did he tell you that?

12 A. We didn't talk about that.

13 Q. And you've got no reason to disbelieve him when he makes that

14 assertion, have you?

15 JUDGE MUMBA: No, again, that's not a fair question.

16 MR. DI FAZIO: Okay.

17 Q. Just one last topic --

18 JUDGE MUMBA: I think, Mr. Di Fazio, you have to remember that

19 this witness is no ordinary witness, she is the wife of the accused.

20 MR. DI FAZIO: I'm very mindful of that, Your Honours and I've cut

21 my questions short every time that you have indicated, I have no problem

22 with that at all, if Your Honours please.

23 Q. Your brother, I think, is Fadil Topcagic, am I correct?

24 A. Yes.

25 Q. Did you have an opportunity to speak to him between the 16th and

Page 18052

1 the -- sorry, between the 17th and the 21st of April, when you left?

2 A. We didn't meet at all. We didn't see each other at the time at

3 all. I tried to reach him on the phone but there was nobody at his house,

4 and we didn't see each other at the time at all.

5 Q. Okay. He was in the 4th Detachment. Do you know what position he

6 held in the 4th Detachment?

7 A. He was just a private, a soldier like any other.

8 MR. DI FAZIO: Thank you very much. I have no further questions.

9 JUDGE MUMBA: Any re-examination?

10 MR. LAZAREVIC: No re-examination, Your Honour.

11 JUDGE MUMBA: Thank you very much, Mrs. Zaric, for giving

12 evidence. We are finished with you. You may now leave the courtroom.

13 THE WITNESS: [Interpretation] Thank you.

14 [The witness withdrew]

15 JUDGE MUMBA: Yes, any other witness?

16 MR. LAZAREVIC: Your Honours, our last information is that three

17 of our witnesses have left Bosanski Samac yesterday, arrived in Belgrade,

18 and we don't have so far any information whether they have arrived in The

19 Hague. They should have been here by now, but there is no information

20 from witness and -- Victims and Witnesses Section. So at this point, I

21 believe we have no any witness for today. Hopefully -- well, what I can

22 assure the Trial Chamber is that tomorrow we will have three witnesses who

23 arrive -- who I hope will have arrived this morning in The Hague, and I

24 can give the order of their appearance for the Trial Chamber right now.

25 First witness would be Sekulic, Stoko. After him, witness Arnautovic,

Page 18053

1 Jusuf. And then after him, witness Omeranovic, Mustafa. Witness Tihic,

2 Pasaga will come in The Hague on Saturday and he will be ready to give his

3 testimony on Monday, together with some other witnesses, and we will

4 inform the Trial Chamber as soon as we can. And these are all four

5 witnesses -- all these four witnesses were supposed to give their

6 testimony by the way of Rule 71 but the Trial Chamber decided to call them

7 here and to hear their testimony viva voce.

8 JUDGE MUMBA: Yes, so that we can observe them, yes. Yes. So do

9 please keep the legal officer informed.

10 MR. LAZAREVIC: Yes, Your Honour, I have already seen her an hour

11 ago and I promised -- made that promise to her.

12 JUDGE MUMBA: Mr. Lukic, have you checked your documents, the ones

13 Judge Lindholm had raised yesterday?

14 MR. LUKIC: [Interpretation] Yes, I have. We have verified it

15 yesterday. These documents were not admitted into evidence, the ones that

16 Honourable Judge Lindholm asked about. We intended to tender these but

17 have actually decided to withdraw them.

18 JUDGE MUMBA: Thank you very much. Any other matters before we

19 rise? No?

20 MR. DI FAZIO: No, Your Honours.

21 JUDGE MUMBA: We shall rise and continue our proceedings

22 tomorrow.

23 --- Whereupon the hearing adjourned at

24 11.28 a.m., to be reconvened on Friday,

25 the 4th day of April, 2003, at 9.00 a.m.