Tribunal Criminal Tribunal for the Former Yugoslavia

Page 14763

1 Monday, 31 March 2003

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 9.12 a.m.

5 JUDGE SCHOMBURG: Good morning. Please be seated to this rather

6 early meeting at 9.00 mid-European summertime.

7 Can we please hear the case.

8 THE REGISTRAR: Good morning. This is Case Number IT-97-24-T, the

9 Prosecutor versus Milomir Stakic.

10 JUDGE SCHOMBURG: May I already ask the usher to escort the

11 witness into the courtroom while I'll ask for the appearances.

12 Prosecution, please.

13 MR. KOUMJIAN: Good morning, Your Honours. Nicholas Koumjian,

14 Ann Sutherland, and Ruth Karper.

15 JUDGE SCHOMBURG: Thank you. And for the Defence, please.

16 MR. LUKIC: Good morning, Your Honours. Branko Lukic and

17 Danilo Cirkovic for the Defence.

18 JUDGE SCHOMBURG: Thank you. The schedule for today and for

19 tomorrow is clear. I hope that we can continue this way. Mr. Koumjian,

20 please, you wanted --

21 MR. KOUMJIAN: Sorry, I was just going to alert the

22 Registrar -- sorry.

23 JUDGE SCHOMBURG: Only that you know, having reviewed the

24 transcript, I have to come back with some questions under Rule - I think

25 it's - 96.

Page 14764

1 [The witness entered court]


3 [Witness answered through interpreter]

4 Further questions by the Court:

5 JUDGE SCHOMBURG: Good morning, Mr. Kuruzovic.

6 A. Good morning. Good morning.

7 JUDGE SCHOMBURG: Before we start, there was a long weekend in

8 between. I just want to recall that you are always aware of your rights.

9 First of all, I have to make it quite clear once again, you are not the

10 accused in this case. You are here as a witness. You arrived without any

11 subpoena. But nevertheless, you have the right to be assisted by counsel.

12 You have the right to remain silent, also to remain silent on those

13 questions where the answer could tend to be of self-incriminatory nature.

14 And this right is an ongoing one. At any point in time, you may make use

15 of this right.

16 But let us go for a moment, please, in private session.

17 [Private session]

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

Page 14765












12 Page 14765 redacted private session














Page 14766

1 [Open session]

2 JUDGE SCHOMBURG: Let's turn first to the question of the

3 municipal -- the Serbian Municipal Assembly or as you called it the

4 Serbian Assembly of the Municipality of Prijedor. On page 15, 16, of Day

5 143, you testified straightforward and without any hesitation that it was

6 the 7th of January that the Serbian Assembly of the Municipality of

7 Prijedor was formed, on the 7th of January. This is page 15 following

8 lines 17 until page 16, line 4, Day 143.

9 Then you told us the development until the 29th, when you had a

10 meeting in the barracks. Then during the line of questions put to you by

11 the Defence, being confronted with some documents, that in general, the

12 name of the Assembly should be replaced and the word "Serbian" should

13 appear. And a document showing that in a meeting, I think it was the

14 fifth meeting of the Serbian Assembly, you were together with others

15 elected; whereas in the beginning, you testified that you were already

16 elected the 7th of January.

17 Let me now hear first, what is, to the best of your recollection,

18 the truth? Have you been already elected or maybe only provisionally

19 elected already the 7th, or was it only Dr. Stakic and others, the

20 president and vice-president, who were elected this 7th of December [sic],

21 a remarkable day, the day of Orthodox Christmas. Can it be or may it be

22 that during this meeting, mid-April 1992, the declaration or the election,

23 as we can see it on the basis of the document, this is more or less a

24 declaration, or was it only then that you yourself were elected?

25 A. I've understood your question. I have been thinking while I was

Page 14767

1 in the hotel, and I'm sure I must have made a mistake. As regards the

2 establishment of the assembly, it took place on the 7th of January, and

3 the president and the vice-president were elected on that day. And since

4 this indeed was a remarkable day, I thought that everything was over on

5 the 7th of January. But later on, there were ballots, and that was in

6 mid-April. And on those ballots, the delegates voted for other people. I

7 still have that ballot. I've remembered I've made a mistake, and I

8 apologise once again for the mistake that I've made.

9 JUDGE SCHOMBURG: Then next question would be the 7th of January.

10 This was apparently the first meeting. Mid-April, this was apparently the

11 fifth meeting of this Serbian Assembly. Did you attend one of the

12 meetings, the second, the third, or the fourth meeting of the Serbian

13 Assembly?

14 A. I don't remember having attended other meetings. But I must have

15 remembered the one in April, and there's a good reason for that. At that

16 time, I was doing my military obligation. That was in January. And in

17 February, I was in Sarajevo sometime around the 2nd. I don't remember

18 exactly when. Sometime around the 2nd, I got news that my daughter was

19 ill, and that's when I went to Sarajevo with my daughter -- with my wife

20 and my son. And I spent there almost a whole month while my daughter was

21 awaiting surgery. And she has survived, thank God. And on the 4th March,

22 I returned home from Sarajevo.

23 So I really don't know when these sessions took place, and I don't

24 remember having attended them.

25 JUDGE SCHOMBURG: Thank you. Then let's come to the second issue,

Page 14768












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Page 14769

1 and this is the establishment of the Crisis Staff. I have to recall that

2 straightforward and more than one hour, you testified on this, also the

3 143rd day of this case. You were asked: "When was the first meeting of

4 the Crisis Staff in Prijedor?" My question, page 36, starting line 1 was:

5 "Was it one, two, three, or five days after the takeover?" You said:

6 "Perhaps three days. I don't recall exactly." And then on page 35, line

7 1, you stated: "It was two or three days after the takeover of power. I

8 don't know who ordered this formation." And the same page, 35, line 22, I

9 asked you: "When did you attend for the first time a meeting of the

10 Crisis Staff"? You answered: "A few after the 30th of April. I can't

11 remember exactly."

12 Then later on, you were more concrete, told us that "The meetings

13 were held in the basement of the Municipal Assembly where the canteen

14 was," absolutely in line with the testimony of other witnesses. Then you

15 went on, went on with the same testimony. I asked you on page 46, line 6:

16 "It is correct that in conclusion with your previous testimony, this was

17 more or less a declaration of that what already existed some days after

18 the takeover? Would this be correct?" You answered: "Yes, yes." And

19 then you continued on line 13: "Well, at that time the disposition was

20 signed on the 17th that I was being relieved of my duty as the commander

21 of the staff and was to attach myself to the brigade, to the army."

22 So I think this simply confirms something that was already in

23 existence and that it was simply legalised in this way because you know

24 how it is with documents. They are always late. But this composition

25 probably reflects what's there." This was when you were confronted with

Page 14770

1 this document S180.

2 Before I ask you, maybe it assists you that we for a moment listen

3 what Mr. Miskovic has to tell us and told us in the past during the same

4 reportage in Prijedor Municipality on this matter. Let me just see. This

5 would be Document Number -- yes, once again, S91. You recall that we

6 heard the clip when you gave an interview, but also Mr. Miskovic gave an

7 interview that same day.

8 Could the audiotape please be played now from that point where we

9 have it.

10 [Audiotape played]

11 [Please refer to Exhibit S91A for audiotranscript]

12 JUDGE SCHOMBURG: Stop. Here we can read "you are well aware and

13 we have heard you are well aware of the events that ensued. However, as

14 president of the party and the chairman of the Crisis Staff at that

15 moment..." So Mr. Miskovic apparently speaks about the existence of a

16 Crisis Staff already the 29th of April, 1992. How is this possible that

17 when being asked by Mr. Lukic and being confronted with the document on

18 the composition of the Crisis Staff and the establishment of the Crisis

19 Staff in the Prijedor Municipality, you mentioned that "apparently I was

20 wrong". It reads: "It was only the 20th of May." Previously when I

21 confronted you with the same document, you state, as typical for

22 paperwork, it's always late, and it was established already previously

23 immediately after the takeover.

24 Mr. Miskovic in this interview states that he was at that time or

25 at that moment, to be more correct, the chairman of the Crisis Staff.

Page 14771

1 Could you please try to explain us these different testimonies both from

2 your side and from Mr. Miskovic.

3 A. Mr. Miskovic liked to show off a bit, you know. Usually, he would

4 introduce himself in the following way: Simo Miskovic -- just let me take

5 a while to remember -- commander of the Crisis Staff for the Bosanska

6 Krajina region. That's how he would always introduce himself. The staff

7 that he was talking about, that was the party staff as the Crisis Staff of

8 the SDS, the party. It was not a government staff, a government body.

9 That was different, and this only came to being after two or perhaps three

10 days after the takeover. That was later. These are two completely

11 different things.

12 JUDGE SCHOMBURG: Before you continue, may we hear Mr. Miskovic

13 what he has to say later. Please continue with the tape.

14 [Audiotape played]


16 So you have heard that the Crisis Staff was mentioned twice

17 related to the night from the 29th of April to the 30th of April. Once

18 Mr. Miskovic stated: "Then I scheduled a meeting of the Crisis Staff for

19 2.00 a.m. and ordered Mr. Kuruzovic and Simo Drljaca to do the job with

20 the army as we had agreed at the said meeting and that they were going to

21 submit the report by 2.00 a.m."

22 And then later on, after we have heard that immediately in the

23 barracks, Mr. Kuruzovic, Mr. Kovacevic, and Stakic, Mr. Jankovic, Cado and

24 others attended, and from the military side, Arsic and Zeka, then there

25 was a discussion on the meeting, where to meet in the Hotel, and then

Page 14772

1 finally at 2.00, I attended the session of the Crisis Staff and the

2 reports were submitted and it was decided by the Crisis Staff that the

3 takeover will commence at 4.00 hours a.m. and that's how it started."

4 Could you please comment on this.

5 A. Again, this is about what he called Crisis Staff, but that's the

6 party Crisis Staff because he was the president of the municipal board of

7 the SDS. The rest of it is correct and truthful. As far as the military

8 aspect is concerned, which refers to me, there was no special army there

9 because I was the commander of the regional staff of the Territorial

10 Defence at that time, and we simply informed the people who were outside

11 the town across the local communes that should there be any shooting or

12 any major problems arising, they should be prepared to defend the people.

13 As for the other part concerning the takeover, that was carried out by the

14 police in its entirety, and that was organised by Simo Drljaca, Jankovic,

15 Cadzo, Marko Dzenadija and so on and so forth.

16 So if you want me to repeat this, this is not the same

17 Crisis Staff.

18 JUDGE SCHOMBURG: Yes, so when was this SDS as you call it, SDS

19 Crisis Staff, when was this Crisis Staff established?

20 A. I don't really know. I was not aware of the existence of any such

21 thing officially. But Simo knows this. I told you that in March, I was

22 not in Prijedor at all. Whether the party set this up earlier on

23 someone's orders and on whose orders, well, yeah, I should assume so. As

24 far as I remember, there was a Crisis Staff, and there was the imminent

25 threat of war that had been proclaimed on the level of the whole party.

Page 14773

1 So he said that this should be official. I'm sorry to say this, but I

2 think he was merely showing off, even what we just heard, the interview.

3 He was a show-off in general.

4 JUDGE SCHOMBURG: But it is still your testimony that at that

5 time, something else existed, and this would be the SDS Crisis Staff.

6 Correct? Opposed to the Crisis Staff established then later based on the

7 documents both me and later Mr. Lukic has shown to you. Correct?

8 A. Yes, yes. The election, the voting at the assembly, that's when

9 this one was set up. The Executive Board and the president of the

10 Assembly, that was there. And as soon as the takeover occurred two or

11 three days later, I can't remember accurately, then someone ordered

12 someone from the Krajina, Autonomous Region, I suppose, Karadzic probably,

13 said that Crisis Staffs should be established from the Executive Boards

14 and said who the members should be of these Crisis Staffs.

15 Whether this was actually ordered by the president of the republic

16 or the presidency or the Crisis Staff of the Krajina Autonomous Region

17 from Banja Luka, I really don't know.

18 JUDGE SCHOMBURG: And then to be quite concrete, when it reads

19 here, there was a meeting, and this is absolutely in line with what you

20 told us beforehand, "I went up to the barracks where Kuruzovic, Mico

21 Kovacevic, and Stakic, Simo Jankovic, Cadzo and others were," what was

22 this? Was this a meeting of the SDS Crisis Staff or was it a meeting of

23 that what was called by others shadow government or option 2, that what

24 was elected mid-April 1992?

25 Was it already a meeting of those people who should form the

Page 14774












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Page 14775

1 Serbian Municipal Assembly as of the takeover, recall the document shown

2 to you by Mr. Koumjian, that it was ordinary in the past planned for the

3 1st of May, and then a decision was taken to implement this already

4 the -- during the night from the 29th to the 30th of April? So what was

5 this meeting in the barracks, a meeting of the upcoming Municipal Assembly

6 and those persons replacing others in the municipality, or was it a

7 meeting of the SDS Crisis Staff?

8 A. Well, probably a mix between the two. This was not a wholly

9 official body. I was then the commander of the regional staff in Urije

10 and Prijedor too, so that's probably why they wanted me to be there, too.

11 Only later when I remember, when I thought about April, the proposal, the

12 municipal elections for commander. This was a meeting of a group of

13 people, certainly party representatives, who when Mr. Stakic found out

14 about the telegram and brought it there and when it was read out, as I

15 said, I did not hear it in its entirety. A while before Mr. Miskovic

16 came, I arrived, too, but I understood -- because there was no reason for

17 me to believe it wasn't that way, but now I've had an opportunity to

18 actually see and become familiar with the content of that document, and a

19 decision was taken and an agreement was reached there. About what later

20 happened at 4.00 in the morning, when the police, in an organised manner,

21 left and took over the facilities. And then at 6.00, the officials went

22 to their positions.

23 JUDGE SCHOMBURG: To the best of your recollection, did you attend

24 a meeting of the SDS Crisis Staff prior to the 29th of April, 1992?

25 A. Not that I remember. I had not even heard up to that point that

Page 14776

1 it was referred to as the Crisis Staff. I don't remember attending any

2 such meetings. And it was a long time ago. I think not, but I can't be

3 positive about this.

4 JUDGE SCHOMBURG: Thank you for this assisting which indeed helped

5 to clarify things a little bit more. Let me now come to the third point

6 and let us hear what Dr. Stakic has to say on this.

7 May we please play Exhibit Number S187. This is a video.

8 [Videotape played]

9 [Please refer to Exhibit S187A for videotranscript]


11 Is this assessment of Dr. Stakic correct, that Trnopolje was

12 mainly filled with Muslims from Kozarac, a good part of those extremists

13 were from Kozarac and they went to Trnopolje?

14 A. This first part of Mr. Stakic's statement is true, most of those

15 people were from Kozarac. As for the latter part of his statement, I

16 don't know they were extremists or not. There were many men there who

17 were military -- who were fit for military service, able-bodied men. I

18 don't know the exact figures, but what he started saying when you

19 interrupted the tape, 1.450, I'm not how many of them UNHCR later took to

20 Karlovac. I don't know whether those men were healthy and able-bodied,

21 whether they were extremists or not, but no one there acted in such a way

22 as to create any special problems apart from the difficult conditions

23 themselves.

24 JUDGE SCHOMBURG: But can you understand why Dr. Stakic used the

25 terms "Muslims" and "part of those being extremists"?

Page 14777

1 A. Well, the people we referred to as Muslims, probably he believed

2 that among those people, there were men who were extremists. Now why and

3 what grounds, I really don't know. Probably on the basis of something

4 that happened later. I don't know.

5 JUDGE SCHOMBURG: Would it be true that as it is stated here:

6 "Trnopolje was mainly filled with Muslims from Kozarac"? Would this be

7 true?

8 A. Well, yes, later people came from the town. They arrived by

9 train, by cars, in cars from Hambarine. But most of them were from

10 Kozarac, or at least I believe so.

11 JUDGE SCHOMBURG: And then in order to save time, if you want, we

12 can play also this part of the one and same interview. Previously

13 Dr. Stakic said: "These places such as Omarska, Keraterm, and Trnopolje,

14 were a necessity in a given moment and were formed according to a decision

15 of the civilian authorities in Prijedor.

16 "Reporter: So these three camps, or how are they --

17 Dr. Stakic: Reception centres.

18 Reporter: "Reception centre, they were formed according to a

19 decision of your civilian authorities.

20 Stakic: Yes, yes." To be continued.

21 Who were those civilian authorities in Prijedor taking the

22 decision to establish Omarska, Keraterm, and Trnopolje?

23 A. As for the latter two, I don't know, I can only assume about

24 Trnopolje. I told you how it was established. If there was an agreement

25 or a decision, I was not aware of it. I was simply surprised, and there

Page 14778

1 was that request that was made, and I did say that. Whether the other

2 thing was necessary, too, I don't know. Those were investigation services

3 as far as I knew. Only the public security centre had the authority to

4 establish those on the orders of someone from the government or the

5 Ministry of the Interior. Now, whether there was any agreement with the

6 municipal leaders from other segments, I really don't know, believe me. I

7 can only speak about Trnopolje. Whatever else I said, I simply stated

8 what I believed.

9 If there were extremists, if it was necessary to look into their

10 actions, for them to give statements, then that's what it was for. But

11 Trnopolje was not a camp; it was something quite different. It was a

12 gathering of unfortunate people at the time, a refuge for people to go to,

13 as we called it. People fled from combat operations to save their necks,

14 elderly people, women, that kind of thing.

15 JUDGE SCHOMBURG: May the witness please be shown the document

16 tendered by the Defence, 65 ter number 414. Once again, the English

17 version, please, on the ELMO and B/C/S to the witness.

18 Would this be correct that this is a, as we can read at the top of

19 the page, a decision or a document issued by the 1st Krajina Corps

20 command, confidential number 621, from 2 September, 1992? And then please

21 look what we can see under number 2. And would you please be so kind and

22 read in B/C/S the entire number 2.

23 A. "The following was agreed in reference to the closure of Manjaca

24 and Trnopolje prisoner of war camps. First, to evacuate 79 sick detainees

25 from the Manjaca and Trnopolje camps; to secure their unobstructed

Page 14779

1 transport to the Mahovljani airport in Banja Luka; on that day, to open

2 the airport for the landing of ICRC aircraft that would transport the sick

3 prisoners of war abroad for treatment.

4 "After their requests have been met and we accepted our

5 obligations, they were advised to seek authorisation from the Croatian

6 authorities for landing the aircraft because Mahovljani airport was under

7 Croatian fire.

8 "Taking note of this, they gave a clear commitment to notify us

9 about the operation of transporting prisoners of war at least 24 hours

10 before so that could secure the landing and take-off of the aircraft. At

11 this point, they handed us a list of names of 65 prisoners of war who are

12 either wanted or ill."

13 JUDGE SCHOMBURG: Stop. You can see that the 1st Krajina Corps

14 command apparently used totally different terms. It started already:

15 "The following was agreed in reference to the closure of Manjaca and

16 Trnopolje prisoners of war camps." And it ends, quoting a list of the

17 names of 65 prisoners of war.

18 Then let's please continue. May the usher please show the Defence

19 exhibit tendered by the Defence, 65 ter number 416. Once again, issued by

20 the 1st Krajina Corps command, operational confidential number 655, 11

21 September, 1992. "Decision on granting amnesty from criminal prosecution.

22 Article 1, the following prisoners of war in Manjaca and Trnopolje prisons

23 are freed from criminal prosecution." And then it follows a list of 69

24 detainees.

25 So once again, prisoners of war in Trnopolje prison. Could you

Page 14780












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Page 14781

1 please explain how it's possible that the 1st Krajina Corps command comes

2 to a totally different assessment of what Trnopolje was at that time. Was

3 it a prison as reflected in the last document? Was it a prisoner of war

4 camp? And that there were prisoners of war in this camp?

5 A. I don't know where these names come from. I don't know what

6 these -- who these people are. Maybe they are from Manjaca. I don't

7 know. I've already said on several occasions that this name does not

8 correspond to what Trnopolje was. And anybody who was there can confirm

9 that. Regardless of how long they spent there, no Muslim was in uniform

10 there, and I didn't see any Muslims arriving with weapons there. So I

11 really don't know who the people referred to in this document are. I

12 don't remember anybody leaving in this way from Trnopolje. I remember

13 that only once the UNHCR came. I don't know when that was. I don't know

14 exactly. It may have been in June or in July. I don't know exactly. And

15 some 30 or 40 men were on their list. It was said that they were sick and

16 that they were supposed to be transported by plane to London for

17 treatment. I believe that the deputy minister of health also came, and

18 they were checked by a doctor from Prijedor. I didn't interfere with all

19 that because I didn't know who these people are and on what grounds they

20 were taken away. But I believe that that was that one occasion when some

21 of the people left.

22 As for the fact that they were prisoners of war, that is out of

23 the question, and I can swear before God and I can claim that Trnopolje

24 was not even a camp, let alone a prison as it is stated herein.

25 JUDGE SCHOMBURG: You can see that the latter document, it

Page 14782

1 reads: "We received the following telegram from the presidency of the

2 Serbian Republic," and then it starts with a quote, and it's finally

3 signed by the president of the Presidency, Dr. Radovan Karadzic?

4 A. Yes, I can see that.

5 JUDGE SCHOMBURG: So in his assessment apparently, it was granting

6 amnesty in relation to Trnopolje prisons. And the other documents,

7 speaking the same language "prisoner of war camps" and once again, "65

8 prisoners of war." So how can we bring your testimony together with the

9 other testimony? Was it maybe a mix? Was there a separate unit within

10 Trnopolje which could be called a, as it reads here, "prisoner of war

11 camp" or, in the other document, "prison"?

12 A. No. Trnopolje was never any such thing. There were -- people

13 were never interrogated there. There were no investigations carried out

14 there, so I really don't know understand what this is all about. Was

15 there maybe some other private agreement, I really don't know. I can see

16 here that this was signed by the president. I see the term "prisoners of

17 war". I see that both Manjaca and Trnopolje are being referred to as

18 prisons. It doesn't say here how many of these people were in Trnopolje,

19 among those who were taken away. I really don't remember. I just told

20 you that at the very beginning, some people were indeed taken away from

21 Trnopolje by somebody who came from the ministry. And they had a list on

22 which it said that these people were sick and that they were being

23 transported to London for treatment. That's the way I understood it. I

24 could not influence that. I could not have a bearing on that, whether

25 they would go or not go. There was a list signed by the Red Cross. I

Page 14783

1 suppose the Red Cross was aware of that. I believe that there must have

2 been a preliminary agreement with either the Red Cross or the UNHCR.

3 Their representatives were in Trnopolje on a daily basis, and they

4 themselves could see that this was not a camp or a prison, that people

5 were not being brought in or taken away. If somebody had been a prisoner,

6 they would have been tied, I suppose, but something like that never

7 happened in Trnopolje.

8 JUDGE SCHOMBURG: Do you know Colonel Milutin Vukelic?

9 A. Vukelic, no, never heard of him. I can see here that that was

10 signed by him in the corps command, but I don't know who that is.

11 JUDGE SCHOMBURG: But I hope, Mr. Kuruzovic, that based on these

12 documents and Dr. Stakic's own comments, we have some doubts on your

13 testimony on the nature of Trnopolje. And maybe following now and

14 answering the questions put to you by Mr. Koumjian, maybe it will assist

15 you and maybe there will be a chance and a possibility for you to correct,

16 in whole or in part, your previous testimony. Because I think you can

17 agree that on the basis of these documents, a totally different impression

18 is given of that what is the nature of Trnopolje. Would you agree? Would

19 you please --

20 A. Yes, this is a big surprise for me. I've never heard any such

21 thing. I've never seen any such thing. I don't know why Trnopolje would

22 be made equal to Manjaca or some other camp. I don't know on what

23 grounds. Maybe this was just a matter of red tape or administration.

24 Maybe -- given the fact that people were gathered in several places, one

25 term was given to all of these places just to facilitate things.

Page 14784

1 JUDGE SCHOMBURG: Would you agree that the list of names you can

2 read here, the 69 names, that these are Muslim names?

3 A. I haven't read all of them, but I can see this guy, his name is

4 Milomir Antunovic, he is not a Muslim. But the majority are Muslims.

5 JUDGE SCHOMBURG: Which was the number you just mentioned?

6 A. 58. Number 9 as well.

7 JUDGE SCHOMBURG: Milomir Antunovic. Do you know him in person?

8 A. No, no. I can tell by the first name and by the last name that he

9 cannot be a Muslim.

10 JUDGE SCHOMBURG: And the same would be true of number 9,

11 Janko Antunovic.

12 A. Yes, yes.

13 JUDGE SCHOMBURG: To be honest, for us it's extremely difficult to

14 make a distinction between Muslims, Serbs, Croats, based on the name. In

15 the past, we were never acquainted to do this exercise, but unfortunately

16 in this period of time, we have to look very seriously on the question of

17 the ethnic background of these persons. I hope we can overcome this

18 distinction we have made in the past in the future.

19 For the moment, it remains for me only to do some technical

20 exercise, and this would mean Document 65 ter number 414 was tendered by

21 the Defence. Are there any objections by the Prosecution?

22 MR. KOUMJIAN: No, Your Honour.

23 JUDGE SCHOMBURG: Then it would be admitted into evidence as D126A

24 and B correspondingly. And the other, 65 ter 416, the document from the

25 11th of September, 1992, this would be D127A and B correspondingly.

Page 14785

1 Objections?

2 MR. KOUMJIAN: No objection, Your Honour.

3 JUDGE SCHOMBURG: Both documents are --

4 MR. LUKIC: No objection, Your Honour.

5 JUDGE SCHOMBURG: Both documents are admitted into evidence under

6 these numbers.

7 May I then ask, please, Mr. Koumjian, to continue with your line

8 of questions.

9 Questioned by Mr. Koumjian: [Continued]

10 Q. Mr. Kuruzovic, you've mentioned several times the Autonomous

11 Region of Krajina. Did any leaders of the Autonomous Region of Krajina

12 such as Radoslav Brdjanin or Dr. Vukic or the mayor Predrag Radic visit

13 the Trnopolje camp, the Trnopolje reception centre, whatever name you want

14 to use for it?

15 A. No. As for Brdjanin and who else, Predrag Radic, they were never

16 there. And as for Vukelic, he's a doctor, no, I don't think so. I don't

17 remember. I don't remember their names. But if they had been, they would

18 have probably come together. Brdjanin, Radic were certainly not there.

19 And as for Dr. Vukelic, I think that he wasn't there either.

20 Q. It's Dr. Vukic who I believe was the SDS president in Banja Luka,

21 just to we're clear we're talking about the same person. You never saw a

22 Dr. Vukic to your knowledge did not visit the Trnopolje camp?

23 A. I don't remember.

24 Q. How about Stojan Zupljanin or General Talic, did you ever see them

25 at the camp?

Page 14786












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13 English transcripts.













Page 14787

1 A. No, no.

2 Q. Were you aware of a visit by Mr. Brdjanin and Predrag Radic and

3 others from Banja Luka, Stojan Zupljanin, to Prijedor in July?

4 A. I don't remember. They may have been there, but I don't remember.

5 If they had been there, they probably talked to the president of the

6 municipality and the president of the Executive Board, not with me. I

7 don't know.

8 Q. Sir, you talked about the Crisis Staff of the SDS. To your

9 knowledge, who were the members of the SDS Crisis Staff that existed prior

10 to the takeover?

11 A. As I've already told you, I heard that only subsequently. These

12 are the terms that Mr. Miskovic used. I was not in Prijedor at that time.

13 But if there had been such a Crisis Staff, then its members should have

14 been members of the presidency of the Serbian Democratic Party of

15 Prijedor. As far as I can see, Mr. Simo Miskovic is talking about the

16 party Crisis Staff at the time when this happened. This was before the

17 war, during the imminent threat of war. I don't know what else to call

18 that period.

19 Q. When you say the presidency of the SDS party in Prijedor, do you

20 mean the president and the vice-president of the party for Prijedor?

21 A. Yes, president, vice-president, and probably some other people who

22 were presidents of various standing committees and who helped with the

23 work. And if there had been a Crisis Staff, then nobody else but these

24 people could be its members.

25 Q. You were asked some questions by Mr. Lukic about Dr. Stakic,

Page 14788

1 Dr. Stakic's party membership. It was clear in 1991 that Dr. Stakic was a

2 member of the SDS, and in fact, he was the vice-president of the party.

3 Isn't that correct?

4 A. I don't know whether he was the vice-president of the party. I

5 know he was the vice-president of the Municipal Assembly. I hear -- I

6 heard it only the other day that he was not a member of the SDS, but it is

7 quite possible. Later on, he was. I know that for a fact, when he was

8 the president of the Municipal Assembly. Whether he was even before that,

9 really, I don't know.

10 MR. KOUMJIAN: Could the witness be shown S94, please.

11 Q. Just while that's being prepared, sir, what kind of car did you

12 drive when you were working at the Trnopolje camp? Excuse me, Trnopolje

13 centre.

14 A. It was a Renault given to me by the company called Borac from

15 Prijedor, and I returned it after only a few days. And I returned it

16 because a guy called Icic offered me to take a car that was in his garage.

17 He took me there, gave me the keys. This car was a Golf.

18 Q. Sorry, what was the name of the gentleman that gave you his car?

19 A. I think his name was Icic, Fikret or something like that. Yes.

20 And that car was then registered there and mobilised. And when I was

21 demobilised on the 22nd August, 1993, that car was given to the brigade

22 command, and I believe that the brigade command then gave it to the

23 hospital. I believe that was the sequence of events with this car.

24 Q. Sir, why did Mr. Fikret Icic give you his car to use?

25 A. Because he was afraid that somebody else would take it, so nobody

Page 14789

1 would know where that car was because such things happened. And if you

2 remember, we were talking about the establishment -- actually, whether the

3 Municipal Assembly was supposed to issue orders to the army and to the

4 police to control these cars which were driven without a travel order.

5 Unfortunately, a number of people from my ethnic group confiscated

6 property from other people. This man offered me the car because he knew I

7 would look after it, and once everything was rectified and once I was

8 demobilised, that car would be returned to him. So that I believe if he

9 really went there to ask for the car, that the car had indeed been

10 returned to him.

11 Q. Was Mr. Icic in Trnopolje?

12 A. Yes.

13 Q. Sir, now, in front of you is S94.

14 A. I don't know what his name was. Yes, go ahead, please.

15 Q. We're now turning to S94. You'll see that these are some notes

16 from the minutes -- excuse me, minutes of the assembly meeting of the

17 Prijedor SDS party held on the 11th of September, 1991. There's an

18 interjection, page 3 of the English. Sorry, I don't have the B/C/S in

19 front of me. By someone named Kuruzovic. Sir, do you believe that that

20 would be you, the person who indicated objected to Article 44, moving that

21 the text "but must be a member of the SDS BH be included." Would that be

22 you? Would that indicate to you that you were in attendance at this

23 meeting?

24 A. Since this is my name, it could only be me.

25 Q. Thank you. Sir, do you see that in this document, there were

Page 14790

1 elections for the party president and for the party vice-president. And

2 that 139 individuals voted in the election for the vice-president,

3 Milomir Stakic received 103 of the 139 votes. Does this remind you that

4 Dr. Stakic was the vice-president of the SDS party as of the 11th of

5 September, 1991?

6 A. I can't find it. But if this is how it reads, then it must be

7 true.

8 I've located that. It says vice-president, Dragan Savanovic,

9 Milomir Stakic, 103. And some Mirko Galamdzija or whatever his name is, 7

10 votes. So that means that Dr. Stakic became the vice-president of the

11 party. I said that I knew that he was an SDS member, but I don't know at

12 what period of time, from when up to when.

13 Q. Thank you.

14 MR. KOUMJIAN: I'd like the usher to please distribute another

15 document that has not been entered into evidence. It's 65 ter 316 on the

16 Prosecution 65 ter list. It has the ERN number in English beginning

17 03015836.

18 Q. You had testified, sir, about receiving a uniform. You said that

19 was intended for Mr. Srdic. Is that correct?

20 A. That's what I was told. I was told that there was no uniform for

21 me. Later on, I signed the receipt of that uniform.

22 Q. Now, according to your testimony, as I understand it, conflict

23 broke out in Prijedor after the 22nd of May. Is that correct? Sometime

24 after the Hambarine incident.

25 A. Yes.

Page 14791

1 Q. If you can take a look at this document, and perhaps the first

2 page of the English could be put on the ELMO, or has it already? Thank

3 you. And I believe Your Honours has copies.

4 Do you see that it indicates that the Prijedor Municipal Assembly

5 acquired a certain quantity of material for sewing flags and green

6 camouflage uniforms according to a delivery note dated the 3rd of May,

7 1992. And that the ordered goods were received on the 28th of May, 1992.

8 Would this indicate to you, sir, that uniforms that were made for members

9 of the Crisis Staff and others of prominence were ordered just after the

10 takeover of power?

11 A. It is possible. If this is official, then I assume the answer

12 would be yes. As far as I know, the uniform that I received and those who

13 were members of the Crisis Staff, those uniforms were not green. They

14 were light-brown with some yellow patches or spots. It was a very

15 lightweight summer uniform.

16 Q. It was camouflage, when you say "spots"?

17 A. Yes. And I can tell you that this type of uniform was worn by

18 every single manager of every company in town. Nobody forced them to wear

19 those uniforms, but what do I know? Maybe they wanted to go with the

20 flow. All managers wore such uniforms.

21 MR. KOUMJIAN: Your Honour, I have another document I would like

22 distributed. And that is -- has the ERN number 03074605 in English. It

23 begins with that, and concludes with 03074610A. And the B/C/S begins P,

24 as in Paul, 0008404, through 8410.

25 JUDGE SCHOMBURG: Not to lose control on the documents, the

Page 14792












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13 English transcripts.













Page 14793

1 previous one would be provisionally marked S432A and B respectively. And

2 the now distributed would be S433A and B respectively.


4 Q. Sir, this latest document is one of those I asked you to look at

5 over the weekend. Perhaps before we begin with that and so I don't

6 forget, I also asked you to look over that newspaper article that was

7 marked S238, Kozarski Vjesnik. Excuse me, that's not the right number. I

8 asked you to look over a newspaper article that we discussed

9 yesterday -- Friday. And that was an interview with you from 1995. Was

10 there anything else in that article -- or was there anything in the

11 article that you wanted to comment on or dispute, the 1995 article?

12 A. Well, I'd prefer a more straightforward question if that's

13 possible. This was a piece of coverage on the memorial day, the day when

14 the takeover took place. I may have been trying to show off a little bit

15 there myself. You know, everyone likes people to talk about

16 them -- everyone likes people to see them as able persons. But I suppose

17 I am about to receive some more specific questions from you regarding

18 that.

19 Q. Well, sir, I'm trying to be specific. Is there anything false in

20 that newspaper article?

21 A. Well, there are several things there that were not mentioned and

22 are connected to this. This Mr. Grubor who came to request, well, -- the

23 way is seems here is that he was under my command, that he had - I don't

24 know how many people - both armed and unarmed. So perhaps I should

25 clarify that a little bit. At that time, there was a war in Slovenia.

Page 14794

1 I'd already returned home. I'd buried my daughter. But in 1991, in late

2 September or early October, at the request of the people, a meeting was

3 held at the local commune building in Prijedor. About a thousand people

4 were there. A decision was made, which had been requested by the

5 representatives of all parties. But that was not a party meeting for

6 people to be listed, to draw up lists of people, people who were members

7 of the JNA, because they believed that that was the only form of

8 protection because all sorts of things were happening about town already

9 and people were scared. So people signed up who were members of the TO

10 and the police, too. Even those who had been members of the brigades, and

11 sometimes not. They wanted to be counted on should there be an attack

12 against the Serbian people. There were even women there, young men, young

13 women. That's what it was about.

14 And there were TO men there who were armed. They probably thought

15 that that was some sort of an army or some armed group. And this

16 gentleman came there requesting -- well, you can imagine what it looked

17 like if I released any lists to him. Anyway, I was not the one keeping

18 the lists. Stevanovic was, what's his name? This is something that was

19 public. As far as I remember, about 4.000 people signed up, women, young

20 men, girls. So perhaps I could answer the question why this sort of thing

21 happened. At that time, the 343rd Brigade was on the front in Western

22 Slavonia, the 5th Kozara, the 6th Sana, and the 11th Dubica Brigade,

23 including a lot of people from Prijedor, mostly Serbs, but there were

24 Muslims there, Croats, throughout the war even at the commands of these

25 brigades, Muslim citizens, Croatian citizens. And most of the Muslims who

Page 14795

1 had served their military service were in Prijedor. It was the talk of

2 the town how Muslims were arming themselves. And some of them were

3 members of the reserve police forces, people were scared because a lot of

4 men had left town. And these remained.

5 So that was a thing that happened of its own volition,

6 simultaneously. That's how it happened. So he thought in the spring that

7 this still existed and he was requesting people and that kind of thing and

8 so on.

9 Q. Just for the record, I believe it's time for a break. But the

10 document we were talking about, the one you read over the weekend was the

11 one entitled "memories of April's events in 1992" and that was S430, just

12 for the transcript.

13 MR. KOUMJIAN: Does Your Honour wish to take a break now before we

14 begin with the next document?

15 THE INTERPRETER: Microphone, Your Honour, please.

16 JUDGE SCHOMBURG: I think we have to stay with this document for

17 only one purpose. If you could please be so kind and have a look on the

18 fifth-last paragraph, that's in English, the English version page 5, and

19 there it's the fourth paragraph where it reads: "At the meeting of the

20 Crisis Staff of the Serbian Municipality of Prijedor and the Garrison

21 command held on 10th of June, 1992, and attended by Major

22 Slobodan Kuruzovic" --

23 MR. KOUMJIAN: I'm sorry, I actually haven't begun. He was

24 talking about the last document on Friday. It's my fault for confusing

25 the two.

Page 14796

1 JUDGE SCHOMBURG: Okay. Of course. Then let's come back to this.

2 It's then for you. The trial stays adjourned until 5 minutes past 11.00.

3 --- Recess taken at 10.36 a.m.

4 --- On resuming at 11.10 a.m.

5 JUDGE SCHOMBURG: Now once again, sorry that I already anticipated

6 something you want to discuss. But please, Mr. Koumjian.


8 Q. Mr. Kuruzovic, could you please explain to us what your role was

9 in the logistics base at Cirkin Polje, and explain how it changed, if it

10 did, over time.

11 A. At the beginning, it was a TO staff. Until the brigade

12 commander's order came on the resubordination, and then the order was

13 confirmed from the administration of the Municipal Assembly. There was a

14 decision. And as I said, one of the main tasks was to provide food for

15 all checkpoints throughout the municipal territory. After the 16th or the

16 17th, I can't remember the date, after that order, the staff was

17 abolished, and it was transformed into a so-called logistics base which

18 continued to work on the same tasks, providing food to all checkpoints,

19 and then regional staffs in the whole town, or rather in the whole

20 municipality, down to Ljubija, Brezicani, on to Omarska. That's where

21 another regional TO staff was. It was all TO. And the army and the

22 police, they all got their supplies from there.

23 Later, the chief of the logistics base was Mirko Mudrinic. I only

24 occasional used the opportunity on my way to Trnopolje, because it was

25 necessary for the children, and they would give me milk and fruit, fruit

Page 14797

1 juice, bread, from the Zitopromet company and so on.

2 Q. So please explain, after the Territorial Defence was absorbed into

3 the army, into the 43rd Brigade, by the order of Colonel Arsic and the

4 order of the Crisis Staff of the 29th of May, signed by Dr. Stakic, did

5 you continue to have any role in the Cirkin Polje logistics base other

6 than stopping by to pick up food for children?

7 A. I did not have any particular role. I was not in a leading role

8 of any kind certainly. Those other people who remained at the base were

9 in charge. As far as the fuel supplies and the fuel distribution and the

10 certificates was concerned, the municipal organ was in charge of that. I

11 don't think it was even the logistics base. That's what I'd been in

12 charge of, right at the beginning.

13 Q. I'm a bit confused when you say you didn't have any particular

14 role or a leading role. Did you have any road in the logistics base,

15 let's say, from June on?

16 A. Well, I said what I did. I would sometimes use the opportunity

17 for them to give me and they did give me very often food, milk,

18 cigarettes, that sort of thing.

19 Q. These are things for yourself, these are things for the persons in

20 Trnopolje? Who was -- for the guards at Trnopolje? Who did you get these

21 things for?

22 A. For the guards and for the people. Among those who came with

23 their unit commanders, there were no women and children. At the Red

24 Cross, there were. It was because of the small children. Because the

25 children, there were lots of small children in the camp. The cigarettes

Page 14798












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13 English transcripts.













Page 14799

1 were for the guards.

2 Q. And this is items that you would carry yourself to the camp, to

3 Trnopolje? Excuse me.

4 A. Yes. Yes, I put it into the boot of my car, and when I arrived, I

5 would distribute it to the guards and to the people. But the people knew

6 that I would always bring something, apples, milk, other kinds of fruit.

7 Elderly people, Muslims, would be waiting for me most often in the morning

8 when I arrived, and then they would take these things to the children over

9 there.

10 Q. Now, did you originally -- your original work with the logistics

11 base, in addition to food, part of your duties were to issue these

12 certificates for fuel. Is that correct?

13 A. Yes, yes, that was right at the beginning. Before the Executive

14 Board of the Municipal Assembly regulated the whole thing in a different

15 way, and then it was done by a kiosk which was close to the logistics

16 base, and then the municipal officials were in charge of issuing those

17 certificates after that. Whatever was left, they took from us. The

18 lists, the records. As to how many certificates had been issued, to which

19 persons, to which companies, and then all the companies got their fuel

20 from there. Some of those companies, that is, the car that they gave over

21 there, they used them for their own needs. So when food was being taken

22 or water to the checkpoints, there were cars and companies would be going

23 and then come back the next morning and that kind of thing.

24 Q. Originally, were you based in the Municipal Assembly building?

25 A. No, no. I was at the logistics base.

Page 14800

1 Q. Perhaps you could explain, on the transcript for the Day 143, that

2 is, your testimony Wednesday, on page 19 of my LiveNote -- I notice my

3 page numbers are never the same as Mr. Lukic's for some reason, line 7,

4 you stated: "It was the Executive Board, the Executive Board which urged

5 us to move out of the municipal hall and to undertake to issue - I mean

6 the Territorial Defence staff - to issue vouchers to issue fuel, petrol

7 vouchers, petrol coupons there so that companies and self-employed

8 entrepreneurs, those who needed fuel, that to go there to be issued with

9 some kind of voucher so they could get fuel."

10 So can you explain why you said on Wednesday that you were urged

11 by the Executive Board to move out of the municipal building, municipal

12 hall? Can you explain that?

13 A. Perhaps you misunderstood me. They asked for that job not to be

14 done at the municipality building because that was an admin building. All

15 the services serving citizens in any way since the takeover were there, so

16 that would create a mess. So they wanted this to be done at

17 the -- wherever the logistic base was. But this only lasted for about 10

18 days. I can't remember exactly. And then the Municipal Assembly service

19 took over. They had set up a kiosk there, and that's where this was done.

20 Q. Are you saying that you never worked -- the Territorial Defence

21 staff never worked out of the municipal hall?

22 A. Yes, never, never.

23 Q. Sir, where did you get the fuel from that you issue the vouchers

24 for? There was not a refinery, I presume, in Prijedor. Where did the

25 fuel come from?

Page 14801

1 A. We were not getting fuel. The fuel was being sold. Fuel in

2 Prijedor was stored in Jugopetrol or Krajinapetrol, I can't remember

3 exactly. The distance between the town was 6 kilometres, and this was

4 their own service area or rather station, and they were selling it. The

5 Municipal Assembly probably influenced the fact that not anyone was in a

6 position to get as much as they would like. So a voucher would be issued

7 and they would go there and get fuel from that petrol station. But not in

8 unlimited quantities.

9 Q. Thank you. You've anticipated my next question. What guidelines

10 did you receive as to who to give the vouchers to or the quantities

11 allowed? Were you allowed to give the vouchers just to your friends as

12 much as they wanted, or did you receive some guidelines, some rules, about

13 that?

14 A. There were no special guidelines as to how much. Someone might

15 have private needs, someone may have been ill, so these people would be

16 given about 5 litres. If it was a more remote part of town, it would have

17 been 10. And then companies could take up to 50, talking about oil. I

18 hope that I did my job in an honest way. I did have complaints coming in

19 from the municipal officials who thought that I would just let it go and

20 let people have as much as they thought they needed, so they complained

21 with the president of the Executive Board and the president of the

22 municipality. They wanted me not to give away so much fuel. So that may

23 have been one of the reasons why the municipal officials took over the job

24 at a later stage. I may have made a mistake at some point and given

25 someone 7 instead of 5 litres because the person had special reasons for

Page 14802

1 needing fuel, but I don't remember that. Maybe there were such cases,

2 exceptionally.

3 Q. Did you provide fuel to the army and the police so that -- to

4 ensure that they had sufficient fuel for their needs?

5 A. Yes.

6 Q. And this was -- you were issuing these again at the -- under the

7 authority of the Executive Board or Municipal Assembly? They're the ones

8 that authorised you to issue the certificates. Correct?

9 A. Yes. And the army and the police came with orders from the

10 brigade commander stating -- or the secretariat of the interior. But not

11 so often the secretariats. I think they got their fuel from the army and

12 a certificate would be issued. Most of it was for the medical centre,

13 because many people had to go to Banja Luka for kidney operations and

14 dialysis. So every morning, there would be a person who was taking them

15 there in all the ambulances for all the hospitals and the medical centre.

16 Q. Thank you. Now let's go to the report on mobilised motor vehicles

17 in Cirkin Polje logistics base. That's in front of you dated the 17th of

18 June. Sir, I'm a bit confused when you indicate that you had no role in

19 the logistics base from June on when apparently this document indicates

20 that you attended a meeting regarding the logistics base. I'm looking at

21 page 9 of the English. On page 9 of the English, I don't have the B/C/S

22 in front of me, but it would be -- it has the date the 10th of June, and

23 it should be the fifth paragraph from the end.

24 Excuse me, I have the draft, and Ms. Karper has given me the

25 final. I may have the wrong numbers. If you see the signature of

Page 14803

1 Mr. Mudrinic, if you go up six paragraphs from the end, so six paragraphs

2 from the end --

3 JUDGE SCHOMBURG: Sorry, we would like to follow you. Our English

4 version ends on page 7.

5 MR. KOUMJIAN: Yes, thank you. I was using a draft that we had

6 last week, and Ms. Karper just gave it to me. So the English is now page

7 5. Thank you. And on the B/C/S, it would be the page ending 8408, the

8 second paragraph on that page, the first full paragraph on that page.

9 Q. In that paragraph it states that "at the meeting of the Crisis

10 Staff of the Serbian Municipality of Prijedor and the garrison command

11 held on the 10th of June, 1992, and attended by Major Slobodan Kuruzovic,

12 commander of the Serbian army staff as well as deputy commander for

13 logistics, Mirko Mudrinic, and then also quartermaster Stevan Nikolic and

14 all commanders of sector staffs, all instructions given by the garrison

15 command and the Crisis Staff relating to the transformation of the

16 Territorial Defence into the army of the Serbian Republic of

17 Bosnia-Herzegovina were accepted."

18 Do you recall this meeting of the Crisis Staff and garrison

19 command held on the 10th of June, 1992?

20 A. No, I don't. But probably it was held, and it says that I was in

21 attendance. Yes.

22 Q. Can you explain in what role you would have attended that meeting?

23 A. This, as you can see, is the 17th of June, the time when the staff

24 comes into existence. And this report dates to the beginning of the

25 existence of a part of the logistics base. So this is a working report,

Page 14804












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13 English transcripts.













Page 14805

1 cars that were mobilised on the 2nd and 3rd of May. There are a number of

2 those that were mobilised later when I was no longer there but I was

3 supposed to attend because there were reports which pertained to the

4 period when I was there at the staff.

5 Regardless of whether I was a member or not, it was my duty to be

6 there and to confirm what they wrote here in this report. Among other

7 things, they discussed about the transition of the Territorial Defence as

8 a whole to the army of Republika Srpska. I am not only referring to the

9 Serbian TO, the TO in its entirety. But you know what the times were

10 like. There was a special name, but actually it was all the same because

11 at that time, there were only Serbs that were members of the TO, except at

12 the command. At the command, there were Muslims, and that other part over

13 there in the town, there were also Muslims but that was a little bit

14 divided already.

15 Q. The report indicates, if we go up a few paragraphs, going up two

16 paragraphs: "We would like to point out that from the day of the takeover

17 and the establishment of the logistics section in the Serbian army TO

18 staff in Prijedor, up to the 10th of June, in addition to many sanitation

19 and medical measures, we have also provided the weapons and ammunition for

20 sector staffs and secured and delivered about a hundred thousand meals to

21 members of the police and Serbian army TO units."

22 So was part of the duties of the logistics base to also distribute

23 weapons and ammunition?

24 A. No, not weapons, ammunition. The weapons, they had. I said the

25 TO, which was part of the town, but when there was the takeover, then

Page 14806

1 everything was all the same thing, it was more under the command of

2 Mr. Javoric than mine because anyway, I did not have any special military

3 units. But this all went together, and I was in a lot of difficulty

4 issuing certificates for fuel and all the other miracles. And then all

5 the way until the incident that happened there, and then I had to go to

6 Trnopolje. But, for example, this would be given to the police, the army

7 units because you see they're referring to the TO and the Serbian army,

8 too, because when the Serbian army existed, then there was no more TO.

9 And the man who wrote this report -- well, you do understand what it's

10 about. The food, the ammunition, and all of that. This was given all at

11 once because as far as I remember, aside from that, it wasn't used very

12 much because there were no ongoing operations in the town itself.

13 Q. Was it the Crisis Staff that directed the logistics support from

14 this base?

15 A. Yes. Everything that the logistics base had, the orders had to be

16 given from the secretary for the economy. For example, if somebody was to

17 take bread, then an approval had to be given. And as far as I know,

18 reports had to be written on the quantities of food that were taken. At

19 the beginning, this was taken from a restaurant in town, and the food was

20 taken to the checkpoints. Thereafter, this was prepared in the logistics

21 base, and it was transported either by lorries or by cars, depending on

22 how far away the checkpoints where the food was needed were.

23 Q. Sir, if we go up one paragraph, and that would be in English the

24 bottom of page 4, it begins: "Since 1st of May, 1992, Cirkin Polje

25 logistics base has been providing complete logistics support to all police

Page 14807

1 officers in Centar, Prijedor II, and all members of" and it lists a number

2 of local sector staffs. "Supplies have been delivered in accordance with

3 the decision of the Crisis Staff of the Serbian Municipality of Prijedor

4 on the basis of which a report has been compiled and sent to the Crisis

5 Staff and garrison command." And I believe that's consistent with what

6 you just told us. Is that correct?

7 A. Yes, reports so that it was known what was given to the military,

8 how much food, how much of everything else, and the same applied to all

9 the Territorial Defence, all the regional staffs across the town, and that

10 is correct.

11 Q. Going back to the paragraph I began with, that's page 5, that

12 begins: "At the meeting of the Crisis Staff held on 10 June, 1992... ,"

13 is it correct, sir, that the logistics centre also provided food to the

14 Keraterm and Omarska prisons?

15 A. As far as I know, yes, but I don't know whether it was transported

16 for here or was it the police that transported it? But whatever was

17 within the purview of either the police or the army, the food was prepared

18 there and transported from there. I don't know that the food would be

19 taken from this logistic base to Omarska and Keraterm. I believe that

20 this was first taken to the police, and then the police distributed it and

21 transported it. But I can't be sure, I can't claim that for a fact.

22 MR. KOUMJIAN: If we could now have -- Ms. Karper prepared 65 ter

23 368.

24 JUDGE SCHOMBURG: Are you ready to leave this document?

25 MR. KOUMJIAN: Yes, I'm ready to leave this document if Your

Page 14808

1 Honour has some questions.

2 JUDGE SCHOMBURG: Then please, in the same paragraph you just

3 mentioned, it was said you participated in the meeting of the 10th of

4 June. I already confronted you previously with the enactments passed this

5 10th of June, 1992, based on the document S250, and only to recall the

6 first conclusion was requesting the municipal secretariat to report on the

7 logistics base. Second, assigning the duty of providing security for the

8 Trnopolje camp to the regional command.

9 Would it be correct to conclude that you in fact participated in

10 this meeting of the Crisis Staff the 10th of June, and you were present

11 when these two issues were dealt with?

12 THE WITNESS: [Interpretation] I assume that I did, since this is

13 what it says here. But not as a member of the Crisis Staff. This report

14 covered a longer period of over a month. I was supposed to attend this

15 meeting as somebody who had participated in the reorganisation of these

16 tasks relative to the supply of food to the army and the police, the

17 checkpoints, the supply of fuel and so on and so forth. Because here --

18 JUDGE SCHOMBURG: That's absolutely in line with that what we can

19 read in Document S250. There was, for example, an order banning Krajina

20 petrol company from issuing petrol without Crisis Staff permits. This

21 would fall under your area - Correct? - of responsibility?

22 THE WITNESS: [Interpretation] Yes, I issued those permits or

23 certificates and then people would go buy fuel. The Executive Board

24 demanded a maximum savings or -- of energy and fuel.

25 JUDGE SCHOMBURG: And then that we are not once again confusing

Page 14809

1 the months, it's not a document of May 1992, but the document dated the

2 17th of June. And here it reads: "The decision" - in the first

3 paragraph - "the decision of the Crisis Staff of the Serbian Municipality

4 of Prijedor, and the orders of the commander of the Serbian army

5 Territorial Defence staff of Prijedor Municipality, Major

6 Slobodan Kuruzovic. Troops and equipment were mobilised in the logistical

7 support staff." That would mean that, in fact, this 17th of June, 1992,

8 you still were the commander of the Serbian army Territorial Defence staff

9 of Prijedor Municipality. Correct, as it reads in paragraph 1?

10 THE WITNESS: [Interpretation] No, Your Honour. This is a report

11 which was written on the 17th and covered everything that happened up to

12 that date, including the things relative to the Territorial Defence staff,

13 and the logistics base. Some of these cars were mobilised at the very

14 beginning, and most of the people were drivers from these companies who

15 would work in their companies in the afternoon, and then work other things

16 in the morning. So this is submitted by Mudrinic, the chief of the

17 logistics base. But whatever was carried over to that base prior to the

18 17th of June, I don't know whether anything else is mentioned here, so

19 everything that was carried over up to the 17th of June, together in the

20 logistics base and the territorial staff. I never submitted these reports

21 before. I hope I've helped you to understand this. So this is a report

22 that covers a long period. I can see the dates here, the 2nd of May, the

23 3rd of May, and after the 17th -- actually, the 29th, I no longer operated

24 in the capacity of a commander of the staff, of the territorial staff, as

25 per the decision that we saw.

Page 14810












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Page 14811

1 JUDGE SCHOMBURG: So repeat, you do not dispute that you attended

2 the meeting of the Crisis Staff of the Serbian Municipality of Prijedor

3 and the garrison command held on 10th of June, 1992, and attended by Major

4 Slobodan Kuruzovic, commander of the Serbian army staff?

5 THE WITNESS: [Interpretation] That is just the way he put it,

6 because later on, I did not have any position or post. And prior to that,

7 I had that one. I was in the brigade. It was just a habit. He had to

8 mention some position that I had, but not the one that I had at that time,

9 but the one that I had prior to that because he mentions things happening

10 on the 2nd and the 3rd of May. So this is a report that covers a month

11 and a half period.

12 JUDGE SCHOMBURG: And then we have also a prologue in an addendum

13 to the report. And there it reads: "On 15th of June, 1992, a number of

14 members of the Territorial Defence staff of the Serbian army, members of

15 Cirkin Polje logistics bases who are permanently involved in the securing

16 of Trnopolje refugee centre addressed a request to the leadership of the

17 command logistic base underscoring the problem of fuel shortage" and so on

18 and so forth.

19 And then under 5, it reads: "Slobodan Kuruzovic took a diesel

20 vehicle, Golf vehicle, registration number PD-630-02 from Fikret Icic.

21 Slobodan Kuruzovic is working as commander of the territorial defence

22 staff of the Serbian army of the Prijedor Municipality. Alongside other

23 duties, he has been active in Trnopolje from the very first day when the

24 refugee centre was set up as the Crisis Staff of the Serbian Municipality

25 of Prijedor is well aware." Is this correct what we can read under number

Page 14812

1 5?

2 THE WITNESS: [Interpretation] Yes, this is correct. I am only not

3 sure about the dates. I believe that I got this vehicle from this man

4 earlier than that, but I'm not sure. Maybe five or six days earlier. I

5 don't know exactly. All I know is that I asked for this vehicle to be

6 accepted as mobilised but it was not done by the staff -- excuse me, by

7 the logistics base. I registered this vehicle as a conscript's vehicle,

8 as a vehicle that was mobilised by the secretariat of defence. I did it

9 with Mr. Slavko Budimir. And as of that moment on, this vehicle became a

10 soldier, just like I was a soldier. It was mobilised. When I was

11 demobilised, I returned that vehicle, and I believe that that vehicle was

12 then returned to its original owner.

13 JUDGE SCHOMBURG: And the assessment is correct, as we can read it

14 here, "he, that is Slobodan Kuruzovic, has been active in Trnopolje from

15 the very first day when the refugee centre was set up."

16 It was not loud enough. Interpreters apparently couldn't hear

17 you. You said "da," yes, correct?

18 THE WITNESS: [Interpretation] Yes, yes. I apologise.

19 JUDGE SCHOMBURG: And then the sentence starts: "Alongside many

20 other duties, he has been active in Trnopolje." Could you please tell us

21 which were these "many other duties"?

22 THE WITNESS: [Interpretation] That is exactly that. The person

23 who drafted this report tied things to the whole month preceding this

24 report, because these certificates had to be issued. I don't know what

25 else he had in mind. There were no other duties or tasks. As you can

Page 14813

1 see, this is just a report of a person who wants to justify his work

2 before his superiors and peppers it a little bit, as the popular saying

3 goes. As far as my engagement in Trnopolje goes, this has been described

4 correctly. I was there every day on a daily basis. And before the order

5 was issued for me to be resubordinated to the brigade, before the decision

6 was issued on the abolishment, I also looked after the vehicles, whether

7 they were in good order, whether the food was being transported where it

8 had to be transported. I checked the documents to avoid any abuse. I

9 made sure that the food arrived and reached those that it was intended

10 for.

11 Because the times were, as I've already said, odd. I believe that

12 I have already mentioned this. There were people who thought it was their

13 right to do all sorts of things, without any authorisation, just because

14 they wore a uniform.

15 JUDGE SCHOMBURG: And then finally, coming back to the mere fact

16 that you attended the meeting the 10th of June, 1992, and one of the

17 enactments passed this day was the conclusion assigning the duty of

18 providing security for the Trnopolje camp to the regional command. First

19 of all, we should be aware that it reads here not "centre," not "reception

20 centre," but "camp". And then why is it necessary if people are there, as

21 you explained it until now, more or less on a voluntary basis, why is it

22 necessary to provide security and then to the regional command bearing in

23 mind the previous documents where the language was "camp," "prisoners,"

24 "prisoners of war"?

25 THE WITNESS: [Interpretation] I told you a little while ago with

Page 14814

1 regard to the materiel and goods, this was the only way. Somebody had to

2 be subordinated to somebody else. It was not the civilian police because

3 it was not a prison. And there were lots more troops. And since I was

4 subordinated to the army as of the 17th onwards, and even before that, the

5 Crisis Staff and I asked for the army to provide security for these people

6 because that was the safest way. There was a clear line of subordination.

7 There were officers who were in charge of the 20 men-strong units. They

8 would be there all night. They would return in the morning. They would

9 be replaced by others, and they would report to the regional command that

10 everything was carried out in order. If security had been provided by

11 some private individuals serving as guards, all sorts of things might have

12 happened. As it was, nothing did.

13 JUDGE SCHOMBURG: Thank you.

14 Let us now turn once again to the Prosecution. They tendered a

15 document from -- dated Prijedor, the 30th of September, 1992. This would

16 be provisionally marked S434A and B respectively. Please, Mr. Koumjian.


18 Q. Sir, before we leave the report on mobilised motor vehicles, just

19 a few questions. Fikret Icic, would I be correct in assuming that he was

20 a Muslim?

21 A. Yes, yes.

22 Q. And now, if you turn to number 15 on the list of mobilised motor

23 vehicles in the first part of the report, it indicates that on the 11th of

24 May, 1992, a Zastava vehicle was mobilised and given to Vinko Kos of the

25 SDS. I understand this to be a report that the only people that could

Page 14815

1 mobilise vehicles were the army. Is that correct? It had to be under the

2 authority of the army or the secretariat of national defence to mobilise a

3 vehicle. Is that correct?

4 A. Vehicles were mobilised by the secretariat for national defence,

5 and this vehicle was taken from the company Bosna Montaza, probably

6 returned in good working order. Now why did Vinko from the SDS used it, I

7 don't know. Maybe this person didn't know what this Vinko was doing. As

8 far as I know, I believe that he was in a company, in a timber industry or

9 somewhere. I don't know. I've forgot.

10 JUDGE SCHOMBURG: Paragraph 13. Is this the same Vinko Kos?

11 THE WITNESS: [Interpretation] Yes, yes. He was in Lamovita in the

12 sector staff. As far as I remember, he worked in a construction company.

13 It's the same man. In one place, it says "sector staff"; in other place,

14 it says the SDS. I don't know why this gentleman Mudrinic drafted it this

15 way.


17 Q. Well, sir, these are two different -- From the plate numbers

18 given, these are two different vehicles. First let me ask you --

19 A. Yes.

20 Q. When you talk about the secretariat for national defence, you're

21 speaking of the office headed by Mr. Budimir at this time, in the spring

22 of 1992. Correct?

23 A. Correct. If these vehicles are mobilised for the purpose of the

24 army, then a mobilisation chart has to be issued. It is possible that

25 some of the vehicles were mobilised by the staff, not for the military

Page 14816












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Page 14817

1 purposes, then a certificate would be issued and would be taken to the

2 Executive Board, and it would be the secretary for the economy who would

3 deal with that. And then the vehicles, such vehicles, would be returned

4 to those that they were taken from.

5 Those are -- were the vehicles which were mobilised for certain

6 purposes and for no other purposes.

7 Q. Okay, sir. If we could now move to the next document --

8 MR. KOUMJIAN: Perhaps Your Honour wants to mark this one.

9 JUDGE SCHOMBURG: It's already marked provisionally S434A, B

10 respectively. Prijedor, 30th of September 1992 report.


12 Q. Sir, looking at this document, it appears to be a report. It

13 indicates in the introduction: Pursuant to the conclusion of the

14 executive committee of the Prijedor Municipal Assembly of 5 May 1992,

15 Dr. Srdjo Srdic is named as acting president of the Prijedor Red Cross.

16 I'm summarising.

17 You mentioned in your testimony to estimate the number of people

18 who passed through the Trnopolje camp, and you told us you thought there

19 were maybe six or seven thousand. Turning to page 9 of the English, I'll

20 try to find it on the B/C/S, it's under Section 8 "conclusion and

21 comment." I'm having trouble finding it on the B/C/S because the

22 numbering of the sections does not make sense. On the B/C/S, I believe

23 it's page 6954.

24 MR. LUKIC: It's number 13 in Roman.

25 MR. KOUMJIAN: Thank you. It's number 13. Thank you.

Page 14818

1 Q. Do you see, sir, that in the last point under that number 13,

2 there are several indented paragraphs with a dash. The last one indicates

3 that "23.000 people have been housed through the reception centre at

4 Trnopolje, of whom we in the International Red Cross have dispatched 1.561

5 to the Karlovac reception centre. On 29 September, 1992, a convoy was

6 escorted to Karlovac in the presence of European observers".

7 JUDGE SCHOMBURG: I think it would be appropriate also to read the

8 next paragraph.


10 Q. "The problem of Trnopolje is becoming more complicated with the

11 onset of autumn, so that there are those -- so that all those who have

12 been left without homes are arriving in great numbers seeking

13 accommodation. There are now more than 3.000 citizens there."

14 JUDGE SCHOMBURG: Thank you.


16 Q. Sir, first, would it be correct that at times, the Trnopolje

17 facility held up to 3.000 individuals?

18 A. I don't know. People came and went. There may have been even

19 more. I never made any assessments or estimates. If this information was

20 provided by the Red Cross, I don't know what they base their information

21 on. Either on the number of people or on the number of meals, because a

22 lot of these people were accommodated in the houses around. I cannot

23 either confirm or dispute this Red Cross report. I don't think it is

24 incorrect because I believe it was drafted in consultation with the

25 International Red Cross and the UNHCR.

Page 14819

1 Q. Sir, how many different convoys were there to Croatia, not just

2 Karlovac, but to Croatia from Trnopolje?

3 A. I don't remember any. There were organised departures from town,

4 from Prijedor. And those were organised by the Red Cross. Maybe those

5 people who left from town, they considered to have been in Trnopolje.

6 This sounds a bit exaggerated to me. Maybe they did it on purpose for

7 administrative reasons. I really don't know. I only know that very

8 often, buses would leave from town. Whether they went off towards

9 Croatia, I wouldn't know for a fact. You've already asked me, I believe

10 it was the day before yesterday, about people having to pay their bills

11 first, the utilities, and then they would leave.

12 Q. Sir, the Trnopolje facility was located a hundred, 200 metres from

13 the railway station. Correct?

14 A. Yes.

15 Q. How many organised convoys were there from the Trnopolje facility

16 using trains?

17 A. I don't remember exactly, but I believe two or three, possibly. I

18 don't know. This was organised by the Executive Board of the Municipal

19 Assembly. Mr. Savanovic, I think, was the manager of the railroads, and

20 he used the help of his colleagues in Zenica, and that's how people went.

21 They were taken to Zenica. There were two or three-passenger vehicles at

22 different time intervals.

23 Q. Sir, when you say "passenger vehicles," the people were put on to

24 cattle cars. Isn't that correct?

25 A. I think one of the convoys, in addition to passenger wagons, had

Page 14820

1 two or three other ones, but there were more things there. It was hot.

2 Not a single one of the convoys consisted merely of cattle cars. But I

3 think there were freight cars that were included.

4 Q. How many bus convoys were there out of the Trnopolje facility?

5 Bus and truck convoys?

6 A. I don't know. Well, I never kept any records on that. There were

7 at least three or four, I believe.

8 Q. Is it correct that at one point, the convoys were going to

9 Croatia, and then later they went to Central Bosnia?

10 A. I don't remember any convoys going to Croatia. Central Bosnia,

11 yes. That's why I'm saying, those who were going to Croatia, it's

12 possible that they went by public transport organised by the Red Cross.

13 They were going to Croatia. Except for what I mentioned about late 1991

14 and early 1992 when people were leaving the municipal territory with

15 organised departures, mostly women, children, and the elderly, those who

16 were men of military age and able-bodied men mostly remained in town.

17 Now, what the reason was for that, I suppose they should know.

18 Q. Sir, I'd like to --

19 MR. KOUMJIAN: We're breaking at 12.30, Your Honour? It may

20 affect the order I do things.

21 Q. Sir, you indicated -- let me ask you the following question: I'm

22 going to ask you the same question I asked you in Banja Luka. Sir, in the

23 times of conflict in Prijedor - I'm talking about May and June of

24 1992 - did the Crisis Staff and military work to coordinate their efforts?

25 A. It would be difficult for me to answer that question. I don't

Page 14821

1 believe that the Crisis Staff gave any orders to the army. As far as I

2 can remember, the few meetings that I attended, two or three times there

3 was Colonel Arsic or Zeljaja or Rajlic mainly with requests for meeting

4 the needs of the army. If you actually meant that the Crisis Staff was

5 ordering military operations, first of all, I don't remember any such

6 thing. Secondly, I don't believe that that would have been possible. I

7 don't know.

8 Q. Sir --

9 JUDGE SCHOMBURG: Mr. Koumjian, could you please be so kind and

10 make reference to the page number of the statement.

11 MR. KOUMJIAN: I'm referring to page 46, line 10 of the transcript

12 of our conversation in Banja Luka. And I will read again the question and

13 the answer as it's translated -- transcribed.

14 Q. "In those times of the appeal and conflict in Prijedor, and I'm

15 talking about May and June of 1992, did the Crisis Staff and military work

16 to coordinate their efforts?" And you answered: "Yes."

17 What did you mean? Do you deny that you answered yes to that

18 question no Banja Luka, and if you do not deny it, would you like to

19 explain your answer?

20 A. Well, I believe I just have explained it. I don't mean to say

21 there were no contacts between the civilian authorities and the military.

22 But I assume that was your question, and that's perhaps why I said yes.

23 It's not that the army didn't come to the Municipal Assembly, to the

24 people in the leading positions because those were the people who were in

25 a position to deal with the vital problems that the army was facing. So

Page 14822












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Page 14823

1 accordingly, I do remember, although I was only there twice, perhaps three

2 times, attending the meeting of the Crisis Staffs. And I know that they

3 made certain requests at these meetings, but I can't remember any of the

4 specifics, when, perhaps, the army had to go to the front, then lorries

5 were to be secured because a lot of stuff had been destroyed. And what do

6 I know? This is merely my assumption.

7 Q. Sir, in fact, your own work at that time was an example of the

8 coordination and the overlap between the civilian and military

9 authorities. On Wednesday, on page 26, line 6 of Wednesday's transcript,

10 you described yourself at that time as "I wasn't a soldier, I wasn't an

11 army officer, I wasn't the Red Cross, and I was all that at one and the

12 same time."

13 So you were, yourself, both a municipal official, an army officer

14 at the same time. Correct?

15 A. Well, it strikes me as a bit strange. I said it as a human being

16 because there were great problems that we were facing. There was the camp

17 at Trnopolje. Those people had to be taken care of. There were

18 obligations related to the issuing of the vouchers and certificates. And

19 then after about a fortnight, I received orders to join the army. So no

20 wonder I referred to a number of different tasks and positions. I was not

21 officially a member of the Red Cross, but, well, perhaps it's not a nice

22 thing to say, but I took better care of those people over there than the

23 Red Cross themselves.

24 Q. Sir, were you -- you were tasked by the Crisis Staff to provide

25 security at the hospital. Is that correct?

Page 14824

1 A. The hospital?

2 Q. Yes.

3 MR. KOUMJIAN: Could the witness be shown S21, please. S21.

4 Q. Sir, do you have it yet? Sir, the usher is handing you S21 which

5 indicates that at a meeting on the 6th of June, 1992, the Crisis Staff of

6 the Municipality of Prijedor issued the following conclusion: "The chief

7 of the public security station, Simo Drljaca, and Slobodan Kuruzovic

8 coordinate security of the Prijedor hospital. Which they will inform the

9 Crisis Staff at the next meeting."

10 Do you recall this meeting from the Crisis Staff, sir?

11 A. I don't have the same thing, the one you've just given me. That's

12 a different one. This is not the same document. This is on the blockade

13 of the town, and then concerning the traffic.

14 MR. KOUMJIAN: Excuse me, I gave you the wrong number. 71.

15 Q. Sir, this document also indicates that copies were given to the

16 public security station, Simo Drljaca, Slobodan Kuruzovic, and the cashier

17 Zarko Zgonjanin. Do you recall receiving this order or being present when

18 it was made?

19 A. I remember neither. But there is some logic to such a thing being

20 done, because that's one of the most sensitive facilities in the town.

21 But I was in no way related to that as far as I remember, unless he

22 actually -- unless this was represented as a decision, so probably they

23 thought that someone from the barracks would do it. And in that case, I

24 should be responsible, but I've never seen a conclusion like this one,

25 although I do believe that this was a necessary step to be taken, for

Page 14825

1 security to be provided for the hospital to prevent possible accidents.

2 Q. Did you ever speak to Simo Drljaca about providing security at the

3 hospital, or did you ever send -- arrange for any security for the

4 hospital?

5 A. No, I didn't. Not I. Whether I talked to him, I don't remember.

6 But organised in cooperation with the public security centre, no, I

7 didn't. I don't know how this -- why this includes my name, but here you

8 have it.

9 Q. Sir, I'd now like to ask you some questions about the conditions

10 and things that happened in the Trnopolje camp. You told us Wednesday on

11 page 27 and 28, you were asked some questions -- you talked about people

12 entering the camp and committing crimes, the last paragraph of page 27.

13 You said: "On one occasion, some villagers, some local people entered,

14 and I think some women, I believe four of them, were raped. Otherwise in

15 that centre, there were physicians all the time. I think two physicians,

16 two Muslims, and there were also nurses there. And in daytime, a doctor

17 and a male nurse would come whenever it was necessary for them to do

18 something. From what I know, people were taken to the hospital in

19 Prijedor. Those rapes, to try to establish -- and I think only one of

20 them was actually raped."

21 Sir, how did you come to the conclusion that only one of the women

22 was raped?

23 A. Well, I didn't come to any conclusion, but people talked over

24 there. Those locals, because they were not inside any kind of fences.

25 They were either outside in the street or at the Red Cross. They talked

Page 14826

1 among themselves. I may have misheard, but I do know that those ladies,

2 I'm not sure how old they were, they were taken to hospital. And now what

3 was confirmed over there or not, and all the other things, I have no

4 information.

5 Q. Well, sir --

6 A. I only know that that one was the lady of an advanced age.

7 Q. Well, how did you first learn that -- you originally said four

8 women were raped by these villagers that came in. How did you first learn

9 of this?

10 A. When I came in the morning from the town, they told me that there

11 had been such an incident, that the guards then intervened, and that

12 doctors took care of those ladies and took them to hospital. That's what

13 I found out when I came. But it was before the noon. It was not early in

14 the morning. It was before the noon, and that's when I heard about that.

15 I did not hear any of the details, though. The people from the Red Cross

16 were talking about it because they had come before me and they said that

17 women had been assailed. Well, that, and they referred to Cavic, but I

18 don't know for sure. I don't know whether if it was that man or whether

19 there was another man with him. I don't know.

20 Q. When you say "they told you" do you mean the people from the Red

21 Cross, from the Serbian Red Cross?

22 A. Yes, because they, too, apparently heard about it.

23 Q. What made you believe that only one of the women was raped, if you

24 heard that they were -- the guards had intervened and four women had been

25 raped?

Page 14827

1 A. Well, I don't know whether I referred or that one specially. I

2 probably thought that because there was one woman who said something

3 different. It wasn't a very decent thing to say. I wouldn't like to say

4 it now. She said it was okay, that she wasn't -- and the rest she didn't

5 know. But it seems that only one woman had sexual intercourse. I don't

6 know about those others. The doctors' later official reports, I didn't

7 get any official reports or anything. It was, you know, within the

8 purview of the Red Cross, and they never told me anything about how the

9 whole thing ended up.

10 Q. You never followed up to see what happened, who was arrested and

11 what happened to the women?

12 A. As far as I know, I believe those women then came back to the open

13 centre. Cavic was then arrested, and another man whose name escapes me

14 now, another colleague who was there with them often. But how the whole

15 thing ended, I don't know. I know that they were in prison. Now whether

16 anyone else was taken away, I don't know. But I think that they told me

17 the women actually went back to the centre and that they were fine.

18 That's to the best of my recollection.

19 Q. Sir, didn't you tell us that Cavic was arrested for killing a

20 policeman?

21 A. That was at a later stage, much later actually, when the policeman

22 was killed. That was a year later, more perhaps. I can't remember.

23 Recently, something -- there was something about that in Kozarski Vjesnik

24 remembering those people. But a long time has passed. That was after the

25 centre at Trnopolje ceased to exist, maybe the next year. I don't know,

Page 14828












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Page 14829

1 but there was only the police station then and they had a drunken brawl

2 there, and then Cavic killed the police officers.

3 Q. Sir, a few moments ago, I asked you how it was you determined it

4 was one woman. You said it's ugly, but she said it was okay. Do you mean

5 the woman who was raped said it was okay? Can you explain your comment?

6 A. Well, that's what I was told, that's what I heard. She was

7 probably joking, because she is a very serious lady. Otherwise, how much

8 at all, I think I heard they said thing about four women, but I don't know

9 for sure, and I don't know what was ascertained at the hospital later and

10 what the Red Cross reported about that.

11 Q. Sir, on page 35 of the interview in Banja Luka, beginning on line

12 10, you were talking about rapes in the camp. And you said: "Perhaps

13 it's not nice to say it now because it's an ugly situation, but the older

14 Muslims that were in there were also making jokes on that because we are

15 that kind of people. How the older lady said that she had a nice time.

16 It's not nice to say, but that's what I heard, like, two days after."

17 So is that what you were repeating here, that you heard that the

18 older woman indicated she had a nice time when she was raped?

19 A. Yes. Well, something along these lines, yes, what I said before,

20 and now mainly I don't believe that. But yeah, that's how it was

21 probably, some sort of a prank. I don't think anyone was seriously

22 physically injured, otherwise people would have had a different reaction.

23 You can't hide a thing like this from the people, because sooner or later,

24 people learn about everything.

25 JUDGE SCHOMBURG: Mr. Koumjian, could you please continue that we

Page 14830

1 have it in the context the following lines of the statement on page 35.


3 Q. Mr. Malik then asked you: "You mean the person who was raped, she

4 said how nice it was?" And you answered: "Yes. Whether, she was raped

5 now, but I don't know. Well anyway, there were no test results of any

6 real defloration or any real defloration or anything because I just had

7 other things to take care of in my mind. Those women later came to

8 Trnopolje. No, I don't remember if it was one, two, or three. I don't

9 remember exactly." I asked, "one, two, or three women?" And you said,

10 "I'm not a man who lies, not even to my children or anyone else. I could

11 have said that, I don't know, but I didn't hear. There were lots of

12 stories about rapes, so if there was any, but not only in Trnopolje, but

13 generally." And then you were asked by Mr. Malik, "what kinds of stories

14 about rapes?" And you said, "stories you would read about all over the

15 country, in newspapers all over the country that happened, regardless of

16 whether it's Muslims to Serbs, Serbs to Muslims, or Croats to other two."

17 Mr. Malik asked: "In fact, isn't it true that girls as young as

18 12, 13, and 14 were being raped in Trnopolje? You answered: "I never

19 heard about that, except it's possible that the Muslims did that to

20 themselves because there were many young people of both sexes, and perhaps

21 later it has been said that it was something else. But as much as I know,

22 the army did not go in there."

23 JUDGE SCHOMBURG: Thank you.


25 Q. Sir, when you talk about stories all over the country, isn't it

Page 14831

1 true that there was a lot of publicity in Prijedor about Serbian women

2 being raped in camps in places like Bosanski Brod, in Celebici, in

3 Dretelj, which a Croat-HVO camp that one of our witnesses Mr. Vulliamy

4 visited. And that there was a lot of publicity about what was being done

5 to Serbian women around Bosnia by Muslim and Croat forces?

6 A. I believe you're right, and vice versa. The publicity, these are

7 things that one should not keep silent about, no matter who the people in

8 question are. The other side said the same. And the third side said the

9 same. They still speak about it and I don't think one should stop

10 speaking about these things. Military activity is one thing, and this is

11 an altogether different thing. I am sorry that I was not fully informed

12 about all these things, how many women and whatever.

13 As for this statement of yours, yes, you are right. And this goes

14 for all the different ethnic groups and for all the information, and for

15 all the reports and for all the media.

16 Q. Sir, at the camp during the night, you had young army recruits

17 guarding the camp. Is that correct?

18 A. Well, I wasn't looking at their age, but there were few young

19 people there. Mostly elderly, from town. Elderly people from town, many

20 people knew each other. The Muslims and those who were the guards then,

21 but yeah, it's possible there were young people there, too. I was not

22 considering their age.

23 Q. These men that were guarding the camp, whether they were younger

24 or older, they had heard these stories. They had also heard the statement

25 in Kozarski Vjesnik and the media that the Muslims had a plan to commit

Page 14832

1 genocide on the Serbs. And they were indoctrinated by these reports to

2 fear and to hate the Muslims. Isn't that true?

3 MR. LUKIC: Objection, Your Honour.

4 THE WITNESS: [Interpretation] These are difficult questions.

5 MR. LUKIC: Asks for speculation.

6 [Trial Chamber confers]

7 JUDGE SCHOMBURG: Objection dismissed.


9 Q. Isn't that true, sir?

10 A. I think you are jumping at conclusions, jumping to conclusions. I

11 think you're saying this was indoctrination, and just because those people

12 were actually watching TV and this was an act of revenge and that they

13 were trying to get back on the others, this is not something I find myself

14 inclined to believe. Because this is not what happened in Prijedor at the

15 time. Then on the other hand, you could expect, for example, that in the

16 centre at Trnopolje or down there in town, on a massive scale, hundreds of

17 them, this would have been psychological pressure, indoctrination, but

18 nothing like that ever occurred.

19 Q. Sir, most of the people in the Trnopolje camp were women and

20 children. Correct?

21 A. At one period, yes; at one period, no. In the camp, in the open

22 centre, not the camp, the open centre, there were women there, children,

23 elderly people, young people, depending on the period of time. Sometimes

24 those prevailed and sometimes the other group prevailed. There were young

25 people there, too, Muslims and, yes.

Page 14833

1 Q. There were young women there, young girls. Correct?

2 A. Well, as long as women were there, that means there would have

3 been young and somewhat older children, too.

4 JUDGE SCHOMBURG: Sorry to interrupt at this moment, but could you

5 please explain what you just said on page 59, line 19: You made a

6 distinction between in the camp, in the open centre, not the camp. Could

7 you please explain the distinction between Trnopolje camp and the open

8 centre?

9 THE WITNESS: [Interpretation] Your Honour, I was convinced that I

10 have already explained this on several occasions. You've noticed that in

11 this report, this logistics man from the logistics base says a refugee

12 centre. This -- or shelter. This is a word used in our area which means

13 "to take refuge from a problem," to take shelter. That's why it's not a

14 camp. A camp is a place where people are being brought in an organised

15 fashion, such as in World War II, for example.

16 JUDGE SCHOMBURG: Sorry to interrupt. They were your own words.

17 "In the camp, in the open centre, not the camp. The open centre, there

18 were women there, children, elderly people." So when was you making now

19 the distinction now between the open centre and the camp.

20 THE WITNESS: [Interpretation] No, no, Your Honour. I addressed

21 Mr. Koumjian, and I told him not to use the word "camp." That's why I've

22 repeated it several times. Normally, I never use this word. But the

23 whole thing altogether, it was called the open centre. There were no

24 particular sections. And it really was open. It remained open the whole

25 time. You can translate it as "open centre." But our people, not the

Page 14834












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13 English transcripts.













Page 14835

1 Serbs only, but all the people over there, they refer to these places as

2 shelters, a place where people take shelter.

3 JUDGE SCHOMBURG: Thank you. Mr. Koumjian, do you want to

4 continue now or --

5 MR. KOUMJIAN: I'll just ask one more question.

6 Q. Sir, what did you do to protect the women and girls in Trnopolje

7 from being raped?

8 A. Well, there was nothing special I could do, except all those

9 people who were bringing their own security units over there, I warned

10 them against entering the school building if possible, the warehouse that

11 was there, the storage where people were being kept in order to keep

12 strange things from happening. And this was a successful measure, nothing

13 ever happened except that once. I warned them to stay outside to keep the

14 same things from happening. When those people came from Petrov Gaj, those

15 paramilitaries, and do stupid things. Not only these serious things, but

16 I wanted to make sure no contact was possible between the locals and those

17 people coming in and wreaking havoc. That was the only thing I was in a

18 position to do.

19 Q. And did you yourself set an example for gentlemanly behaviour

20 towards the women in the camp?

21 A. Well, I certainly hope so. I don't recall any complaints. A

22 delegation came once, an international delegation containing a

23 congressman. He asked me to meet me specially to tell me that he had

24 heard everyone was happy there with my behaviour and my treatment of them.

25 MR. KOUMJIAN: This is an appropriate time.

Page 14836

1 JUDGE SCHOMBURG: The trial stays adjourned until 2.00 sharp.

2 --- Luncheon recess taken at 12.35 p.m.

3 --- On resuming at 2.09 p.m.

4 MR. KOUMJIAN: Your Honour, I don't know if anyone's in the public

5 gallery now. Could we begin in private session.

6 JUDGE SCHOMBURG: I think to be on the safe side, we have -- it's

7 your intention to play a video now?

8 MR. KOUMJIAN: I'm going to ask a few questions, but related to

9 the witness from the video before I play it.

10 JUDGE SCHOMBURG: I think then to be on the safe side, we have to

11 go into closed session.

12 [Closed session]

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 14837












12 Pages 14837 to 14858 redacted closed session














Page 14859

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 (redacted)

18 [Open session]

19 JUDGE SCHOMBURG: We are already in open session.


21 Q. Sir, the video that you saw, you saw the young man whose back was

22 covered, his whole body, with black and blue marks. Did you see men like

23 that, boys like that in the camp?

24 A. In the open centre Trnopolje, I never saw anybody like that. I

25 remember when those people came, a C group from Omarska, that's what they

Page 14860

1 called them, I believe. Some of them were a bit thin. I never saw

2 anybody injured, nor did anybody tell me about that. People would have

3 told me because a lot of these people knew me and they would have

4 complained to me. And a number of them were really glad to find me there

5 because they knew me and they knew that there wouldn't be any problems

6 because we helped them there to recover. There was just one person who

7 was sick. I believe his nickname or his family name was Hadzalija. He

8 was brought on a stretcher because he was ill, and he was seen by a doctor

9 that we provided for him, and he also was glad to see me. Some six months

10 ago, he died in Prijedor. He had returned to Prijedor. He had lived

11 there with his family, and I would see him very often. Sometimes we would

12 play preference, a card game together. And I saw that picture

13 with -- depicting that person with scars and marks, but I never saw any

14 such person in Trnopolje. Believe me.

15 Q. You saw on the video a young doctor, Idriz Merdzanic. Do you

16 recall him being in the camp -- excuse me, in the open reception centre of

17 Trnopolje?

18 A. Of course. That is the name -- the man whose name I didn't know

19 when you talked to me. I believe that he was an amateur pilot, a sports

20 pilot. There was him and another doctor, and a male nurse and two female

21 nurses or maybe one. I can't remember exactly. In addition to this

22 doctor and the male nurse, who would come from Prijedor -- again I

23 don't --

24 Q. Was Dr. Merdzanic and the other doctor, who I believe you know as

25 Jusuf Pasic --

Page 14861

1 A. Yes, Dr. Pasic, correct. I don't know his name. I didn't know

2 about the other guy, that his name was Merdzanic. I forgot. And there

3 was also this guy Pasic, together with him, yes.

4 Q. Were they free to leave the camp whenever they wanted to?

5 A. Yes, they went to Prijedor. I don't know which one of them and

6 when they went. I believe they went to fetch some medicines from the

7 surgery in Kozarac, and they brought some drugs and some dressing and

8 other things. I don't know when that was, but I know that they went

9 there.

10 Q. So Dr. Merdzanic was another one of the refugees that you assisted

11 in the open reception centre at Trnopolje. Is that correct?

12 A. Yes.

13 Q. Would he have any reason to mislead this Court about the

14 conditions under which he was there and the fact that he says he was not

15 free to leave?

16 A. I don't know. What do I know? Again, there may be God knows what

17 agenda behind that. He didn't want to leave. I understood that he was

18 from Kozarac, and if he was to go to Prijedor, he would have had to stay

19 with somebody, or maybe he would have been attacked by somebody. But I

20 never heard it from him that he wanted to leave and was not allowed to

21 leave. Why does he now want to state differently I really don't know.

22 Q. Actually, Dr. Merdzanic was from Prijedor but was caught in

23 Kozarac during the attack during the one day of the week that he held a

24 clinic there. Dr. Jusuf Pasic was taken from Trnopolje and taken to

25 Omarska and killed. Isn't that correct?

Page 14862

1 A. Honest to God, I don't know that. I believe that once the police

2 came, and they took him for an interview. Where he was taken to, I don't

3 know. I heard it only subsequently. I heard that he was taken to

4 Omarska. And what his lot was, I don't know. I didn't know about

5 Merdzanic, that he was from Prijedor and that he was forced to come to

6 Trnopolje from Kozarac. As far as I remember, the majority of the people

7 there came of their own will. When I arrived there, people were already

8 there. And after that, they kept coming and coming.

9 Q. And they would -- many of them came in buses escorted by police

10 and army. Correct? For example, in the late July, when the Brdo area was

11 cleansed, buses arrived carrying men from Brdo. Correct?

12 A. Yes, men and women with their families. But that was to remove

13 them from the area where combat activities were taking place. Yes, now

14 you've reminded me. I believe there were either one or two buses, but I

15 don't remember exactly.

16 Q. Were you told that those buses came to Trnopolje because Omarska

17 was full?

18 A. How am I to remember that, I really don't know. According to what

19 I heard and according to what was going on in Omarska, I heard that there

20 were investigations, there were judges there, that there were

21 interrogations going on. That has nothing whatsoever to do with

22 Trnopolje, it's a totally different thing. So now I don't know what you

23 mean when you say there was no place in Omarska. People who took refuge

24 from combat activities came to Trnopolje. As for the others and for what

25 grounds they were taken elsewhere, I don't know. Maybe they have killed

Page 14863

1 somebody or something else. I really don't know why people were taken to

2 other places.

3 Q. Sir, you were shown by the Judge S12 which was a certificate

4 signed by you and Pero Curguz indicating that someone had the authority to

5 leave the Autonomous Region of Krajina. And on page 40 of Friday's

6 transcript, Mr. Lukic was asking you about the fact that people had to get

7 approval, even Serbs, from the Ministry of Defence to leave the territory

8 or the secretariat for national defence. Sir, you were not a

9 representative of the Ministry of Defence or secretariat for national

10 defence, were you?

11 A. No, of course not. A conscript had to get an approval to be able

12 to leave town.

13 Q. Okay, thank you --

14 A. -- Because it was during the war.

15 Q. Since neither you or Mr. Curguz knew or had records of people's

16 mobilisation or military service, then why was it that you and Mr. Curguz

17 signed this certificate allowing this person to leave Trnopolje and the

18 Autonomous Region of Krajina?

19 A. I haven't a clue to be honest. I really don't remember this

20 document. I saw it here. It was sitting in front of me. I saw that Pero

21 signed it. I saw the number and the Autonomous Region of Krajina, but I

22 really don't know what this could have referred to. Maybe it could have

23 been something along these lines, people were filling out when they

24 arrived there. Then the Red Cross representatives had to take the

25 personal details of these people according to the Geneva Conventions.

Page 14864












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13 English transcripts.













Page 14865

1 Maybe I have signed such a blank form. Maybe not one but even more of

2 them. And maybe these blank forms were to be filled in at a later date,

3 and maybe somebody abused that. I'm not saying that for a fact. I'm not

4 allowed to say something that is not correct. But I really don't know

5 what this is all about, who these people are.

6 MR. KOUMJIAN: For the purpose -- for the benefit of counsel for

7 the Defence and for Your Honours, I'm referring to page 9518 of the

8 testimony, prior transcript of Witness DD.

9 Q. Sir, in order for someone to be released from the Trnopolje

10 reception centre, did they have to get a guarantee from a Serb? Did you

11 ever hear about that procedure, where Serbs had to give a guarantee to

12 have friends or relatives released from the camp?

13 A. No. I don't remember ever having seen or heard anything like

14 that. I only know that there were some officers who came for their

15 families or relatives. There was a JNA officer who was a Muslim who came

16 to fetch his family, and then these families could be certain that nothing

17 would happen to them. But as for those guarantees, that you mentioned I

18 don't remember any such thing.

19 Q. Sir, would members of the intervention squad bring people to the

20 camp, to Trnopolje? Excuse me. Let me rephrase the question. Did you

21 see members of the intervention squad bringing people to the Trnopolje

22 reception centre, the intervention squad of the Prijedor police?

23 A. I don't remember that. I know that there was fighting at one

24 point, and that was in Kozarac. And people who lived in Suvi Brod close

25 to the road, maybe two families came, and they said there were some

Page 14866

1 specials up there. But nobody of that sort brought people to Trnopolje.

2 I don't remember that.

3 Q. Did you, sir, give permission to a group of people to go or

4 instructions to go bury a family that was killed close to the camp, the

5 Foric family?

6 A. I don't remember any such thing. I don't know that family. That

7 may have been somebody from the Red Cross. I don't remember -- I remember

8 one Foric. He was the trade union representative in town, or a member of

9 the socialist union. He was a young, very, very nice man. But I don't

10 remember this particular incident. Nothing similar to that happened in

11 the centre. Maybe it was something that happened far away from the

12 centre, but then it would have been the Red Cross who would have dealt

13 with that, not me. I don't remember anything like that.

14 MR. KOUMJIAN: This would be an appropriate time.

15 JUDGE SCHOMBURG: The trial stays adjourned until half past 3.00.

16 --- Recess taken at 3.16 p.m.

17 --- On resuming at 3.43 p.m.

18 JUDGE SCHOMBURG: Please continue. Sorry for the delay.


20 Q. Sir, I'll try to ask direct questions, and if you keep your

21 answers short, hopefully we can finish this afternoon. You indicated

22 you're not sure whether you were present when the foreign journalists

23 first came to the camp. Sir, I'm putting it to you that the foreign

24 journalists that made the video that you saw, Penny Marshall, Ed Vulliamy,

25 and Mr. Williams, came on the 5th of August. Isn't it true that following

Page 14867

1 that visit, there then were a great number of journalists from all over

2 the world coming to Prijedor and to the Trnopolje camp to report on what

3 was happening in Prijedor?

4 A. I don't remember whether this was the first visit, but if you say

5 so, I'm sure you're right. Many journalists came.

6 Q. Sir, isn't it a fact that the International Red Cross, as opposed

7 to the local Red Cross, which was headed by Srdjo Srdic, the International

8 Red Cross did not have access to the Trnopolje camp until after the

9 foreign journalists had visited the camp in August of 1992?

10 A. I don't think that this was the case. I believe that they came

11 much earlier, both them and the -- as well as the UNHCR. I can't claim

12 that to be a fact, but I believe that they came much earlier.

13 Q. Well, sir, you would certainly know when the International Red

14 Cross showed up at the Trnopolje centre, I would assume.

15 MR. KOUMJIAN: Could the witness be shown Exhibit S238, please.

16 Q. Isn't it a fact that the authorities in Prijedor and the Crisis

17 Staff had denied the International Red Cross access to the camp until the

18 foreign journalists came there on the 5th of August and after the

19 reporting in the world press?

20 A. I wouldn't know that. If I said something, I don't know. I would

21 be lying. It is possible, but I don't recall those events in any

22 particular sequence. I don't remember the dates.

23 Q. Okay. And Ms. Karper has another document to be distributed now.

24 Sir, going to Exhibit S238, I'm going to read to you the last

25 sentence which is a quote from Predrag Radic, the mayor of Banja Luka,

Page 14868

1 following a visit of officials from Banja Luka to the camp -- excuse me,

2 to Prijedor. And it indicates "to the collection centres." Mr. Radic is

3 quoted as saying, in the last sentence: "The International Red Cross has

4 been trying for days to reach Prijedor, but as we have stated, we will

5 make it possible for them only after they personally acknowledge the

6 situation of Serbian refugees and captives in Odzak, Rascani, Travnik,

7 Zenica, Sarajevo, Konjic, and many other places."

8 Now, sir I'd also like you -- there's another document which we

9 have only in English which I will read to you.

10 MR. KOUMJIAN: And Your Honour, this bears the ERN number

11 00317985.

12 JUDGE SCHOMBURG: This would be provisionally marked D435A.



15 MR. KOUMJIAN: Thank you.

16 Q. This is dated, sir, this is a press release, the 2nd of October,

17 1992. "ICRC evacuates 1.560 people from Trnopolje camp." Paragraph it

18 indicates on the first sentence: "The International Committee of the Red

19 Cross confirmation having evacuated on 1st of October 1.560 people from

20 Trnopolje camp near Prijedor in northwestern Bosnia-Herzegovina to a

21 reception centre in Karlovac southwest of Zagreb where they were handed

22 over to staff of the United Nations High Commission for Refugees. The

23 evacuation started in the early morning and was completed during the

24 night. The people concerned are civilian victims of the ongoing

25 hostilities in northern Bosnia and had all been visited and provided with

Page 14869

1 assistance by ICRC delegates since the ICRC was first able to enter the

2 camp on 10 August."

3 Sir, reminding you that you are under oath, isn't it a fact that

4 the International Red Cross was not permitted into the camp, did not come

5 to the camp until after the foreign journalists' visit in August 1992?

6 A. I don't know. Again, you've taken me by surprise with these

7 dates, like the Defence counsel before you. I don't remember that it was

8 so late, unless it was something unofficial. This now shows me

9 again -- because it was not just the UNHCR and the Red Cross from Prijedor

10 that came, but also representatives of the International Red Cross, and I

11 don't believe that it happened as late as you claim it did. I really

12 don't know.

13 Q. Can you explain, sir, why Predrag Radic would say that we're not

14 going to allow the ICRC to reach Prijedor until camps that Serbs are held

15 in are first inspected?

16 A. I don't know. He was a political leader in Banja Luka. I don't

17 remember what he was exactly. I think he was a mayor. I don't know what

18 he was before that, so I cannot provide any comment about his words. I

19 don't think that he could impose any conditions. What the Red Cross is

20 doing has nothing whatsoever to do with politics or fighting. He should

21 have allowed them because what the Red Cross is doing is providing better

22 conditions for everybody.

23 Q. Can you explain why the Red Cross press release would indicate

24 that they were first able to enter the camp on the 10th of August?

25 A. Again camp, okay, very well then. This means that officially,

Page 14870












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13 English transcripts.













Page 14871

1 they were not allowed. I don't think that I've gotten that old and

2 forgetful. Maybe this was official because Mr. Mignon came at that time,

3 and I believe that he held some talks there. I believe that the president

4 of the Executive Board was also there. I did not participate in those

5 talks. I did not voice any opinions because that was outside of the scope

6 of my authorities and competencies.

7 Q. Well, the visit by Mr. Mignon that you're speaking of, he said

8 that he spoke to others that are outside your authority. Who did he speak

9 to?

10 A. I believe that Dr. Mico Kovacevic, the president of the Executive

11 Board was there, as well as representatives of the Red Cross. Later on, I

12 heard that he was angry that the International Red Cross wanted to

13 organise their transportation. I believe that I've already said that.

14 Q. Sir, isn't it a fact that the persons in the Trnopolje reception

15 centre were not registered by the Red Cross until after the 21st of

16 August, in other words, that they were not registered yet when the convoy

17 set off for Vlasic mountain in which over 200 men were killed at

18 Koricanske Stijene?

19 A. I believe that the registers were open much earlier. I'm not

20 sure, but this is what I believe. I've forgotten. It was a long time

21 ago. However, I believe that it was much earlier. I remember there was a

22 woman whose name was Angie. She was an interpreter. I remember her

23 sitting under a tree and writing something down together with those people

24 from the Red Cross. I believe that this must have been earlier on, but I

25 don't know it for a fact.

Page 14872

1 Q. Sir, I'm going to read to you from the testimony of

2 Dr. Idriz Merdzanic. It's page 7789 of the trial transcript. He was

3 asked: "I want to ask you about one particular convoy about which you

4 later heard that the people had been killed. Did you see the loading of

5 the people that eventually you heard from killed on Mount Vlasic?" And

6 Dr. Merdzanic answered: "That was, I think, the last convoy to leave

7 Trnopolje, and that was when the International Red Cross had already

8 announced their arrival. I think in fact that the representatives of the

9 International Red Cross had already arrived in Trnopolje, but the camp

10 inmates had not been registered yet. So over the next two days, this

11 convoy was organised, which could be joined freely by men, whoever could

12 fit on to the lorries and buses. Up to that point, it was only on rare

13 occasions that any of the men managed to smuggle themselves out, but this

14 time, they could join."

15 Does this remind you that in fact the International Red Cross had

16 not yet taken down the names of the men that were put on the convoy over

17 Mount Vlasic?

18 A. I don't know. According to what you say, that is a possibility.

19 Still, I'm convinced that it was earlier on and Dr. Merdzanic must have

20 made a mistake. As far as I know, after that, there were one or two more

21 transportations for people. I believe that every time, there were one or

22 two buses leaving, and nothing happened to these people. Now, I'm so

23 confused that I really can't remember things clearly. I believe that

24 there were more --

25 Q. Sir, you were present that day at Trnopolje when the buses and

Page 14873

1 trucks were loaded, the men that went over Mount Vlasic on the convoy

2 where the massacre occurred at Koricanske Stijene, and you also were

3 present that day in Tukovi when the trucks were loaded of persons wanting

4 to join the convoy from a separate origin at Tukovi. Is that correct?

5 A. Yes. I don't believe that those were only men. It never happened

6 that it would be only men leaving. Most often, it would be families,

7 women and children leaving. And as for Tukovi, yes, I was asked to go

8 down there by the Red Cross because these people down there only trusted

9 me, and nobody else. Some of them even asked me to influence these people

10 not to leave because by that time, the incidents had stopped in town and

11 Trnopolje was very safe. It was the safest place in town, because there

12 were no killings or looting there. Nobody could take anybody away from

13 there.

14 Some people whom I know, for example, Mehto [phoen] who has

15 returned to Prijedor and some others who lived there whom I've seen

16 several times, and I saw his wife and I was asked to influence those

17 people not to leave. Later on, it turned out that some people, members of

18 my people for material gain have destroyed people's lives. And I'm sure

19 that my people, my town, will be ashamed because of them for as long as

20 they live. Because before that, nothing of that sort had ever happened.

21 I apologise.

22 Q. You mentioned that Prijedor was safe at that time. In fact, it

23 was safe because after the foreign journalists came and world attention

24 focussed on Prijedor, the Omarska camp, the Keraterm camp were closed, and

25 the killing had stopped inside the municipality. Correct?

Page 14874

1 A. Honest to God, I don't know that.

2 Q. Who organised the buses, the trucks, the fuel and drivers for

3 those buses and trucks, and the security for that convoy on the 21st of

4 August over Vlasic mountain?

5 A. As far as the equipment was concerned, the materiel organisation,

6 it was the Executive Board, Dr. Mico Kovacevic. As for the security, it

7 was the public security centre or rather the SUP.

8 Q. Who was present providing the security on those buses? Who did

9 you see at the Trnopolje camp and at Tukovi?

10 A. Well, at Tukovi, I didn't see anyone providing security. As far

11 as Trnopolje, I really don't remember. Do you remember when we talked

12 last year around the same time, those people were too young. I didn't

13 know those people. Except now I heard that Mrdja had been arrested and

14 brought to The Hague and he, too, had been escorting that particular

15 convoy. Other than that, I don't remember those people. I was already 50

16 at that time, plus everything I had to go through, and the death of my

17 daughter. I just wasn't paying attention. The only thing I really tried

18 to do was to look after those people there.

19 Q. Can you describe what Dado Mrdja looked like at that time?

20 A. Well, that was a long time ago. I know what he's like. He's

21 rather tall, dark hair. He was probably wearing uniform, if he was

22 escorting. Then he must have been wearing police uniform. I believe he

23 was wearing glasses for a while, but I can't really remember that. A

24 small man whom they called Babin, also an ex-student of mine, was also

25 escorting one of those convoys. But Dado, I don't remember his being

Page 14875

1 there. And this other man, I did see him once because he gave me a jacket

2 once when they set out. I think he's in a wheelchair now. I can't

3 remember his name.

4 Q. Is that Zoran Babic, nicknamed Babin or Bakin?

5 A. Yes, yes, that's possible. I've forgotten, but that sounds

6 possible.

7 Q. Isn't it a fact that Babin and Dado Mrdja were in the same unit,

8 that you would see them together?

9 A. It's possible, it's possible that they were. But I don't remember

10 seeing them. They were the police. I didn't have anything special to do

11 with them. Whether they were together then or not, I don't know. But I

12 do remember that the small man brought me an apple. But I can't remember

13 seeing Dado there, and I didn't even know the rest of them.

14 Q. You worked every day with Pero Curguz. Do you know the name of

15 his son?

16 A. Honest to God, I can't remember. But, yes, I do know his son.

17 Q. Is that Igor Curguz?

18 A. Igor, yes, yes.

19 Q. Was he a member of the police, the same unit?

20 A. I don't know. I don't think so. He was a student at the time in

21 Banja Luka, I believe. He was pursuing his studies, and he only came to

22 Prijedor occasionally, because Pero over there and me and there was his

23 son and I don't know. I'm not sure if he was a member of that police unit

24 or not.

25 Q. Did you know Dado Mrdja when you were fighting in Croatia? Did

Page 14876












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13 English transcripts.













Page 14877

1 you see him there in 1991?

2 A. I don't remember that either. I'm sorry.

3 MR. KOUMJIAN: Your Honour, I have a document, draft translation

4 L0099217. And the B/C/S is 01190801. It's a response to a request for

5 assistance to the Republika Srpska.

6 JUDGE SCHOMBURG: This would be provisionally marked S436A and B

7 respectively.


9 Q. Sir, this short document, as you can see, is a response to an

10 inquiry regarding the service of Darko Mrdja. If you turn to the bottom,

11 look at the bottom of that document, the second page of the English, would

12 it be correct that Mr. Mrdja was in the army, served in the military, from

13 September 19th, 1991, until April 29th, 1992, at which time he was then

14 transferred to the police. And he was in the police until September the

15 9th, 1992, and then transferred back to the military. Can you tell us

16 whether you find it significant or could explain why it was that someone

17 would be transferred on the 29th of April from the military to the police?

18 That would be the night before the takeover.

19 A. Well, I don't know. It may be that this indicates that there is a

20 coincidence between these dates, but this is regular work for the Ministry

21 of Defence. I see this is signed by Aleksic. I'm not sure. I can't

22 comment on this. I don't know what it has to do with these dates. All I

23 can see is he was transferred from the army to the police and vice versa.

24 Q. Sir, isn't it a fact that people were mentioned the name of

25 Dado Mrdja as being one of the perpetrators of the massacre immediately

Page 14878

1 following the massacre, in the next few days?

2 A. I don't know. I never heard his name or the name of any of the

3 others. I did hear that, well, since we knew that the police was

4 escorting, that this had happened. Now, whether they all participated in

5 it, whether everyone was shooting those people over there, were they all

6 perpetrators of this crime, I don't know. I don't even know if it was on

7 that day, what I said about that young man once when he was escorting that

8 people, he gave me that. Once, it was on a train, I believe. But I can't

9 be sure really, the apple. At which time, which buses, I'm sorry really I

10 don't know who meant.

11 Q. Sir, how is it that you mentioned you wrote a report and you

12 learned about this two or three days after the massacre. How is it that

13 you could not at that time remember the name of any of the people

14 providing the escorts to the convoy? Is that what you're saying, that you

15 did not at that time remember the name of any of the escorts?

16 A. No, not at that time, not now. Here, I know these names here, but

17 I'm not sure these people were actually there then. I assume you are in a

18 situation to check the statement. I don't even know myself how courts

19 work. But in that statement, I didn't say who was there or who led them.

20 They asked me to say on which day this happened, the transport was

21 organised by the Autotransport Company through the Executive Board, and

22 that security was provided by the public security centre. That was all I

23 was asked to say in that statement. As for the other things that

24 happened, I'm really sorry, I don't know, as for the other people. I did

25 hear a lot of other things later on TV and so on and so forth at that

Page 14879

1 time. For two days maybe, I heard about it, I think, that's unless I've

2 forgotten.

3 Q. Sir, who would have had the record -- first, there were more than

4 a thousand people probably in that convoy, correct, between the buses, the

5 trucks in Tukovi, and the buses that came to Trnopolje?

6 A. Well, I don't believe it was that many. But there were quite a

7 number, yes. You mean who might have the record as to who the people were

8 who had joined the convoy, or who escorted the convoy? Now, as to who

9 escorted them, that should still be at the public security centre, I

10 suppose. I don't believe they just went like that without anyone knowing.

11 That would have been impossible.

12 Q. How many police would have escorted a convoy of that size?

13 A. Well, as far as I know, there was always one police officer with a

14 driver in the bus. And that's how they provided security for those people

15 when travelling. I think that's the way it was.

16 Q. So there would have been one police escort on each of the

17 vehicles, and there also would have been at least one police car leading

18 the way. Correct?

19 A. Yes, yes, correct. That's one thing I forgot. There was a police

20 vehicle, yes, excuse me. You see, I keep forgetting things.

21 Q. If a convoy left from Trnopolje and Tukovi, went to Travnik or the

22 front line at Smetovi and returned in one day, at that time that would

23 have been -- that would have taken all day, correct, that journey there

24 and back?

25 A. Yes. Once back, the buses would go back to Autotransport. They

Page 14880

1 were not reporting to me. So I don't know what exactly happened, but

2 sometimes they would just phone me and tell me that they reached Travnik

3 without any trouble and down at Trnopolje, the Red Cross, many people

4 would call.

5 Q. So, sir, it would have been relatively easy to obtain the police

6 records of who was escorting the convoy on that all-day journey. Correct?

7 A. Well, I don't know. If you went looking for those at the public

8 security centre, well, probably. But this should have been done by the

9 Executive Board. The order should have come from them to whoever was the

10 organiser of those convoys, that is, the president of the Executive Board.

11 I was only looking after the people, nothing else.

12 Q. Sir, the Executive Board followed the instructions or served under

13 the Municipal Assembly. Correct?

14 A. Well, the Municipal Assembly was the legislative power, and the

15 Executive Board was the executive power. And all jobs, no matter what the

16 area, there would always be someone on the Executive Board appointed for

17 those jobs.

18 Q. Isn't it correct that the top political position in the

19 municipality was president of the Municipal Assembly as seen by the fact

20 that Professor Cehajic was given that position when the SDA won the most

21 seats in the 1990 election?

22 A. Yes. And later, Stakic took up that position. That's the highest

23 legislative authority, or rather the highest representative of legislative

24 authority.

25 Q. The highest political position, the position seen by the people of

Page 14881

1 Prijedor as being the top political representative of the people in the

2 municipality. Correct?

3 A. Yes.

4 MR. KOUMJIAN: Thank you. No further questions.

5 JUDGE SCHOMBURG: May I ask the Defence, do you have any questions

6 in return?

7 MR. LUKIC: I would probably have only to clarify the functions of

8 the president of the municipality, but I think that this witness already

9 answered that he does not know what the functions of the bodies in the

10 municipality are.

11 JUDGE SCHOMBURG: So you would have no further questions?

12 MR. LUKIC: If Your Honours do not have any questions, I might

13 finish in two, three minutes.

14 JUDGE SCHOMBURG: So please.

15 Further questions by Mr. Lukic:

16 Q. [Interpretation] Mr. Kuruzovic, just -- this will not take more

17 than two minutes. Do you know which are the duties of the president of

18 the Municipal Assembly?

19 A. Well, I believe we've answered this once already. He carries out

20 the decisions of the Municipal Assembly. If the Municipal Assembly adopts

21 a decision, that's actual -- actually, he doesn't carry them out, he signs

22 them. But if these are implemented, then this is supposed to be done by

23 the Executive Board of the Municipal Assembly. At least that's how I

24 understand it.

25 Q. Do you know if any of the members of the Executive Board are

Page 14882












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13 English transcripts.













Page 14883

1 responsible to the president of the Municipal Assembly? Do they answer to

2 the president of the Assembly?

3 A. No, they answer to the assembly, not to the president.

4 Q. To the best of your knowledge, the position of the president of

5 the Municipal Assembly, was it more representational in character, or does

6 it have any real actual power?

7 A. Well, probably the former, it's more ceremonial. That's the case

8 with most presidents, when the assemblies meet, they preside over the

9 sessions. But the true executive power lies with the Executive Board, and

10 they report in writing to the assembly on their work.

11 MR. LUKIC: [Interpretation] Thank you very much, Mr. Kuruzovic.

12 I've no further questions.

13 JUDGE SCHOMBURG: Thank you. Anybody else, any question? This is

14 not the case. Then we have to discuss the admission into evidence of the

15 documents tendered today.

16 S432, 17th of August. Objections?

17 MR. LUKIC: Your Honour, our position is that each and single

18 document offered today in which the Crisis Staff is mentioned is late to

19 be asked for the admission. So the OTP had the obligation to disclose to

20 us all the documents dealing with the Prijedor Crisis Staff. And

21 obviously, it has not been done until today. So yes, we object on these

22 grounds, among others, to S432.

23 JUDGE SCHOMBURG: So this is a general remark related to all the

24 documents from S432 through S436. Correct?

25 MR. LUKIC: I'm just checking whether the Crisis Staff is

Page 14884

1 mentioned in every and single one. S435 does not have mentioned the name

2 of the Crisis Staff, so --

3 JUDGE SCHOMBURG: S435. Any other objections?

4 MR. LUKIC: Only there is no source for this document, for S435,

5 there is no source. This is -- it's not known who composed the document

6 or to whom it was sent. And the last one, S436, we do not have any

7 objections.

8 JUDGE SCHOMBURG: May I hear the submission by the Prosecution.

9 MR. KOUMJIAN: Your Honour, we believe that none of these fall

10 under Rule 68. We're not obligated to disclose them. They all were in

11 direct response to the testimony of this witness. Two of the documents

12 counsel mentioned were previously disclosed in any event, and they are

13 S432, which was disclosed on the 65 ter list as 316; and S434, which was

14 disclosed on the 65 ter list as 368.

15 As for the source of the ICRC, we could have Mr. Inayat add that

16 to his sourcing list, which is actually -- he has prepared it except for

17 these new documents, and we could submit that to the Court.

18 JUDGE SCHOMBURG: Wouldn't it be correct to regard this as an

19 official press release.

20 MR. KOUMJIAN: It is a press release. It's a public document.

21 JUDGE SCHOMBURG: So it would be in the public domain and no doubt

22 be accessible even on the internet.

23 But let's wait one minute, please.

24 [Trial Chamber confers]

25 JUDGE SCHOMBURG: All the documents mentioned are under the

Page 14885

1 respective numbers admitted into evidence. It is true that S432 and S434

2 were already 65 ter as 316 and 368.

3 Document S433 was apparently not 65 terred, but it was a response,

4 a clear response, to the question which Crisis Staff meetings

5 Mr. Kuruzovic attended, especially the one of the 10th of June, 1992, and

6 also on the question of the mobilisation of one or several cars.

7 Then 435A, public domain. 436, nothing is mentioned about the

8 Crisis Staff. It's only apparently related to this case that Mr. Mrdja

9 seems, as it's written here, to have left the military post the 29th of

10 April, 1992, and this would be a question of the evaluation of evidence.

11 So therefore, these are the reasons why we decided to admit these

12 documents into evidence.

13 Mr. Kuruzovic, this was a very long testimony of yours. It

14 was -- whatever the content was, it was extremely difficult for you.

15 Therefore, do you want to add anything from your side?

16 THE WITNESS: [Interpretation] I can only thank you. But yes, if I

17 may, I would like to add a sentence or two. (redacted)

18 (redacted)

19 (redacted)

20 MR. KOUMJIAN: Could we go into private session, please.

21 JUDGE SCHOMBURG: Yes. Please in --

22 [Private session]

23 (redacted)

24 (redacted)

25 (redacted)

Page 14886












12 Pages 14886 to 14892 redacted private session














Page 14893

1 at 9.00 a.m.