Page 981
1 THE INTERNATIONAL CRIMINAL TRIBUNAL CASE NO. IT-94-1-T
2 FOR THE FORMER YUGOSLAVIA
3 IN THE TRIAL CHAMBER
4 Tuesday, 21th May 1996
5 (10.00 a.m.)
6 THE PRESIDING JUDGE: Mr. Niemann, would you call -----
7 MR. NIEMANN: Your Honour, I just wanted to mention a couple of brief
8 matters.
9 THE PRESIDING JUDGE: I thought we were hearing from Dr. Greve.
10 MR. NIEMANN: Yes.
11 THE PRESIDING JUDGE: Is it "Dr." or "Judge" or "Miss".
12 MR. NIEMANN: Dr. Greve, yes. Mr. Tieger will take over in a short
13 moment. There are a couple of matters I wanted to mention, if I may?
14 Firstly, your Honours, we would just like to notify a change in the
15 order of witnesses. I mentioned it to the Defence, but the witness
16 Medunjanin, Anes Medunjanin -----
17 THE PRESIDING JUDGE: What number is that on your witness list?
18 MR. NIEMANN: Currently No. 11, your Honour. This witness is not
19 available. We have not been able to make contact with the witness at
20 the moment; we expect to be able to do so but we have not been able
21 to at the moment. So we are seeking to replace that witness spot No.
22 11 by the witness Jerko Doko. He is currently No. 16.
23 THE PRESIDING JUDGE: I see, he is No. 16 now.
24 MR NIEMANN: The witness Mirsad Mujadzic, currently No. 14, we seek to put
25 him following the witness Semenovic.
Page 982
1 THE PRESIDING JUDGE: No. 10?
2 MR. NIEMANN: Semenovic, your Honour, and that witness is No. 10.
3 THE PRESIDING JUDGE: So 14 will go before 10?
4 MR. NIEMANN: After 10.
5 THE PRESIDING JUDGE: After 10, OK. So, we have just saved three to five
6 hours! I am sorry, I am just joking.
7 MR. NIEMANN: Probably.
8 THE PRESIDING JUDGE: In the scheme of things, it is not tremendously
9 important. OK. Is there anything else?
10 MR. NIEMANN: Yes, your Honour, there is. Your Honours, we received a
11 notice that next week this Chamber is, apparently, going to be used
12 for a matter on Tuesday morning, and there is another matter on
13 Wednesday morning and so we will not be sitting until Wednesday
14 afternoon. We have also heard there is to be, not a deferral
15 hearing, a Rule 61 hearing, set for sometime in June/July which,
16 apparently, may take as long as 10 days
17 We are becoming somewhat concerned, your Honours, that with
18 respect to next week, we have witnesses here who are arriving today
19 we cannot stop who were planning to give evidence early next week who
20 will probably be pushed right back to the end of next week or maybe
21 into the next week because of these changes.
22 I am just wondering, your Honours, is there any possibility that
23 we could sit somewhere else or that other matters could be placed
24 somewhere else in the building? I just raise it because it will
25 seriously lengthen the trial if these interruptions are to come as
Page 983
1 regularly as they have been up until now.
2 THE PRESIDING JUDGE: We have - at the close of testimony today, I will
3 talk to you about our schedule next week, but since you have raised
4 it, yes, you are right, there is a deferral hearing set for Tuesday
5 28th in the morning.
6 With respect to using another location, believe me, Mr. Niemann,
7 I have lost sleep over the schedule, not the length of time that the
8 Prosecutor is taking, but the number of intrusions that I know that
9 we will have on this trial. There is a possibility of using the
10 room that we used for pretrial, but there are logistical problems,
11 equipment problems, money problems; believe me, I am very sympathetic
12 to the desire of everyone to proceed as quickly as possible and we
13 are doing the best that we can, but we just have other matters, this
14 Chamber has other matters, it has to hear. As far as the other Trial
15 Chamber, I will not speak for the other Trial Chamber, but perhaps
16 they do have matters that are coming up as well.
17 We have one courtroom and it took us a while to get this
18 courtroom, but at least we have it and that is all that we have at
19 the moment. We will do the best that we can. You are perfectly
20 correct in raising that concern because I have asked you to present
21 your case more efficiently and more expeditiously, and then there are
22 all these intrusions into the schedule that have nothing to do with
23 the Prosecution. You are right and correct. We will do the best
24 that we can. I will inform you at the close of the testimony today
25 regarding our schedule for next week.
Page 984
1 MR. NIEMANN: Thank you.
2 THE PRESIDING JUDGE: Mr. Tieger, will you call Dr. Greve?
3 DR. GREVE recalled
4 Examined by MR. TIEGER, continued
5 THE PRESIDING JUDGE: Dr. Greve, you may be seated, please. You are still
6 under oath; you understand that?
7 THE WITNESS: Yes.
8 THE PRESIDING JUDGE: Thank you.
9 MR. TIEGER: Dr. Greve, before the adjournment yesterday, we were speaking
10 about the dissemination of propaganda related to Serbian nationalism
11 and Serbian imperilment. In that connection, I wonder if I might ask
12 Exhibit 85 to be brought to the witness's attention very quickly?
13 (Handed). Can we have that document focused on the top of the page,
14 please? Dr. Greve, do you see the date indicated on the article
15 entitled the "The Glory of all Serbian Glories"?
16 A. Yes, I do and I forget yesterday to mention that this has been
17 wrongly translated as 1st June; it should actually be 1st July. I
18 recognise this because it is the celebration of St. Vitus Day. That
19 is, I do not read Serbo Croatian myself, so I am unable to read the
20 original text, but St. Vitus Day is celebrated on 28th June, so it
21 has to be 1st July. It was checked with the translators, it is 1st
22 July, so that is a mistake, unfortunately, in the document presented.
23 I also have to apologise. I made a bad guess yesterday when I
24 equated Prince Lazar with St. Vitus. The correct version (and I
25 checked this this morning) is that Prince Lazar, the prince, the
Page 985
1 Serbian prince who is so well respected and celebrated in Serbian
2 history, died on 15th June, that is, on the day of St. Vitus. That
3 is why they celebrate him and St. Vitus at the same day. The reason
4 also why I wanted, of course, to correct my own bad guess of
5 yesterday -- I did say it was a guess and I am happy I did say that
6 at least -- is also because it brings attention to a fact that
7 confused me during my study of Prijedor area, and that is the
8 distinction between the Julian and the Gregorian calendar.
9 As you will know, we all use (or most of the world today uses)
10 the Gregorian calendar. It was initially the Julian calendar which
11 was adopted by Emperor Julius Caesar before Christ, adopted by the
12 Christian world 325 AD and revised by Pope Grego, I think it was
13 XIII, in 1582, because there was not full correspondence between the
14 solar year and the year of the calendar. So although we have leap
15 years to compensate, we had three leap years too much in 400 years.
16 So in 1582, 10 days were crossed out of the calendar; some call
17 it the Gregorian calendar; some call it the revised Julian calendar.
18 But the significance of this is that th
19 orthodox church with reference to celebration of religious feast
20 use reference to the old and not revised Julian calendar.
21 That is, sometimes I came across witnesses who gave me a date,
22 for instance, of Petrovdan which varied with a fortnight from what
23 others said and I was, it made me insecure, and I wondered if they
24 were that mistaken when they were referring to these holidays. But
25 the truth is that in the year 1992, which is our focus, there is a
Page 986
1 fortnight between the Julian calendar and our Gregorian calendar.
2 That is, 1st January 1992 in the Julian calendar comes on 14th
3 January 1992 in the Gregorian calendar. So there is a difference
4 and, if I may say so, if it comes to reference to feasts, it may be
5 useful to ask according to which calendar if a date is used.
6 Q. Dr. Greve, I would like to move now to 1990: Following the breakdown
7 of the communist system in Yugoslavia, were democratic elections held
8 in 1990?
9 A. Yes, they were.
10 Q. In opstina of Prijedor, which were the main political parties
11 involved in that election?
12 A. It was the SDA, the party of Democrat Action; it was the SDS, the
13 Serbian Democratic Party; it was the HDZ which was the Croatian
14 Democratic Union, and there were some leftist parties, the
15 Reformists, the Liberals, etc., and Ante Markovic actually had his
16 founding ceremony for the Reformist party held in Prijedor.
17 Q. Who were among the leaders in Prijedor in the SDA?
18 A. There were several leaders in the SDA. Actually, their names have
19 been referred to when it comes to sources mainly by witnesses, but
20 some of them are also reported in the later newspaper articles; among
21 them Muhamed Cehajic who became the Lord Mayor; Mirsad Mujadzic who
22 was from the Ljubija area; Hilmija Hopovac who was from that same
23 area. I do also know a number of names from the Kozarac area, but
24 only from witness statements, and I have not had these names
25 confirmed from other sources.
Page 987
1 Q. Who were among the leaders of the SDS?
2 A. Among the leaders of the SDS were Srdo Srdic; it was Simo Miskovic;
3 it was Milan Stakic; it was Miko Kovacevic; it was Simo Drljaca and
4 Slobodan Kuruzovic.
5 Q. Those are names we will be hearing about further in the testimony?
6 A. Yes, these are all names that is being mentioned in all the public
7 reports as well, so their names, I have heard them both from
8 witnesses and from the local media; many of them have given
9 interviews, that is.
10 Q. What was the outcome of the elections in Prijedor in 1990?
11 A. The outcome of the election, let me immediately mention, there is a
12 local Assembly in Prijedor which has 90 seats. According to the
13 votes, the seats were distributed with 28 seats for the SDS, the
14 Serbian party, with 30 seats for the SDA, the Muslim party, and two
15 seats for the HDZ, the Croat party, and 30 seats for other parties.
16 That is a considerable amount of seats were distributed to
17 parties that did not link so much to any particular group and, of
18 course, this was the first ever free election in a multi-party
19 system. So it was a very young democracy that went to throw their
20 ballot.
21 Q. Did this plurality victory by the SDA mean they were in a position to
22 fill all appointed political positions with its members?
23 A. For (1) democracy means to distribute this according to the vote. So
24 it was, of course, reflected the composition of the Assembly as other
25 political positions were reflecting the position between the parties;
Page 988
1 but also it is my understanding that Tito's Yugoslavia was built on
2 very elaborate keys for the division of positions according to ethnic
3 groups, so that all of them would be represented.
4 Q. So after the election, the appointed positions to be filled were to
5 be distributed among the parties?
6 A. That is correct.
7 Q. Were all the positions immediately filled?
8 A. No, not all of them, that is to say, there were no positions that
9 were left vacant, but they were not immediate changes in all of them,
10 according to the outcome of the election.
11 Q. Were some of the positions filled within a reasonable amount of time
12 after the election?
13 A. Yes, they were. That is, essentially, the political position.
14 Q. As time went on, were the remaining positions agreed upon? Was there
15 a consensus reached on which party member should occupy which
16 appointed position?
17 A. Not without some bickering, but eventually they were, yes,
18 distributed.
19 Q. Did the bickering that took place in the Assembly decrease, remain
20 the same or increase over time?
21 A. It may have been quite difficult immediately and it has to be kept in
22 mind that it is an enormous step for any one society to move from a
23 totalitarian communist regime to become a democracy. One cannot just
24 click fingers and it is done with that; it is a process
25 it has to do with learning. I think it was difficult from the very
Page 989
1 start, but as ethnic hatred or propaganda started it became even more
2 difficult.
3 Q. As time went on, did the Serbs in Prijedor begin to establish their
4 own separate political structure outside of the existing democratic
5 institutions?
6 A. Yes, they did, and that was also in the light of what happened
7 outside the opstina as such.
8 Q. Was a separate Assembly or any other institution established by the
9 Serbs in Prijedor?
10 A. Yes, actually there was a separate Assembly set up. Initially, people
11 did not know much about it. Later, we have received documents that
12 verify this. But what witnesses told us, or told me, reported, was
13 that there were some kind of meetings, they considered it to be
14 peculiar meetings, among the Serb politicians. They were not so sure
15 if this was just meetings so that they would prepare themselves
16 before they came into the Assembly or if it was some kind of a
17 separate structure, but they were wondering. Essentially, they were
18 sort of not too keen on knowing what this exactly was.
19 Q. Was the establishment of this separate Serbian Assembly an
20 independent act by local Serbian political authorities or was it done
21 at someone else's direction?
22 A. Well, this was happening in co-operation between the local Serbs and
23 the central SDS, Serbian party, administration and the separate
24 Serbian structures that at this time were being developed.
25 MR. TIEGER: Your Honour, may I have these documents marked, please, for
Page 990
1 identification as Exhibit 91? (Handed)
2 (To the witness): Dr. Greve, what is this document?
3 A. This is again an article from Kozarski Vjesnik, this time dated 28th
4 April 1994. The caption is how Dr. Milomir Stakic, first Chairman of
5 the Serbian Municipal Assembly of Prijedor, saw the events of 30th
6 April and after.
7 MR. TIEGER: Your Honour, I tender that document for admission.
8 THE PRESIDING JUDGE: Any objection to Prosecution 91?
9 MR. ORIE: No objection, your Honour.
10 THE PRESIDING JUDGE: Exhibit 91 will be admitted.
11 MR. TIEGER (To the witness): Dr. Greve, let me direct your attention to
12 that portion of the article you just indicated at the top of page 1.
13 At the top of the page, does it indicate that Dr. Milomir Stakic was
14 the first Chairman of the Serbian Municipal Assembly of Prijedor,
15 the institution to which you were just referring?
16 A. Yes, and I hasten to add he was the Vice, he was the Deputy Mayor in
17 the official structure.
18 Q. Now directing your attention to paragraph (3), you see the sentence
19 in the approximate middle of the paragraph that begins, "On the
20 direction"?
21 A. Yes.
22 Q. Does that article indicate at whose direction the separate Serbian
23 Assembly of Prijedor was established?
24 A. Yes, it indicates that this was established at the direction of the
25 SDS, Srpska Demokrastka Stranka, which is the Serbian Democratic
Page 991
1 Party.
2 Q. Was that the local SDS?
3 A. No, no, this is the SDS.
4 Q. The central office of the SDS?
5 A. That is the way I would look at it, yes.
6 THE PRESIDING JUDGE: Where is the central office then of the SDS?
7 A. In Bosnia-Herzegovina -- at the time that would be in Sarajevo.
8 THE PRESIDING JUDGE: I am sorry, Mr. Tieger.
9 MR. TIEGER: No, your Honour, that is fine. (To the witness): In addition
10 to the establishment of a separate Municipal Assembly outside the
11 democratic government, was any other separate institution created by
12 Serb officials in Prijedor?
13 A. Yes, particularly, in particular, there was the setup of a separate
14 police, and the main source of the information about the separate
15 police is again the interview that was given about a year after by
16 head of the Serbian police, Simo Drljaca. When he was promoted to
17 become the vice Minister of Interior, he was explaining how he had
18 been working. He used the word or it is translated as "illegally",
19 how he was setting up an illegal entity of Serbian police working on
20 this for months or half a year approximately prior to 30th April
21 1992. That was a complete structure for the police.
22 MR. TIEGER: In that connection, may I have these documents marked for
23 identification as Exhibit 92? (To the witness): Dr. Greve, what is
24 this document?
25 A. It is the article from Kozarski Vjesnik dated 9th April 1994 (sic)
Page 992
1 which is an interview with Simo Drljaca, then Deputy Minister of
2 Interior, of the Serb Republic.
3 Q. Looking at, you said April 9th, 1994?
4 A. I am sorry, it is 1993.
5 Q. That contains an interview with Simo Drljaca?
6 A. It does.
7 MR. TIEGER: I tender that for admission.
8 THE PRESIDING JUDGE: Any objection?
9 MR. ORIE: No objection.
10 THE PRESIDING JUDGE: Exhibit 92 will be admitted.
11 MR. TIEGER (To the witness): Dr. Greve, can I direct your attention then
12 to the top of the first page of that article? On April 9th, 1993,
13 what was Simo Drljaca's position within the declared Serb Republic?
14 A. He was designated Deputy Minister of Interior.
15 Q. In 1992 what was his position?
16 A. In 1992, from 30th April onwards, he was head of police.
17 Q. Directing your attention to the second line of this article -- let me
18 direct your attention first to the first line. Does the interview
19 with Simo Drljaca indicate who selected him to set up these illegal
20 police stations?
21 A. Yes, it is indicated that it was done by the Serb Democratic Party,
22 the SDS.
23 Q. Does the article indicate when that work began?
24 A. Yes, it does.
25 Q. How long before the takeover?
Page 993
1 A. Six months before the takeover.
2 Q. As a result of Simo Drljaca's efforts to establish an illegal police
3 force, how many stations were created manned by how many officers?
4 A. A force of 1,775 well-armed men in 13 police stations, is his
5 figures.
6 Q. Was the establishment of this illegal Police Force by Serb officials
7 done in co-operation with any other group in Prijedor other than the
8 SDS?
9 A. Yes, with the army, and that was at the time the JNA, the army of the
10 Yugoslavian people.
11 MR. TIEGER: May I have this document marked as exhibit 93 for
12 identification, please? (Handed). (To the witness): Dr. Greve, what
13 is that document?
14 A. It is another newspaper article from Kozarski Vjesnik dated 19th
15 November 1993. It is headlined "21 November, the day of Security
16 Services of Republica Srpska".
17 MR. TIEGER: I tender that document for admission.
18 THE PRESIDING JUDGE: Any objection?
19 MR. ORIE: No objection, your Honour.
20 THE PRESIDING JUDGE: 93 will be admitted.
21 MR. TIEGER (To the witness): Dr. Greve, may I direct your attention then
22 to the third paragraph of that article? Does the article also
23 confirm the establishment of illegal Serbian police stations?
24 A. Yes, it does. It refers to 30 illegal Serbian police stations.
25 Q. Does the article also indicate who participated in the establishment
Page 994
1 of the illegal police stations and the takeover of power?
2 A. Yes, it states explicitly that all the preparations had been carried
3 out in an exemplary co-operation with the Serbian army, and this was
4 still the JNA.
5 Q. Look at the top of the page, the event which prompted this article
6 was what?
7 A. It is a celebration, actually it celebrates, and again it links the
8 celebration of the police to the celebration of the day of the Arch
9 Angel Mihajlo.
10 Q. Were the police, the Serbian police, in Prijedor closely linked to
11 Serbian officials outside the opstina?
12 A. Yes, they were, and again our best source is head of police, Simo
13 Drljaca, head of police at 30th April 1992, because he is confirming
14 that he worked closely with the central authorities in Banja Luka,
15 and that they again took the orders straight from what is called
16 Ministry of Interior.
17 MR. TIEGER: May I have the previous exhibit, Exhibit 92, presented to the
18 witness?
19 THE PRESIDING JUDGE: That will be the Minister of Interior of the
20 Republika Srpska?
21 A. Yes, but I hasten, or I should immediately add that one may be
22 slightly confused with the wording "Republic" in this context. We
23 will, I think, explain it in detail a little later, but the Republika
24 Srpska was never declared as an independent state; it was always said
25 that it was one, it was one federal unit within the great Serbian
Page 995
1 state with Serbia proper and with these four areas that had been
2 taken under Serb control in Croatia. So it is not to be confused
3 with an independent state.
4 Q. You say that it was said that it was a unit of Serbia, it was said by
5 persons in the Republic of Srpska that it was a unit of Serbia?
6 A. It was proclaimed, when they proclaimed Republika Srpska, or actually
7 they started with proclaiming, and we will have the documentation
8 coming, they started with proclaiming Republic of the Serbian people
9 in Bosnia and Herzegovina, and they were pointing out at
10 that point that they did not want to become a state, but they
11 declared to be in statehood with.
12 Q. I have a feeling that I am getting ahead of this story, and so I
13 will retreat. The question that I had though really related to not
14 what was the intention of the Republic of Srpske vis-a-vis the
15 relationship with Serbia, but the reaction of Serbia to that
16 proclamation, not an official proclamation but at least the position
17 taken by the Republik of Srpska, but we will get to that later.
18 A. Well, I may, if it can of any assistance -----
19 THE PRESIDING JUDGE: I do not know whether Mr. Tieger would enjoy that,
20 interrupting his direct.
21 MR. TIEGER: I have no objection whatsoever in disrupting .....
22 THE PRESIDING JUDGE: We will hear it in tandem. We will hear it at the
23 appropriate time.
24 THE WITNESS: But I may give you, your Honour, one indication, and that is
25 when this separate structure is being set up, it is with full
Page 996
1 co-operation of the JNA, that is, the army of the country with which
2 they want to belong in statehood. Of course, there is still a
3 linkage between the Serb Republic and the Republic of
4 Bosnia-Herzegovina, but even after the breach when Bosnia-Herzegovina
5 becomes independent or declares independence in early April 1992 and
6 up to the Serbs are taking power in Prijedor, there are at least 24
7 days, and in this period the JNA exists and it fully cooperates.
8 JUDGE STEPHEN: At this time was the Belgrade government calling itself
9 Serbia, Serbian, or did it still call itself Yugoslavia?
10 A. The Socialist Federal Republic of Yugoslavia.
11 Q. So the references we just seen to Serbian co-operation or the Serbian
12 army really is a misnomer, is it?
13 A. Well, this, of course, is a newspaper article when they are
14 communicating with the local people, and then it is perhaps
15 considered convenient to use the then new names. That is perhaps
16 the way I have tended to read it.
17 JUDGE STEPHEN: Yes.
18 THE PRESIDING JUDGE: Mr. Tieger, do you know where you are?
19 MR. TIEGER: Yes, thank you, your Honour. (To the witness): Just to
20 clarify the chronology a bit, Simo Drljaca was the man designated by
21 the SDS in Prijedor to establish the illegal police stations in 1991?
22 A. That is correct.
23 Q. Then after the military takeover of Prijedor he became the Chief of
24 Police?
25 A. That is correct.
Page 997
1 Q. It was thereafter that he was appointed, promoted to the position of
2 Deputy Minister of the Interior?
3 A. That is also correct.
4 Q. What is the relationship between the Ministry of the Interior and the
5 police department?
6 A. If I may say a few general words about this? It has to be kept in
7 mind that what we are seeing is an old totalitarian regime that is
8 changing to become more democratic. In the old communist setting,
9 one of the key ministries were the Ministry of Interior and the
10 Ministry of Interior would be the one in charge of both the secret
11 police, state police and public security police issues. The Ministry
12 of Justice would, in comparison, be a tiny and not so important
13 entity.
14 Q. I had asked you about the connection between the police in Prijedor
15 and Serbian entities outside the opstina. Can I ask you to look at
16 the bottom of page 2 of Exhibit 92? Looking at that document, the
17 interview with Simo Drljaca, then the Deputy Minister of the
18 Interior, does he indicate the relationship between the police in
19 Prijedor and entities outside ---
20 A. Yes.
21 Q. -- that is the Serbian police, excuse me?
22 A. Yes. He is actually at this time he is answering to some criticism,
23 and he is saying that if something, quoting the last sentence in the
24 paragraph, "If something was not done correctly, then I should be
25 replaced and not they because they executed my orders and those from
Page 998
1 the chief of the central police headquarters in Banja Luka and the
2 Minister of the Interior".
3 Q. You mentioned that the separate Serbian Assembly of Prijedor was
4 established at the direction of the central office of the SDS. I
5 would like to discuss the links between that separate Assembly in
6 Prijedor and the separate Serbian structures outside of Prijedor. In
7 that connection, may I have this marked as Exhibit 94 for
8 identification? (Handed) What is that document, Dr. Greve?
9 A. This is a decision dated 17th January 1992. It states that it is a
10 decision to unite with the autonomous region of Bosanska Krajina and
11 article (1) states that -----
12 Q. Doctor, before you proceed with the document, I would like to tender
13 that for admission.
14 THE PRESIDING JUDGE: Any objection to Exhibit 94?
15 MR. ORIE: No objection.
16 THE PRESIDING JUDGE: 94 will be admitted.
17 MR. TIEGER: Can the document be placed on the screen, please? (To the
18 witness): Dr. Greve, you indicated that this was a decision reached
19 on January 17th 1992?
20 A. That is correct.
21 Q. Again that decision was -----
22 A. It is a decision to unite with the autonomous region of Bosanska
23 Krajina.
24 Q. It is a decision by which institution to unite with the autonomous
25 region?
Page 999
1 A. The Serbian People's Assembly in Prijedor municipality.
2 Q. It was signed by the individual you referred to earlier, Dr. Milomir
3 Stakic?
4 A. That is correct.
5 Q. As Chairman of the Serbian People's Assembly?
6 A. That is correct.
7 Q. At the time he was also the Vice President of the democratically
8 elected Assembly in Prijedor?
9 A. That is also correct.
10 Q. Dr. Greve, what was the autonomous region of Bosanska Krajina that is
11 referred to in this document?
12 A. At this time it was a region similar to the regions previously
13 proclaimed in Croatia as SAOs, Serbian autonomous -- Srpska Autonomna
14 Oblast, that is, Serbian autonomous districts. Krajina, I should
15 say, is an area to be divided by the border between Croatia and
16 Bosnia-Herzegovina, so you have one region of Krajina in Croatia and
17 another region of Krajina in Bosnia-Herzegovina. For what reason
18 they already existed a sole, an autonomous region of Krajina. That
19 is why one is using now a different name for the autonomous region on
20 the Bosnian side of Krajina; it is called a region and not an
21 "oblast".
22 Q. Was the autonomous region part of the democratically elected
23 government within Bosnia-Herzegovina?
24 A. No, it was not. It was set up and step by step moved further away to
25 be completely autonomous from the government in Bosnia and
Page 1000
1 Herzegovina.
2 Q. What was the first step in the creation of this separate autonomous
3 region?
4 A. I may, perhaps, say that before any steps were taken, there were no
5 such thing as total regional structures. There were two main
6 Chambers of Commerce in north western Bosnia-Herzegovina, and there
7 were some financial co-operation and there were some association of
8 municipalities to do co-ordinated planning and trade, which was
9 obviously very good and very welcome. But then at one point, that
10 is, late April 1991, late April 1991, there was a change in this
11 structure, and the autonomous region of Krajina, Bosnian Krajina,
12 becomes an entity which also takes upon it to have some military
13 independence. That is firmly objected to by the government in the
14 Republic of Bosnia-Herzegovina. It is not yet -- the Republic is not
15 yet independent, but still the legal authorities all seated in
16 Sarajevo and they object to this creation.
17 Only in September 1991, there is a formal declaration of
18 independence for the ARK, Autonomous Region Krajina, which is the
19 entity located within Bosnia-Herzegovina in contra-distinction to the
20 South Krajina on the other side of the border, that is, inside
21 Croatia. So it is two entities with the name "Krajina" because the
22 area is not so naturally divided in a sense, the name is found in
23 both areas.
24 Q. In April 1991 when an association of municipalities in the Krajina
25 region took on some military aspects rather than purely economic
Page 1001
1 co-operative aspects, did it call itself the autonomous region at
2 that time or did it continue to call itself an association of
3 municipalities?
4 A. It was moving towards autonomy already at that time.
5 Q. Was it known as the autonomous region of Krajina or was it known as
6 the association of municipalities in April when it took on these
7 military aspects?
8 A. I am perhaps not exactly sure of that, because I think at this time I
9 think it called itself autonomous region of Bosanska Krajina, but it
10 left out the name "Bosanska" later -- but I may be mistaken on this.
11 MR. TIEGER: Let me have, if I may, this document marked as Exhibit 95 for
12 identification.
13 JUDGE STEPHEN: Can I ask you, I hope this is idle curiosity but we have
14 come across "Bosanska" in a number of place names, has it got a
15 meaning?
16 A. Yes, it means "Bosnian".
17
18 JUDGE STEPHEN: Thank you.
19 A. And that is the reason, and that adds to some confusion, or it did on
20 my part: At a later stage one of the things that the separate
21 Serbian structure is eager to do is to cross out the reference to
22 anything that is Bosnian. So when it is called Bosanska Krajina, it
23 becomes "Krajina"; if a city is named Bosanska Novi, Bosanski
24 Gradica, it changes the name, leaves out "Bosnian".
25 MR. TIEGER (To the witness): Dr. Greve, can I ask you to look at Exhibit
Page 1002
1 95 marked for identification? What is that exhibit?
2 A. That is again a translation of a newspaper article which appeared in
3 the newspaper, Oslobodenje, which is printed in Sarajevo. It is
4 dated 24th May 1991.
5 MR. TIEGER: I tender that for admission.
6 THE PRESIDING JUDGE: Any objection?
7 MR. ORIE: No objections, your Honour.
8 THE PRESIDING JUDGE: 95 will be admitted.
9 MR. TIEGER: If that could be placed on the screen, please?
10 (To the witness): Does this document indicate the reaction to the
11 establishment of a separate association in the Krajina region at that
12 time?
13 A. Yes, it is noting that the SDA, the party of Democratic Action, that
14 is, the one associated with the Muslims in Banja Luka, are strongly
15 opposed to the idea of creating what they call a state within a
16 state.
17 THE PRESIDING JUDGE: Dr. Greve, I have a question, I guess, a confusion,
18 about how this operated from a practical point of view. You had a
19 General Assembly in Prijedor. The SDA received not the majority but
20 received the largest number of votes of 30 seats, I guess, out of 90.
21 Then you say there were 30 others. I do not know how these others
22 aligned with the SDA. But when the SDS was developing these
23 relationships with other areas in Bosnia-Herzegovina, for example,
24 the relationship with Krajina, what was the reaction of the leaders
25 in the General Assembly? Did the SDS continue to participate in the
Page 1003
1 Assembly in Prijedor and at the same time try to create an autonomous
2 state of Bosnian Serbs in Prijedor and align with other areas of
3 Bosnia-Herzegovina that were predominantly Serb? What was the
4 reaction within the General Assembly? It would seem to me that the
5 SDA and other parties would respond within the Assembly.
6 A. Your Honour, unfortunately, most of those key people from other
7 parties than the SDS
8 -- from other parties than the Serbian parties and outside the Serbian
9 group are dead, meaning that we have not been able to question them
10 about this particular issue, but the information we had which is
11 second-hand, I admit, is that people did not fully understand this.
12 It was in a sense so much happening in Eastern Europe in general,
13 confusion; transition; communism breaking down; it was combined with
14 financial crisis; democracy was being established; republics were
15 considering to leave the Federation; people were confused. They were
16 not used to be tuned into political thinking like people in a
17 democracy, that is, it always used to be decided by the party what
18 was to be the line of the country.
19 So many people, it seems to me from secondary sources, I admit,
20 did not really feel that they knew enough about the situation to be
21 really alerted in time. They were taken by surprise. They saw that
22 certain things were happening, but to a degree their reaction was
23 more that this was peculiar than that this was dangerous. But when
24 it came to the independent or autonomous regions, as we will come to
25 Prijedor through its Assembly, the elected Assembly refused to join
Page 1004
1 this entity. But all parties remained within the elected Assembly,
2 but it became more and more difficult to operate in that Assembly as
3 previously indicated.
4 If I also may answer your first question, which was, what about
5 the 30 votes which were distributed between different other parties?
6 As indicated, Reformists and the Liberal Party which were some, what
7 shall I say, reawakened communist parties -- maybe that is not the
8 right way to describe them -- it is leftist parties, and people would
9 join them from different groups, and the mere fact that one-third of
10 the population did not vote along the lines of these three main
11 parties, that is, being associated with specific ethnic groups,
12 indicates that, perhaps, people did not think that ethnic groups had
13 anything really to do in politics at this time.
14 Many Serbs, and they will blame this afterwards both in
15 newspaper articles and according to also Serb people with whom we
16 have been speaking, had voted for other parties than the SDS, the
17 Serbian Democrat Party. But eventually it became no more acceptable
18 for a Serb not to be of true Serbian nationalist thinking, that was
19 also to join the party.
20 There are actually decisions made in the independent region of
21 Krajina to the effect that to be a real Serb and have any
22 leading position or be entrusted, one should be a party member and
23 know that guidance of the Serb people was firmly taken care of by the
24 SDS.
25 MR. TIEGER: Referring to this association or entity that was established
Page 1005
1 in April of '91, was that constitutionally challenged?
2 A. Yes, it was.
3 Q. May I have this document marked as Exhibit 96 for identification,
4 please? (Document handed). (To the witness): What is that document,
5 Dr. Greve?
6 A. It is a ruling which is published in the official gazette of the
7 Socialist Republic of Bosnia-Herzegovina which is still within the
8 former Yugoslavia.
9 MR. TIEGER: I tender that for admission.
10 THE PRESIDING JUDGE: Is there any objection?
11 MR. ORIE: No objection, your Honour.
12 MR. TIEGER: May that be placed on the screen, please?
13 THE PRESIDING JUDGE: Exhibit 96 will be admitted.
14 MR. TIEGER (To the witness): Dr. Greve, looking at the top of the page,
15 that is a decision by which institution?
16 A. The constitutional court of Bosnia-Herzegovina.
17 Q. On what date?
18 A. At the session held on 1st November 1991.
19 Q. The ruling concerns which institution as indicated in that first
20 paragraph?
21 A. It concerns the Association of Bosanska Krajina municipalities.
22 Q. And focuses on the agreement to join the association of Bosanska
23 Krajina municipalities?
24 A. Yes, it does.
25 Q. The ruling by the constitutional court is what?
Page 1006
1 A. It is that this decision will be null and void.
2 Q. That ruling was on November 1st 1991?
3 A. That is correct.
4 Q. By that time, had the Association of Bosanska Krajina municipalities
5 become the autonomous region of Krajina?
6 A. Yes, it had in September.
7 Q. Dr. Greve, I would like to ask you which municipalities in the area
8 joined the autonomous region, and it might be helpful if I had
9 Exhibit 73 displayed to you.
10 THE PRESIDING JUDGE: Is this the entire decision while we are locating
11 73?
12 MR. TIEGER: Yes, your Honour, not what is depicted on the screen, of
13 course.
14 THE PRESIDING JUDGE: I was just wondering whether there is any reasoning
15 or rationale. All I see is a declaration it is null and void.
16 MR. TIEGER: It is contained in the documents which has been tendered.
17 THE PRESIDING JUDGE: You are offering the entire decision?
18 MR. TIEGER: Yes.
19 THE WITNESS: That is the so-called justification that is added on the
20 following pages.
21 MR. TIEGER (To the witness): Dr. Greve, does this map assist you in
22 indicating the municipalities which joined the autonomous regions?
23 A. Yes, I am just waiting to get on the screen the exact -- yes. What
24 we can see is, if we start to the west of Prijedor, we see Bosanski
25 Novi which joined; to the north of Prijedor we see Bosanski Djubica
Page 1007
1 which joined; we see Bosanski Gradiska which joined; and I am afraid
2 I cannot read on my screen -- oh, I can -- it is Srbac which joined;
3 it is Prnjavor which joined; it is Laktasi which joined; Banja Luka
4 joining; Celinac joining, and I skip Kotor Varos which did not join,
5 Skender Vakuf joining; Mrkonjic Grad joining; Sipovo, and then I move
6 further south, I mention Kljuc which joined; Sipovo joined; Kupres
7 joined; Glamoc joined; Bosanski Grahovo, Titov Drvar joined and
8 Bosanski Petrovac joined. In what is called Bosanski Kupres the
9 river Una comes done along this border and flows through Bosanski
10 Kupres.
11 So there was a part of Bosanski Kupres which was referred to as
12 Kupres, now "Una", the part which is to the east of the River Una,
13 which was Serb controlled, and that part also associated itself. But
14 important to point out in this context is, perhaps, that Prijedor
15 became isolated with three other or two other provinces in the area.
16 Sanski Most did not join. Prijedor did not join, that is, the
17 legally elected Assembly of Prijedor did not join, and Kotor Varos
18 did not join.
19 Q. What eventually happened to Prijedor, Sanski Most and Kotor Varos?
20 A. They were all ethnically cleansed, so-called, by violent means and
21 force and they then joined.
22 Q. Did Serbian authorities also form a separate political entity on the
23 republic level as well as the Municipal and regional level?
24 A. Yes, they did.
25 Q. What was that entity called?
Page 1008
1 A. First of all, it was the politicians that were participants in the
2 legal parliament in Sarajevo, in the Republic of Bosnia-Herzegovina.
3 They together with other representatives of the Serb people on 9th
4 January 1992, 9th January 1992, declared a republic, but again a
5 republic as being a federal unit wanting to be in statehood with what
6 I, for reasons of convenience, call Serbia proper and the autonomous
7 Serb areas in Croatia, and they formed what was called at the time
8 the Republic of the Serbian People in Bosnia and Herzegovina -- a
9 name which was changed on 28th February to be the Serbian Republic of
10 Bosnia-Herzegovina, a name which was changed again on 12th August
11 1992 to be Republika Srpska. There was no other main changes than
12 this change in name, so the entity is the same whatever the name it
13 is referred to. It only has a difference in time.
14 Q. Did the separate Serbian Assembly in November or in October call for
15 the holding of a plebiscite?
16 A. Yes, it did, 21st October it decided to ask for that.
17 Q. May I have this document marked as Exhibit 97 for identification?
18 (Document handed). (To the witness): Dr. Greve, what is Exhibit 97
19 for identification?
20 A. This is a ballot paper which was used in the plebiscite held in
21 October, sorry, in November 1991, and in which the Serbian people in,
22 particular were, asked in what kind of statehood relationship they
23 would want to stay.
24 MR. TIEGER: We tender 97 for admission.
25 THE PRESIDING JUDGE: Any objection?
Page 1009
1 MR. ORIE: No objection, your Honour.
2 THE PRESIDING JUDGE: 97 will be admitted.
3 MR. TIEGER: May that be put on the screen, please?
4 (To the witness): Dr. Greve, what is the general issue presented by this
5 plebiscite?
6 A. I should perhaps indicate immediately that this ballot paper is
7 actually -- in one paper we have two different ballot papers, and
8 what is being shown at the screen at the moment is the ballot paper
9 which is given to the people of Serb ethnic background, those who
10 declare themselves as Serbs. They are asked to vote and indicate
11 whether they are in
12 favour of a decision reached by the Assembly of the Serbian people in
13 Bosnia and Herzegovina on 21st October 1991, whereby the Serbian
14 people shall remain in the common state of Yugoslavia which would
15 include Serbia, Montenegro, SAO Krajina, SAO Slavonia, Baranja,
16 Western Srem along with all others willing to remain in such a state.
17 Q. How was the ballot framed for non-Serbs?
18 A. That is shown and indicated on this same paper. It was formulated
19 differently for the non-Serbs. They are asked if they are in favour
20 of Bosnia and Herzegovina remaining a republic with equal status in a
21 common state of Yugoslavia with all the other republics which also
22 declared themselves willing to do so.
23 Q. Aside from the reference to the Assembly of the Serbian People in
24 Bosnia and Herzegovina in the ballot presented to Serbs, is there
25 any mention of Bosnia and Herzegovina in the common state of
Page 1010
1 Yugoslavia?
2 A. Excuse me, may I ask you to repeat the question?
3 Q. Sure. In the ballot presented to non-Serbs where it indicates
4 whether or not the Serbian people shall remain in a common state of
5 Yugoslavia, and list the members of that common state, is
6 Bosnia-Herzegovina indicated anywhere? I am sorry, I misspoke.
7 This is the ballot presented to Serbs, excuse me. Does the -----
8 A. No, excuse me, I was a bit slow. I am sorry. No, in the ballot
9 paper presented to the Serbs there is no indication of the existence
10 of Bosnia-Herzegovina as such. Here we are only -- they are only
11 referring to these autonomous regions.
12 Q. Did most Serbs vote in the plebiscite?
13 A. Yes.
14 Q. What about non-Serbs?
15 A. There were a few non-Serbs voting, but I have not seen any figures
16 for how many participated. It is my understanding it was relatively
17 few.
18 Q. Was the plebiscite regarded as an important event by Serbian
19 officials?
20 A. Yes, later it is actually -- whether or not one had participated in
21 this plebiscite is considered significant as to have demonstrated
22 one's true understanding of what it means to be a Serb.
23 Q. Was its importance in part affirmed by the subsequent declaration of
24 a wholly separate Serbian entity?
25 A. Yes, it was.
Page 1011
1 MR. TIEGER: Can I ask that Exhibit 50 be shown to the witness? (Document
2 handed).
3 THE PRESIDING JUDGE: Dr. Greve, maybe this is very naive on my part, but
4 how did the election for the plebiscite take place or how did the
5 voting take place? One ballot was given to Serbs; would people line
6 up and show some proof that they were Serb and they would get the
7 ballot for Serbs, and then there would be another line of people who
8 would demonstrate that they were non-Serbs, and they would get the
9 other ballot? Is that the way it operated and, if so, what about
10 the people who were mixed?
11 A. It is my understanding for (1) that the word, it was spread by word
12 of mouth. This I have from witnesses and information gathered in
13 general. I have not been able to see any newspaper article listing
14 this completely, but I understand that Serbs were approached
15 informally and told that it was appreciated that they would go and
16 vote. Everyone was asked to vote. According to non-Serbs who came
17 to vote, it was a question whether they had to be registered on this
18 list or that list. It is like going to vote in our countries; we
19 will be marked off on whether we come to vote or not. There would be
20 separate lists for Serbs.
21 If at this time people also, which there is some indication to,
22 could sort of declare themselves as Serbs, if they came from a mixed
23 background and had not considered themselves Serbs before, possibly
24 they could do that. I am not completely sure on it. But those who
25 said, "I am a non-Serb" were at least be given the ballot paper for
Page 1012
1 non-Serbs. That is my understanding. I apologise it is
2 superficial.
3 MR. TIEGER: Your Honour, if I could follow up on the court's question and
4 recall the previous exhibit, Exhibit 97, before we proceed?
5 THE PRESIDING JUDGE: The two ballots?
6 THE WITNESS: Linked to the two ballots, there is also an instruction as
7 to how to proceed and it is for the Serb Democratic Party to organise
8 this.
9 MR. TIEGER: Could page 2 of that document be displayed on the elmo? (To
10 the witness): Accompanying the article in which the ballot or copies
11 of the two ballots are shown, are there also instructions, specific
12 instructions, for how the voting should take place and who should
13 organise it? Dr. Greve, I am sorry, I am just identifying that
14 portion of document. Does it indicate that organs were established
15 for the conduct of the plebiscite and instructions on how to
16 undertake that?
17 A. Yes, it does.
18 Q. Turning to the last page of that document, are there instructions on
19 how the ballots are
20 to be presented to individuals who appeared to vote in the
21 plebiscite?
22 A. Yes, it is. There is, however, there is one interesting point in
23 this, if I may say so. It is not particularly clear whether an
24 identity card at this moment would already indicate national
25 background or ethnic group, but possibly this could be read out of
Page 1013
1 the ID card and the numbers already, I do not know.
2 Q. It indicates that the ballots would have separate colours?
3 A. Yes. Yellow for the non-Serbs.
4 JUDGE STEPHEN: I wonder if I could ask a question at this stage? Bearing
5 in mind the long years of communism in Yugoslavia, if one was
6 completely irreligious, how would anyone know that one was Serb or
7 Croat or Muslim? Would it just be by common repute, the
8 language will be the same, the true ethnicity would be the same?
9 A. This, your Honour, is a very good question which a number of people
10 have told me they asked themselves because they simply said, "I have
11 lost track; I have two grandparents from this group and one from each
12 of the others. I never practised religion. Our language is the
13 same. We cannot be distinguished by features or anything". It was
14 not common in the period of the communist regime to think in ethnic
15 terms. One was a Yugoslav.
16 So time and again people would come forward and say, "I really
17 do not know. I am me, but I do not really find myself as belonging
18 to this group as opposed to that group". But some people would live,
19 and this was particularly, perhaps, in remote rural areas where there
20 was more homogenous structure and people had lived and married within
21 a tiny little circle for a long time, but particularly in the cities,
22 there seems to be a lot of people who found themselves to be of such
23 a mixed descent that it was a matter of choice to present yourself as
24 this or that.
25 MR. TIEGER: Turning back to page 3 of that document, does it indicate
Page 1014
1 that the Commissions were to be established for the conducting of the
2 plebiscite including a main Commission, a District Commission and
3 then at the more local level election board?
4 A. Yes, it does.
5 Q. These were the instructions on how to conduct the plebiscite?
6 A. That is correct.
7 Q. But you have, aside from word of mouth, not seen articles on the manner
8 in which it was actually conducted when it happened?
9 A. No.
10 Q. If we can now return to Exhibit 50? Dr. Greve, I had asked you about
11 the importance attached to the conducting of a plebiscite by Serbian
12 officials, and whether or not the establishment of a separate Serbian
13 entity affirmed that importance. In that connection I would like you
14 to look at Exhibit 50 and ask that it be placed on the elmo.
15 A. That is the declaration.
16 Q. In paragraph 1 of that document does it indicate the basis on which
17 the declaration of the Serbian Republic of Bosnia and Herzegovina ---
18 A. Yes, it does.
19 Q. -- is made?
20 A. Yes, it does. It refers to the plebiscite held on 19th November
21 1991.
22 Q. And indicates that it has done so on the basis of the plebiscite?
23 A. Yes, it does and the Serbian people's decision in that plebiscite.
24 Q. Dr. Greve, I appreciate that the discussion of these entities in a
25 kind of chronological order maybe a bit confusing, so if I can have
Page 1015
1 this marked for identification as Exhibit 98? What is that document?
2 A. This is a tiny organogramme which I made simply to visualise the
3 different levels in the different structures.
4 MR. TIEGER: I tender that document for admission.
5 THE PRESIDING JUDGE: Any objection?
6 MR. ORIE: No objection, your Honour.
7 THE PRESIDING JUDGE: 98 will be admitted.
8 MR. TIEGER: May that be placed on the screen, please?
9 (To the witness): What does the left side of the document indicate?
10 A. The left side of the document indicates the legal structure in the
11 time of the Socialist Federal Republic of Yugoslavia, and the
12 different levels, administrative levels, the Republic, the Federal
13 Republic level, the Republic of Bosnia and Herzegovina, the regional
14 level, which at that time was not that significant -- it was the two
15 main Chambers of Commerce -- and the opstina level -- here indicated
16 by opstina Prijedor -- and what I referred to yesterday as the Mjesna
17 Zajednica meaning the local communes.
18 Q. What does the right side of the document describe?
19 A. The right side is made to indicate the separate structure which is
20 being set up in 1991, 1992. On 27th April 1992, it is recalled from
21 Dr. Gow's explanation that the Federal Republic of Yugoslavia was
22 declared which is a legal entity. Then there are these new entities,
23 and I have placed them sort of from the federal level and down to the
24 commune level; the Republic of the Serbian people of Bosnia and
25 Herzegovina, which was declared on 9th January 1992, changing its
Page 1016
1 name, 28th February 1992, to become the Serbian Republic of Bosnia
2 and Herzegovina, changing again its name on 12th August 1992 to
3 become Republika Srpska, and having declared itself in statehood with
4 the Federal Republic of Yugoslavia.
5 This again operated with the autonomous regions. There were
6 several of them. I have indicated the autonomous region of Krajina,
7 which carries the acronym ARK, because that is the regional unit
8 which is just about opstina Prijedor. When the Serbs took power in
9 Prijedor, they declared it to be Srpska opstina Prijedor, meaning the
10 Serbian opstina Prijedor, and still the local communes, which then
11 became Serbian communes, remained Mjesna Zajednica. It is only to
12 indicate the different levels as I myself find it easier to relate
13 something sometimes to what is illustrated.
14 Q. I note that on the left side, which indicates the democratically
15 elected structure of Bosnia and Herzegovina, the region is marked but
16 there is no box. In the official government, was there any regional
17 structure analogous to the autonomous region of Krajina?
18 A. No, there was not. It was only these two Chambers of Commerce which
19 had a very different background and level of functioning.
20 MR. TIEGER: I am about to move on to a separate topic, your Honour,
21 unless the court has questions?
22 THE PRESIDING JUDGE: I did have a question regarding 98, is it? Dr.
23 Greve, on the right-hand side of the diagram, you have the boxes in
24 dotted lines, the four boxes, below the Federal Republic of
25 Yugoslavia. Why are they in dotted lines?
Page 1017
1 A. I have put them in dotted lines because it is disputed if this is
2 legal structures or not. They are objected to as being legally and
3 lawfully established structures, but they are definitely de facto
4 existing structures. I only did this to visualise something, but not
5 to minimise the debate on that important issue.
6 Q. It is helpful to visualise it. But I also note that you do not have
7 any arrows. When I think of an organisational chart, I think of
8 something being at the top, and then there being arrows to show who
9 reports to whom;is it the purpose of this chart to suggest or to
10 establish that the Republic of Srpska reported to the Federal
11 Republic of Yugoslavia?
12 A. As political science is not my field of expertise, I have purposely
13 left out arrows so that I should not move beyond my own
14 understanding.
15 THE PRESIDING JUDGE: We will stand in recess for 20 minutes.
16 (11.30 a.m.)
17 (The court adjourned for a short time)
18 (12.00 p.m.)
19 THE PRESIDING JUDGE: Mr. Tieger?
20 MR. TIEGER: Thank you, your Honour. Dr. Greve, we have been discussing
21 in general a period of time between the elections in August 1990 and
22 the takeover in April 1992. I would like to take you to a point in
23 the middle of that in 1991 when the war in Croatia erupted. Did that
24 have an effect on ethnic relations in opstina Prijedor?
25 A. Yes, it did when it came to mobilization.
Page 1018
1 Q. And did the national or ethnic groups respond differently as groups
2 to the mobilization?
3 A. Yes, they did.
4 Q. How did the Serbs respond to the mobilization to fight in the war in
5 Croatia?
6 A. In contradistinction to the non-Serbs, Serbs responded positively in
7 principle. There were of course many among them as well who were
8 hesitant to go to the war.
9 Q. What was the Muslim and Croat community response to the mobilization?
10 A. In general they did not respond, that is they would not be willing to
11 fight in the war in Croatia.
12 Q. Did the SDA on a republic and opstina levels support the mobilization
13 or opposed the mobilization?
14 A. It opposed the mobilization.
15 Q. Did they take any steps, however, to physically obstruct the
16 mobilization in any way?
17 A. Not in principle, but they were quite eager to see at the time that
18 there would be rather a reduction in armament and war efforts.
19 Q. Did this disparate response by the ethnic groups create heightened
20 tensions between those groups
21 A. To a certain extent I think it was most efficient in terms of
22 being useful for the propaganda efforts, and the split being created
23 by the Serbs being threatened and having many enemies among them.
24 Q. Was there an increase in propaganda following the outbreak of the
25 Croatian war?
Page 1019
1 A. Yes, there was indeed.
2 Q. Now did the different responses to the mobilization have an effect on
3 arming within or on the level of arms within opstina Prijedor?
4 A. Yes, it did.
5 Q. First of all, with respect to those Serbs from Prijedor who responded
6 to the mobilization what effect did it have?
7 A. They were armed and they were equipped and trained and sent to the
8 theatre of war in Croatia.
9 Q. When they returned to Prijedor, were they demobilized?
10 A. No, they were not. There was a decision by the legal authorities in
11 opstina Prijedor that they should be disarmed and demobilized, but
12 that was not accepted and did not happen de facto.
13 Q. Did Muslims who had previously been members of the reserve units
14 become no longer part of those reserve units of the JNA?
15 A. Yes, in part that happened, quite to some, a large extent I would
16 say.
17 Q. Now in addition to the arms received by Serbs who responded to the
18 mobilization and who returned with those arms and were not
19 demobilized, was there additional arming of persons within opstina
20 Prijedor?
21 A. Yes, there was considerable additional arming. The general
22 population were not alarmed by the fact that soldiers going to war
23 were being armed, but they started to be alarmed when they saw
24 neighbours and Serbs in general being armed.
25 Q. So Serb citizens who were not part of the war in Croatia were also
Page 1020
1 being armed?
2 A. Yes, such as elderly women, young youngsters, clearly under age to go
3 to war.
4 Q. Did Serbian de facto officials in Prijedor later acknowledge this
5 arming of citizens?
6 A. Yes, they did.
7 Q. May I have this document marked as No. 99 for identification, please?
8 (Document handed). Dr. Greve, what is this document?
9 A. This is a newspaper article from Kozarski Vjesnik dated 9th July 1993
10 where it is excerpts from what was broadcast on Radio Prijedor in the
11 programme Srdjan Mrdjan Maladan which was broadcast on 30th June
12 1993.
13 Q. Does it contain the presentation of a programme which included the
14 participation of the Deputy Chairman of the Prijedor municipality?
15 A. Yes, it does.
16 Q. The commander of the 43rd Brigade Militia Unit?
17 A. Yes, it does.
18 Q. The head of the public security station in Prijedor at that time in
19 July 1993?
20 A. Yes, it does.
21 Q. Your Honour, I tender that No. 99 for admission.
22 MR. ORIE: No objection.
23 THE PRESIDING JUDGE: Exhibit 99 will be admitted.
24 MR. TIEGER: Dr. Greve, can I draw your attention to page 3, please. Can
25 the monitor be focused on the fifth paragraph. Dr. Greve, you see the
Page 1021
1 fifth paragraph which is a Radanovic speaking according to the text?
2 A. Yes, I see that.
3 Q. Who is Simo Radanovic?
4 A. He is the military commander.
5 Q. Was he an active leader during the time of, following the takeover
6 and during the time of cleansings in the Prijedor municipality?
7 A. Yes, he was. According to himself he was the head of the so-called
8 Gypsy Brigade.
9 Q. Did he later become deputy Chairman of the Prijedor Municipality
10 Assembly after that?
11 A. Yes, according to himself and statements in the newspaper.
12 Q. OK. Does he confirm whether or not there was arming of Serbs in
13 opstina Prijedor before the takeover?
14 A. Yes, he does.
15 Q. In fact, does he certify it in that first sentence?
16 A. Yes. He says: "I hereby certify that, with agreement and
17 co-operation of some countries Serbs at the time, we had indeed
18 started the armament of Serbian people, but under condition that the
19 abuse of weapons should be avoided."
20 Q. Is he speaking about the time prior to the military takeover of
21 Prijedor?
22 A. That is that he does.
23 Q. May I have this document marked as Exhibit 100, please? (Document
24 handed). What is this Exhibit, Dr. Greve?
25 A. This is again a translation of a newspaper article printed in
Page 1022
1 Kozarski Vjesnik, 6th August 1993 with a headline: "Third Anniversary
2 of the Serbian Democratic Party of Prijedor preventing a repetition
3 of the Serbian massacre of 1941".
4 Q. Who is primarily quoted in this article?
5 A. There are several. Simo Miskovic, I think he is the one who is
6 primarily quoted.
7 Q. We tender this document for admission, your Honour.
8 THE PRESIDING JUDGE: Any objection to Exhibit 100?
9 MR. ORIE: No objections, your Honour.
10 THE PRESIDING JUDGE: Exhibit 100 will be admitted.
11 MR. TIEGER: May that be placed on the screen, please. Dr. Greve, you
12 mentioned Simo Miskovic, who was he?
13 A. He was Chairman of the SDS, the Serbian Democratic Party District
14 Committee.
15 Q. Does the article at the top indicate the occasion which prompted the
16 interview with Simo Miskovic?
17 A. Yes, the third anniversary of the Serbian Democratic Party of
18 Prijedor.
19 Q. Turning to the last sentence in paragraph 3, does Simo Miskovic
20 indicate whether or not Serbs were armed prior to the military
21 takeover in 1992?
22 A. Yes, he acknowledged this, saying the SDS leadership saw what they
23 were planning, referring to non-Serbs,and started to arm their own
24 people in order to prevent the tragedy of 1941.
25 Q. I note in that same paragraph, Dr. Greve, in the second sentence it
Page 1023
1 says that: "On August 2nd 1991 we in the district of Prijedor have
2 formed the SDS." Is that an accurate date for the establishment of
3 the SDS in Prijedor?
4 A. No, it cannot be as they participated in the election the previous
5 year, but also, as this is printed in 1993, there could be a mistake
6 in the original or in the translation, as this is called "the third
7 anniversary" indicating, of course, that this party was established
8 in Prijedor before participating in the election.
9 Q. Was the process of arming Serbs by the SDS within opstina Prijedor
10 accelerated as the time drew closer to the military takeover?
11 A. Yes, indeed.
12 Q. In that connection I ask you to look at Exhibit 91, if that can be
13 presented to the witness. (Document handed). Dr. Greve, who
14 participated in the arming of Serbs in the opstina Prijedor?
15 A. It was again a joint effort between the party, the military and the
16 Serb people.
17 Q. Can I ask that page 1 of Exhibit 91 be displayed on the screen? Can
18 we focus on the fourth paragraph, please? Looking at that paragraph
19 and the one on the next page, does it indicate the co-operation and
20 assistance of the Commander of the army in Prijedor at that time?
21 A. Yes, it does. It is actually referring in the last line to Colonel
22 Arsic, Vladimir Arsic, who was the Commander in the area.
23 Q. Can we display the top of the next page, please?
24 A. Here it is stated that he was the Commander of "our garrison, a good
25 soldier and a man with a lot of experience and we decided that we
Page 1024
1 must speed up the process of arming ourselves."
2 Q. All this was before April 30th 1992 when the takeover occurred?
3 A. Yes, it was.
4 Q. And before the announced time of withdrawal for the JNA from Bosnia
5 and Herzegovina?
6 A. Yes, it was. If I may add something which I think is significant,
7 which is that this process of armament, of arming the ordinary
8 people, fed well into the line of propaganda, that is, people became
9 even more fearful when they were told that they had to be armed to
10 protect themselves, so as if there were enemies everywhere.
11 Q. Now in addition to the standing army, the JNA, the defence system of
12 the former Yugoslavia also included Territorial Defence; is that
13 right?
14 A. That is correct.
15 Q. Which was in some practical effect a sort of republic army?
16 A. Yes.
17 Q. Were weapons of the TO under that system held by the local opstinas?
18 A. Yes, it was.
19 Q. Did that mean that in this case weapons were available to Muslims and
20 Croats by virtue of the existence of the TO?
21 A In principle, yes. In practice they had started to withdraw arms from
22 the TO in 1991. This is one of the issues that I think Dr. Gow
23 was looking into also with reference to the book of General
24 Kadijevic.
25 Q. May I have this document marked as Exhibit 101? (Document handed).
Page 1025
1 Dr. Greve, what is this document?
2 A. This is also a translation of an article in Kozarski Vjesnik dated
3 20th May 1994, headlined: "We know our goal".
4 Q. It contains an interview with?
5 A. Colonel Radmilo Zeljaja, Commander of the 33rd Prijedor Motorized
6 Brigade.
7 Q. We tender this document for admission, your Honour, 101.
8 THE PRESIDING JUDGE: Any objection?
9 MR. ORIE: No objection, your Honour.
10 THE PRESIDING JUDGE: 101 will be admitted.
11 MR. TIEGER: Can that be displayed on the screen, please, on page 1? Can
12 we look to the second paragraph, please? Dr. Greve, looking at the
13 middle of that paragraph, the sentence which begins "Our command",
14 does Colonel Zeljaja indicate what happened to the weapons of the TO?
15 A. Yes, he does. He is saying that, "Our command, with the approval of
16 the Corps," that is the one headquartered in Banja Luka, "managed to
17 get together both the weapons and technical equipment from the
18 Territorial Defence TO units of the municipalities, Prijedor,
19 Sanski Most, Novi Grad and Bosanski Dubica, as well as Kninska
20 Krajina region, and place them under our control in our depots."
21 Q. So those TO weapons would at that point be under the physical control
22 of the JNA?
23 A. That is my understanding from the article.
24 Q. Do you know whether any of these weapons were later redistributed to
25 the TOs?
Page 1026
1 A. Yes, they were.
2 Q. In general what amounts and what quality weapons?
3 A. In general it was just a small amount of the total number of weapons,
4 and it was not good quality weapons.
5 Q. Now in addition to having a separate Police Force and a separate
6 Assembly, did Serbs authorities refer to a Serbian TO, a separate TO?
7 A. Yes, they did. They started to refer to a Serbian TO prior to taking
8 power on 30th April 1992.
9 Q. And who was the head of that Serbian Territorial Defence?
10 A. It was Slobodan Kuruzovic.
11 Q. May I have this document marked as Exhibit 102 for identification,
12 please? (Document handed). What is this document, Dr. Grieve?
13 A. This is again an article from Kozarski Vjesnik dated 30th May 1994.
14 It is headlined: "Staff changes in IBC (the Information and Business
15 Centre) Kozarski Vjesnik, new manager Slobodan Kuruzovic".
16 Q. We tender this document for admission as 102.
17 MR. ORIE: No objection.
18 THE PRESIDING JUDGE: Exhibit 102 will be admitted.
19 MR. TIEGER: May that be displayed on the screen? If we could go back and
20 look at the third paragraph. Looking at the third paragraph, Dr.
21 Greve, does it indicate Slobodan Kuruzovic's position in the Serbian
22 TO?
23 A. Yes, the last sentence in paragraph 3 refers to him, Slobodan
24 Kuruzovic, as being the Commander of Serbian Territorial Defence
25 headquartered in Prijedor and one of the organisers of the seizure of
Page 1027
1 power in Prijedor on 29th/30th April 1992.
2 Q. Does it indicate whether or not he was also a member of the SDS?
3 A. Yes, it does.
4 Q. After Mr. Kuruzovic was commander of the Serbian Territorial Defence
5 headquarters in Prijedor and had assisted in organising the military
6 takeover of Prijedor, what position was he appointed to according to
7 this article?
8 A. According to this article, he is becoming head of the Kozarski
9 Vjesnik which at this point has long been a mark piece of the Serbian
10 propaganda and information efforts in opstina Prijedor.
11 Q. Looking at the last line of the article, does Mr. Kuruzovic indicate
12 the principles by which he will be guided in running Kozarski
13 Vjesnik?
14 A. Yes, he does. "The orthodox creed, the interests of Serbian people
15 in Republika Srpska will be the main guidelines for my editorial
16 policies in IBC, said Kuruzovic."
17 Q. Dr. Greve, I would like to bring your attention to the period of time
18 immediately before the military takeover of Prijedor at the end of
19 April 1992. First of all, let me ask you briefl
20 about the political situation within Prijedor at that stage. Was the
21 Municipal Assembly functioning effectively and as a working
22 democratic institution at that point?
23 A. No, it was not, but let me perhaps add that there was an Executive
24 Board with secretariats that did function, although the Assembly with
25 its committees did not function or not function very well.
Page 1028
1 Q. So the opstina was not completely broken down, but were political
2 decisions being made in the normal fashion?
3 A. It was running as a political entity, yes.
4 Q. What was happening within the Assembly at that point? How
5 effectively was it functioning?
6 A. It was not functioning effectively. It was being obstructed. It was
7 almost impossible to reach a consensus on anything and there were
8 occasions where participants would leave the Assembly.
9 Q. So the mechanisms were still available but decisions could not be
10 made?
11 A. That is correct.
12 Q. Had a separate Assembly been established by that time by Serbs in
13 opstina Prijedor?
14 A. Yes, it had, as it was illustrated earlier by the decision that they
15 wanted to join the autonomous region of Krajina.
16 Q. And had the separate police stations been established by that time?
17 A. Yes, they had.
18 Q. With respect to the military situation at that point, had troops or
19 reservists who had gone or volunteers who had gone to fight in
20 Croatia returned?
21 A. Yes, the majority had returned and even more than the people who came
22 from Prijedor. There was a cease-fire in Croatia early in 1991, and
23 because Prijedor has this infrastructure and link between the regions
24 in Croatia where the battles had been fought, all the troops that
25 withdrew through Bosnia-Herzegovina or a large number of those troops
Page 1029
1 necessarily would be withdrawn through Prijedor. That is not exactly
2 the corridor but it is this important link by road from these
3 Croatian battlefields and to Serbia.
4 Q. Were those persons who had been mobilized or volunteered to fight in
5 Croatia, primarily of one ethnic group?
6 A. The majority were Serbs, yes.
7 Q. When they returned were they demobilized?
8 A. They were not.
9 Q. Did they retain their arms?
10 A. They did.
11 Q. Were additional troops beyond those persons who were originally from
12 the opstina placed in or near opstina Prijedor?
13 A. Yes, that is to say, some of them had been placed when the war in
14 Croatia was already on and the people will claim that, "This was our
15 troops, so we were not afraid of them", they were placed locally and
16 it was said that possibly they would move on to Croatia if they were
17 needed on the battlefield, and they just were stationed in Prijedor.
18 Others when going back did not leave Prijedor but stayed on for a
19 while in Prijedor.
20 Q. Had heavy weaponry been brought into the area?
21 A. Yes, a lot of heavy weaponry, such as tanks, howitzers, artillery.
22 Q. Were there paramilitary troops in Prijedor?
23 A. Yes, there was.
24 Q. Were the origins of some of those troops known to citizens?
25 A. Yes, it was. I may perhaps explain at this point that there are two
Page 1030
1 main variations to my understanding of the Serbo Croatian language;
2 it is Ekavian which is spoken essentially in Serbia, and Ijekavian
3 which is spoken in Croatia and Bosnia. Again, I do not know the
4 language, but it is explained to me that the difference is equal to
5 that between British-English and American-English, so that people
6 will immediately be able to distinguish if a person speaks the
7 Ekavinin language which is found in Serbia proper. But there are
8 exceptions. There are some areas in Serbia proper which speaks the
9 same Ijekavian language as the people in Croatia and Bosnia, but not
10 the other way round, according to the dictionaries which I have
11 consulted.
12 Q. Finally, were Serb civilians armed at that time?
13 A. Yes, they were.
14 Q. What happened on the night April 29th, April 30th?
15 A. In the very early hours of 30th April, that is after midnight,
16 approximately 4 o'clock, the Serbs in opstina Prijedor, co-operation
17 between army, including paramilitary forces, police and the party,
18 were seizing power with armed force; that is, they established all
19 over the town of Prijedor checkpoints, placed armed guards outside
20 all the main buildings, police station, bank, town hall and inside
21 the radio station, etc., etc., and ha
22 snipers on the roofs. They also went public on Radio Prijedor to
23 announce that they
24 had by force established Srpske opstina Prijedor.
25 Q. Now did the de facto Serbian authorities later claim that the
Page 1031
1 takeover was triggered by some particular event?
2 A. Yes, they did. When journalists spoke, well, I should say this, that
3 the people living in opstina Prijedor at this time, as mentioned
4 yesterday, had been cut off from receiving TV transmissions and
5 broadcasts from Sarajevo. They would only see the broadcasts that
6 came from Belgrade, Banja Luka or eventually Pale. The TV station in
7 Belgrade had on 29th April transmitted a facsimile of a telefax to
8 the effect that the Republic -- the leader of TO in the Republic of
9 Bosnia-Herzegovina had given an instruction to the TO in
10 Bosnia-Herzegovina to attack and obstruct the JNA when they were to
11 withdraw from Bosnia-Herzegovina. But immediately this telefax was
12 denounced and declared false by the authorities in Sarajevo, and I
13 have not come across people who have actually had themselves access
14 to this telefax in Prijedor. However, when journalists later came to
15 Banja Luka, they were given a copy of this telefax as the pretext why
16 this power change had to take place.
17 Q. May I have this document marked as Exhibit 103? (Document handed).
18 What is that document, Dr. Greve?
19 A. It is called FBIS EEU 92084, of 30th April 1992 -- FBIS EEU is the
20 Foreign Broadcast Information Service Eastern Europe -- and it is
21 referring to a broadcast which was made by radio Sarajevo network in
22 Serbo-Croatian at 1818 GMT, 29th April 1992.
23 MR. TIEGER: I tender this document for admission, your Honour.
24 THE PRESIDING JUDGE: Any objection?
25 MR. ORIE: No objections, your Honour.
Page 1032
1 THE PRESIDING JUDGE: Exhibit 103 will be admitted.
2 MR. TIEGER (To the witness): Does this document indicate whether or not
3 Bosnian authorities were aware of reports that an order had been
4 given to local TOs?
5 A. Yes, it indicates that they were informed of this and they thus had
6 to come out immediately to state that this was false.
7 Q. Does the exhibit indicate whether or not a public denunciation of
8 that fax as false was made?
9 A. Yes, it is referring to such denunciation already having been made
10 and it is repeating it.
11 Q. In fact, Dr. Greve, did the de facto Serbian officials of Prijedor
12 indicate themselves whether or not the takeover was a spontaneous
13 event in response to this fax or, in fact, a long-standing plan?
14 A. They are consistently referring to a long-standing plan. At one point
15 they speak about why it had to be the 9th to 30th; they are saying
16 that, "We had it considered to make it the 30th, the night after this
17 night to 1st of May, but because of this we had to move forward 24
18 hours". But I should also add that years after this happened, there
19 is no more any mention of this telefax. However, there is reference
20 to a completely different telefax to which no mention was made in the
21 early days.
22 Q. May I ask that Exhibit 91 be placed before the witness? If I can ask
23 you to look at the third paragraph, does this indicate whether or
24 not the takeover was a spontaneous reaction or a planned event for
25 some time?
Page 1033
1 A. It clearly states that this was not a spontaneous reaction; it was
2 only the final act of a long-standing plan.
3 Q. The person who says this is whom?
4 A. It is Milomir Stakic.
5 Q. Was he the first Chairman of the Serbian Municipal Assembly?
6 A. He was.
7 MR. TIEGER: May document Exhibit 90 be placed in front of the witness
8 once more? (To the witness): Dr. Greve, you indicated that the
9 takeover was a co-ordinated effort between political police and
10 military authorities?
11 A. Yes, I stated that.
12 Q. Does paragraph 3 of Exhibit 93 indicate who participated in the
13 takeover?
14 A. Yes, it does.
15 Q. What does that article say?
16 A. This paragraph refers, if I should take at this point only the second
17 half of it, "It was not easy to hold illegal meetings and to prepare
18 for defence, but after the presidency of the former BIH blockaded the
19 barracks and other military installations, it was decided in
20 agreement with the officers of the Serbian army, the Serbian
21 Democratic Party and the Executive Committee of the Municipality of
22 Prijedor to seize power from the Muslim extremists"
23 Q. In this takeover which took place by force of arms on April 30th
24 1992, with the agreement and co-operation of the JNA, was that before
25 the announced withdrawal of JNA troops from Bosnia and Herzegovina?
Page 1034
1 A. Yes, it was.
2 Q. They were the JNA at that time?
3 A. Yes, they were.
4 Q. Did the Muslims physically resist when confronted by the arms, the
5 combined arms, of the JNA, the Serbian police, the paramilitaries?
6 A. No, they did not, and I assume that is why it can also be stated here
7 in the article, in the next paragraph, that all this happened without
8 one shot being fired, and that is repeatedly referred to in
9 newspaper articles.
10 Q. In that connection, can I draw your attention back to Exhibit 100?
11 In Exhibit 100, does Simo Miskovic indicate whether or not there was
12 Muslim or Croat resistance to the takeover on April 30th?
13 A. Simo Miskovic is stating that on 30th April 1992 the takeover was
14 achieved without a single shot being fired and without a single
15 casualty.
16 Q. Dr. Greve, I would next like to ask you about the immediate
17 consequences of this takeover. First of all, did it have an effect
18 on the dissemination of propaganda or information?
19 A. Yes, it did. Immediately, both Kozarski Vjesnik and radio Prijedor
20 became virtual mouth-pieces of the new authorities, that is, the
21 Srpska opstina Prijedor.
22 Q. Was there an escalation of the tenor or the tone of that propaganda?
23 A. Yes, the terms used for Croats and Muslim became much more
24 derogative.
25 Q. Was there an effect on the movement for Muslims and Croats within the
Page 1035
1 opstina?
2 A. Yes, movement for these groups was severely obstructed, but I should
3 perhaps say that when one refers to Muslim and Croats, it is perhaps
4 even more correct to refer to non-Serbs because there were other tiny
5 minority groups who were also not included in the Serb group. Among
6 Serbs were considered also the Montenegrins, there were not many of
7 them, but they were like smaller brothers, and there were some of the
8 aliens who were well accepted, but, essentially, it was the Serbs and
9 the non-Serbs of whom the Muslims were the majority.
10 Q. What was the nature of the control of movement within the opstina,
11 how was it affected?
12 A. There were several measures being implemented. There were road
13 blocks at intersections where people would have to show their IDs,
14 and if their ID card would not prove them to be Serbs, then they
15 could not been identified as Serbs, they were not necessarily
16 entitled to pass the road blocks. They would need special permits to
17 travel, and it was very limited and restricted where were they were
18 able to travel. They could no longer leave opstina Prijedor,
19 essentially. They also had to abide by a curfew.
20 Q. Did Serbian officials later acknowledge just how tight these controls
21 became?
22 A. Yes, they did.
23 Q. Can I direct your attention back to Exhibit 99, please? Directing
24 your attention to page 3 of that document, looking at the middle of
25 that page where there is a statement by Mr. Ecim, does he indicate
Page 1036
1 in any way how tight some of those controls became?
2 A. Yes, he does indeed, because he is referring to the difficulties,
3 well, actually he is placing blame on some Serbs who assisted,
4 allegedly, Muslims to leave or non-Serbs to leave, saying that they
5 were leaving the region in coffins, in cars owned by the Serbs and
6 with Serbian IDs which indicates it was not an easy thing to get out.
7 Q. Was there a control of communication?
8 A. Yes, it was control of communication. It is recalled that there are
9 some main roads going through the area and it was no more possible
10 for the non-Serbian population to have bus tickets to leave, and they
11 could not leave with their own cars least they had had Serbian IDs,
12 and they could not easily get a ticket, if at all, on the railway,
13 and there is an aerodrome in the area, but it is not a modern
14 airport, it is more like a sports field for sports planes and there
15 were no regular air traffic through the area.
16 Q. What about the use of telephones, did that change in any way?
17 A. Yes, they were on and off the telephone lines were blocked for the
18 non-Serbs. This soon became more the general rule than the exception
19 and also electricity was in part shut down.
20 Q. After the takeover, was there an effect on the employment status of
21 Muslims and Croats?
22 A. Yes, actually, and this is later being confirmed by the official
23 gazette by the autonomous region of Krajina, now it became important
24 to be a good Serb, someone who knew that and had demonstrated that
25 they were loyal to the Serbs, the party, the plebiscite had voted for
Page 1037
1 independence etc., and this definitely meant that all the non-Serbs
2 would no more qualify for leading positions and they were asked to
3 leave all leading positions
4 Eventually, within days, the majority of the workforce, even in
5 factories, were asked
6 to leave their positions.
7 MR. TIEGER: Your Honour, may I have this document marked as Exhibit 104
8 for identification, please? (Document handed).
9 (To the witness): What is this document, Dr. Greve?
10 A. This is a full translation of a newspaper article. It is not
11 mentioned where it is published in the translation, but it mentioned
12 that the date of publication is 22nd June 1992, and its headline is
13 "Leaders - only loyal Serbs!". Within this article there is a
14 facsimile from a decision made by the autonomous region of Krajina.
15 It is Crisis Staff in Banja Luka.
16 MR. TIEGER: We tender this document.
17 THE PRESIDING JUDGE: Any objection?
18 MR. ORIE: No objection, your Honour.
19 THE PRESIDING JUDGE: Exhibit 104 will be admitted.
20 MR. TIEGER (To the witness): Can that be raised a bit? Dr. Greve, does
21 this document indicate whether or not the process of termination from
22 the employment of Muslims and Croats which began after the takeover
23 continued?
24 A. Yes, it indicates that this continued and it was more and more
25 demands being made concerning those who were to keep positions.
Page 1038
1 Q. Does it also indicate the conditions or qualifications for continued
2 positions, important positions, within the autonomous region?
3 A. Yes, it does. This is the time when virtually most of the
4 non-Serbian population has already been asked to leave their jobs.
5 Now, the remaining ones are Serbs, and it is being indicated that any
6 Serb is not good enough. It is stated that in addition to being of
7 Serbian nationality -- I am looking at the second paragraph, the
8 second part -- "In addition they", that is the Serb nationals, "must
9 have confirmed their Serbian nationality in the plebiscite". That
10 is the one, 9th and 10th November 1991, and it must be ideologically
11 clear to them that the only representative of the Serbian people is
12 the Serbian Democratic Party.
13 JUDGE STEPHEN: I wonder if I can ask a question about this? I see the
14 reference here to the army of the Serbian Republic of
15 Bosnia-Herzegovina. This was at a time when it had been declared
16 that a Serbian Republic would remain part of Yugoslavia.
17 A. That is correct, your Honour.
18 Q. Could one have a separate army if one was a Republic of the Yugoslav
19 nation?
20 A. In my opinion, no, your Honour.
21 Q. Did the other entities of that rump nation have their own armies?
22 A. Eventually, they moved to establish their own armies and armed
23 entities but, as was illustrated yesterday with the decision made by
24 the committee of senior officials in the then conference on
25 co-operation and security in Europe, it was pointed out in that
Page 1039
1 decision that the heavy equipment belonging to the JNA had to be
2 withdrawn, as had all the personnel that did not belong to Bosnia or
3 come originally from Bosnia-Herzegovina, and that it could not simply
4 be up to the JNA to decide to establish a Bosnian-Serb army, give
5 them full armament etc.; either the arms had to be withdrawn from
6 Bosnia-Herzegovina or it had to be placed under the control of the
7 legal authorities, that is, Sarajevo.
8 MR. TIEGER: Did the new de facto Serbian authorities following the
9 takeover begin to make demands on the Muslim and Croat population?
10 A. Immediately.
11 Q. What were the nature of those demands?
12 A. One of the first demands was in a sense a follow-up, if I may
13 mention, of what had happened already previously or prior to taking
14 power; that is, that non-Serbs who for one reason or the other had a
15 weapon, they were being approached by police or tanks or anyone.
16 Although this might be a hunting rifle and they may have a licence
17 for carrying that hunting rifle, they were asked to give up their
18 arms. They were told if they did not accept to give it up, they will
19 be forced to give it up.
20 So many people had started to hand in whatever hunting weapons
21 they had, or other weapons if they were members of sports clubs,
22 handling weapons or whatever. But this was speeded up considerably
23 after the Serbs took power. Then they made a demand that everyone
24 who had any kind of weapons should hand them over immediately.
25 Q. In general, how did the Muslim and Croat community respond to those
Page 1040
1 demands to surrender their weapons?
2 A. By and large, I believe most of those weapons were handed into the
3 Serbs because they were confronted with an overwhelming strength of
4 arms. However, there were people who were appointed policemen by the
5 legal authorities in Sarajevo who were not
6 necessarily immediately willing to give up their arms to an illegal
7 entity; there was a conflict of loyalty in this situation.
8 They were appointed as representatives of a legal government,
9 and they did not, all of them, immediately give up their arms. The
10 same was the case with this not so good arms kept by some of the
11 Territorial Defence. They were also in this; they were a part of a
12 legal structure and immediately to hand over their weapons to an
13 illegal entity was not always done.
14 Q. Did the de facto Serb authorities demand any demonstration or pledge
15 of loyalty to their new regime?
16 A. Yes, they did. Before virtually dismissing all the police, they
17 called them for meetings and said they would have to carry the new
18 Serbian insignia, they would have to pledge loyalty to the new
19 Srpska opstina Prijedor, etc.
20 Q. Did the schools function normally?
21 A. Initially, yes, but it was decided (and that is also confirmed by the
22 decision made by the autonomous region of Krajina) that this
23 particular year they would end school much earlier than normally.
24 They would end on 20th May which, I think, is a significant date for
25 the later events. This is also the time when virtually everyone in
Page 1041
1 the Serb population had been mobilized to the army, to the reserve,
2 to the police, to the Reserve Police Force, and this way also the
3 teachers became available to take up service also in the Territorial
4 Defence Forces of which the Serbs had their special branch.
5 Q. Schools were closed by order of the autonomous region Krizni Stab on
6 May 20th?
7 A. Yes.
8 Q. When did the first military action against a Muslim or Croat
9 community take place?
10 A. 22nd May. If I may add also one thing, already during the
11 mobilization for Croatia, it had become a problem that there were not
12 enough military uniforms when they tried to get everyone into
13 uniform. So it seems that on occasions many people would go to war
14 partly dressed in uniform and partly in civilian clothing.
15 MR. TIEGER: Can we have Exhibit 78 displayed? I apologise. Apparently,
16 Exhibit 79 will better illustrate the region for the witness. (To
17 the witness): Dr. Greve, can you show us the area where the first
18 military attack occurred?
19 A. It is on this stretch from Prijedor and up to Hambarine which is
20 located on a higher level than Prijedor, the town, and Hambarine is
21 one village, but it is also a Mjesna Zajednica which includes areas
22 to its north and west, essentially -- also some to the south.
23 Q. Was there any incident which preceded the military attack?
24 A. Yes, there was. Hambarine is located on the way towards Ljubija --
25 this road actually continues down to Ljubija -- and Ljubija was an
Page 1042
1 area which at that time had not been -- the full Serbian control had
2 not yet been established; that is, as we will return to later, on the
3 day of 22nd May, the Serbs claimed that once again they took power in
4 Ljubija without any violence, they just being cunning (as they are
5 saying themselves) were able to get all the weapons away from all the
6 non-Serbs in that area.
7 But, at this day there was a road block on the road from
8 Prijedor up to Hambarine, manned by some Muslim people, and there was
9 a car coming up, I believe it was, according to newspaper articles
10 referring to this later, four Serbs and one Croat in this car; the
11 Croat being the driver, the Serbs possibly being members of the
12 Bijeliorlovi which is the White Eagles which is a paramilitary unit.
13 They were in uniform and they were carrying arms and they were asked
14 to stop at this check point to give up their arms before they passed.
15 Apparently, they did not want to do that and there was a shooting
16 incident in which two Serbs were killed; one of the Muslims was
17 initially wounded and subsequently died from his wounds.
18 Q. Following that incident, was there an ultimatum made on the residents
19 of Hambarine?
20 A. Yes, there was an ultimatum that Hambarine as such would have to hand
21 over to the authorities in Prijedor town, it was announced on radio
22 Prijedor, the three or four people who had actually been manning this
23 checkpoint.
24 Q. When the ultimatum expired the next day, what happened? Was there a
25 military attack?
Page 1043
1 A. There was a military attack. Compared to what was later to come,
2 this was not an extreme attack. It was an attack whereby Hambarine
3 area and nearby locations were initially shelled by heavy artillery,
4 some of which were stationed in the town of Prijedor at the airfield,
5 aerodrome, Urije, in that area, so they were actually shooting from
6 across Prijedor and up to Hambarine. When the bombardment ended, the
7 Serb armed entities came with tanks and other weaponry to the area of
8 Hambarine. Many of the people had already left this area going either
9 north to Rizvanovici, Biscani and other villages in this
10 area which at this point were not that much attacked, and they had
11 tried to withdraw to the south which is a forested area -- it is
12 called Kurevo -- and that was being shelled as well as the people
13 left.
14 THE PRESIDING JUDGE: We will stand in recess until 2.30.
15
16 (1.00 p.m.)
17 (Luncheon adjournment)
18 (2.30 p.m)
19 THE PRESIDING JUDGE: Mr. Tieger, you may proceed.
20 MR. TIEGER: Thank you, your Honour. Your Honour, yesterday I tendered
21 document 82 with the understanding that it was a black and white copy
22 of a document we expected to receive in full colour shortly. That
23 document is here and it can be used today.
24 THE PRESIDING JUDGE: Fine. That is 88?
25 MR. TIEGER: 82, your Honour.
Page 1044
1 THE PRESIDING JUDGE: 82, sorry. Is there any objection to the colour
2 being substituted for what was admitted yesterday as 82?
3 MR. ORIE: No objection, your Honour.
4 THE PRESIDING JUDGE: OK, very good. It will be substituted.
5 MR. TIEGER: May the new document 82 be displayed for the witness?
6 THE PRESIDING JUDGE: Mr. Tieger?
7 MR. TIEGER: Yes, your Honour. (To the witness): Dr. Greve, you
8 explained this map to us yesterday when it was only depicted in black
9 and white. Perhaps you can indicate to us quickly what the colours
10 represent?
11 A. Yes. The colour code will be that the green indicates predominantly
12 or mainly Muslim habitations and settlements, the blue indicates the
13 Serb ones and the red indicates the Croat ones.
14 Q. Can you indicate then on this map of the ethnic distribution of
15 opstina Prijedor where the region you were talking about before the
16 adjournment or the recess is located?
17 A. We then was looking at Hambarine which is both a village and a Mjesna
18 Zajednica which covers adjacent areas as well.
19 Q. You indicated that on May 23rd Hambarine was subjected to first
20 shelling and then troops?
21 A. Invaded by troops and tanks, yes.
22 Q. What did the residents of Hambarine do when the shelling began?
23 A. They tried to run away, run to the north, to other Muslim areas, or
24 to the south, still to Muslim areas; and the Carakovo which is
25 indicated here, that is in a forested area as well, so it is possibly
Page 1045
1 easier to hide to the south than to the north, but it was shelling
2 also in the Carakavo area for those who fled to the forest.
3 That eventually led to a number of people seeking even further
4 to the southwest, to the
5 area marked as Ljubija.
6 Q. Did the residents of the area eventually return to the Hambarine
7 area
8 A. Yes, quite a number did return. It should be remembered, though, that
9 there had been ethnic cleansing going out outside of opstina
10 Prijedor, in opstina Bosanski Novi, to the west, that this, so some
11 people had come into opstina Prijedor and, essentially, come to
12 settle in this western/southern part of opstina Prijedor with people
13 who were Muslims or who were Croats as again in Bosanski Novi the
14 people who were ethnically cleansed were the non-Serbs.
15 Q. The residents who fled that initial shelling of Hambarine and the
16 invasion of troops, and then returned, did they eventually leave the
17 area again?
18 A. Yes, at a later stage they did.
19 Q. OK. We will come to that in the course of your testimony?
20 A. Yes, we will.
21 Q. You mentioned that after this initial attack on Hambarine on May 23rd
22 some of the residents fled to the Ljubija area which is also
23 depicted on the map?
24 A. That is correct. It is this area. It is actually divided in two
25 settlements. It is called Donja Ljubija and Gornja Ljubija; "donja"
Page 1046
1 is lower and "gornja" is upper.
2 Q. Were there weapons available in Ljubija at the TO headquarters?
3 A. Yes, there were.
4 Q. Did the residents of Hambarine who fled to the Ljubija area gather up
5 those weapons?
6 A. No, they did not.
7 Q. What happened to those weapons that were in the TO?
8 A. According to the Serb chronicles of what happened in Ljubija at this
9 time, the Serbs succeeded in taking hand of all these weapons
10 immediately before they ever been used.
11 MR. TIEGER: May I have this document marked for identification as Exhibit
12 105? (Document handed).
13 JUDGE STEPHEN: You raised my expectations; I thought you were going to
14 give each of us a coloured map, not so?
15 MR. TIEGER: I had the same hope, your Honour, but I understand, based on
16 discussions, we can scan that document this evening, and produce
17 colour copies from the printed.
18 JUDGE STEPHEN: Thank you very much.
19 MR. TIEGER (To the witness): Dr. Greve, what is Exhibit 105?
20 A. This exhibit is once again an article from Kozarski Vjesnik. It is
21 dated June 17th 1994, and it is a series of articles and it is set in
22 connection with May 22nd when Serbian rule was established in
23 Ljubija.
24 MR. TIEGER: We would tender that document for admission.
25 THE PRESIDING JUDGE: Any objection?
Page 1047
1 MR. ORIE: No objections, your Honour.
2 THE PRESIDING JUDGE: Exhibit 105 will be admitted.
3 MR. TIEGER (To the witness): Dr. Greve, can I ask you to look at the
4 second page of that document -- actually perhaps we had better place
5 it in context. Would you look at the first page? In the bottom of
6 the first paragraph, does it indicate what happened after the attack
7 on Hambarine?
8 A. Yes, it referred to the fact that mostly non-Serbian population lived
9 in the environs of Ljubija and they were well-armed. In Ljubija
10 itself, there was a Territorial Defence unit which had only three
11 Serbs. All the extremists from the left side of the Sana, that is
12 the river that flows on the left side of this area, hid in the woods
13 around Ljubija and in the wake of May 22nd, 1992 refugees started
14 pouring into town.
15 Q. Does the article go on to disclose what happened to the weapons in
16 Ljubija which were, according to the article, guarded by only three
17 Serbs -- if you could turn to page 2?
18 A. Yes, it does.
19 Q. Looking at the bottom of the page, does that indicate what happened
20 to those weapons?
21 A. Yes, it referred to the fact that the local leader of the Crisis
22 Committee, his name being Slobodan Taranjac, concludes that the only
23 real danger they, meaning the people in the Ljubija area, still faced
24 was from the Territorial Defence, because it was largely made up of
25 non-Serbs, and it is referring that as being yet another problem.
Page 1048
1 Q. Did the leader of the Serbian Territorial Defence find it necessary
2 to rest those weapons from the non-Serbs weapons of the TO with
3 force?
4 A. No, he decided it would be enough to resort to cunning behaviour.
5 Q. How were those weapons extracted from the TO?
6 A. Do you want me to have the third page of the article?
7 Q. Please.
8 A. The first paragraph on this page explains it. Do you want me to read
9 it?
10 Q. Certainly.
11 A. He is stating that they resorted to cunning: "I sent Krivi to tell
12 the Territorial Defence that we were being attacked by 150 green
13 berets; that Ivica Milosevic and his men had placed themselves under
14 my command and that we were defending Ljubija. About 30 minutes later
15 I sent Milo Gliga in his van to pick up the weapons from members of
16 the Territoria
17 Defence. He asked me how he was going to disarm them and I told him
18 they had already done it themselves, because they would not defend
19 Ljubija. Then Gliga arrived at Territorial Defence headquarters. He
20 found Krivi there alone with all the weapons. That is how we
21 eliminated yet another danger without firing a bullet."
22 Q. So, according to the article, Krivi walked in and took the weapons?
23 A. Yes, took care of the arms.
24 JUDGE STEPHEN: Would you look at page 1, there is a reference to a
25 military unit there, the commander of which told them, the 43rd
Page 1049
1 Brigade, not to open a front. What Brigade is that? What sort of
2 unit is that?
3 MR. TIEGER: If it helps your Honour, we will be submitting documentation
4 which indicates what the 43rd was and where it operated during this
5 period of time.
6 JUDGE STEPHEN: Thank you.
7 MR. TIEGER: Can we see the exhibit 82 again, please?
8 THE WITNESS: The article which we just saw on the screen there -- I
9 should perhaps have mentioned then -- also referred to 8,000 refugees
10 coming into the Ljubija area.
11 MR. TIEGER: Dr. Greve, the ethnic distribution indicates a large area
12 depicted in green representing a large concentration of the Muslim
13 population in the Hambarine area. Looking to the right, is there
14 also, or was there also, a large concentration of the Muslim
15 community of Prijedor in the Kozarac area?
16 A. Yes, there was the possibly largest concentration of Muslim people in
17 this area. The larger Kozarac area or the Potkozarac area, it is the
18 mountain of Kozarac which is up, that is why there are no Serbian
19 settlements up in the mountain.
20 Q. I believe you indicated this earlier, but approximately how many
21 people lived in that region?
22 A. In that larger area, including also down to Trnopolje and to
23 Kevljani, there would be approximately 27,000 people of non-Serbian
24 origin.
25 THE PRESIDING JUDGE: What region is this now?
Page 1050
1 A. This is the larger region of Kozarac, Kozarac being this location,
2 but it is often referred to as one larger area, the Kozarac area.
3 The mountain is called Kozara and it runs up the entire length.
4 Q. I thought you were talking about the entire Prijedor region opstina;
5 I understand now.
6 A. Excuse me, your Honour.
7 THE PRESIDING JUDGE: Thank you.
8 MR. TIEGER: Can we call up photos 5/0101 followed by 5/0102 and 03? (To
9 the witness): Dr. Greve, what does this depict?
10 A. To my understanding, this is a post card and it actually shows the
11 mosque in Kozarac.
12 Q. Next picture, please? What does this picture depict?
13 A. Again it is my understanding that it is another picture from Kozarac,
14 and it shows the Marsala Tito which is the main street which crosses
15 the two streets running Prijedor, Banja Luka, the old and the new
16 one.
17 Q. The next picture, please? Does this picture depict another shot of
18 Kozarac?
19 A. It does.
20 MR. TIEGER: Your Honour, I tender these for admission as Exhibit 106 and
21 we do so in the form of this single document.
22 MR. ORIE: No objection, your Honour.
23 THE PRESIDING JUDGE: 106 will be admitted.
24 MR. TIEGER (To the witness): Dr. Greve, what sort of town was Kozarac,
25 what did the people do primarily? How prosperous was it?
Page 1051
1 A. It was a prosperous area. It was located close to the mountain of
2 Kozara. It was an area which had sawmills and some timber
3 activities. It was an intersection, a cross-road. It was the access
4 road up to the main war memorial on the Kozara mountain, and a number
5 of people in this area had been working abroad as foreign workers and
6 had had some financial means to establish themselves with small
7 businesses, etc. So it was considered to be a prosperous area within
8 a, generally speaking, prosperous opstina Prijedor.
9 Q. After the armed takeover of opstina Prijedor, did the de facto
10 Serbian authorities make demands or ultimatums on the Kozarac
11 community?
12 A. Yes, they did. They did demand that the TO also in this area would
13 immediately pay respect, be subordinate to, the new authorities in
14 Srpska opstina Prijedor.
15 Q. Was there any demand made on police officials in Kozarac?
16 A. Yes, the same as on every police official in the opstina.
17 Q. Did negotiations take place between the representatives of Kozarac
18 community and the de facto authorities in Prijedor?
19 A. Yes.
20 Q. Were those negotiations successful?
21 A. Possibly the participants thought they were successful to a certain
22 degree and did expect them to go on but, as it all turned out, they
23 were not successful.
24 Q. Did the demand for a pledge of loyalty by the police and the TO to the
25 new Serbian authority continue?
Page 1052
1 A. Yes, it continued.
2 Q. Was there a demand for disarmament?
3 A. Yes.
4 Q. Did that continue to be made?
5 A. Yes.
6 Q. How well armed was the Kozarac community?
7 A. There were weapons with the police and there were weapons with the
8 Territorial Defence forces, and there were a number of Muslims who
9 had bought weapons if they could as they saw others being armed.
10 But, generally speaking, there was very limited arms as compared to
11 the arms available to the other side.
12 Q. Let me ask you one more question about the oath of loyalty that was
13 demanded by de facto Serbian leaders. That would be an oath to be
14 loyal to the new Serbian authority?
15 A. Yes, as being a party to this separate structure and separate
16 Republika Srpska.
17 Q. Would it mean that the people of Kozarac would no longer be part of
18 Bosnia-Herzegovina?
19 A. That would be so.
20 Q. After the demand for surrender of arms and after the demand for a
21 pledge of loyalty to the new officials, was Kozarac attacked?
22 A. Yes, it was.
23 Q. When did that begin?
24 A. It is my understanding that it started on 24th May.
25 Q. How did the attack on Kozarac begin, using what sort of military
Page 1053
1 force?
2 A. This time it was very heavy bombardment of the entire area. If we
3 can have again perhaps the map of -----
4 Q. Perhaps we could exact Exhibit 79, 2/35? If the court is looking on
5 the screen, it is a little difficult to read so perhaps you can
6 orientate us before you describe -----
7 A. This is Kozarac; this is the town of Prijedor; this is the
8 mountainous area behind; these are the main roads Prijedor, Banja
9 Luka; this is the fish farm, lake; yes, these are the basics that one
10 needs just at this point to have an understanding. When Kozarac was
11 attacked it is combined information from, well, actually all sources
12 will indicate that it was attacked and bombarded from several
13 different areas. Some were across -- or maybe I should start, there
14 are proper military installations, long-term military installations,
15 on the top of the
16 Mountain Kozara. There were several installations on this mountain
17 that were used to bombard Kozarac and nearby areas.
18 However, there were also installations, to my
19 understanding, placed somewhere in this area, the Kamen area, I
20 understand, from the other side of the fish farm or the lake, Topjka
21 Brdo and in some other areas here, Racelici, perhaps. That is that
22 the people in Kozarac felt as if they were bombarded from every side
23 at the same time and it was heavy bombardment with all kinds of heavy
24 artillery which was only available, or had only been available, to
25 the JNA.
Page 1054
1 Q. How long did that heavy bombardment continue?
2 A. The immediate heavy bombardment continued for about 24 hours.
3 Q. Then did it stop entirely?
4 A. Not entirely.
5 Q. Did it continue intermittently?
6 A. Yes.
7 Q. For approximately how long?
8 A. For approximately up to 12 hours, I believe.
9 Q. What did the residents of Kozarac do when the bombardment began?
10 A. Seek shelter, essentially, that is to say, some would immediately try
11 to find the best cellar in the area, their own house or a
12 neighbouring house; others would try to move towards the foot of the
13 mountain although they were being shelled from the top of the
14 mountain. This is as it is read out of the map, slightly hilly and
15 they probably thought it would be safe in some of these areas. But
16 as people moved up to the foot of the mountain the shelling also
17 focused on the foot of the mountain.
18 Q. After the shelling ceased, what happened militarily after the
19 shelling ceased?
20 A. Again, there was one co-ordinated operation where several units were
21 working together. It was ordinary military units with reserves and
22 paramilitaries and police and reserves, and some local Serbs -- this
23 was the time when about every adult male Serb was in uniform -- and
24 moving in from different directions on the roads would come tanks and
25 troops, and they would start attacking some of the different
Page 1055
1 localities.
2 Q. That happened to the residents of Kozarac after the troops moved in?
3 A. They were forced to leave their houses, their shelters and asked to
4 come out into the streets.
5 Q. Once they gathered in the streets, where were they taken?
6 A. They were taken to some points of, to where they were to be gathered
7 and concentrated. Those who were from the centre of Kozarac were
8 taken, essentially, in the direction of Kozarusa; some were also
9 taken down on this main road towards Trnopolje, as we will come back
10 to.
11 The people were then separated so that women with small
12 children up to 12, 15, and the elderly men, 60, 65 in this context,
13 would be one group and the male population between 12, 15 or 60, 65,
14 would be another group. A number of people were killed in the
15 process -- we will come back to that, I think -- but those who were
16 not killed were separated like this.
17 Q. Did the destruction of Kozarac end with the cessation of the
18 shelling?
19 A. No.
20 Q. Did you have an opportunity to see video footage taken by journalists
21 who visited the Prijedor area in the summer of 1992?
22 A. Yes, I did. I also spoke with some NGOs who were let into the area
23 when it was almost so-called cleansed of non-Serbs who travelled
24 through on the main road.
25 Q. Have you seen recent footage of the Kozarac area or footage recently
Page 1056
1 taken?
2 A. Yes, I have seen footage taken by the Prosecutor's office.
3 Q. Is that also the most comprehensive footage of the area which you
4 have seen?
5 A. Yes, it is.
6 Q. Does it include both sides of the street, of the main street, that
7 you showed us?
8 A. Yes, it does.
9 Q. Does it include portions of both the main highway and the old road
10 going in the direction both toward Omarska and toward Prijedor?
11 A. That is what I have been told and it corresponds to information I
12 have from other sources but I have not been there, but maybe I should
13 say that when the area had been cleansed and when it had been
14 bombarded or bombarded and cleansed, each and every property which
15 belonged to non-Serbs were, essentially, pillaged and then they were
16 blown up from inside. So all the damage that could be seen on this
17 footage is not due to the bombardment; it is also later activities.
18 MR. TIEGER: Your Honour, can we play video No. 5 at this time? Before we
19 start it, the video is a portion of the footage taken all of which
20 has been made available to the Defence. The extract is approximately
21 40 minutes long. It is not my intention to play the entire extract
22 to the court at this time. I am sure the court will be interested in
23 seeing it at
24 a time more convenient, but I will play a portion of that before we stop
25 the tape. I would like that marked for identification as 107
Page 1057
1 then.
2 THE PRESIDING JUDGE: Is there any objection to Prosecution 107?
3 MR. ORIE: No objection, your Honour.
4 THE PRESIDING JUDGE: 107 will be admitted.
5 (The video tape was played)
6 MR. TIEGER: Dr. Greve, this is the main street of Kozarac?
7 A. That is my understanding, yes.
8 Q. Is this the mosque depicted in the photograph we saw earlier?
9 A. That is also my understanding, yes.
10 Q. Has the vehicle from which this video was taken now left the main
11 portion of the town and proceeding up the road leading up to the
12 mountain?
13 A. Yes, that is my understanding.
14 Q. Dr. Greve, this section of the video is back down from the mountain
15 leading back to town?
16 A. That is my understanding, yes.
17 Q. That was the Prijedor Banja Luka highway where the video ended?
18 A. That is my understanding, yes.
19 MR. TIEGER: Can we stop the video, please? Your Honour, as I indicated,
20 the video which was just an extract from a longer video goes on for
21 approximately 45 minutes depicting similar scenes of destruction
22 along the old road on both sides leading in the direction of
23 Prijedor, on the Prijedor, Banja Luka highway on both sides leading
24 towards Prijedor on that same highway and going toward the Omarska
25 area and the old road going towards the Omarska area. There are just
Page 1058
1 two additional questions I want to ask Dr. Greve about that, and then
2 I will leave it to the court to review at its convenience.
3 (To the witness): Dr. Greve, does the video to your recollection depict
4 this Serbian orthodox church in Kozarac?
5 A. Yes, it does.
6 Q. Is the church damaged or destroyed?
7 A. No single sign of damage is shown in the video.
8 Q. Does the video also depict the Serbian village of Omarska?
9 A. Yes, it did.
10 Q. That can be shown at the end of the video. What is the condition of
11 Omarska village?
12 A. That is intact; it has not been destroyed.
13 Q. Dr. Greve, after the Muslims and Croats of the Kozarac area were
14 rounded up and segregated, where were the men of that area taken?
15 A. The men were taken to two camps that were opened, one in Prijedor
16 City, which is the one that is referred to as "Keraterm", and the
17 other one just to the south of Omarska village, and that is referred
18 to as "Omarska".
19 Q. Was there a third camp in the area?
20 A. Yes, there was a third camp in the area and that is actually the
21 railway station for Kozarac. It is also called Trnopolje.
22 Q. If we could call up 2/35-2 on the computer screen, and could we have
23 a zoom on the Omarska area in the upper right-hand corner? Dr.
24 Greve, does this exhibit depict the location of Omarska village?
25 A. This is the central of Omarska village, according to the map, yes.
Page 1059
1 Q. If we could hand back the original of the exhibit, please? First of
2 all, I would like to tender that map as No. 108.
3 THE PRESIDING JUDGE: Any objection?
4 MR. ORIE: No objection.
5 THE PRESIDING JUDGE: Exhibit 108 will be admitted.
6 MR. TIEGER: Do I need to request for that to be printed? Thank you. (To
7 the witness): Just to orientate us here, Dr. Greve, as I look up on
8 the top portion of the map to the left side, does that show a small
9 corner of the fish farm you referred to earlier?
10 A. Yes, it is this one -- should there be an arrow? I do not know how I
11 make this -----
12 Q. You may want to return, if necessary, I am just trying to orientate
13 us according to the map we saw earlier that showed Prijedor and
14 Omarska which is Exhibit 79.
15 A. Here we see the village of Omarska which is linked again through to
16 the railroad that leads the whole way up to Prijedor, and we see the
17 lake, the fish farm, here.
18 Q. Is the location of the camp that was established in the Omarska area
19 depicted on this map?
20 A. To my understanding, it is not. It is two kilometres south of
21 Omarska village, and the scale of this map is that every square is
22 500 metre by 500 metre, so it is two kilometres to the south,
23 slightly to the west of Omarska city, I understand, or village.
24 Q. Is it located near any physical landmark?
25 A. Yes, it is located close to an open pit mine and there is an
Page 1060
1 extension of the iron ore mine, the Omarska extension of that mine.
2 Q. OK. If we return to Exhibit 108 -- let me ask you this question
3 first. The iron ore mine, I take it, that is located next to or in
4 the vicinity of iron ore or iron ore pits. Are those shown on the
5 map?
6 A. Yes, they are. I see that by accident I placed an arrow on the map,
7 that was just my ignorance, but if I can move this, there are open
8 pit mines in this area here. I may remind for convenience that this
9 is the second largest iron ore mine in Europe so it is quite a large
10 mine.
11 Q. The portion of the mine that was turned into a camp, what did that
12 consist of?
13 A. It consisted of an administrative area and a huge garage or, rather,
14 it was almost like a hangar. The compound as such had actually five
15 buildings; the one administrative building in which there was a
16 canteen and the first floor with offices; this huge garage which was
17 for maintenance of the heavy equipment used in the mine; a seemingly
18 a tiny little building which was the "white house" and then there was
19 another small building called the "red house" and a small pump
20 station.
21 Q. Who operated the camp?
22 A. It was called a military investigation centre. It was run in
23 co-operation between the police and the military, that is, the
24 Serbian police.
25 Q. Were only men taken to Omarska camp?
Page 1061
1 A. Primarily men, but there were 36, 37, 38 women in the camp.
2 Q. What age groups were taken to the camp?
3 A. This was with reference to women or with reference to the male?
4 Q. The overall population. Let us start with men.
5 A. The men were those between 12, 15 and 60, 65, essentially.
6 Q. When did Omarska begin to function as a detention camp?
7 A. It is referred to by the Serbs themselves as having operated from
8 25th May.
9 Q. Approximately how many people were held there at any given time?
10 A. The numbers have varied. I think it had an absolute maximum
11 capacity, somewhere about 3,000, 3300 perhaps.
12 Q. I would like to ask you some questions about the general conditions
13 of the camp, and the general conditions in which the prisoners there
14 were held. First of all, let me ask you about into what spaces the
15 prisoners were put, how much space was there for the prisoners who
16 were placed in areas or rooms of the former mine complex?
17 A.This varied over time but, initially,people were extremely cramped and,
18 that is to say, it is described as if they were sardines in a tin.
19 They would have to stand. They could not turn around and they would
20 stand like this for a few days.
21 Q. Were the prisoners provided with any bedding or blankets?
22 A. They were provided with nothing in terms of bedding and blankets.
23 Q. So they sat or slept on bare floors?
24 A. That is correct.
25 Q. How much food did the prisoners get?
Page 1062
1 A. They got food once a day, one-eighth of a bread is what they referred
2 to, and a ladle full of some soup-like fluid and possibly with some
3 cabbage or macaroni in it and some water.
4 Q. Was this a diet sufficient to sustain a person?
5 A. No, it was not.
6 Q. Were prisoners fed immediately upon arrival?
7 A. No, they would frequently face a period of three, four, five days
8 when they were only cramped in with no water and no food.
9 Q. How long did the camp operate, through portions of the summer of '92?
10 A. Yes, it was actually closed 5th/6th August, essentially, 1992.
11 Q. Is the summer hot in the Prijedor area?
12 A. The summer is said to be very hot in the Prijedor area, yes.
13 Q. How much water was available to the prisoners and what was the
14 quality of that water?
15 A. It was not pure water; it was water generally available in the mine
16 and it was very limited water made available to them. So all water
17 they had, essentially, went for drinking and no cleaning purposes.
18 Q. What about facilities for personal hygiene; were they provided?
19 A. There were very few such facilities. There were a few toilets which
20 were not sufficient.
21 Q. How did prisoners attend to their personal needs in that regard?
22 A. They would, essentially, be showed to the field.
23 Q. Could the prisoners leave their rooms when they needed to and use
24 whatever facilities were available for that purpose?
25 A. They could not.
Page 1063
1 Q. Over time did the prisoners begin to suffer from medical conditions?
2 A. Yes, they did; malnutrition, diarrhoea, lice, very soon different
3 diseases became rife, particularly it was very difficult to disinfect
4 any wound.
5 Q. Was regular medical care provided?
6 A. There was no regular medical care or medical care to any degree.
7 There were some prisoners who were doctors and they tended to fellow
8 prisoners if they could, but, essentially, with no implements, no
9 medicine, no disinfectant.
10 Q. Were interrogations conducted in the camp?
11 A. Yes, they were. I think that is also indicated by the main
12 intelligence centre.
13 THE PRESIDING JUDGE: Indicated by the main?
14 MR. TIEGER: I am sorry, could you repeat that? I think you were not
15 heard.
16 A. I mean, this was a military investigation centre, so if
17 investigations are carried out, it in a sense followed from that they
18 were likely to want to do some kind of question.
19 MR. TIEGER: In that connection, could I have Exhibit 92 presented to the
20 witness? (To the witness): Were interrogations conducted at all
21 three camps?
22 A. Yes, they were, but the tougher interrogations were in Omarska and
23 Keraterm where the men were held. I may just add, that some men
24 ended up in Keraterm, sorry, in Trnopolje, but it seems that was if
25 an individual Serb would help them, or if there were so cramped
Page 1064
1 conditions they could not possibly be put into one of the two other
2 camps. So, in principle, the males were taken to Keraterm and
3 Omarska.
4 Q. Did the Serbian officials have a designation or name for the
5 interrogations?
6 A. Yes, they referred to them as "informative talks".
7 Q. Was that in conversations with journalists and people from outside?
8 A. Yes, and in conversations with journalists and aid personnel and in
9 their own newspaper articles.
10 Q. Do we have an indication, according to the Serbian officials, at any
11 rate, how many informative talks were conducted in the camps in the
12 summer of 92?
13 A. According to Simo Drljaca, the head of the Serbian police, 6,000 such
14 talks were held in these camps.
15 Q. Can I ask you to display Exhibit 92 on the monitor looking at the
16 second paragraph from the bottom, the first sentence? That is an
17 interview with Simo Drljac?
18 A. That is again, yes, the one interview he gave when he had been
19 appointed to be Vice Minister.
20 Q. Indicating that more than 6,000 informative talks were held at the
21 three camps?
22 A. That is correct.
23 Q. He was the Chief of Police at this time ---
24 A. Yes, he was.
25 Q. -- at the time the camps were in operation?
Page 1065
1 A. Yes, for the entire length of that.
2 Q. Who was it that actually conducted the interrogations or informative
3 talks?
4 A. It was interrogators coming from outside and most of them belonged to
5 the police, but they would have people with them who would also be
6 army related personnel. It is said as being a military centre, but
7 some of the investigators, that is, came from the public security
8 office, the office of the police.
9 Q. In what manner were the interrogations conducted?
10 A. In very brutal manners.
11 JUDGE VOHRAH: Dr. Greve, could you speak a bit louder because I have
12 difficulty hearing. I believe Mr. Orie too has difficulty hearing.
13 A. I really apologise because ......
14 MR. TIEGER: I am sorry. I will repeat the question, your Honour. (To
15 the witness): In what manner were these interrogations conducted,
16 Dr. Greve?
17 A. In very brutal manner.
18 Q. Were prisoners beaten?
19 A. They were severely beaten.
20 Q. Were they tortured?
21 A. Many were severely tortured.
22 Q. Were the statements extracted from the prisoners during these
23 informative talks later used to justify both their imprisonment and
24 the cleansing of Prijedor?
25 A. Yes, they were.
Page 1066
1 Q. In that regard, can I ask you to look at Exhibit 91, to be presented
2 to the witness? Can page 2, the second full paragraph, be displayed
3 on the monitor? Dr. Greve, this issue of Kozarski Vjesnik contains
4 an account of how the first Chairman of the Serbian Municipal
5 Assembly of Prijedor, Dr. Milomir Stakic, saw the events?
6 A. That is correct.
7 Q. In that first sentence of the second paragraph does he indicate what
8 happened after the prisoners were taken into custody?
9 A. Yes, he is indicating that enough information was gathered from them
10 to conclude that the Muslims were very well organised and determined
11 to liquidate their fellow citizens, the Serbs.
12 Q. So after the prisoners were taken into custody, that information was
13 gathered, according to Mr. Stakic?
14 A. That is correct.
15 Q. Looking three sentences past that in the sentence which begins, "From
16 the interrogation records ... "?
17 A. It is claimed that they learned, the Serbs learned, that they,
18 meaning the non-Serbs, had intended to simultaneously take over power
19 and seize the barracks and with it the arms.
20 Q. What else was learned during those interrogation sessions, according
21 to Mr. Stakic?
22 A. Worst of all, according to him, the Serbs found out that the Muslims
23 had a detailed plan for the liquidation of the Serbian population of
24 Prijedor.
25 Q. So the interrogation records extracted from prisoners during these
Page 1067
1 brutal interrogations then produced the information that Mr. Stakic
2 was talking about?
3 A. That is my understanding.
4 Q. In addition to beatings during interrogation, Dr. Greve, were
5 prisoners subjected to physical abuse at other times?
6 A. Yes, they were. They were subjected to physical abuse when they went
7 to the canteen to get their food, when they could be beaten at any
8 one time, to the extent that prisoners, although they needed the food
9 badly, had to consider whether they were in a shape to go to fetch
10 their food.
11 Similarly, if they needed to relieve themselves, they had
12 to consider if it was safe to do that considering who were the guards
13 on duty because they were also subjected to beatings on such
14 occasions. A number of prisoners who at night-time slept in the
15 canteen would stay outdoor. It is called a pista. It is a concrete
16 platform between the administrative building and a huge garage. When
17 they were staying there, they could also be randomly subjected to
18 ill-treatment. Particularly at night-time, people would come to
19 where the prisoners were kept and ask for a few names and take them
20 out.
21 Q. This was just regular shift guards who subjected prisoners to such
22 beatings?
23 A. No. There were people from inside and outside the camp, police,
24 military, paramilitary, locals.
25 Q. Were any particular type of people, people from any particular
Page 1068
1 segment of society, more at risk in Omarksa than others?
2 A. Yes, for (1) it seems to have been the tendency that in Omarska the
3 upper echelons or the elite of the non-Serbian community was gathered
4 and, particularly, the elite, meaning people who held important
5 positions in the community, politicians and leaders, everything from
6 people who were good football players and onwards would be
7 particularly subjected to ill-treatment.
8 Q. Were any particular parts of the camp more dangerous for prisoners
9 than others?
10 A. The by far most dangerous part of the camp was the seemingly small
11 white house.
12 Q. What happened in the white house that made it more dangerous or were
13 special people put in the white house?
14 A. Well, people were frequently put in the white house upon
15 interrogation, if they had survived the interrogation, and they were
16 subjected to possibly the most extreme of the ill-treatment.
17 Q. What treatment were the women who were held in Omarska subjected to?
18 A. On one level they had better conditions than the male population.
19 However, for them the main problem was rapes at night-time, and it
20 happened almost all the time, it is being reported.
21 Q. Dr. Greve, were prisoners killed in Omarska?
22 A. Yes, a number of prisoners were killed in Omarska. It is difficult
23 to establish the exact numbers, but the fact that, according to Serb
24 officials, there were no large scale releases and considering the
25 numbers who were taken to the camp, it must have been a substantial
Page 1069
1 number.
2 Q. By "substantial" do you mean dozens, tens?
3 A. I would rather suggest thousand or more, but I am not in a position
4 to establish numbers.
5 Q. Were these killings of prisoners secret ---
6 A. No.
7 Q. -- kept by the prisoners?
8 A. No, they were not secret, that is to say, interrogation took place in
9 closed offices and the white house had closed doors and was a
10 compound on its own. However, dead prisoners would be left outside
11 so that other prisoners going to relieve themselves, going to fetch
12 their food or staying on the pista, that is, the concrete platform in
13 day time, would be able to see them.
14 Q. Was the camp a secret? Did local Serbian leaders know about it or
15 not know about it?
16 A. Yes, it was no secret.
17 Q. Did they ever visit the camp?
18 A. Yes, some of them did visit the camp.
19 Q. What about Simo Drljaca, the chief of police?
20 A. Yes, he did visit the camp.
21 Q. Did Serbian officials from outside opstina Prijedor visit the camp?
22 A. Yes, they did from Banja Luka. It is also my understanding that
23 Radio Televizija Banja Luka came to the camp.
24 Q. What about the ICRC or humanitarian organisations, were they able to
25 visit and inspect the camp during its operation?
Page 1070
1 A. As long as Omarska was operated this way that is being described now,
2 they never visited the camp. When it was being closed down and given
3 beautification or shined up for foreign journalists to come in, also
4 ICRC was entitled to come to the camp.
5 Q. When was the camp closed or when did it begin to close?
6 A. There was an article in the American press, 2nd August, and
7 subsequent to that it was an immediate effort made to close the
8 camp, transfer prisoners. It was basically closed on 5th and 6th
9 August 1992.
10 Q. When the camp's existence was made known to the western world, did
11 journalists try to enter the camp?
12 A. Immediately, yes.
13 Q. Were some journalists able to enter the camp around the time period
14 you have just mentioned?
15 A. Yes, but only after the main group of prisoners had been removed and
16 a lot of clean up had been made and then only to a very limited area
17 of the camp -- essentially the canteen.
18 Q. Were the majority of prisoners from Omarska transferred at that time,
19 end of the first week of August?
20 A. Yes, the vast majority or possibly they were left 100 or some more
21 than 100 but .....
22 Q. Where were they taken?
23 A. The majority was most probably taken to Manjaca. Manjaca is a camp
24 which is located in opstina Banja Luka, to my understanding. I have
25 not focused much on that particular camp, but it has been referred to
Page 1071
1 by the Serb authorities. But also maybe more than 1,000 were taken to
2 Trnopolje which was kept open after the time when Omarska was closed.
3 Q. Although I appreciate that you have not focused on Manjaca
4 extensively, do you know whether or not conditions in Manjaca were
5 the same as in Omarska?
6 A. It was far better. It was not that dangerous. It was the likelihood
7 of survival.
8 Q. Did some prisoners remain behind in Omarska after the majority of
9 prisoners were transferred?
10 A. Yes, as the camp was being showed to the international media, they
11 were the ones to be paraded.
12 Q. Were they responsible for cleaning up the camp and making it as
13 presentable as possible when the media came?
14 A. Yes, these men who were left behind, and also the women before they
15 were transferred, were asked to do some of the cleaning. Three women
16 were left behind initially, but when the press came it was denied
17 that there were any women in the camp and they had been taken out in
18 a car to Omarska at the time.
19 Q. Were Serbian officials connected with the operation of the camp
20 questioned about the nature of the camp after the journalists
21 discovered it?
22 A. Oh, yes, they were.
23 Q. Were they questioned, in particular, about whether or not prisoners
24 had been beaten or killed?
25 A. Yes, they were questioned about this.
Page 1072
1 THE PRESIDING JUDGE: When did you testify that you believed journalists
2 learned about the camp? You said that it was closed in August,
3 August 4th or 5th, I believe, 1992, and that would have been shortly
4 after they learned. So when do you believe that they first learned
5 about the camp and came to the camp?
6 A. The first article written about the issue which was well-known was
7 Roy Gutman's article published in Newsday, I believe, in the United
8 States, 2nd August 1992. Then things happened very, very quickly
9 because prior to that it had been alleged that camps existed, and now
10 pressure was put on Radovan Karadzic to let journalists into the
11 specific locations in Prijedor. So it happened very, very quickly, I
12 understand.
13 MR. TIEGER: May I have this marked for identification as Exhibit 109,
14 please? (To the witness): Dr. Greve, what is Exhibit 109?
15 A. This is a transcript from an interview where Stakic is making
16 statements concerning, inter alia, Omarska.
17 Q. I tender that for admission.
18 THE PRESIDING JUDGE: Any objection?
19 MR. ORIE: No objection, your Honour.
20 THE PRESIDING JUDGE: Exhibit 109 will be admitted.
21 MR. TIEGER: May that be displayed on the monitor, please?
22 (To the witness): First of all, does Milomir Stakic indicate at whose
23 direction or upon whose decision the camps were set up? I would
24 direct your -----
25 A. Yes, he does. In the second paragraph he is saying that this was
Page 1073
1 done at the decision -- on the decision of the Prijedor Civil
2 Authorities.
3 Q. Was Milomir Stakic asked about beatings in Omarska?
4 A. Yes he was.
5 Q. What did he say?
6 A. He is saying that, according to the information, there was no
7 maltreatment and physical violence in the centres themselves.
8 Q. Was he confronted about reports of killing in Omarska?
9 A. He was, and said, "There were cases, as the Commander in charge let
10 me know, of death which all have medical documentation which
11 testifies to that and not to murder".
12 Q. Does he indicate that he is referring to Omarska?
13 A. Yes, he does. He is particularly asked if this was in Omarska and he
14 confirms that.
15 Q. Does he say that in any event the number of prisoners who died of
16 natural causes was small?
17 A. Yes, he said that he is unable to say exactly, but it was not a large
18 number. He is asked again if it was not many people and he says, no.
19 Q. Was this denial of beatings in Omarska always consistently
20 maintained by the de facto officials of opstina Prijedor?
21 A. No.
22 Q. May I have this marked as Exhibit 110 for identification? (Document
23 handed). What is Exhibit 110, Dr. Greve?
24 A. It is again a transcript from an interview this time with Kovacevic.
25 Q. A member of Krizni Stab?
Page 1074
1 A. Yes, he was.
2 Q. And a member of the SDS?
3 A. Yes, he was or may still be, I do not know.
4 Q. In this interview is he also asked by Omarska and physical
5 mistreatment in Omarska?
6 A. Yes, he is.
7 MR. TIEGER: I tender that for admission, your Honour.
8 THE PRESIDING JUDGE: Any objection?
9 MR. ORIE: No objection.
10 THE PRESIDING JUDGE: Exhibit 110 will be admitted.
11 Mr. Tieger, you asked Dr. Greve if he was a member of
12 what? Chris?
13 MR. TIEGER: Krizni Stab or Crisis Staff.
14 THE WITNESS: That brings to mind that we have, perhaps, not focused on
15 the establishment of the Krizni Stab. I think we left that out. If
16 your Honours would like, I am happy to briefly describe that.
17 MR. TIEGER: It may be more convenient to finish this section of the
18 examination and pick it up after the break.
19 THE PRESIDING JUDGE: That is fine.
20 MR. TIEGER (To the witness): Can we focus on the bottom part of the page?
21 Is Mr. Kovacevic asked about the situation in Omarska and
22 investigations of Omarska?
23 A. Yes, he does.
24 Q. OK. Is he confronted by a reporter who was told that some men had
25 been investigated because of Omarska, some prison guards?
Page 1075
1 A. Yes.
2 Q. How does he respond to that?
3 A. He is saying that there were some mistakes. He accepts that some
4 mistakes have been discovered, and then he moves on to say that war
5 is war and some people got drunk, and then he is being interrupted by
6 the interpreter. And "Of course, we condemn it and we are working to
7 solve it. Some of the men have been imprisoned already".
8 Q. Does the reporter press on to find out how many people have been
9 imprisoned for mistakes in Omarska?
10 A. Yes.
11 Q. What does Kovacevic tell him on page 2 of that document?
12 A. He is saying that this is not his field of work. His field is
13 economy, and he does not know how many they are, but they do exist,
14 according to him.
15 Q. Was Mr. Kovacevic interviewed on another occasion about Omarska?
16 A. Yes, he is -- I think on many other occasions than this one.
17 MR. TIEGER: May I have this document marked as Exhibit 111 for
18 identification? (Document handed) (To the witness): What is
19 document 111, Dr. Greve?
20 A. It is again an interview where Mr. Kovacevic is answering questions.
21 Q. Is he answering questions about Omarska?
22 A. Yes, he is.
23 MR. TIEGER: I tender that for admission, your Honour.
24 THE PRESIDING JUDGE: Any objection?
25 MR. ORIE: No objection, your Honour.
Page 1076
1 THE PRESIDING JUDGE: Exhibit 111 will be admitted.
2 MR. TIEGER (To the witness): In this interview Mr. Kovacevic is asked
3 about how many people died on the Serbian side and how many on the
4 Muslim side?
5 A. That is correct.
6 Q. What is it that he starts talking about at that point?
7 A. At this point he makes a reference to Jasenovac which was mentioned
8 yesterday as being the most notorious of the death camps during World
9 War II located in Croatia. Here a comparison is made with Auschwitz.
10 Q. Does he indicate that it is impossible to know even at this late date
11 exactly how many people, Serbs in that case, were murdered in
12 Jasenovac?
13 A. Yes, he is indicating that even after 50 years they are still unable
14 to say how many people were killed in Jasenovac.
15 Q. In the question of how many people were killed, in this interview,
16 does Mr. Kovacevic spontaneously raise the issue of the deaths camps
17 to explain why it is so difficult to approximate numbers or estimate
18 numbers?
19 A. Yes, it is his comparison.
20 MR. TIEGER: We are just about to show the video, your Honour, but it is
21 all three clips, it will probably consume about 10 minutes.
22 THE PRESIDING JUDGE: Then we will stand in recess for 20 minutes, please.
23 (4.00 p.m.)
24 (Short Adjournment)
25 (4.20 p.m.)
Page 1077
1 THE PRESIDING JUDGE: Mr. Tieger?
2 MR. TIEGER: Thank you, your Honour. Just before the recess we were about
3 to play the video clips from which the transcripts were taken.
4 Before that is played, can we give the court three copies of those
5 transcript exhibits? (Documents handed) Your Honour, are they
6 marked by an exhibit number?
7 THE PRESIDING JUDGE: At the top upper right-hand corner they have your
8 numbering, I think, whatever, 4/227. I see. I have Exhibit 110, 111
9 and then a page with nothing, 109.
10 MR. TIEGER: There were stickers on them before. The order should be a
11 one page interview with Stakic, a two-page interview with Kovacevic
12 and then a small, single paragraph or a brief interview with
13 Kovacevic again. Can we then show tape clips 2, 3 and 4?
14 (Tape clips 2, 3 and 4 were played).
15 Can you play No. 4, please?
16 Thank you. Your Honour, I tender document the video as
17 No. 112 in evidence.
18 THE PRESIDING JUDGE: Any objection to 112?
19 MR. ORIE: No objections, your Honour.
20 THE PRESIDING JUDGE: Exhibit 112 will be admitted.
21 MR. TIEGER (To the witness): Dr. Greve, you mentioned that some of the
22 Serbian officials we saw were members of the Crisis Staff. Could you
23 tell the court whether or not the Crisis Staff was an organ of the de
24 facto Serbian government in opstina Prijedor?
25 A. Yes, in opstina, in Srpska opstina Prijedor, the Crisis Staff was
Page 1078
1 sort of the Crisis Headquarters. It was composed of the leading
2 military people, the head of the police and the leading members of
3 the SDA, in addition, one of the directors of the mine, key people,
4 that is, from different aspects of society to make it possible to
5 co-operate closely.
6 Q. Dr. Greve, you mentioned that those persons who were rounded up after
7 the attack on Kozarac were sent to Omarska, Keraterm and Trnpolje
8 depending upon sex and perhaps other factors. Where was Keraterm
9 located?
10 A. Keraterm is located within the town of Prijedor. It is within the
11 vicinity of the town centre. It is this former ceramic tiles
12 factory.
13 Q. Perhaps you could show us on Exhibit 79?
14 A. This is the clay -- it is called on the map "clay production plant".
15 It is located here, in the main buildings here.
16 Q. Was it established and run by the same authorities who established
17 and operated Omarska camp?
18 A. That is my understanding, yes.
19 Q. Approximately how many Muslims or Croats or non-Serbs were held in
20 Keraterm plant at any given time?
21 A. At a maximum, approximately 1,500. May I also say that there were the
22 occasional Serb who was taken to Omarska and Keraterm if they tried
23 specifically to assist their non-Serbian fellows.
24 Q. Were the conditions in Keraterm camp, the crowding, the lack of food
25 and absence of hygiene and sanitary facilities, similar to those you
Page 1079
1 have described briefly in Omarska?
2 A. More or less the same, yes.
3 Q. Were prisoners also beaten and killed in Keraterm?
4 A. They were.
5 Q. Were there any incidents in which particularly large numbers of
6 prisoners were killed at any one time?
7 A. Yes, there was one particular incident. In this camp, it is one main
8 building and there are different halls, one called hall No. 3. The
9 night between 25th and 26th of July, it is believed that at least 150
10 people were machine gunned down in the night, and when their dead
11 bodies were removed, the wounded were taken out with the dead, and
12 possibly it could have been numbers like 60 or 80 wounded among them.
13 That is indicated on -- I am not exactly sure of the numbers, but
14 this was an event which was given much attention. It was considered
15 a massacre. I would like to draw your attention to the fact that
16 there is the main road running just by this camp, so actually people
17 could see from the main road, look into, not the inside of the camp,
18 but at least the camp compound, and roads were blocked following this
19 incident as the cleaning up was taking place.
20 Q. Were other prisoners who were killed in Keraterm murdered by bullet
21 in the same way or were there other forms of killing?
22 A. I think that the rest of those killed were mainly killed by beatings
23 or stabbings or a combination of this, not so much by bullets.
24 Q. Can you show us where Trnopolje camp is located, please?
25 A. Actually, on this map Trnopolje is not listed by name, but as Stanica
Page 1080
1 Kozarac, that is to say, the station of Kozarac, but it is also --
2 the village of Trnopolje, it is also located here.
3 Q. Was Trnopolje camp run by the same authorities whom you referred to
4 earlier?
5 A. Essentially, yes, but also the by then Serbian local Red Cross played
6 an important role in running of this camp.
7 Q. Who was the head of Trnopolje camp?
8 A. It is the man previously referred to as head of the TO, SDS member,
9 Slobodan Kurozovic.
10 Q. That is the man who later was placed in charge of some aspect of
11 Kozarski Vjesnik?
12 A. That is correct.
13 Q. Did the function of Trnopolje camp differ in any way from that of
14 Omarska and Keraterm?
15 A. Yes, it did; its main function was to be a staging area for
16 deportations,so in this respect it is conveniently located next to
17 the railroad station.
18 Q. Who was held in Trnopolje camp?
19 A. This was what briefly may be called the women's group with the
20 children and the elderly men.
21 Q. In general, how were conditions in Trnopolje compared to Omarska and
22 Keraterm?
23 A. Much, much, much better. But still it was a concentration camp and
24 there were many difficulties.
25 Q. Was there physical abuse of prisoners from Trnopolje?
Page 1081
1 A. Yes, there was.
2 Q. Of what type?
3 A. Again, beatings, some arbitrary killings and for the women rape was
4 the perhaps most important problem.
5 Q. Can you return to Omarska and Keraterm camps for a moment? Is there
6 any indication what was intended for the prisoners of Omarska and
7 Keraterm had the international press not discovered and exposed those
8 camps?
9 A. Yes, I think it is indicated well by the head of police, Simo
10 Drljaca, once again in the interview he gave, because at that time in
11 April of 1993 he is indicating that it was only due to pressure from
12 the western world that those whom he labelled extremists,
13 fundamentalists, etc. did not got their right punishment, indicated
14 that would be the most severe punishment possible, or existing.
15 Q. Can I direct your attention to Exhibit 92, please? Looking at the
16 second to last paragraph -- first of all, is this an interview with
17 Simo Drljaca?
18 A. That is correct.
19 Q. Does he indicate in his interview that more than 1500 Muslims and
20 Croats had been proven through proper documentation to have actively
21 participated in conflicts against the army of the Serb Republic?
22 A. That is correct.
23 Q. In the context of this article and other statements from Serbian
24 officials, does that proper documentation refer to the
25 interrogations, the "informative talks"?
Page 1082
1 A. Yes, it does. It is also listed two lines above.
2 Q. Based on those "informative talks" and the information extracted from
3 them, what other crimes were these 1500 Muslims and Croats believed
4 to be guilty of by Simo Drljaca?
5 A. Participating in the genocide of the Serb people.
6 Q. Does he complain that Serb officials were not permitted to impose
7 just punishment on those Muslims and Croats who had been proven to
8 have participated in genocide?
9 A. I read the last sentence to state that, yes. The last sentence in
10 the paragraph, that is, "Instead of receiving their just punishment,
11 the white world mighty men forced us to release them all from
12 Manjaca".
13 Q. Thank you. By the time the camp was discovered and prisoners were
14 transferred to Manjaca and Trnopolje from Omarska, what were their
15 physical states by that time, in general?
16 A. People had lost considerable weight. As we will come back to, there
17 were two main occasions on which males were brought to Omarska and
18 Keraterm. It was after the attack on the Kozarac area and the
19 immediate following attack on Prijedor town, and it was in late July,
20 after 20th July, when the Ljubija area became surrounded and attacked
21 and ethnically cleansed, so-called. That is, some people had been in
22 the camps since late May/early June and many of them had lost weight,
23 20 or 30 kilos, or even more.
24 MR. TIEGER: I would like to tender a photograph for admission which has
25 been presented to the Defence. It is No. 113. It is photo 5/1/04.
Page 1083
1 MR. ORIE: No objections, your Honour.
2 THE PRESIDING JUDGE: Exhibit 113, there is no objection to Exhibit 113?
3 That will be admitted.
4 MR. TIEGER: Can that be displayed on the elmo, please?
5 (To the witness): Dr. Greve, is that a photo of a prisoner who had
6 recently been released from Omarska by the time the photo was taken?
7 A. I do not know if it is correct to say "released". He had been
8 transferred to Trnopolje but he had been a detainee of Omarska.
9 Q. This depicts his condition immediately or shortly after his transfer
10 from Omarska?
11 A. That is correct.
12 Q. I had asked you about the difference in the primary function of the
13 camps in Omarska, Keraterm and Trnopolje. You indicated that
14 Trnopolje camp served the function of
15 deportation centre as well. What happened to the majority of the
16 prisoners who were held at the Trnopolje camp?
17 A. The majority were deported out from opstina Srpska, opstina Prijedor.
18 Q. Through what means were they deported?
19 A. I am not able to say if the majority were deported by rail or road,
20 but these were the two main used. It is reported that up to 25
21 cattle wagons at a time would be placed at the railway station in
22 Banja Luka when in transit. So at least a large number did leave by
23 rail and, essentially, by cattle wagons -- like it was used during
24 deportations in World War II in Europe.
25 THE WITNESS: May I have this marked for identification as Exhibit 114?
Page 1084
1 (Document handed). (To the witness): Dr. Greve, what is this
2 document?
3 A. This is a communication to the press by the International Committee
4 of the Red Cross. It is dated 2nd October 1992.
5 MR. TIEGER: I tender document 114 for admission.
6 THE PRESIDING JUDGE: Any objection?
7 MR. ORIE: No objection, your Honour.
8 THE PRESIDING JUDGE: Exhibit 114 will be admitted.
9 MR. TIEGER (To the witness): Dr. Greve, does Exhibit 114 reflect one of
10 the evacuations of prisoners from Trnopolje camp?
11 A. Yes, and now we have moved on in time, that is to say, that this is
12 an evacuation; it is not a deportation. This is the time when the
13 International Committee of the Red Cross has been granted access to
14 some camps, including Trnopolje, and they are asking to be entitled
15 to evacuate people out, among them a number of those who had been
16 released also from previously from Omarska and Keraterm.
17 Q. Was the release of prisoners from Trnopolje either by deportation in
18 the earlier stage or by evacuation once the ICRC conditioned on the
19 relinquishment of anything by the prisoners?
20 A. Yes, they had to sign a special document where they relinquished all
21 their material goods, moreover agreed not to return to Srpska opstina
22 Prijedor.
23 MR. TIEGER: May I have this document marked as 115 for identification?
24 (Document handed). (To the witness): What is that document, Dr.
25 Greve?
Page 1085
1 A. It is a quote of article 11 from an agreement on the release and
2 transfer of prisoners which was made on 1st October 1992. The quote
3 as such was included in my study, but it is taken, I had at that time
4 the original agreement -- that is a photocopy of the original
5 agreement -- at hand.
6 MR. TIEGER: We tender document 115 for admission.
7 THE PRESIDING JUDGE: Any objection?
8 MR. ORIE: No objection, your Honour.
9 THE PRESIDING JUDGE: 115 will be admitted.
10 MR. ORIE: We have difficulties in keeping track of the -- would there be
11 a copy available for us because we cannot trace this exhibit at this
12 moment? (Document handed) Thank you, your Honour.
13 THE PRESIDING JUDGE: No objection to 115?
14 MR. ORIE: Still no objection, your Honour.
15 THE PRESIDING JUDGE: It is still admitted then.
16 MR. TIEGER (To the witness): Dr. Greve, referring to 115, Article 11 is
17 an agreement reached with which parties?
18 A. It is suggested and proposed by the International Committee of the
19 Red Cross. It is entered into and signed by the different parties
20 participating in the conflict in Bosnia-Herzegovina. That is also a
21 representative of Radovan Karadzic.
22 Q. Does Article 11 reflect an understanding by ICRC officials that the
23 release of prisoners from Trnopolje camp was dependent upon their
24 giving up property voluntarily, and any right of return voluntarily?
25 A. I do not know whether the understanding of the ICRC is linked to what
Page 1086
1 they had experienced by then in Trnpolje or if it is based on their
2 general understanding of what was happening, because it was a
3 practice which we have come across, the Commission of experts came
4 across, all over Bosnia-Herzegovina where areas were ethnically
5 cleansed. Possibly the ICRC could build on information from any one
6 area in this respect. But it speaks to the fact that ICRC was aware
7 that two categories of people, prisoners who were to be released or
8 transferred and civilians, would be asked to sign this kind of
9 document.
10 Q. OK, so this practice was not limited to Trnopolje camp?
11 A. No, it was not.
12 Q. Article 11 reflects a general understanding of the use of that
13 practice in camps throughout Bosnia
14 A. At least it reflects this as being a widespread problem and it
15 is general in the way it is made, yes.
16 Q. Did prisoners in Trnopolje execute such documents in order to be
17 released?
18 A. Yes, and they were also advised to do so by ICRC because it was a
19 precondition for leaving, so the International Committee of the Red
20 Cross actually advised people to sign in order to get out.
21 Q. Did all of those who were deported from Trnopolje during its
22 operation for the ICRC intervention make it to safety after they left
23 the camp?
24 A. No, they did not. There were two main obstacles. It was the
25 conditions during transportation, the lack of fresh air, water and
Page 1087
1 food, it could take some days, and the least healthy ones would not
2 always make it, babies, elderly people. At the end of the transport,
3 the deportees would normally be asked to continue walking and
4 frequently they would have to cross the frontline which was mined and
5 there would be shooting above their heads and occasionally at a group
6 of people walking.
7 Q. Were there any particular incidents in which large numbers of
8 deported prisoners or evacuated prisoners did not make it to safety?
9 A. Yes, there is one particular incident in which it may, perhaps, be
10 useful, if I may suggest so, to have back again the general map of
11 Bosnia-Herzegovina so that it could be pointed out in which direction
12 the peoples were moved?
13 Q. Certainly. If we could have Exhibit 78 shown to the witness?
14 A. As can be seen on this map, from Prijedor the railroad goes to Banja
15 Luka and it continues the way to Doboj, and from this area it
16 continues further down. Frequently people were just taken by rail a
17 little further on from Doboj and then asked to proceed on foot in the
18 direction -- I am sorry, I need to read the map more carefully. Some
19 would move towards Tuzla, others would move towards Zenica. In the
20 direction of Zenica, however, people were also deported by road, and
21 then they will go from Banja Luka on the road in the direction of
22 Zenica and/or rather to Travnik first. These were areas in Central
23 Bosnia controlled by the government of Bosnia-Herzegovina at the
24 time.
25 When moving down on road, you will see a place called
Page 1088
1 Skender Vakuf -- it was also pointed out as being an opstina -- and
2 the road moves on, and a little further to the south and east of
3 Skender Vakuf, there is a mountain called Vlasic. On this mountain,
4 22nd about of August, as I seem to remember, possibly some 250 or 300
5 males deported by road were taken out of the column of deportation
6 vehicles and moved up on the mountain, the prisoners or the
7 deportees. These were, essentially, people who had been detained in
8 Keraterm, some in Omarska. They were asked to move out and on to the
9 edge of a cliff, to kneel down and were shot down. Very few, maybe
10 four, five, six, that we have been able to trace, survived.
11 But this incident is also, to some extent, documented by
12 the fact that it took place outside of opstina Prijedor and the
13 military Commander, the Serb military Commander, in the place where
14 it happened was not pleased to have this number of prisoners killed
15 within his area of responsibility. So, they were virtually all shot
16 down at the side of the cliff, down the cliff.
17 Q. Dr. Greve, you indicated that these camps were put in active
18 operation after the attack on Kozarac which occurred on May 24th.
19 Did the cleansing of the Muslim and Croat communities of opstina
20 Prijedor end with the attack and collection of citizens from Kozarac?
21 A. No, it did not, and one may also add that it did not only start with
22 the attack on Kozarac, because at the same time, from mid May 1992,
23 some members of the elite were individually rounded up and sorted out
24 in Prijedor town as well and when the main cleansing had taken place
25 in the Kozarac area, it continued for some time as some people had
Page 1089
1 been able to hide in some shelters in nearby small villages and
2 hamlets, but their fate was no better than that of the others.
3 Possibly, the killings of those who were not rounded up immediately,
4 more of them possibly percentage-wise were killed.
5 Q. In Prijedor town itself, or within the opstina, was there any
6 coordinated act of resistance against the coup leaders in the
7 takeover of the town?
8 A. Not from within Prijedor town, but if I may exchange the maps?
9 THE PRESIDING JUDGE: Which one do you want to put on?
10 MR. TIEGER: I think you need Exhibit 79.
11 THE PRESIDING JUDGE: 79?
12 MR. TIEGER: Yes, I believe 79 is the map which the court has copies of.
13 A. On this map we have Prijedor town and we have the Sana River and we
14 have the left bank of the Sana River. We have the village Hambarine
15 which was attacked prior to Kozarac, and we have a forested area
16 called Kurevo to which some people had been retreating. Among them
17 were some people who organised an armed resistance led by a Croat
18 named Slavko Ecimovic who later died in Omarska. Approximately
19 150-strong this group launched an attack on Prijedor town to regain
20 power from the Serbs.
21 Q. How successful was that attack?
22 A. That attack was without any success at all. That is, maybe they
23 thought they would have support from within Prijedor, but they had no
24 support. They were not well-armed and they were routed and driven
25 out again, some killed within a few hours. They came through across
Page 1090
1 the Sana River and then through the old part which is called Stari
2 Grad of Prijedor town.
3 Q. May I direct your attention to Exhibit 93? Looking at the bottom of
4 Exhibit 93, does it refer to the effort by these 150 or so people to
5 regain Prijedor?
6 A. Yes, it does. They are being referred to as green berets which
7 again is a reference to Muslim military or paramilitary units.
8 Q. You indicated that the people who carried out the attack were not
9 particularly well-armed. Did they have any heavy weapons, any
10 armour, any artillery?
11 A. No, they did not have anything but handguns, machine guns and
12 possibly some grenades, possibly grenade launches, but they had no
13 artillery or any heavy equipment.
14 Q. Were all of them armed?
15 A. Not all of them were armed.
16 Q. Why was that?
17 A. As they could not find the needed number of arms, and also most
18 probably because they thought when coming into town possibly some of
19 them would be able to assist them, that they might be able to kindle
20 some kind of rebellion, but that was not possible.
21 Q. According to the Serbian authorities, how long did it take to defeat
22 these 150 poorly armed people?
23 A. Several hours.
24 Q. Then the attack was over?
25 A. Then the attack was over, from the attackers' side that is.
Page 1091
1 Q. OK. Were announcements made on Radio Prijedor about the attack?
2 A. Yes, announcements were made in the early morning on Radio Prijedor,
3 essentially telling the people to stay indoors, to keep calm and not
4 be afraid because this would soon be controlled by the Serbian
5 authorities.
6 Q. Were Muslims or Croats of Prijedor advised to do anything?
7 A. Yes, they were advised to put up sheets of white material, blankets
8 or whatever they would find, to mark their house and to indicate
9 that they had surrendered or were loyal to the Serb authorities in
10 Prijedor town.
11 Q. What happened in portions of Prijedor that day after Muslim and Croat
12 citizens, or at least those who received the word, put white flags
13 out of their windows to identify their homes?
14 A. A number of quarters in Prijedor were this very morning ethnically
15 cleansed, that is, the incoming Serb armed groups, army paramilitary,
16 police and locals, would after having reported the attackers go on
17 and ask all non-Serbs living in houses that had been marked in this
18 manner to come out into the streets, and again they would subdivide
19 them into these two categories: the male group between 12-15, 60-65,
20 and the women's group, who were the children and the elderly men.
21 They would move them then on, men again to Keraterm and Omarska, and
22 women to Trnopolje. I should perhaps add that at this time it was so
23 cramped everywhere that it was very difficult to find room for
24 people. So some of the women's group were taken to a gymnasium, a
25 sports hall, Mladost, in the city itself which also served as a
Page 1092
1 staging area. Others were initially detained in schools just for
2 there to be enough space in the three camps proper for the different
3 categories.
4 Q. Were any portions of the Prijedor town destroyed?
5 A. Yes, the one portion that was particularly destroyed was the Stari
6 Grad, meaning the old city, and the old city is located next to the
7 Sana River and then it is on all other sides surrounded by a canal.
8 It is said to have had particularly old, beautiful and Muslim
9 dominated architecture, and it was almost raised to the ground.
10 Reportedly there were afterwards only a few buildings left. But not
11 all the buildings were destroyed in the attack. It was followed up
12 later, being raised to the ground.
13 Q. Did the cleansing of Muslims and Croats continue in other parts of
14 the opstina?
15 A. Yes, it did continue. I should hasten to add that in this period
16 after Kozarac region had been cleansed and the town of Prijedor had
17 been cleansed, I believe, if for nothing else, logistical purposes it
18 was impossible to take on cleansing of further areas immediately.
19 But cleansing went on in villages, hamlets, separate houses in the
20 manner that they would come to a house, arrest an individual and they
21 would put very hard pressure on the remaining population. This was
22 the time when they were also asked to wear a white arm band to
23 distinguish themselves when they went out to the streets. Virtually
24 any Serb could go to a home of any non-Serb and demand whatever they
25 liked, be it property, be it for the women to join them. No one had
Page 1093
1 any protection, legally speaking, any more if they were non-Serbs.
2 Q. Were and where did the last major cleansing take place?
3 A. The last major cleansing was concentrated on the one remaining main
4 area with non-Serbian population, that is the Ljubija area, the
5 Hambarine area, the Kurevo forest. All that is on the west bank of
6 the Sana River.
7 Q. Can we show Dr. Greve Exhibit 79 again.
8 A. This again is the Sana River. This is the left bank of the Sana
9 River. This is Ljubija. This is Hambarine. I should also perhaps
10 point out some other names that you will probably hear again from
11 witnesses: Rakovcani, Ecimovic, Biscani and Carakovo. This entire
12 area is frequently referred to as "Brdo" meaning mountain. It is a
13 mountainous forested area. Ljubija is again one large extension of
14 this main mining complex.
15 Q. Approximately how many non-Serbs were in the area when this last
16 major cleansing took place?
17 A. It is estimated to have been approximately 20,000 altogether. I
18 should add that moving south of Ljubija we still have some part of
19 opstina Prijedor, and these were areas essentially inhabited by
20 Croats. There were only 5.6 per cent Croats in the opstina according
21 to the census of 1991, and many of them were living in the Ljubija
22 area and to its south.
23 Q. If I can have the elmo panned back in the direction of the area
24 between Prijedor and Kozarac. I would like to move you
25 chronologically through the period of time which you have described
Page 1094
1 this afternoon leading up to the last major cleansing in the
2 Hambarine area. You already indicated that the first attack took
3 place in Hambarine and then the next day moved on to the Kozarac area
4 which is depicted here. Did some of the residents of the Kozarac
5 region, which included that broader area you showed us, flee in
6 various directions?
7 A. Yes, they tried to flee in various directions, but it was again
8 extremely difficult for them to get out. Some were eventually
9 rounded up as they tried to climb the mountain and get over it to the
10 northern side of the Kozara mountain. Some were actually also
11 rounded up by UN and handed over to the Serbs. Some of them tried to
12 go into other areas. When it was cramped in Trnopolje at one point
13 it was decided that some of the women and children could go out again
14 and stay with relatives. Some of these relatives lived in a
15 predominantly Muslim suburb to Prijedor named Puharska and others
16 would go to a village named Cela which is across the fish lake, fish
17 farm from Kozara, and a number may have also tried to get into
18 Ljubija area. But their freedom of movement was severely restricted
19 at this time.
20 Q. Over the succeeding weeks following the attack on Kozarac, was the
21 area systematically cleansed of Muslims and Croats piece by piece and
22 village by village?
23 A. Almost house by house, yes.
24 Q. That would include the area we see south of Kozarac?
25 A. It would include all the areas that we see here. When we come over
Page 1095
1 to, for instance, the area of Orlovci or in this direction we find
2 more Serb dominated areas, but essentially it may be said that every
3 single village and hamlet and settlement was cleansed for the
4 non-Serbs. It should also be mentioned that before the main attack
5 on the Kozarac area and later on the left bank of the River Sana and
6 also before Stari Grad was attacked by the Muslims, the Serbs one way
7 or another had been alerted and were out or primarily out. Of course
8 there were the occasional people who did not want to move.
9 THE PRESIDING JUDGE: Dr. Greve, just for the record, what do you mean by
10 "cleansed"?
11 A. I may perhaps, first of all, apologise for using this term. It is a
12 euphemism. "Ethnically cleansed" means by armed force or violence,
13 being rounded up. If one survives this rounding up, it means being
14 transferred to camps such as Omarska or Keraterm for the males and
15 for the women to be ready for deportation. It means there is no room
16 for them any more in Srpska opstina Prijedor.
17 MR. TIEGER: During this period of time from May 24th, actually from May
18 23rd until the attack on the Hambarine area in July, did some people
19 attempt to flee in the direction of the Hambarine area?
20 A. Yes, they did.
21 Q. Then when did this last major attack take place?
22 A. It started on 20th July 1992.
23 Q. How did that attack begin?
24 A. Again the area was bombarded and then it obviously had been
25 surrounded as troops were moving in from all their front directions.
Page 1096
1 With "troops" I refer to ordinary military forces, Reserve troops as
2 well. I refer to paramilitary groups. I refer to police units and
3 Reserve Police and I refer to some occasional local Serbs.
4 Q. After the bombardment, that is when those units moved in?
5 A. That is when those units moved in.
6 Q. Did this cleansing action differ in any respect from those which had
7 preceded it in Hambarine in May and in Kozarac in May and in the
8 smaller cleansings that followed
9 A.It is difficult to establish exactly,but possible on-the-spot
10 killing was happening to a
11 larger extent in this last killing, excuse me, than in these
12 previous cleansing operations. I do not know if it has anything
13 to do with the fact that there were still many prisoners both in
14 Omarska and in Keraterm, and now when they had rounded up prisoners
15 they seem to find no place to put them. So there are reported bus
16 loads of killings.
17 JUDGE STEPHEN: I am not clear in what area this happened.
18 MR. TIEGER: Sorry, your Honour. If we can refer back to Exhibit 79. I
19 apologise for departing from the map.
20 Dr. Greve, you had indicated Kozarac and then the areas
21 of the intermittent and systematic cleansings which took place
22 thereafter. Now you have just been discussing the last major
23 cleansing. Can you direct the court's attention to where that took
24 place?
25 A. Yes. This is in the Hambarine-Ljubija area. It is on the left bank.
Page 1097
1 Maybe we can have some details of the map, first to the north of
2 Hambarine. Actually, everything from Prijedor and up in this
3 direction, or actually on the left bank of the River Sana, there is
4 another area which is cleansed in smaller operations later, and that
5 is on the east bank of the River Sana and the fish pond. But at this
6 time it is from Prijedor town up to approximately this Biscani,
7 Hedici and down again all over the Ljubija area and all the areas
8 between the River Sana and the roads. This is the main road. This
9 is the main road leading down to Sanski Most. It is also known that
10 troops, the 6th Sana Brigade, for instance, came from Sanski Most to
11 participate in this cleansing operation.
12 Q. Where were those Muslims and Croats who survived the shelling or the
13 invasion of troops taken after that?
14 A. The male groups were taken to Keraterm and Omarska. The women's
15 group, children and elderly men, were taken to Trnopolje. Some may
16 have been deported straight from an athletic field that was to be
17 built in Tukovi which is a suburb to Prijedor town on the left bank
18 of the River Sana.
19 Q. Ultimately, if they survived the camps, to be deported from opstina
20 Prijedor?
21 A. That is correct.
22 Q. You mentioned one of the contingents of military forces which
23 participated in the last cleansing action against Hambarine. I would
24 like to ask you about some of the military forces which participated
25 in the cleansings which you have described in Kozarac and Hambarine
Page 1098
1 and so on. Can we learn from Serbian officials themselves some of
2 the military units which participated in these cleansings?
3 A. Yes, we can as they are celebrating this later.
4 Q. In that regard I would like to direct your attention to this exhibit
5 which I would ask to be marked as No. 116 for identification what is
6 this document, Dr. Greve?
7 A. It is again a newspaper article from Kozarski Vjesnik dated 20th May
8 1994. It is headlined: "To the Pride and Honour of the Fatherland".
9 Q. Is that an article which occurs in honour or which is written in
10 honour of the day of 43rd Prijedor Motorized Brigade?
11 A. That is correct.
12 Q. We tender this document for admission.
13 THE PRESIDING JUDGE: Any objection?
14 MR. ORIE: No objection, your Honour.
15 THE PRESIDING JUDGE: Exhibit 116 will be admitted.
16 MR. TIEGER: Dr. Greve, turning to page 3, the second paragraph, does the
17 article indicate where the 43rd Motorized Brigade participated in
18 actions in opstina Prijedor?
19 A. Yes, it does. It refers to Prijedor which, from the context, must be
20 the town of Prijedor, Kozarac, Kurevo, the forested area on the left
21 bank of the River Sana that is, Panjik, Hambarine and what is
22 referred to as other Mujaheddin strongholds.
23 Q. Did units of the 43rd also participate with other contingents of the
24 Serb military forces in other clensings?
25 A. Yes, it is referred to participation in Novi Grad, Kljuc, Sanski Most
Page 1099
1 and Krupa on the River Una.
2 Q. Along with what other military units?
3 A. The 5th Kozara and the 6th Krajina. The 6th Krajina is the same as I
4 previously referred to as the 6th Sana. It had its headquarters in
5 Sanski Most which is the opstina and the town to the south of
6 Prijedor.
7 Q. May I now direct your attention to this document which I would ask to
8 be marked as No. 117 for identification.
9 A. Maybe before we move I may also point out that in the next paragraph
10 there is a reference to 5th Kozara and 6th Grmec. It is my
11 understanding that the headquarters or a headquarters of the above
12 mentioned 6th Krajina is at the plateau of a small mountain called
13 Grmec, meaning that it is the same unit as it is referred to call 6th
14 Grmec and 6th Krajina.
15 Q. Dr. Greve, what is this document?
16 A. This again is a newspaper article from Kozarski Vjesnik, dated 6th
17 August 1994: Persistent in the defence of Serbian people, the war
18 path of the 5th Kozarac Brigade.
19 Q. I tender this for admission.
20 THE PRESIDING JUDGE: Any objection to 117?
21 MR. ORIE: No objection.
22 MR. TIEGER: Dr. Greve, as you indicated, this is an article on the war
23 path of the 5th Kozara Brigade?
24 A. That is correct.
25 Q. Does the article indicate why the 5th Kozarac Brigade will be
Page 1100
1 created?
2 THE PRESIDING JUDGE: Excuse me, is there any objection to 117?
3 MR. ORIE: There is no objection, your Honour.
4 THE PRESIDING JUDGE: 117 will be admitted. Do you want to repeat the
5 question?
6 MR. TIEGER: Dr. Greve, is there any indication why the 5th Kozara Brigade
7 had been created?
8 A. Yes. It is in the first paragraph. It is specifically stated that
9 the 5th Kozara Brigade had been created as a territorial formation
10 within the army forces of the former Yugoslavia to carry out the
11 warfare in the region of Prijedor municipality.
12 Q. Does the article indicate further down on that page where the 5th
13 Kozara Brigade conducted its operations? If I could direct your
14 attention to the last section of that first major paragraph.
15 A. The troops and the commanding officers contributed a great deal
16 towards the preparations of the Serbs to take control in Prijedor, as
17 well as during cleansing of the town from the Muslim fundamentalists.
18 Q. When does the article indicate that the 5th Kozara Brigade
19 successfully completed its combat operations at Prijedor?
20 A. On 1st August 1992 as it could then move on to other obligations.
21 Q. The cleansing operations were largely completed at that point?
22 A. That is correct.
23 Q. May I have this document marked as Exhibit 118 for identification,
24 please? What is this document, Dr. Greve?
25 A. This is again an article in Kozarski Vjesnik, dated 29th July 1994.
Page 1101
1 It has the headline: "The Brigade of a long and honourable war path,
2 a war path of the 5th Kozara Brigade, immense contribution to the
3 freedom."
4 Q. I would tender this document for admission.
5 THE PRESIDING JUDGE: Any objection?
6 MR. ORIE: No objection, your Honour.
7 THE PRESIDING JUDGE: Exhibit 118 will be admitted.
8 MR. TIEGER: Dr. Greve, may I direct your attention to the fourth page of
9 this article, the last paragraph? Does that indicate where the 5th
10 Kozara Brigade participated in the cleansings and with what other
11 units?
12 A. Under the headline "20th May 1992" it is referred that, "The Assembly
13 in the village of Jaruge Prijedor of the first battalion consisting
14 of the troops from Slavonia and some new recruits. Subsequent
15 involvement in the battles for liberation of the villages of Kozarac
16 in a joint operation with the first battalion of the 43rd Transport
17 Brigade and parts of the 2nd Battalion of our Brigade previously
18 gathered in the village of Gornji Garevci", that is a Serb dominated
19 village.
20 MR. TIEGER: Your Honours, does the court wish me to continue?
21 THE PRESIDING JUDGE: No, it is 5.30. I just had a question about where
22 these troops came from. Where did they get their material and who
23 were the troops themselves? Were they Bosnian Serbs, Serbs from the
24 Prijedor area or somewhere else? But I suppose we can explore that
25 tomorrow.
Page 1102
1 Dr. Greve, you are excused until tomorrow at 10.00 a.m.
2 Thank you for coming.
3 We want to talk about the schedule for next week, Mr.
4 Niemann?
5 MR. NIEMANN: Yes, your Honour.
6 (The witness withdrew).
7 THE PRESIDING JUDGE: As you indicated this morning, Mr. Niemann, you had
8 heard that there will be another matter handled by this Chamber I
9 suppose next week. You have heard a number of things, but let me
10 focus on that. The schedule for next week will be as follows. Much
11 to my regret, on Monday we will not hear this case. Monday is a
12 holiday. I just enquired what holiday it is and I was told that it
13 is Whitsun. Anyway, it is an official holiday and government
14 offices are closed, so we will not hear this case. Tuesday we will
15 also not hear this case, Mr. Orie and Mr. Niemann. The Trial
16 Chamber has another matter that it has to consider. On Wednesday we
17 will not hear this case in the morning; this Trial Chamber has two
18 matters it has to consider. But we will continue Wednesday afternoon
19 of next week, as well all day Thursday and all day Friday
20 So, to recapitulate, Monday is an official holiday, the Tribunal will
21 be closed. On Tuesday this Trial Chamber has
22 another matter to handle and on Wednesday we have two additional
23 matters to handle. So we will not hear the case on Tuesday at all.
24 On Wednesday we will begin at 2.30 of next week and we will sit all
25 day Thursday and all day Friday.
Page 1103
1 Are there additional matters, Mr. Niemann or Mr. Orie?
2 MR. NIEMANN: No.
3 THE PRESIDING JUDGE: OK. Then we will adjourn until tomorrow at 10 a.m.
4 (The hearing adjourned until the following day)
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