Tribunal Criminal Tribunal for the Former Yugoslavia

Page 2343




4 Wednesday, 12th June 1996(10.00 a.m.)

5 (closed session-released by Trial Chamber II on 30 August 1996)

6 WITNESS Q, recalled

7 Cross-examined by MR. KAY, continued.


9 MR. KAY: Yes, your Honour. Thank you. I am coming through in a

10 different language. I have had French and Serbo-Croat which is why I

11 was thrown a bit, your Honour. Perhaps the interpreter can say

12 something in English?

13 THE INTERPRETER: Can you hear us now in English?

14 MR. KAY: Yes, I am on the right wavelength.

15 THE PRESIDING JUDGE: Good morning, everyone again. Let us start over.

16 MR. KAY (To the witness): Mr. Q, I am going to ask you some questions now

17 about the incident concerning the church in Kozarac village when some

18 young guards spoke to you concerning Mr. Tadic and having seen him at

19 the church. Do you remember telling the court about that yesterday?

20 A. Yes.

21 THE INTERPRETER: The witness' microphone is off.


23 MR. KAY: First of all, I would like to know when that was in relation to

24 the war in Kozarac, the attack on Kozarac, when that took place?

25 A. As I can recollect, as far as I know, some 15 to 20 or perhaps a few

Page 2344

1 more days, as far as I can remember.

2 Q. That is before the attack on Kozarac?

3 A. Yes.

4 Q. How long had you been on guard duty at the hospital before this

5 report was given to you?

6 A. Slightly over than, slightly more than when that incident happened,

7 slightly more.

8 Q. So was this incident reported to you soon after guards had been

9 placed at the various positions in Kozarac?

10 A. Yes, immediately after, so to speak, a couple of minutes after that

11 event.

12 Q. I am actually talking about how long the various positions in Kozarac

13 had been provided with Muslim guards, whether you had just started

14 this procedure?

15 A. Approximately, I think that the guards began much earlier than that,

16 but I do not really know when they started exactly. As regards myself,

17 I just told you.

18 Q. Very well. Your position was at the hospital and did you guard that

19 position on your own or with others?

20 A. I guarded that place together with (redacted), outside of the

21 hospital.

22 Q. How many of you were on guard duty that night when the boys reported

23 to you about the church?

24 A. Where I was, there were about five or six, not more than seven,

25 people. I cannot give you the exact number.

Page 2345

1 Q. Can you give me the names of any of those people on guard duty with?

2 A. A couple of names that I could mention, it should be Becirevic Anes,

3 Modronja Suad, Modronja Senad, Modronja, Gromilic is the family name,

4 I cannot remember his first name.

5 Q. Sorry -- you were still thinking and I interrupted you. Is there

6 anything further you wanted to tell us about the names of the people

7 on duty with you?

8 A. I cannot remember exactly the real names and I do not feel like

9 mentioning nicknames which the court perhaps does not -- I do not know

10 their full names.

11 Q. Did any of you have weapons whilst were you guarding the hospital?

12 A. Yes.

13 Q. When you referred to the guards at the hospital (redacted)

14 (redacted), were they men of a similar age to yourself or older or

15 younger?

16 A. Well, different ages.

17 Q. What age range did the group at the hospital consist of? What was the

18 youngest and what was the oldest?

19 A. The youngest -- I would have to go four years back now --

20 approximately 17 years of age, that should be the age of the youngest

21 one, and 45, more or less 45, the eldest member.

22 Q. How many places in Kozarac had you decided to guard?

23 A. Approximately, as far as I know, the number of places that were

24 guarded, as far as I know, there were several. One of them I can

25 list, if necessary.

Page 2346

1 Q. Perhaps you can give us the list of places then in Kozarac where

2 there were guards?

3 A. I could list some that I know of and they are approximately the

4 hospital; the place of the church; the place of the Local Commune; the

5 place of the post office; (redacted) the

6 fountain of the triangle and later on it was moved further on.

7 Another one was on the same road from the church towards Kamicani next

8 to a cafe, we called it "Devetka". That is as far as I know.

9 Q. Thinking back, can you remember when the guarding of these places

10 first started?

11 A. To my knowledge, as far as I know, about one month or slightly over

12 it before the outbreak of the war.

13 Q. On guard duty at the church on the night you had a conversation with

14 the young guards were how many people?

15 A. Four or five. One of these figures is correct, but I am not sure

16 about one man, four or five people.

17 Q. What were the names of the people who were on guard duty at the

18 church?

19 A. I could not list all people, but I will give you some of the names as

20 far as I know. As a matter of fact, I will give you surnames, rather.

21 Q. Give us any name you feel as a means of identifying the people.

22 A. That name can be identified very easily. The surname is Besic; that

23 he is a man a little advanced in age and he stutters, and I can also

24 identify his house if you want me to, but I cannot tell you his first

25 name because I do not know. We all called him "Mucko", and in Kozarac

Page 2347

1 we identified each other in this manner rather than by our full names.

2 Q. Any other names of the guards at the church on that night?

3 A. The rest who were there by the church that night, there were

4 children, in fact, and I could not give their names because there was

5 a difference in age between me and them, and I simply would not go

6 into their names because, in fact, I do not know them.

7 Q. When they stood on guard duty at the church, whereabouts was their

8 position, or did they have a number of positions?

9 A. No, there was only one centre post and the explanation for it can be

10 shown on one of those pictures where Kozarac was depicted. To try to

11 draw you this picture, the road towards Marsala Tita goes towards the

12 church and then further on to Kamicani, and then the crossroads of

13 this road with the road towards the hospital, now the line between

14 that road and the hospital is linked by a small path. At the --

15 there is a small slope and at the corner when you go down there, there

16 is a huge tree. They were by that tree. So, deep down this slope,

17 some five or six metres.

18 Q. Is that tree at the front of the church?

19 A. As we look at the church, as we look from that place, it is right in

20 front of the church, but that tree is by the fence around the church

21 and the distance between that tree and the church is some 15 metres.

22 Q. At what time did the children come and speak to you that evening?

23 A. It was, as we would put it, in the late hours, between 11.00 and

24 12.00 at night.

25 Q. So it was dark at the time?

Page 2348

1 A. Rather.

2 Q. The names of the children who came to speak to you and to tell you

3 what had happened, can you give us any of their names?

4 A. I can give -- I can give the name of the father, but again I cannot

5 give the name of the father, but I can give the orientation because

6 the only car washing shop, it was owned by Juso, I do not know his

7 surname, but his youngest son -- he, by the way, has two sons -- his

8 younger son was that night.

9 Q. So how many people came to speak to you?

10 A. One chap came, not one of those that I just listed, but another chap

11 came -- now, how shall I put it -- scared out of his wits from there.

12 Others hid immediately when they discovered him, when they saw him,

13 when they started running. That was the moment when they began to run.

14 He reached us beyond himself and said, started saying: "Well, we

15 have just seen Dule Tadic. He is carrying something but I do not know

16 what. He is over there". That was very short.

17 The rest of the story that I told you happened immediately

18 after that, because we were at that place by the hospital and then we

19 ran down to see. The end of the story was from those people then.

20 Q. So you did not see Dule Tadic?

21 A. No.

22 Q. When you were spoken to by these people, do you know if they had been

23 on duty as guards at the church?

24 A. I shall tell you one thing straightaway. There was no, some, order

25 of sequence, or the list, when and how one would go on duty.

Page 2349

1 Sometimes I would tell myself: "Well, let us go and see what the mood

2 is; is there any reason for us to have a party, to tell some jokes, to

3 tell some events, to pass the time nicely".

4 Q. Had you seen them on duty at the church?

5 A. Personally, I did not go down before all that it was going to happen.

6 I was up there all the time. The guard duty, our guard duty, did not

7 mean patrolling.

8 Q. Did they have any weapons with them when they guarded the church?

9 A. Yes, they had weapons, as I could see it immediately after that event

10 when we met.

11 Q. So am I right in summarising this way, that on duty at the church was

12 one older man, called Besic, and the rest were children who were

13 guarding the church?

14 A. Yes.

15 Q. Am I right in also saying this, that Besic did not come to speak to

16 you?

17 A. No -- I mean, yes, that is correct, he did not speak to us.

18 Q. But you were spoken to by a number of children, including the father

19 of a child who himself had not been on duty at the church?

20 A. The first story that something had happened down there was told by a

21 child, and only a very small part, as I have just indicated. The rest

22 of the story was told by the rest of those people who remained there

23 and those were those children and this elderly man, Besic, that I

24 mentioned.

25 Q. Would it be right to say that you were told that Mr. Tadic was seen

Page 2350

1 carrying a can?

2 A. Yes, that is true.

3 Q. Do you know where he was seen carrying the can, where he was?

4 A. To try to explain what direction he came from, from the road of

5 Marsala Tita and the by-road leading to the church, that is, we are

6 coming from the direction of the Marsala Tita Street.

7 MR. KAY: I think it would help if Exhibit 196 was put on the screen. I

8 do not know whether your Honours keep a copy of it on the side?

9 Perhaps someone could put it on the overhead projector. Thank you,

10 Mr. Bos.

11 (To the witness): Perhaps you would indicate with the use of

12 the stick which direction it had been reported to you Dusko Tadic was

13 walking towards the church. I think you referred to Marsala Tita

14 Street.

15 A. I mentioned the Marsala Tita Street simply to explain where he came

16 from and I will now show the direction from which he came.

17 (Indicated).

18 Q. So you were told that he came from the crossroads which is where your

19 indicator started, is that right? Perhaps if you can put where you

20 were told he started?

21 A. The easiest reference that we could make visually is that the

22 highway, Prijedor/Banja Luka.

23 Q. Keep your indicator on the point where you say you were told he

24 started to come from. Is that at the back of the church?

25 A. Yes.

Page 2351

1 Q. Perhaps you can indicate where the tree is where the sentries would

2 have been on duty?

3 A. (Indicated).

4 Q. Thank you. You say that you were told he was carrying fuel?

5 A. Yes. Yes.

6 Q. Perhaps you could explain how it would be known that there was fuel

7 being carried?

8 A. Well, because he left, he left the can with the fuel when he ran

9 away. He had discarded it.

10 Q. Did you see the can?

11 A. Yes, I saw it and we found it all together.

12 Q. Why did you not tell us that before?

13 A. I did not say that because if I tell all these minor details, then I

14 will stay here for 10 days.

15 Q. Is it not an important detail that if you were telling the truth you

16 would have told us about before?

17 A. Yes, very important detail. I simply did not mention it.

18 Q. Thank you. You said yesterday that you guessed he wanted to create

19 an incident.

20 A. You mean questions about Tadic?

21 Q. Yes.

22 A. If it refers to Tadic, yes. The answer is, yes.

23 Q. Why did you guess at the time?

24 A. Well, one of my reasons on that why I made that guess is that it is

25 very silly to carry about a can late at night, in day time, and not

Page 2352

1 use one of the main roads. It does not make any sense really.

2 Q. Was there any reason why the children reported to you and not to

3 anyone else?

4 A. That incident was not told me only, but all the people who came

5 there.

6 Q. I want to move now to the attack on Kozarac on 24th May and what you

7 saw on that day. You told us yesterday that when the shelling started

8 at 1.45 in the afternoon that you dressed into your military clothes

9 and went to guard the hospital, is that right?

10 A. Yes, it is.

11 Q. You stayed on guard duty at the hospital until 8.00 or 9 p.m. in the

12 evening when you left the church to go and see your family?

13 A. First of all, I was not at the church. I was near the hospital.

14 Q. Left the checkpoint, sorry, I did not read my own writing clearly.

15 You left the checkpoint you were on at the hospital and went to see

16 your family?

17 A. Yes, that is correct.

18 Q. Thank you. Until that time there had been shelling over Kozarac

19 continuously since 1.45 or had there been breaks in the firing?

20 A. There were very short breaks. I would say just what was necessary to

21 refill all the cannons that were shelling.

22 Q. When you were on guard duty at the hospital, whereabouts did you

23 position yourself?

24 A. Well, me and the others, we were in the hospital, in the building.

25 Q. About how many others were there with you?

Page 2353

1 A. I do not know exactly how many hospital staff were there. All in all,

2 maybe some 30 people. I would say some 30 people, as far as I can

3 recall.

4 Q. You with a few others were there for the purpose of guarding that

5 position, that had been the place that you had been on duty in the

6 previous days, is that right?

7 A. It was not the same place. It was -- the location was at a turning

8 point near the entrance to the hospital and on that particular day I

9 was in the hospital.

10 Q. Were you able to see what the effect of the shelling was on Kozarac?

11 Was there fire? Were buildings being damaged?

12 A. There was shooting, there was fire, all over Kozarac. Just to have

13 an orientation as to which houses were on fire, which were hit, one

14 cannot identify that exactly.

15 Q. (redacted)

16 (redacted)

17 A. (redacted)

18 (redacted)

19 Q. (redacted)

20 A. (redacted)

21 Q. In between the hospital (redacted) are many houses, gardens,

22 yards, garages, sheds, buildings?

23 A. Yes.

24 Q. If we look at this plan and those details for good reason have been

25 taken out, but that is how it is in reality?

Page 2354

1 A. Yes, that is correct.

2 Q. You told the court yesterday that when you went to check on your

3 family you walked down from the hospital and on the way you saw Dusko

4 Tadic and Bosko Dragicevic, is that right?

5 A. Yes, that is right.

6 Q. Whilst we are looking at this plan, could you specifically identify

7 whereabouts on the plan it was that you saw those two as you left the

8 hospital?

9 A. Yes, I can identify them. (Indicated on the plan).

10 Q. Thank you. We can all see that. It would be difficult to express

11 it, your Honour, in formal terms, unless anyone is able to improve

12 upon it, but it seems to be --- (To the witness): How many metres away

13 from the hospital?

14 A. Looking from the hospital, there is no more than 60 or 70 metres. I

15 think one should say some 90 metres from the hospital.

16 Q. How far from the hospital had you moved when you first saw them?

17 A. Some 250 metres, if we take that road directly in that small path.

18 Q. Perhaps you can indicate with your pointer where you were when you

19 first saw them?

20 A. (Indicated).

21 Q. So you had come down the road leading up to the hospital and turned

22 right along a track; is that right?

23 A. I passed through some houses that are here. I will show you where.

24 (Indicated).

25 Q. Yes.

Page 2355

1 A. I indicated the direction and the road between those houses and my

2 final position.

3 Q. Perhaps if you could just then show us with that stick moving from

4 the hospital what route exactly you took?

5 A. First, I arrived here. (Indicated).

6 Q. Yes. So you went along the road up to the hospital, is that right?

7 A. Yes, that is right.

8 Q. Continue then with your movement to the position where you were when

9 you say you first saw Dusko Tadic and Goran Borovnica.

10 A. Goran Borovnica?

11 Q. Dragicevic.

12 A. (Indicated).

13 Q. So where you are positioned there, is that at the corner of a track?

14 A. Yes.

15 Q. If you can put your pointer again back to the place where you say

16 that Bosko Dragicevic and Dusko Tadic were when you first saw them?

17 And what time of night was this?

18 A. Between or around 9 o'clock.

19 Q. Were there any buildings on fire in this area that had been hit by

20 shells?

21 A. In the very surroundings there, when I was there at the corner of

22 this small road, there was not a house on fire there.

23 Q. Was anything else happening at this time? Was there still shelling

24 continuing or had that stopped?

25 A. The shelling was going on still, but it was not falling over that

Page 2356

1 part where we were. Kozarac is quite big, but there was shelling in

2 other parts and one could hear it very well.

3 Q. Perhaps then if you put your pointer back on to the corner of the

4 track, you could trace the movements that you then made?

5 A. (Indicated) As I understood it, from the corner of the small road

6 and then further on behind that, behind a house, we mentioned the

7 position around that corner, (redacted)

8 (redacted).

9 Q. (redacted)

10 A. (redacted).

11 Q. Where did you go?

12 A. After all that, when it was finished, I returned towards the

13 hospital, that is, in the hospital. That was my final destination.

14 Q. Why previously have you made a statement in which you have said: "On

15 the first day of the attack, as it was getting dark, I went (redacted)

16 (redacted) up the hill towards the hospital because I was curious and I

17 wanted to try and see what was going on. As I was moving up to the

18 hospital, I saw Dusko Tadic and Bosko Dragicevic firing flares up into

19 the sky. These flares were lighting up the area near the hospital".

20 I have here a copy of your statement for the Prosecution which you

21 made in May 1995, on 18th and 19th May. Perhaps you would like to

22 look at it, Mr. Q?

23 THE PRESIDING JUDGE: Is that something different than Defence 9 and 10

24 ---

25 MR. KAY: Yes.

Page 2357

1 THE PRESIDING JUDGE: -- which you referred to as his statements

2 yesterday?

3 MR. KAY: Yes, your Honour. Perhaps we could identify it as Defence 11?

4 MR. TIEGER: Your Honour, I do not think we are going to have success

5 proceeding in that way since that document is in English.

6 MR. KAY: No, it is not.

7 MR. TIEGER: You have a translated version?

8 MR. KAY: Yes.

9 MR. TIEGER: Can we have a copy of that, please?

10 MR. KAY: Right. (Document handed).

11 THE PRESIDING JUDGE: Is that the statement then that the witness gave in

12 Serbo-Croat and then it was translated into English, Defence 11?

13 MR. KAY: Yes, this is a document served on us by the Prosecution as part

14 of their witness statements.

15 THE PRESIDING JUDGE: Which one, English or Serbo-Croat?

16 MR. KAY: I have given the witness the Serbo-Croat version. It is an

17 English translation that I have, your Honour.

18 THE PRESIDING JUDGE: What was served on you? The English or the

19 Serbo-Croat?

20 MR. KAY: Both.

21 MR. TIEGER: To clarify the procedure, the statement itself is a statement

22 in English which is interpreted to the witness. The translation, the

23 Serbo-Croat translation, was done subsequently and would never have

24 been presented to the witness.

25 MR. KAY: There is no difficulty with this. Perhaps if the Prosecution

Page 2358

1 could be so kind as to put before the witness the version that was

2 taken in English which has a declaration of authentication of the

3 translation and the signature of this witness against that

4 authentication.

5 MR. TIEGER: This is not an authentication problem. I appreciate the fact

6 that the document which counsel has presented is a translation of the

7 English statement, but the procedure, so that the court understands

8 it, is that English speaking representatives of the Tribunal take

9 statements from witnesses in English. That finished statement is read

10 back to the witness and it is translated and then that English

11 statement becomes the operative statement. That statement was

12 subsequently translated for benefit of the Defence. So the witness

13 will never have seen the Serbo-Croat version to the extent there may

14 be the kinds of translation problems that we have been encountering

15 periodically.

16 THE PRESIDING JUDGE: Who prepared the Serbo-Croat translation?

17 MR. TIEGER: The Registry.

18 THE PRESIDING JUDGE: OK, and this witness has never seen the Serbo-Croat

19 translation; is that what you are saying?

20 MR. TIEGER: He would not under the normal procedure and, to my knowledge,

21 has not.

22 THE PRESIDING JUDGE: Mr. Bos, did you want to say something to me, to

23 give me some information, regarding the role of the Registry? We, of

24 course, were acquainted with the problem of the translation and the

25 effect of the translation when the Prosecution filed a motion for the

Page 2359

1 Defence, the witness statements of the Defence, I can recall, the

2 Defence took the position: "Well, you know, these were taken in a

3 different language and when they are translated there are going to be

4 problems".

5 I do not know what to do other than to receive it and give

6 them the weight that we consider appropriate. I understand that as we

7 have heard the translations from English into Serbo-Croat just

8 yesterday, "rags" as opposed to "rake" and then it was "pitchfork".

9 Those things have occurred. But it is a statement and I think Mr. Kay

10 should be able to proceed with the statement and let us see what

11 problems arise, if any, regarding the translations.

12 MR. KAY: If the court could allow me to proceed in this way. I think

13 perhaps this witness speaks a bit of English. I do not know whether

14 you read English, sir? (To the witness): Do you read English?

15 A. No.

16 MR. KAY: That finished that.

17 THE PRESIDING JUDGE: I suppose if you want to impeach him with a prior

18 statement, the statement that should be used is the Serbo-Croat

19 statement, so that you can ask him: "I will show you the statement.

20 Is this the statement that you gave?"

21 MR. KAY: Yes.

22 THE PRESIDING JUDGE: Then he can say "yes" or "no". Then you ask him:

23 "Looking at the Serbo-Croat, did you say this or that?" You, of

24 course, will be using the English one, and let us hope that the

25 translation in English is what it was in Serbo-Croat. Then you will

Page 2360

1 have a chance to explain why there is a difference, if there is a

2 difference, but you have to work with the Serbo-Croat with him.

3 MR. KAY: That is why I chose that document. Thank you.

4 THE PRESIDING JUDGE: That is Defence 11?

5 MR. KAY: Defendant 11.

6 THE PRESIDING JUDGE: It is in Serbo-Croat?

7 MR. KAY: It is in Serbo-Croat. (To the witness): You were interviewed

8 in 1995 on two days; is that right, Mr. Q? Perhaps you do not

9 remember the dates, but you remember being interviewed last year by

10 the Prosecution for this case?

11 A. Yes, I remember the statement I gave and, as far as I can recall, it

12 happened on one day and it lasted till late at night.

13 Q. You had an interpreter, is that right, and perhaps you remember her

14 name, (redacted)

15 A. We had an interpreter and I think, yes, (redacted), I cannot be sure.

16 Q. Yes. In fact, you were interviewed by two gentlemen who are in court

17 today, do you recollect them, Mr. Keegan who questioned you and Mr.

18 Tieger sitting on the other side of the courtroom?

19 A. Yes.

20 MR. KAY: I do not use that as a precedent for a dock ID, your Honour!

21 THE PRESIDING JUDGE: Did he see Mr. Keegan and Mr. Tieger before and does

22 he see them today? I do not know.

23 MR. KAY (To the witness): After that interview took place, the statement

24 that you gave those gentlemen and the interpreter was signed by you,

25 do you remember that? Perhaps you would like to look at this

Page 2361

1 signature here. (Document handed to the witness).

2 A. Yes, I signed this.

3 Q. Yes, with the date. In fact, you acknowledged where you signed your

4 name that the statement that you had given had been read over to you

5 in Serbo-Croat, do you remember that, and that it was -----

6 A. Yes, it was read out in Serbo-Croat.

7 Q. And that it was a true statement, to the best of your knowledge and

8 recollection?

9 A. Yes.

10 Q. And that you gave it voluntarily for proceedings before the

11 International Criminal Tribunal?

12 A. Yes.

13 Q. And that you might be called to give evidence before the Tribunal?

14 A. That is what I was told.

15 Q. Yes. Perhaps you would just like to look at that statement that you

16 have there in Serbo-Croat and perhaps just look at the first page, as

17 you did yesterday on those other statements, where the text is. Can

18 you see that? It starts: (redacted)

19 (redacted)

20 A. Yes.

21 Q. It gives details about your background, where you live, in that first

22 paragraph; is that right?

23 A. Yes.

24 Q. The next paragraph concerns tension before the attack on Kozarac, is

25 that right?

Page 2362

1 A. Yes.

2 Q. The next paragraph deals with the increase of tensions and a group of

3 former members of the TO decided to establish watchers on some

4 important institutions in the village, is that right?

5 A. Yes, that is right.

6 Q. The next paragraph, paragraph 4, perhaps you would like to read out

7 in Serbo-Croat so that it can be translated to us?

8 THE PRESIDING JUDGE: Do you wish to offer Defence 11, and I gather that

9 is the Serbo-Croat statement of the witness, and he has signed that?

10 MR. KAY: Yes.

11 THE PRESIDING JUDGE: You have an English translation. Do you have a copy

12 for the court?

13 MR. KAY: I think he has signed the English translation and not the

14 Serbo-Croat.

15 THE PRESIDING JUDGE: I misunderstood you. You asked him to look at his

16 signature and I guess I was led astray.

17 MR. KAY: I took off the witness acknowledgment because these statements

18 have certifications with them by the translators and a witness

19 acknowledgment.

20 JUDGE STEPHEN: Could I clarify my own mind? The statement was made by

21 him, of course, in Serbo-Croatian but written down having been

22 translated in English?

23 MR. KAY: Yes.

24 JUDGE STEPHEN: He then signed the English copy and subsequently the

25 Registry has translated that back into Serbo-Croatian?

Page 2363

1 MR. KAY: Yes, but there is an important step in that the statement was

2 read back to him in Serbo-Croat ---


4 THE PRESIDING JUDGE: That was not signed.

5 MR. KAY: -- by the translator. That is what I read out from and that is

6 signed.

7 THE PRESIDING JUDGE: But that has not been signed? That Serbo-Croat

8 statement has not been signed?

9 MR. KAY: That has been signed by him on the English statement because it

10 was translated for him. "This statement has been read over to me in

11 Serbo-Croatian language", so that is attached to the English document.

12 THE PRESIDING JUDGE: Exhibit 11 is a statement, you say, of Q in

13 Serbo-Croat that has not been signed, but the English version has been

14 signed?

15 MR. KAY: Yes.

16 THE PRESIDING JUDGE: I would suggest that both be offered and I would

17 like to have a copy of the English translation. Mr. Tieger, you had an

18 objection, I gather, regarding this? I will overrule your objection.

19 Your objection, I gather, has to do with the whole process and how

20 much weight should be given to the translations, but we will work that

21 out later.

22 So 11 will be admitted. It will not help unless we have a

23 copy of the English as well, so why do you not make it 11A and 11B

24 and I would like a copy of the English, if you have a copy for the

25 court, please?

Page 2364

1 MR. KAY: Your Honour, mine are all marked, I am afraid. What I have done

2 is, because we are leapfrogging, I have copies of the Serbo-Croat

3 document, if the court wanted those.

4 THE PRESIDING JUDGE: I just wanted to follow the testimony. You have

5 given the Prosecutor a copy of the English though and the Serbo?

6 MR. KAY: He has that anyway. The Prosecutor has that anyway as he has

7 given it to me.

8 THE PRESIDING JUDGE: OK. Defence 11A will be admitted. Defence 11B will

9 be admitted. Defence 11A is the Serbo-Croat version. 11B is the

10 English version.

11 MR. KAY: Yes.

12 THE PRESIDING JUDGE: Our Senior Legal Officer was suggesting, perhaps,

13 put the English version on the elmo, so if you are going into

14 questioning we can take a look at it as well.

15 MR. KAY: That is an extremely sensible idea. If you could put the first

16 page? There is a way round.


18 MR. KAY: If I indicate to Mr. Bos the page, we are looking at the fourth

19 paragraph. Can the court see?


21 MR. KAY: The attack on Kozarac, the paragraph is the fourth one. (To the

22 witness): Mr. Q, perhaps you could read out in Serbo-Croat that

23 fourth paragraph so it can be translated to us as you read it out.

24 A. I shall read it, but does that reflect the real meaning of the

25 English version? I do not know, but I shall try to read what I have

Page 2365

1 before me. "Because of the ever increasing tension, a group of the

2 former TO members" ------

3 Q. The next paragraph.

4 A. I am sorry. "The attack on Kozarac began on 24th May 1992 in the

5 afternoon. On the local Serb radio station, we heard that the Serb

6 army would go through the region. Everybody knew that something was

7 happening. I was at home eating when the first shells fell. I was

8 shocked. We immediately went down to the ground floor. The

9 explosions went on for the rest of the day and continued the next day.

10 In the evening of the first day of the attack, I went out of the

11 house and started towards the hospital. I was curious and I wanted to

12 see what was going on. On my way to the hospital, I saw Dusko Tadic

13 and Bosko Dragicevic firing rockets in the air. Some 10 minutes after

14 they would fire the projectile, that area would be shelled".

15 Q. Was there a sentence that was missed out, being the second to last

16 sentence?

17 A. I have read all that there is here.

18 Q. Thank you. You see in that statement there which was given by you in

19 Serbo-Croat and read back to you, you stated that you had been at home

20 and you went to the basement of your house when the explosions

21 started, is that right?

22 A. I did not state here what house, nor what basement, as far as I can

23 understand the Serbo-Croatian translation of what I have said.

24 Q. I think you said (and I will be corrected if I am wrong) that you

25 were at home eating when the first explosions hit?

Page 2366

1 A. That is what it says here in the statement, but this statement was

2 not taken, to my knowledge, from one hour to the other, to cover every

3 second.

4 Q. No, but it agrees with your evidence that you gave the court

5 yesterday that when the first explosions hit you were at home eating,

6 is that right?

7 A. Yesterday I said that when I was at home and that I was eating, and

8 when I saw the first shells, and that was when I came to the hospital,

9 that is when I saw them in fact or, rather, heard the shells falling.

10 Q. Yes. You told us yesterday that you stopped lunch, immediately got

11 changed and went to the hospital; but in this statement you tell us

12 that you went to the lower ground floor and it was later, as it was in

13 the evening, that you went (redacted) up the hill to the

14 hospital?

15 A. It is what it says in this statement but, as I said, they were not --

16 there was no full information about all my movements.

17 Q. No, but it says, and you told them, that you were curious and wanted

18 to see what was happening?

19 A. Your Lordships, may I explain something to take all the things into

20 account? I am speaking in my own name and none of us expected such

21 shelling to happen as it did happen. I was astounded because all that

22 was happening one could only see in films about war, and any curiosity

23 to know whether something had happened here or there, I think will

24 drive any man, and so it drove me.

25 If a mistake was made in this first statement that was read,

Page 2367

1 it is possible because the real sequence of events was not taken into

2 account. Everything that was taken was taken very superficially.

3 Yesterday, I think I have never given a fuller statement in my life as

4 yesterday, and I can say that I cannot really give an estimate of

5 percentages, but a large part of my life was what I told you about

6 yesterday. Thank you very much.

7 JUDGE STEPHEN: I am sorry, but I seem to be receiving the Serbo-Croatian

8 loudly which makes it very difficult to hear the translation. I hear

9 the translation as well but the Serbo-Croatian is being amplified. Is

10 everyone in the same position?

11 THE PRESIDING JUDGE: No, but I think the witness is speaking more loudly

12 than the translators, so sometimes I am turning it down when he

13 speaks. No problem. Let me just say this though, sir, you have given

14 your explanation regarding this statement that you gave initially and

15 your testimony yesterday and we have heard that. Now, however, Mr.

16 Kay will be cross-examining you regarding the statement so you should

17 respond to his questions as he asks you. Go ahead, Mr. Kay.

18 MR. KAY: Thank you, your Honour. (To the witness): Can you explain

19 though why you have said two different things on two occasions; on one

20 occasion that you were at home and going to the hospital and on the

21 other occasion that you had been at the hospital for the same period

22 of time and had left there and were going back home? This is more

23 than a mistake associated with translation, is it not?

24 A. Yes.

25 Q. Have you given these two different accounts because what you have

Page 2368

1 said has not been the truth?

2 A. All that I said was true.

3 Q. The area where you say that shells would have landed after the flares

4 had been sent into the sky by Mr. Tadic and Mr. Dragicevic, that would

5 have been very close to Mr. Tadic's house, would it not? Look at plan

6 196, Exhibit 196. You said that after flares were sent into the sky

7 soon afterwards shells landed in the area. That would have been

8 around Mr. Tadic's house, would it not?

9 A. Well, not really all that close because the shells were falling from

10 the direction of Prijedor towards Kozarac, so that would be around the

11 hospital because the flare-up, the flare itself was directed towards

12 the hospital.

13 Q. The hospital was not hit by a shell, is that right?

14 A. Hit the first night and the first day and the first night, I do not

15 -- I cannot give any assessment of the shells because I did not count

16 them, but there were hundreds of shells which fell around the hospital

17 and on the hospital.

18 Q. That hospital was not hit by a shell then, was it?

19 A. I do not know if it was hit then. From our -- from where we were,

20 from our angle, we could see where the shell approximately fell and,

21 even theoretically, it could not have fallen beyond the hospital.

22 Theoretically, they could not have missed the hospital.

23 Q. I would like to now move on to other matters. You told us that the

24 hospital moved from its usual place, that people within it went up to

25 the motel, is that right?

Page 2369

1 A. Yes.

2 Q. When did they move in relation to the attack on Kozarac, at what

3 stage?

4 A. The second day.

5 Q. Can you remember at what time that move took place?

6 A. Well, I should say from 10 o'clock in the morning onwards. That would

7 be how I reckon the time, that the beginning was at around 10 o'clock.

8 Q. Were you at the hospital at that time and did you take part in the

9 move to the motel?

10 A. I was helping to move out the hospital.

11 Q. Did the entire hospital move to the hotel or did some people remain

12 in the old building?

13 A. Yes, two persons remained.

14 Q. So, any patients in the hospital and doctors and other staff moved

15 away, bar two persons?

16 A. They were not moved by two persons. Two persons remained behind in

17 the hospital.

18 Q. I think it got lost in the translation there. Did they take

19 equipment from the hospital when they moved to the motel?

20 A. Only some; as far as I know, they took bandages, first aid kits, some

21 pills, generally all that one needs for the first aid, for wounds and

22 pills.

23 Q. How long did you remain at the motel?

24 A. Until the early hours of the evening that day.

25 Q. So that is the second day of the attack on Kozarac?

Page 2370

1 A. Yes.

2 Q. In the evening of that day where did you go?

3 A. To the woods.

4 Q. Did you go back to the motel having gone to the woods that evening?

5 A. On that evening when I went to the forest, it was -- it was to be in

6 one place, to find some people, to talk and to encourage one another.

7 Then from that place to go to another one, to a third one, to the

8 fourth one, the fifth, to explain it all.

9 Q. I know you went up to the woods, but the purpose of the question was

10 whether you returned on the next day back to the motel where the

11 hospital had moved?

12 A. If we look at the third day, that was a direction, a route, I took to

13 Kozarac.

14 Q. But did you go back to the motel?

15 A. I did not stay in the motel. I went past it because if I go to my

16 home, that is, towards Kozarac, in simplest words, I have to pass by

17 it.

18 Q. Perhaps if you would look at the plan, Exhibit 196, with us again?

19 If we can have that on the monitor, which it is, we see at the top of

20 the plan the word "motel", is that right? Can you see that?

21 A. Yes.

22 Q. Is that where the hospital moved to?

23 A. Yes.

24 Q. In your evidence yesterday when you said that you went to the woods,

25 that would be above the motel on the map, would that be right?

Page 2371

1 A. Yes, that is right. All around the motel or, in simplest terms, the

2 forest begins immediately behind the hotel.

3 Q. That is where you spent that night, and then the third day of the

4 attack in the morning you would have still been in the woods, is that

5 right?

6 A. Very early in the morning.

7 Q. Yes. Could you see how many other people were in the woods at this

8 time? Did you have any idea as to whether there were a lot of people

9 or were there only a few people?

10 A. Very many people, lots of people, thousands.

11 Q. Did you still have your rifle at this time?

12 A. Yes. Yes.

13 Q. But I take it you were not taking part in any fighting?

14 A. No.

15 Q. Were there others of you with weapons in the woods there?

16 A. Some of them.

17 Q. But in the morning time could you see what had happened to Kozarac on

18 the third day of the attack?

19 A. I could see it when I came, when I entered Kozarac, and from the

20 place, from the position of the motel one sees far because the hotel

21 is on elevation higher than the Kozarac area itself.

22 Q. So in that area around the motel where you and the others were in the

23 woods, there does not appear to have been any soldiers?

24 A. Well, there were no soldiers there.

25 Q. It would be right to say that behind you up in the mountain you were

Page 2372

1 aware that there was artillery?

2 A. We found that out later on.

3 Q. Yes. Were you aware of that at the time on the 26th?

4 A. I heard lots of stories about the position, about the surrounding of

5 Kozarac, about the reinforcement of Serb positions around Kozarac,

6 because, to put it simply, there were so many rumours, so many

7 stories, that it only instilled fear in people. Everybody knew that.

8 Only a very few people knew where exactly their positions were.

9 Q. In the morning were people, families, moving through Kozarac down to

10 the road from Banja Luka to Prijedor to the highway there?

11 A. At the very beginning, very early in the morning, there was commotion

12 in the woods, there was a disarray, a complete disarray, in the woods.

13 People did not know what to do at that moment; and they were simply

14 heading towards Kozarac, running away from the forest, forming

15 columns, and directing them towards Kozarac from the woods and then

16 from all parts of Kozarac, a multitude, many people simply began to

17 join in later on.

18 Q. You said people were being directed through Kozarac. Were there

19 soldiers in the town?

20 A. When I saw soldiers in the town, in the centre of Kozarac at the

21 triangle, that was at that same moment when I saw policemen all lined

22 up.

23 Q. Did you have your weapon with you?

24 A. Yes.

25 Q. So, you had moved into the centre of Kozarac on your own, is that

Page 2373

1 right?

2 A. That is right.

3 Q. No-one else with you?

4 A. No, nobody was with me. Everyone tried to save his life, to put it

5 simply.

6 Q. You were dressed in military uniform?

7 A. I was dressed in army boots, trousers and a military fur lined coat

8 and a civilian shirt.

9 Q. Did you have any insignia on your uniform?

10 A. Yes, I did have insignia.

11 Q. What was that?

12 A. They were the insignia of the Yugoslav People's Army, small stars.

13 Q. You had gone through Kozarac like that with a weapon down to where

14 the Serb forces were?

15 A. I did not come into Kozarac by, down the Marsala Tita Street. I used

16 another road to enter Kozarac with arms.

17 Q. But, whatever route you took, you tell us that you went right into

18 the centre of Kozarac at the end of Marsala Tita Street?

19 A. (redacted).

20 Q. That would have put you in the heart of the Serb forces, in the

21 middle of the Serb forces?

22 A. That brought me to that place.

23 MR. KAY: Your Honour, that is a convenient moment at half past.

24 THE PRESIDING JUDGE: We will stand in recess for 20 minutes.

25 (11.30 a.m.)

Page 2374

1 (The court adjourned for a short time)

2 (11.50 a.m.)

3 THE PRESIDING JUDGE: Mr. Kay, you may continue.

4 MR. KAY: Thank you, your Honour. (To the witness): Mr. Q, I would like

5 to ask you now some specific questions about the scene in Kozarac on

6 the third day when you have told the court you returned to the centre.

7 You described it as being chaotic, but how many people were around in

8 the village and moving down Marsala Tita Street? What numbers were

9 involved?

10 A. Many thousand people. I could not give you the exact figure.

11 Q. Did they have possessions with them or were they carrying nothing?

12 A. Some did, some did not.

13 Q. Was there any vehicle movement down Marsala Tita Street? Were there

14 any lorries or carts or other forms of transport?

15 A. I have not seen any.

16 Q. So the people were on foot?

17 A. Yes, on the street of Marshal Tito.

18 Q. Looking at the map of Marshal Tito Street, on the area to the left

19 and right of the town, were people moving through those areas or were

20 they just going down the main high street?

21 A. The people were moving down the street of Marshal Tito. They were

22 going in columns. Other people, individuals, were joining them,

23 smaller groups were joining them as well, people that lived nearby or

24 close to the street of Marshal Tito, from both sides of the street.

25 Q. Were there fires in the town?

Page 2375

1 A. Yes, some houses were burning.

2 Q. When they moved down Marsala Tita Street, where exactly where they

3 going after the end of that street?

4 A. They were going down the street of Marshal Tito, down to the triangle

5 and after that they were selected -- at the beginning most of them

6 were directed towards Prijedor and immediately after some were, some

7 went to Trnopolje, Sivci and towards the direction of Trnopolje.

8 Q. So again were these groups of people still on foot?

9 A. Yes.

10 Q. So if we look at our plan, Exhibit 196, indicate, if you can, the

11 directions that people were going in, having got down to the centre of

12 Kozarac at the triangle?

13 A. (Indicated).

14 Q. Thank you.

15 A. (Indicated).

16 Q. Both those roads up the plan would take you off to Prijedor; is that

17 right?

18 A. The first road I am showing meets the highway, Prijedor/Banja Luka

19 highway.

20 Q. Yes.

21 A. And this additional road, there are a lot of little streets joining

22 it that also are connected to the highway Prijedor/Banja Luka.

23 Q. Yes, and when you indicated down past the football field, that is in

24 the direction of Trnopolje?

25 A. Yes.

Page 2376

1 Q. If you could indicate to us where you exactly were on this plan when

2 you were observing what was happening in the centre of the town?

3 A. (Indicated).

4 Q. (redacted)

5 A. (redacted)

6 Q. You did not get on to the triangle yourself?

7 A. No, I did not go to the triangle.

8 Q. (redacted)

9 A. (redacted).

10 Q. And you did not step on to Marshal Tito Street?

11 A. Not in this part around the triangle, but looking at Marshal Tito, it

12 is a long street, a long road.

13 Q. Yes, I am concerned only with what has happening down here at the

14 triangle.

15 A. When I came to this house from where I was observing this, I saw a

16 group of about 10 guards, and I saw one tank and also many armed

17 Serbian, Serb soldiers. I also saw a large group of people that were

18 stationed in the park of the elementary school Laza Kondic, the groups

19 of people that were moving in the directions that I have shown to you.

20 Q. When you say 10 guards, what do you mean?

21 A. I did not say 10 guards, I said 10 policemen. I meant there were

22 many Serb National Guards there. I am not sure of the exact amount,

23 exact figures. The people were moving in the direction up and down,

24 towards the sides and they were making a lot of noise, scaring the

25 people, so for me there was quite a chaotic situation.

Page 2377

1 Q. Yes. You have described an incident that has allegedly taken place

2 on the other side of the triangle from where you were standing, is

3 that right?

4 A. I have described the incident that occurred exactly from one side of

5 that triangle towards the direction from which I was observing.

6 Q. At the time you say you observed this, were you in a building or

7 actually in the lane?

8 A. I was behind the house. I was behind the house owned by Dzevad

9 Asani, and from the corner of that house I was observing everything.

10 I did not allow any of the Serbs to see me, to notice me.

11 Q. Which weapon did you have with you?

12 A. A kalashnikov.

13 Q. That is a rifle, is it not?

14 A. Yes.

15 Q. If the Serbs had seen you with that, they would have attacked you?

16 A. For sure they would.

17 Q. How long were you observing the triangle from your position behind

18 the house?

19 A. Exact time frame, it would be difficult for me to give you that,

20 maybe 15 minutes, and after that I became afraid because I was seeing

21 what was happening and, of course, I was afraid for my own life.

22 Q. You said yesterday that there came a stage when you no longer had

23 courage and left. Do you remember that?

24 A. Yes, I said I had no more courage, I had no more courage to watch

25 this and I left it, left the position.

Page 2378

1 Q. When you left the area, did anyone detect you, did anyone find you

2 moving around the town of Kozarac?

3 A. Not in that area from which I was observing the incident; nobody

4 detected me there, only later.

5 Q. So looking at the time you spent, the 15 minutes, down near the

6 triangle and the time it came for you to leave, you told us yesterday

7 that you saw Dusko Tadic hit one man, is that right?

8 A. I said yesterday that I saw Dusko Tadic and Goran Borovnica and the

9 incident that took place there.

10 Q. What you told us yesterday was that you saw Dusko Tadic, in

11 particular, hit one man?

12 A. Yes.

13 Q. And he did not hit any other men?

14 A. I did not see whether he hit anybody else. I saw him hit one person

15 and this is when my fear was at its height, and this is why I left

16 that position.

17 Q. You said that you saw Goran Borovnica hit a man with his hand?

18 A. Yes.

19 Q. Is that your recollection of what happened?

20 A. My recollection of what took place is very brief and it goes like

21 this: Goran Borovnica hits this person, and very shortly afterwards

22 Mr. Tadic uses a karate manoeuvre to hit the same person in the right

23 leg. That person falls towards the ground. Borovnica takes this man

24 and grabs him at the throat and lifts him up in the same horizontal

25 position in which he was lying. This is what my statement was

Page 2379

1 yesterday.

2 Q. Why did you say something different in your statement that you gave

3 to the Prosecution last year? Perhaps you will look at Defence

4 Exhibit 11A and just look at the second page and the top paragraph of

5 that second page. Can you see that, Mr. Q? Perhaps you could read out

6 in Serbo-Croat so that it can be translated to us what that paragraph

7 says?

8 A. "At the barracks we recognised Dusko Tadic, Goran Borovnica, Bosko

9 Dragicevic" -----

10 Q. Can I just stop you there for a moment? "At the barricades we

11 recognised", were you on your own or with others?

12 A. I was alone.

13 Q. Is this your account or something else that others have told you?

14 A. This is my account.

15 Q. Why did you say "we" then?

16 A. Probably because this whole incident involving Kozarac people were

17 mostly in groups and this was mostly my mistake.

18 Q. Very well. Perhaps continue then with what you were reading out in

19 Serbo-Croat, you got to "Bosko Dragicevic"?

20 A. "... and other Serbs whom I did not recognise because they were not

21 from our village. Goran Borovnica, Bosko Dragicevic and Tepo, I have

22 recognised because they were local Serbs. In addition to Tadic and

23 others, at the intersection there was also a group of local policemen,

24 Muslims. One of them was Alic. I saw Borovnica and Tadic as they

25 attacked Alic. Borovnica with a butt of his rifle hit Alic several

Page 2380

1 times in the back of his head".

2 Q. Just stop there a moment. What was it? You said then the "butt of

3 his rifle", you told us yesterday it was with his fist or hand, a slap

4 or a punch; which was it? Which is the truth?

5 A. The truth is, I hope you will understand, none of the Serbs had --

6 none of the Serbs left for a second their rifles, and why am I saying

7 in this statement that he was hit by the butt of the rifle, because

8 this is not something you would notice, simply. The rifle was in the

9 hand and the hit, the punch, that was coming came from the side, so

10 the rifle was in hand, the hand and the punch.

11 Q. "Borovnica hit" -- I am reading -- "I saw Borovnica and Tadic as they

12 attacked Alic. Borovnica with a butt of his rifle hit Alic several

13 times in the back of his head". You can tell the difference when

14 someone is holding a rifle and hitting someone and when someone is

15 hitting them with their hand, can you not?

16 A. Yes, I can tell the difference in this blow, but this blow that was

17 actually given, the way that I described it right now, I simply

18 sometimes say "with a hand" because he was in the event hit by the

19 hand, or sometimes I say "with a butt of the rifle", but this is all

20 one unit, because the rifle was in the hand at the time when the blow

21 was given.

22 Q. You did not know yesterday whether it was a slap or a fist?

23 A. I did not know because even now I am not exactly sure whether he hit

24 him with an open hand, with a butt of the rifle. The simplest way to

25 say it is that it was a total blow with the hand, with the butt of the

Page 2381

1 rifle, with a palm, it was altogether.

2 Q. Perhaps you would read on to finish the paragraph?

3 A. "Tadic hit him several times in the leg and probably broke it. I

4 have also seen Tadic and other Serbs abuse other policemen and slap

5 them, take their insignia off and insult them".

6 Q. I thought you told us yesterday and not long ago that the only

7 hitting you saw Tadic did was upon the man Alic, that Borovnica here

8 you have told us that he was slapping other policemen?

9 A. Yes, this is what I said yesterday.

10 Q. No, you did not say that yesterday.

11 A. Everything that is written here, I did not say that yesterday, one

12 part of this I said yesterday; what I saw at that moment when I was

13 standing behind that house, what I saw occur at that moment.

14 Q. So have you put in this statement things that you did not see?

15 A. I did not.

16 Q. Why then does this statement differ and contain other details that

17 you did not tell us about yesterday and today?

18 A. It differs in that I did not tell you, describe each minute of my

19 life to you. This is the second time when it occurred when I saw

20 Tadic in Kozarac with the other group of policemen that were

21 surrendering when I saw what happened.

22 Q. But I thought after you lost courage, as you have told us yesterday

23 and today, that you went through the town and left it?

24 A. Yes, I went into the woods.

25 Q. Yes. So you did not see Mr. Tadic on a second occasion?

Page 2382

1 A. I saw Mr. Tadic at the second occasion, but I did not give a

2 statement regarding this yesterday.

3 Q. This statement we have just looked at says: "I also saw Tadic and

4 the other Serbs mistreat the other policemen", meaning the 10 at the

5 triangle?

6 A. Concerning the second part of this statement, I did not see those 10

7 policemen at the triangle. Those were the others. Probably in this

8 case there will be other statements by other people that saw the

9 surrender of those policemen because not all of them surrendered at

10 the same time.

11 Q. If you are saying then to this court now that there was another

12 occasion when you saw Mr. Tadic and other Serbs mistreat other

13 policemen, slapping them, tearing off their epaulets and ranks and

14 abusing them, perhaps you would like to tell us where this was?

15 A. Can I show on the map that is drawn here?

16 Q. Please do. It is there.

17 A. (Indicated).

18 Q. If you could just keep your pointer on it, so that we can see that it

19 is up near the mosque, you are saying, that there was this other

20 occasion; perhaps you would like to tell us when this was?

21 A. The event that I am going to tell you about now took place near our

22 Local Commune, and it just so happens that there is a triangle there

23 too. From Marsala Tita Street, there are two streets that later

24 joined together. The place where policemen were stopped, mistreated,

25 was the place before the entrance into the youth hall. There is an

Page 2383

1 elevation, a small elevation there, a plateau. If we look from that

2 plateau into, towards the woods, along Marsala Tita Street there is a

3 small road which also leads towards the woods, also towards Besici and

4 nearby private houses. From that side, from that road, by Besici,

5 there is one what we used to call a fishing place, Pecara, and also a

6 company that was manufacturing baskets and things made out of wicker.

7 At that time, Serbs had not yet taken those areas of Kozarac.

8 They had only taken the main road, to put it simply. From that angle,

9 I was looking at the youth hall and the policemen that were there. My

10 assessment, according to my assessment, there were about six, seven,

11 seven, eight policemen, and what happened is this mistreatment of

12 policemen, taking off their epaulets, insulting, insults of the

13 policemen and so on.

14 Q. Were they any of the original policemen amongst the group of 10 you

15 saw also in that group?

16 A. No, they were new policemen.

17 Q. Was this also on the third day after the attack on Kozarac?

18 A. The same day.

19 Q. So you spent your time moving around near the Serb troops, did you,

20 in Kozarac on that day?

21 A. From the forest towards Kozarac.

22 Q. Have you just made up for the benefit of this court that account that

23 you have just given us about this second occasion?

24 A. No. I told you the truth.

25 Q. Thank you very much. Let us now move to Keraterm where you were

Page 2384

1 eventually forced to stay. Just to put into context, can you remind

2 the court what was the date, so far as you can judge it, that you were

3 put in Keraterm?

4 A. It was on 14th June '92 when I was taken to Keraterm from the village

5 of Sivci.

6 Q. You counted near that time soon after you arrived that there were

7 some 572 men in your cell?

8 A. Yes, I had the opportunity to write down those people.

9 Q. Would it be right to say that the area that the 572 were in was

10 insufficient room for that number of people?

11 A. I do not see a question there. I am sorry.

12 Q. Maybe because part of it was not translated, but I will put it more

13 simply. Would it be right to say that the overcrowding for the area

14 you were in for 572 men was appalling?

15 A. In my view, as the Serbs piled us up in there and 300 people more

16 could have been accommodated into that room.

17 Q. How soon after you arrived did the prisoners from Hambarine get put

18 into the other cell?

19 A. First, the people from Hambarine came to the third cell, how soon,

20 about a month, perhaps slightly over a month later.

21 Q. You described an incident involving those men where there was

22 shooting into their cell. How soon after they had arrived did that

23 take place?

24 A. It took place the same night when they were brought in.

25 Q. Thank you. The number of 572 in your cell No. 2, was that increased

Page 2385

1 during the stay that you had there or did the numbers become reduced?

2 A. When I wrote down those people, the number, the figure was 572 and

3 later on when people from Hambarine arrived the numbers increased.

4 However, every day -- I cannot say that it was every day, but new

5 people arrived very often and left those same interns in the Keraterm

6 camp in different directions, that is, they all left in the direction

7 of Kozarac, Omarska, Banja Luka.

8 Q. During the night-time was the door to the cell closed?

9 A. That night when the incident took place with the people from

10 Hambarine, the door of the cell was closed.

11 Q. I am actually asking you about other nights rather than that

12 particular night and for the general picture. During the night-time

13 was the door left open or closed?

14 A. Sometimes yes and sometimes no. They were closed more often than

15 they were open.

16 Q. During the day-time was the door open or closed?

17 A. By and large, the door was open, but there were times when they were

18 closed. In those self-same pictures, we do not see what the camp

19 looked like exactly, because what I could add to that picture and what

20 was on the doors of the cells, Nos. 1 and 2, it is, to put it very

21 simply, there was a large iron frame with an opening and even smaller

22 than a normal door. Naturally, there was the original door that we

23 can see on the picture.

24 Q. During the day were you allowed out of the cell to walk around the

25 outside area?

Page 2386

1 A. Sometimes we were given that opportunity, but we had a very narrow

2 possibility, a very narrow path along which we could walk, but it was

3 never that we could walk for three hours or more. They were always

4 short. I do not know if it depended on the mood they were in, or I do

5 not know why, but yes, they allowed us sometimes for very short

6 periods of time.

7 Q. In those short periods of time, the area in front of the cell would

8 have been a narrow strip, would it not, of how many metres wide that

9 people were allowed to walk within?

10 A. As we look at the cell No. 1 and the last one, which was cell No. 4,

11 from the corner of the cell No. 1 and roughly some 10 metres forward

12 from the cells, that was roughly this walking area for these people.

13 As a rule, none of us separated so far as to walk from cell No. 2 to

14 cell No. 4, because it was dangerous at any rate.

15 Q. When you were in cell No. 2 you told us that you had a particular

16 place where you stayed which was the far right-hand corner, is that

17 right?

18 A. Yes, that is right.

19 Q. So, as we were looking at those video pictures yesterday and the

20 camera went through the door of the cell and proceeded down the room,

21 the part where you stayed would have been past the area of new

22 building that was not originally there, is that right?

23 A. I do not quite understand this route which you followed, but I will

24 try to explain the place where I was. One entered through the door of

25 cell No. 2. Then we can see the wall on the left side, and then if

Page 2387

1 we proceed further along that wall to the end, that is, to the next

2 wall at an angle 90 degrees ---

3 Q. Yes.

4 A. -- and if we then move further down along that wall to the wire

5 because there is a barrier, a partition, between cell No. 2 and the

6 further room and there was a piece of wire as we could see. There was

7 in the corner between this second wall and that wire and that is

8 precisely at the end of cell No. 2 in the right corner.

9 Q. It is from that position and in that room you have described that you

10 tell us you saw Dusko Tadic in Keraterm?

11 A. I did not see Dusko Tadic from that position.

12 Q. I thought yesterday you told us that is where you were?

13 A. I said yesterday that I was there, but I did not say which was the

14 position from which I saw Dusko Tadic.

15 Q. The note I have, because you were asked to position yourself as to

16 where you were when you said you saw him, was that you were usually,

17 if we look at the entrance of cell 2, the far right corner of that

18 room, and you were in cell No. 2 on that day.

19 A. That day I was in cell No. 2 and I did not see Dusko Tadic from that

20 corner, but I did see him from another corner. To put it very simply,

21 from my corner it would be to the right, as one looks towards the

22 door, to the right.

23 Q. The number of people in the cell No. 2 on that day, was it about the

24 same number that you have described to us in your evidence?

25 A. Definitely plus or minus 20 or 30 persons, roughly.

Page 2388

1 Q. How could you see that he drove off in a van?

2 A. This is a situation which, perhaps, has never been described before,

3 this overall, I mean, curiosity, in this case with Dusan Tadic and how

4 we found out when he came, when he left, more or less it was like

5 this. People who know some of the people who come, Dusan Tadic in

6 this case, they were people from Kozarac and I am confident that

7 Kozarac knows him 100 per cent, 99 per cent.

8 What is the first thing said how the information is passed

9 from one person to another? Well, that is, "Here comes Tadic", and

10 then the information from one person to another, to a third, a

11 prisoner, and that is how it would come to the whole room. Further

12 on, there are always people who had come out to cast a look to see if

13 that was that. Then how I saw the van leaving the room, well, it was

14 the reverse sequence of events. He is leaving and we were all very

15 happy because all of us in the camp were afraid of people whom you

16 knew and people who knew you and were of the Serb origin.

17 MR. KAY: Thank you. I have no further questions.

18 THE PRESIDING JUDGE: Mr. Tieger, do you have redirect?

19 MR. TIEGER: Thank you, your Honour.

20 Re-examined by MR. TIEGER

21 Q. Mr. Q, I want to ask you a few questions about something that you

22 were asked about yesterday and that is the discussions you had in

23 Zenica after you had arrived in free territory. First of all, do you

24 recall having some discussion with the representative of the

25 Commission on War Crimes in Zenica?

Page 2389

1 A. Yes, that is correct.

2 Q. When had you arrived in Zenica or how long had you been in Zenica

3 before that conversation?

4 A. As far as I can remember, when did I come to Zenica, it ought to have

5 been 23rd August.

6 Q. The date on the document that was shown to you yesterday indicated

7 that the discussion took place on (redacted), is that correct?

8 A. Yes.

9 Q. Is that generally consistent with your recollection that you talked

10 with someone shortly after your arrival in Zenica?

11 A. Yes.

12 Q. That would have been less than a week after you left Trnopolje camp

13 and travelled through Vlasic and escaped the Vlasic mountain massacre?

14 A. Yes.

15 Q. Can you describe how you were feeling at that time and what you were

16 thinking about during those first few days after your release from

17 camp and your arrival in free territory?

18 A. To put it very simply, on 21st August will be my second birthday.

19 That is certain. Secondly, my feelings, it is very difficult to

20 describe, but after those several months of captivity, when you look

21 at the conditions you are in, what you were fed, how you were kept

22 there in captivity, and if you look at a young married couple, a

23 couple of a man and a woman holding hands freely without fear, and how

24 those same people go to a pub to have a good time, to make a joke,

25 that is something completely different.

Page 2390

1 Finally, there is no need to talk about it so much. I did not

2 long for all that. I longed for something more than that. To put it

3 simply, current, there was a day all around me and yet it was night

4 outside. I had got unused to the light, to current during that recent

5 period in my life, a television set, a video recorder. It is hard to

6 explain this because this is all that I used to have beforehand and I

7 knew what those things were and I was learning about them, I knew,

8 and I say simply I was born again.

9 Q. Sir, our translation says "current", by "current" did you mean

10 electricity?

11 A. Yes, I mean electric current.

12 Q. So part of what was happening in that period is that you were amazed

13 to see electricity again? Were you able to have meals for the first

14 time in months?

15 A. Could I eat? I experienced a happy moment in that place where I

16 stayed for a while, that is, in this primary school. People who

17 already were refugees there, they were already fed up with rice which

18 was not even cooked very well, nor was it spiced properly, but today I

19 still dislike rice. Why? Because for a month I had two meals a day

20 and I ate eight platefuls of rice, well cooked rice.

21 Q. Were you able to sleep for the first time without fear that you might

22 be beaten or killed?

23 A. This is incomprehensible really, what I am going to say. I knew I was

24 free, but those first days I could not sleep because that was not what

25 I was accustomed to. I was accustomed to the possibility that I could

Page 2391

1 be called out whenever I closed my eyes, and there must have been

2 something in my head that I was watchful all the time, on the alert

3 all the time, and during those first days I simply could not get rid

4 of that thought that I could sleep normally again, that I would fall

5 asleep and to know that I would wake up.

6 Q. Were you staying at a refugee centre?

7 A. Yes, that was the primary school in the village of Skrgo.

8 Q. Did you go to seek someone out to tell them the details of what had

9 happened to you or did someone in the refugee centre approach you and

10 ask to talk about Kozarac?

11 A. There was no need to look for somebody. The information about me,

12 not about me, but about an individual who had arrived from captivity,

13 that information spread around. There were times when 15 to 20

14 journalists cameramen, photo reporters would come, and I do not know

15 who else came to that primary school in the village of Skrgo.

16 Q. On the occasion shortly after you arrived that you spoke to the

17 representative of the centre for investigating war crimes, did she

18 take you aside along with another person?

19 A. Yes, the statement we made, I and another chap who had also crossed

20 the Vlasic, was in another room. With that person there was another

21 person from the same centre.

22 Q. During the time shortly after you had arrived, were people interested

23 in you because of your survival of the Vlasic Mountain massacre?

24 A. Yes.

25 Q. Was their interest in talking to you about Kozarac somewhat

Page 2392

1 incidental to their interest in what happened in Vlasic?

2 A. Immediately after I crossed with that convoy the news arrived about

3 those 250 men taken off Vlasic, and it was then at that moment, boom,

4 people started asking around and what has happened to those 250.

5 Within the concept of looking for these people, some information was

6 got out of the man who had made that statement, that statement about

7 250 men that he knew about.

8 Q. On the occasion when the statement or document that you were shown

9 yesterday from the centre for investigating war crimes was taken, the

10 person speaking to you was also interested in finding out some things

11 that had happened in Kozarac, is that right?

12 A. Yes.

13 Q. She talked to you and Husein whose last name is not listed here about

14 what happened in Kozarac in addition to other things?

15 A. Yes.

16 Q. Did she speak to you both at once, together at the same time?

17 A. Yes, our conversation was more or less as follows. To try to explain

18 it, I would be talking about one thing. I would say I am talking

19 about from one to three and what happens then, and that chap Husein

20 talks about item three to four and I will go on saying from four to

21 six, and then he will take over and recount seven to eight. That was

22 the sequence. That was how that statement was taken.

23 Q. Did she write down things, some things as you talked and write down

24 some things as he talked?

25 A. Yes.

Page 2393

1 Q. How long did you and this other fellow talk to her?

2 A. If we are talking about a maximum that could have been, it could not

3 have been more than an hour and a half, and that is too much.

4 Q. Was it your intention at that time to give her all the details of

5 everything that had happened to you during that maximum period of an

6 hour and a half when you were talking with somebody else?

7 A. No.

8 Q. How did the discussion end? Did she just say she was finished talking

9 with you?

10 A. Well, along those lines. Simply that these are all different

11 segments, different parts and you have reached the free territory.

12 Q. Did she ask you to review the document to make sure that every detail

13 of what had happened to you was in there, or that everything that she

14 had written down about what you and Husein were saying was accurate or

15 known to you?

16 A. I do not remember exactly if I read it. I do not think so. I cannot

17 give you an exact answer. I do not remember.

18 Q. Now you were shown -- let me ask you this. While you were in Zenica

19 did anyone ever type out a statement as you were talking to them?

20 A. It happened only once throughout my statement.

21 Q. When was that?

22 A. It was when Mr. Keegan and Mr. Tieger came to my home. That was the

23 only statement typed, and a sheet of paper produced with some date,

24 with some information and in no other case.

25 Q. Now the second document that you were shown yesterday by Mr. Kay was

Page 2394

1 a typed document and that would be No. D10. Can that be shown quickly

2 to the witness, please? Was that document prepared in front of you as

3 you were speaking to somebody?

4 A. No, by no means.

5 Q. Would it then have to be some kind of account taken later from some

6 other source about, following some conversation?

7 A. Very likely.

8 Q. Now this document, if you could look at the first line, or actually

9 the following, the date that is given on May 26th 1992, first of all

10 it indicates that the shelling took place on May 26th 1992. That is

11 not an accurate date, is it?

12 A. True.

13 Q. Then it goes on to say that in Serbo-Croat: "U Kozarcu je bila kao."

14 Does the word "kao" in that statement indicate "something like" or

15 "sort of"?

16 A. Yes.

17 Q. So does this document indicate that in Kozarac there was something

18 like a defence?

19 A. Yes.

20 Q. Does the statement also indicate or this document also indicate that

21 this thing that was "something like a defence" had a few guns.

22 A. Yes.

23 MR. KAY: I think I can assist the court because I have had English

24 translations copied of the documents that are now being looked at. I

25 can see it is very difficult to get over the sense of the words, and

Page 2395

1 these are available for the Bench of both these documents.

2 THE PRESIDING JUDGE: There are translations and there are translations.

3 At the present time you have offered for identification purposes

4 Defence 9 and 10. I do intend to ask you whether you wish to tender

5 those into evidence and then I will rule on that. At the present time

6 they are just in for identification purposes. It would be very

7 improper for a translation done by someone to come in unless you are

8 going to explain where it came from. But it is now time for lunch.

9 How much longer do you think you have on redirect, Mr. Tieger?

10 MR. TIEGER: Not that much longer, your Honour, but I would not hold up

11 lunch. I think it will be long enough.

12 THE PRESIDING JUDGE: Perhaps the two of you can confer regarding the

13 translation, and if the Defence wishes to offer 9 and 10 perhaps an

14 agreement can be reached as to the contents of translation. That

15 would help us if 9 and 10 are admitted.

16 Thank you. We will stand in recess until 2.30.

17 (1.04 p.m.).

18 (Luncheon Adjournment).


20 (2.30 p.m.) PRIVATE

21 THE PRESIDING JUDGE: Mr. Tieger, would you like to continue, please?

22 MR. TIEGER: Yes, your Honour. (To the witness): Sir, when we broke for

23 lunch I was asking you about one of the two documents you were shown

24 yesterday that contained the word "kao" in describing the nature of

25 any defence that existed at Kozarac? When you were asked about that

Page 2396

1 ----

2 THE PRESIDING JUDGE: Can you hear?

3 THE WITNESS: Can I take a little walk? My leg is stiff.

4 MR. TIEGER: Your Honour, before the court entered, the witness was sort

5 of in contortions trying to relieve some obvious pain.

6 THE PRESIDING JUDGE: We will stand in recess for -- I would rather that

7 we stand in recess for five or 10 minutes than for him to walk around?

8 He may have to do something else. Will walking just help you, sir?

9 THE WITNESS: Just walking, it does not matter, I know what has happened.


11 MR. TIEGER: Thank you, your Honour. (To the witness): Sir, are you

12 ready to proceed?

13 A. I am.

14 Q. Yesterday, Mr. Kay asked you some questions about that document based

15 on an English translation from which he was reading. He asked you

16 with reference to this particular sentence, and reading from the

17 translation, about the accuracy of a statement which said: "Kozarac

18 was shelled at 13.45 on 26th May 1992 and the defence of Kozarac was

19 ready and consisted of men who had organised themselves on their own

20 and had a few guns". The question went on to have other details that

21 are contained in document 10. When he asked you whether or not that

22 account fitted the information you provided the court, you indicated

23 that it partly agreed. Do you recall that?

24 A. Yes, I remember that.

25 Q. Is one way in which that document only partly agreed, the fact that

Page 2397

1 you were not aware of an organised or formal defence in Kozarac before

2 the attack?

3 A. What I meant was some sort of defence that existed but what kind of

4 defence, I do not know.

5 Q. Was the defence that you were aware of those guardings of the

6 institutions which you related to the court yesterday?

7 A. Yes, this is part of that defence.

8 Q. The most you saw in Kozarac before the war was something like a

9 defence rather than a formal organised defence; is that what you were

10 trying to indicate to Mr. Kay yesterday?

11 A. Yes, exactly that.

12 Q. Would that have been easier if the translation upon which Mr. Kay was

13 relying had included the word "kao" or a reflection of the word "kao",

14 that is, an indication that the document itself indicated only

15 something like a defence?

16 A. Exactly that.

17 Q. The group which you joined to guard the hospital had already been

18 formed before you joined, is that right, before you were invited by a

19 neighbour to do so?

20 A. Yes.

21 Q. Did you have any part in the organisation of that group?

22 A. I did not take part in organising this group.

23 Q. You did not participate or were not involved in any training with the

24 group after you joined it?

25 A. No.

Page 2398

1 Q. So, you did not know how the group had been organised and you did not

2 participate in any training after you became a part of the group?

3 A. That is right.

4 Q. Had you heard from other people or in the town about a Captain

5 Cirkin?

6 A. I have.

7 Q. You were asked yesterday questions about Captain Cirkin.

8 A. Yes.

9 Q. You were asked about statements which were allegedly made to people

10 in the War Crimes Commission in Zenica and that were contained in this

11 document. You were asked if Captain Cirkin had organised the group.

12 Do you recall that? Do you recall being asked that?

13 A. Yes.

14 Q. Do you recall if Captain Cirkin trained the group?

15 A. I only heard that, but I do not know that for a fact.

16 Q. So you had heard information about Captain Cirkin, but you were not

17 involved in the organisation of the group or the training of the

18 group. Is that what you were trying to indicate to Mr. Kay yesterday?

19 A. Exactly that.

20 Q. Would it have been easier if he had been referring to a document

21 which had been produced in front of you and was not typed at some

22 later time? Do you have any idea when the typed document that was

23 shown to you yesterday was prepared or who prepared it?

24 A. No.

25 Q. Did you yourself see any indications of an organised and formal

Page 2399

1 defence in Kozarac before the war?

2 A. No.

3 Q. When you first got to the forest was there an organised or formal

4 defence?

5 A. No.

6 Q. Before the break Mr. Kay asked you some questions about Keraterm on

7 the occasion when you saw Dusko Tadic come to Keraterm. I would like

8 to ask you a few more questions than you were asked then. First of

9 all, you indicated that your usual place in cell 2 was toward the

10 right rear?

11 A. Yes.

12 Q. I would like you to tell the court, if you will, where you were when

13 you first became aware that Dusko Tadic was in Keraterm that day?

14 A. I was still in my corner where I usually was. The news that I heard

15 was that Dusko Tadic arrived, "Dusko Tadic is here". After that, I

16 simply moved from my position to the large wall and then I glanced

17 towards the exit doors of the cell No. 2, and this is where I saw him.

18 This is the direction in which I saw him and then I went back. After

19 that I immediately went back to my place, mostly hiding from him

20 because I did not want him to detect me because he knows very well

21 that he knows me, just as I know that I know him, and that is because

22 all of us inmates was afraid of those people that knew us inmates.

23 I mean, what I mean is that if I knew some Serbs and I knew

24 they knew me, then at all times I was trying to hide from them, so

25 that they do not detect me because this simple fact has taken many

Page 2400

1 lives in Keraterm and all other camps.

2 Q. So on this occasion you both heard that Dusko Tadic was in Keraterm

3 and then you also saw him with your own eyes?

4 A. Exactly.

5 Q. Was there another occasion on which you heard that Dusko Tadic was in

6 Keraterm?

7 A. Yes, there was another occasion when I heard that Dusko had come to

8 the camp.

9 Q. Was that an occasion on which prisoners from Kozarac were called out

10 and beaten?

11 A. Yes, exactly.

12 Q. Did the prisoners who were called out and beaten come back into the

13 room immediately and relate to others what they heard?

14 A. They did not come back immediately, but they did come back, and they

15 related who was there.

16 Q. Did you hear that Dusko Tadic had been in Keraterm?

17 A. Yes.

18 Q. And had participated in these beatings as the prisoners returned to

19 the room?

20 A. Yes, exactly so.

21 Q. But you did not actually see him with your own eyes on that occasion?

22 A. No, I did not see him with my own eyes.

23 Q. That is the difference between that occasion when you were sure that

24 Dusko Tadic had been in camp and on the other occasion on which you

25 are sure he was in Keraterm?

Page 2401

1 A. Yes.

2 Q. When the Tribunal representatives came to see you, did you indicate

3 to them that there were two occasions on which you were sure Dusko

4 Tadic was in Keraterm?

5 A. As far as I remember, I do not remember that I said two times.

6 Q. But, in any event, there was one time in which you heard that Dusko

7 Tadic was in Keraterm and one time on which you first heard and then

8 saw with your own eyes that he was there?

9 A. Exactly so.

10 MR. TIEGER: That is all I have, your Honour, thank you.


12 MR. KAY: Thank you, your Honour.

13 Further Cross-examined by MR. KAY

14 MR. KAY: Just a few matters, Mr. Q. Your Honour, the Prosecution and

15 Defence have spoken about the translations of those statements in the

16 luncheon adjournment and, as I understood it, they were not opposed.

17 So I tender them as exhibits before the court and copies have been

18 made for your Honours of each statement.

19 THE PRESIDING JUDGE: You will offer Defence 9 and Defence 10 and then, I

20 gather, you have statements for both of those?

21 MR. KAY: Yes.

22 THE PRESIDING JUDGE: Do you want a number -- I was going to suggest you

23 can number 9A, if you wish, and then B, the English translation, then

24 10A the Serbo-Croat and 10B the English translation. Mr. Tieger ---

25 MR. KAY: That is exactly it.

Page 2402

1 THE PRESIDING JUDGE: -- do you have any objection?

2 MR. TIEGER: Just to clarify. I do not have any objection for the limited

3 purpose I understand they are being used. It seems to me important in

4 the light of our statutory restrictions, however broad those may be,

5 to indicate that there is always concern when a document or documents

6 which the Prosecution considers unreliable, and which have been shown

7 to be unreliable, are admitted for broad purposes. But, for the

8 limited purposes to which they have been put here, and to aid the

9 court in understanding that, it seems to me that we would have no

10 objection but -----

11 THE PRESIDING JUDGE: We will admit them and remember your redirect

12 regarding them. I understand what you are saying. So 9A and 9B will

13 be admitted and 10A and 10B will be admitted.

14 MR. KAY: Your Honour has before you what I would call 9B. (Documents

15 handed) The second statement is 10B. If Exhibit 9A could be put

16 before the witness? (Exhibit 9A was handed to the witness) There is

17 no need to put it on the screen because their Honours have a copy.

18 (To the witness): This is the document, Mr. Q, (redacted)

19 (redacted) taken at Zenica and the subject was the testimony of you and

20 someone called Husein concerning Chetnik crimes committed in and

21 around the village of Kozarac, is that right?

22 A. Yes.

23 Q. If we go to the end of this document and you go to the end of your

24 handwritten document, it is signed by you alone and not by Hussein, is

25 that right?

Page 2403

1 A. There is a signature here, but I do not recognise this as my

2 signature here.

3 MR. TIEGER: Your Honour -----

4 THE PRESIDING JUDGE: Which exhibit is that? Is that 9B, or I guess that

5 is the Serbo-Croat.

6 MR. KAY: He is looking at 9A in Serbo-Croat, your Honour.

7 MR. TIEGER: Your Honour, I have had an opportunity to see the original

8 very recently and that portion is not cut off in the original and it

9 shows another signature. We will have a better copy made for the

10 court, I should advise counsel, and produce it immediately. In any

11 event, there are two signatures; the second signature, as I see it, is

12 "Husein" and his last name.

13 MR. KAY: Fine. That is accepted.

14 THE PRESIDING JUDGE: So 9A then, this witness did not sign?

15 MR. KAY: They both signed it. Is that right? Perhaps Mr. Tieger would

16 be able to help me whether they both signed it?

17 MR. TIEGER: There are two names that appear on there. I think the

18 witness has already testified with regard to questions about signing.

19 THE PRESIDING JUDGE: Yes, I understand. He said he did not recognise

20 that as his signature. That is 9A. But on 9B, the English, on the

21 bottom you have signature of the citizen and you have this witness's

22 name, but the "Husein", his name, you have not typed that he also

23 signed it.

24 MR. KAY: It has not been typed on the document.

25 MR. TIEGER: Your Honour, it is, presumably, a reflection of the same

Page 2404

1 problem that has just occurred, and that is that that portion of the

2 document was only very partially copied.

3 THE PRESIDING JUDGE: You will provide a full copy to show the signature

4 on 9A, the other signature, is that not so?

5 MR. TIEGER: That has just been provided.

6 THE PRESIDING JUDGE: Then I suppose we will either receive another copy

7 of 9B or just assume for ourselves that there is another signature on

8 9B which is in English.

9 MR. KAY: Just assume, and the point I was going to make of being one

10 signatures goes.

11 THE PRESIDING JUDGE: Very good. Thank you.

12 MR. KAY: All right. (To the witness): But in this document, Mr. Q,

13 there is no mention of Vlasic at all which, you told us, was the

14 purpose of your being interviewed. It is not mentioned at all. Would

15 you care to look through and see if I am wrong about that?

16 A. If you went through with this document then there should not be any

17 problems.

18 Q. Yes. That can be checked if I am wrong. There is no need to stay on

19 it any longer than is necessary.

20 Thank you. I have no further questions.


22 MR. TIEGER: Nothing further, your Honour.

23 Examined by the Court

24 JUDGE STEPHEN: Mr. Q, I had two questions to ask you. The first one is

25 about the condition of your town. We have seen these films of it.

Page 2405

1 Were they the effect of the shelling on 24th and 25th or was there a

2 great deal of subsequent damage done to all the houses by blowing up

3 or burning later than the shelling?

4 A. Your Honour, if you wanted to hear very brief information that I

5 never mentioned before? From the shelling of the Kozarac, all those

6 houses were not destroyed in the same way. I happened to be in

7 situations where I could roughly describe to you that day, one day, I

8 mean, from the morning until the sunset. It would begin more or less

9 as follows:

10 In places where the Serbs had already dug their strong

11 positions, very early in the morning, around 8 o'clock when the day

12 would break out, in a part of Kozarac we called them sokaci, side

13 streets, APCs would come and men getting off those APCs who looted and

14 took things out of private houses after that, and all this takes place

15 between six and seven hours.

16 Then in the afternoon around 3 o'clock, but it does not really

17 matter, another group arrives with trucks, with largish trucks. There

18 were even tractors, and all sorts of vehicles, except passenger cars,

19 and those same things -- those people, I forgot, I am sorry, those

20 people piled all those things up, all those things that they got out

21 of those private houses, they would pile them up in a place and then

22 this second group would arrive to collect all those things, and load

23 them on to those vehicles and then took them away from Kozarac.

24 Then a third group would arrive dressed in -- as a matter of

25 fact, they sprayed all those same houses with something, with some

Page 2406

1 kind of sprays, we called them brente, and set them on fire. Then

2 they would leave immediately after finishing their business. There

3 were also instances when the third group, what they did, they would

4 throw a bomb into one or into several houses, or mine them, and that

5 is why you could see those pictures, those photographs, of Kozarac as

6 you saw them.

7 Q. You saw this during the days when you were in the forest? That is a

8 question.

9 A. Quite so. Then not at the very outset of the war, as I put it, but

10 some seven days later, perhaps five or seven days later. That is when

11 it started.

12 Q. Thank you. The other question I wanted to ask you was near the

13 church, was there any street lighting?

14 A. Yes, your Honour, Kozarac and main thoroughfares, the larger streets,

15 were all lighted.

16 Q. Did that cast light on the surroundings of the church?

17 A. Yes.

18 JUDGE STEPHEN: Thank you.

19 THE PRESIDING JUDGE: Who is the "they" that you were referring to in

20 response to Judge Stephen's question? You went on for several

21 paragraphs, according to this transcript, talking about it, but who is

22 the "they" who were doing those things?

23 A. In some cases, depending on the situation, sometimes I said "they",

24 presumably, it meant in the majority of cases Serbs. In all

25 likelihood, in most of the cases, it meant Serbs. That was how my

Page 2407

1 answer and the question was phrased in that way.

2 Q. You indicated when you were at Keraterm that you made a list of the

3 people who were in cell 2, 500 some persons, I forget the exact

4 number. What was the ethnicity of those persons?

5 A. 572. In the cell No. 2, there were 572 persons that day. 98 per cent

6 of them were Muslims and two per cent Croats.

7 Q. Were there any Serbs detained there?

8 A. No.

9 THE PRESIDING JUDGE: Mr. Tieger, do you have additional questions?

10 MR. TIEGER: Just one.

11 Further re-examined by MR. TIEGER

12 Q. Do you recall approximately when that list was prepared?

13 A. In the list for cell No. 2?

14 Q. Yes.

15 A. I should say, let me tell you, roughly, if we use the massacre

16 perpetrated in cell No. 3 when people from Hambarine came as a

17 reference, then it was immediately before they arrived, perhaps not

18 more than seven days before they came, that would be the period before

19 Hambarine arrived.

20 THE PRESIDING JUDGE: Mr. Kay, do you have additional questions.

21 MR. KAY: There is one matter arising, your Honour.

22 Further cross-examined by MR. KAY

23 Q. Is there street lighting at the back of the church?

24 A. No, not behind the church.

25 MR. KAY: Thank you.

Page 2408

1 THE PRESIDING JUDGE: Mr. Tieger, I suppose I should ask you, would you

2 like to have any more questions of this witness?

3 MR. TIEGER: Very kind of you to ask, your Honour, no.

4 THE PRESIDING JUDGE: Very good. Is there any objection to this witness

5 being permanently excused?

6 MR. KAY: No, your Honour.

7 THE PRESIDING JUDGE: Very good. You are permanently excused so you are

8 free to leave. Thank you very much for coming.

9 THE WITNESS: Thank you.

10 (The witness withdrew)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

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Page 2414

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2 (redacted)

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7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 THE PRESIDING JUDGE: Very good. Miss Hollis, would you call your next

13 witness please?

14 Miss Hollis: Yes, Your Honour. We would call Azra Blazevic.

15 (Open Session)

16 AZRA BLAZEVIC was called.

17 THE PRESIDING JUDGE: Would you take that oath please, ma'am?

18 THE WITNESS [In translation]: I solemnly declare that I will speak the

19 truth, the

20 whole truth and nothing but the truth.

21 (The witness was sworn)

22 THE PRESIDING JUDGE: You may be seated.

23 Examined by MISS HOLLIS

24 Q. Would you please state your full name?

25 A. Azra Blazevic.

Page 2415

1 Q. What is your date of birth?

2 A. 14th November 1959.

3 Q. What is your ethnic group?

4 A. Muslim.

5 Q. Where were you born?

6 A. Born in Prijedor.

7 Q. Is that the town of Prijedor?

8 A. Yes.

9 Q. How long did you live in Prijedor?

10 A. Until 1986.

11 Q. In 1986 where did you move?

12 A. To Kozarac.

13 Q. How long did you live in Kozarac?

14 A. From 1996 (sic) to the outbreak of the war in 1992.

15 Q. I am sorry, was that from 1996?

16 A. From 86, I am sorry.

17 Q. Are you married?

18 A. Yes.

19 Q. What is your husband's name?

20 A. Ermin Strikovic.

21 Q. What is your husband's ethnic group?

22 A. Muslim.

23 Q. What was your previous occupation?

24 A. Veterinarian.

25 Q. Where did you study veterinary medicine?

Page 2416

1 A. Sarajevo.

2 Q. Where did you practise veterinary medicine?

3 A. Kozarac.

4 Q. Where was your practice located in Kozarac?

5 A. Surgery was in Kozarac, at the entrance into Kozarac, between the

6 sawmill building and the soccer field.

7 MISS HOLLIS: If I could ask that the witness be provided with Prosecution

8 Exhibit 196 which was the map of Kozarac, please? If that could,

9 please, be put on the overhead projector?

10 (To the witness): Mrs. Blazevic, in your practice as veterinarian, did

11 people commonly refer to you as "Dr. Blazevic" or "Mrs. Blazevic"?

12 A. They usually called me "Azra".

13 Q. Perhaps I will call you "Dr. Blazevic". Could you please look at

14 Prosecution Exhibit 196, this map, and if we would use the football

15 field on the map as a point of reference, could you please show the

16 court where your clinic was located?

17 A. The clinic was here. (Indicated)

18 Q. Where did you live in Kozarac?

19 A. In the building of the veterinary clinic.

20 Q. All right. Then looking at the football field and you pointed to a

21 position just beneath the football field as your clinic, is that

22 correct?

23 A. Yes. Yes.

24 Q. Then if you would look below that to a road that runs from the left

25 on the map down toward the right, was this road sometimes referred to

Page 2417

1 as the new Prijedor/Banja Luka highway?

2 A. If you mean this road here, then, yes, that is the new road to Banja

3 Luka.

4 Q. In which direction would Banja Luka be on this map, then?

5 A. (Indicated) Here.

6 Q. Which direction then would Prijedor be?

7 A. Here.

8 Q. The street that runs in front of the location of your house and

9 clinic and the football field and continues up toward the mosque, was

10 this the main street, the main business street, of the town of

11 Kozarac?

12 A. Yes, it is the street which goes through the centre of Kozarac.

13 Q. Was this street at some point at least referred to as the Marsala

14 Tita Street?

15 A. No.

16 Q. This main street going to the mosque?

17 A. No, perhaps it has a different name. The high street, the main

18 street, begins from this intersection here and then led onward to

19 Kozara.

20 Q. Where is the Marsala Tita Street on this map?

21 A. From here upward.

22 Q. Then that portion of the street as it runs from this intersection

23 down past your house, what was that called?

24 A. I cannot remember.

25 Q. All right.

Page 2418

1 A. I received all the mail and everything else came to the veterinary

2 clinic in Kozarac. It could have been Omladinska Street.

3 Q. All right. Now if you would please look at the map again and, using

4 the school as a reference, we see a triangular intersection there, do

5 you see that?

6 A. Yes.

7 Q. This road that runs through that triangular intersection there, was

8 this sometimes referred to as the old Prijedor road?

9 A. Yes.

10 Q. If we were to go back to your house and, instead of going up the main

11 street toward the mosque, we were to go in the opposite direction and

12 follow this road as it crosses over the new Prijedor highway, that

13 would lead us where? That road led where?

14 A. This road here leads to Trnopolje.

15 Q. Then if we are looking at this map and we look at the drawing with

16 the "H" inside, was that the medical centre in Kozarac?

17 A. Yes.

18 Q. The mosque that is marked on this map, what mosque was that?

19 A. It would be Mutnik mosque.

20 Q. Then if we look at the building that is marked as a motel, was this

21 the building that was used as a temporary medical facility during the

22 attack on Kozarac?

23 A. Yes.

24 Q. Thank you. Dr. Blazevic, did you practice only in the town of

25 Kozarac or did you have a certain area, a geographic area, within

Page 2419

1 which you practised?

2 A. I was covering a large area that belonged -- it was a wide, much

3 wider area than just the town of Kozarac and that was covered by the

4 clinic in Kozarac.

5 MISS HOLLIS: If the witness could be provided with Prosecution Exhibit

6 79, and if the Prosecution Exhibit 196 could remain with the witness

7 but on the witness table, please? (To the witness): Could you please

8 look at that map for a moment to familiarise yourself with it? If

9 that could be put on the overhead projector, please? Dr. Blazevic,

10 using this map, could you point out to the court the rough area within

11 which you practised veterinary medicine?

12 A. It would be here if -- if we take, if we picture that this is the

13 centre of Kozarac, then the area in which I worked towards Prijedor

14 came up to the road that led to Gornje Garevci and that would be the

15 road, this would be this road here. This is the road that leads

16 upward.

17 If we went towards Banja Luka, the last area that I covered

18 was the area of Jakupovici village, and that would be the road that is

19 here. In the direction from Kozarac to Trnopolje, it would encompass

20 all area of -- all of the Trnopolje area and then also the whole

21 territory around Kozarac, up to Kozara and up to Mrakovica, up to

22 those hills.

23 Q. Within this geographic area that you have just discussed, did your

24 veterinary practice take you frequently into the villages within that

25 area?

Page 2420

1 A. Yes.

2 Q. Did you come to know many of the inhabitants of those villages

3 through your veterinary practice?

4 A. Yes.

5 Q. Within that geographic area that you have outlined, what was the

6 predominant ethnic group or groups who inhabited those villages?

7 A. Muslim.

8 Q. Was Omarska within your geographic area?

9 A. No.

10 Q. Did you make frequent visits to Omarska for other than business

11 reasons?

12 A. No.

13 Q. Did you visit Omarska at all, the village of Omarska?

14 A. Yes.

15 Q. How frequently would you visit that village?

16 A. Not that often.

17 Q. To your knowledge, how far from Kozarac was the village of Omarska?

18 A. 11 kilometres.

19 Q. How far was Kozarac from Prijedor?

20 A. Also 11 kilometres.

21 Q. If you look again on the map, could you show us, is what is marked

22 "4" on the map which we say was sometimes called the new

23 Prijedor/Banja Luka road?

24 A. It would be this road here.

25 Q. That is a road that has the numerical designation of "4" at some

Page 2421

1 point on the road?

2 A. Yes.

3 Q. When you talked about the old Prijedor road, could you show us where

4 that would be on this map?

5 A. It would be this road here.

6 Q. So that road led in one direction to Prijedor and in the other

7 direction it led to where?

8 A. One direction to Prijedor and the other direction went to Banja Luka

9 -- a long time ago. I do not know if this is still so.

10 Q. All right, thank you. Dr. Blazevic, how far was Kozarac from

11 Trnopolje?

12 A. Six kilometres.

13 Q. I believe you indicated that that village was within your geographic

14 area, is that correct?

15 A. Yes.

16 Q. To your knowledge, what was the ethnic composition of the village of

17 Trnopolje?

18 A. Also mostly Muslim, majority of Muslim population.

19 Q. You have indicated that you lived in Kozarac from 1986 until the

20 attack on Kozarac. When we speak of Kozarac, there was first the town

21 of Kozarac which was fairly small, is that correct?

22 A. Yes.

23 Q. Do some people also refer to a larger Kozarac area which would mean

24 not just the town but also some surrounding villages?

25 A. Yes.

Page 2422

1 Q. During the course of your living in Kozarac, would you go through

2 this main part of town on a daily basis?

3 A. Yes.

4 Q. Did you know many of the people who lived in the town of Kozarac?

5 A. Yes.

6 Q. To your knowledge, how well did the people in the town of Kozarac

7 know their neighbours?

8 A. Fairly well.

9 Q. If you know, what was the ethnic composition of the town of Kozarac?

10 A. Majority of Muslim population.

11 Q. While you lived in Kozarac did you know Dusko Tadic also known as

12 Dule Tadic?

13 A. Yes.

14 Q. How did you know him?

15 A. Superficially, as one of the inhabitants of Kozarac.

16 Q. How would you characterise your relationship with Dule Tadic? Would

17 you say you were friends, you were acquaintances, you knew each other

18 in passing? How would you characterise that?

19 A. We knew each other by passing.

20 Q. On an average during the time you lived in Kozarac, how frequently

21 would you say that you saw Dule Tadic, for example, in a week, how

22 frequently would you see Dule Tadic?

23 A. I did not pay attention to this. I had an every day opportunity to

24 see him, maybe even a few times a day.

25 Q. Over what period of time did you have this passing acquaintance with

Page 2423

1 Dule Tadic, over how many years?

2 A. Probably all of the time, the whole time since I started working in

3 Kozarac.

4 Q. To your knowledge, where was the house of Dule Tadic in relation to

5 your house?

6 A. In relation to my house, the house of Dule Tadic was in the direction

7 when you went through the centre of Kozarac, it was on the right-hand

8 side of the road somewhere approximately across from the pharmacy or

9 maybe a little bit higher than that.

10 Q. About how far would that be from your house, if you could estimate

11 that?

12 A. My personal view, maybe a couple of hundred metres.

13 Q. To your knowledge, did Dule Tadic have a restaurant or a cafe in

14 Kozarac?

15 A. Yes.

16 Q. Where was that cafe located, if you know?

17 A. This cafe was located in front of the house.

18 Q. I would like to show you a video tape of a portion of Kozarac. So if

19 Prosecution Exhibit 195 could be started at the place that I

20 indicated, please? We are going to be stopping at various points and

21 I will ask you to identify structures, if you can. So if we could

22 start that video, please? Do we have that video ready to play?

23 (The video was played)

24 If we could stop the video here, please? Could you tell us

25 what this building is?

Page 2424

1 A. This is Mutnik mosque.

2 Q. If we could then, please, move the video to the return trip on the

3 other side of the street, please? If you could stop the video there,

4 please? Can you tell us what was located in this building?

5 A. This building was the pharmacy of Kozarac, barber shop and a store.

6 Q. If we could go forward, please? If we could stop the video here,

7 please? What is this building?

8 A. This is the elementary school in Kozarac.

9 Q. If we could go forward, please? If we could stop the video here? Is

10 this the triangle intersection on the map where what is called the old

11 road, old Prijedor road, would come into the town?

12 A. Yes.

13 Q. If we could continue, please? If we could stop the video here,

14 please? Pause it. What is this building, this red building?

15 A. This is an office that was built by one of the sons of Bozo

16 Dragicevic.

17 Q. Do you know the name of this son of Bozo Dragicevic who built this

18 office?

19 A. I did not know who this belonged to. One of the sons name was

20 "Bosko", and he lived nearby. The other son, I think, was called

21 "Slavko" and I think he worked in Prijedor at the post office.

22 Q. All right. If we could continue, please? This is the red building

23 you were just referring to?

24 A. Yes.

25 Q. Then if we could hold it there, please? This yellowish looking

Page 2425

1 building next to the red building, what building is that?

2 A. This is the house of Bozo Dragicevic.

3 Q. Do you know where Bozo Dragicevic's house was located?

4 A. Yes.

5 Q. Where would that be?

6 A. It is immediately next to this house in the yard that comes after

7 this house.

8 Q. So if we have the red building here and then the yellowish building

9 is Bozo's home, and then next to that not shown on this film clip

10 would be the home of Bozo Dragicevic?

11 A. Yes.

12 Q. If we could move, please, forward? If we could move to the next

13 segment, please? If you could stop there, please? Do you recognise

14 this building?

15 A. Yes.

16 Q. What is this building?

17 A. This is the clinic, medical clinic, in Kozarac.

18 Q. If we could continue with that, please? How was this medical centre

19 situated in Kozarac? Was it set apart at all from the other homes

20 around it?

21 A. Well, it is located in the part of Kozarac where private houses are

22 located and this is the only house of this type in this area and it is

23 located on a very small hill.

24 Q. Thank you. I would like to direct your attention to 30th April 1992,

25 the date that the Serbs -- if we could stop that, please, and that is

Page 2426

1 all I want of that, please -- took over power in the town of Prijedor.

2 How did you find out about that takeover of power?

3 A. I think that I heard it from the workers at the sawmill who came from

4 Prijedor to work in the first shift.

5 Q. Did you shortly after that become aware that Prijedor opstina had

6 been proclaimed as a Serb opstina?

7 A. Something like that.

8 Q. How did you become aware of that?

9 A. People were saying that something is happening in Prijedor, that all

10 around is the army and that at the house of -- municipal house there

11 is a large flag with a typical Serbian sign, and in that place there

12 always used to be the flag of former Yugoslavia.

13 Q. Did you ever hear any type of formal announcement as to why

14 intervention in Prijedor had to occur?

15 A. Later, during the day we heard information on the radio regarding

16 this.

17 Q. What did you hear on the radio?

18 A. We heard information that the army has taken over the power in the

19 municipality of Prijedor, and they were forced to do that because

20 there was an increased danger of, as far as I could remember, Muslim

21 extremists and something similar to this.

22 Q. Did you actually go to Prijedor after the takeover of the town?

23 A. I went the same day.

24 Q. What did you see there that was different than you would have

25 expected to see in Prijedor?

Page 2427

1 A. The city was unusually empty. One could see the military points

2 everywhere and also this flag with four Ss on the building, municipal

3 building.

4 Q. When you say four Ss are you talking about the Cyrillic S?

5 A. Yes.

6 Q. What was the colour of this flag that these four Cyrillic Ss were

7 shown on?

8 A. Blue, white and red.

9 Q. To your knowledge, what flag is that? Those are the colours of what

10 flag?

11 A. Because of the characteristic sign in the middle of the flag, this

12 flag to me represented a typical Serbian flag.

13 Q. You said that the town was empty. Did you see any people at all in

14 Prijedor on that day?

15 A. There were a couple of people there, but the city was unusually

16 empty. Normally -- and this was in the afternoon -- normally,

17 Prijedor is full of people.

18 Q. Here you are talking about full of civilians, is that correct?

19 A. Yes.

20 Q. Did you see any soldiers in Prijedor on that date?

21 A. Yes, no, I am sorry. There must be a misunderstanding. I probably

22 did not understand the question. I said that normally in Prijedor,

23 normally Prijedor in the afternoon hours is full of civilians, but

24 that time when I came to Prijedor one could almost see no civilians in

25 the streets, almost nobody was in the streets except for the army who

Page 2428

1 was in various points that were all over the town.

2 Q. These army personnel that you saw in Prijedor on that date, do you

3 recall what they were wearing?

4 A. Uniforms.

5 Q. Do you recall what kind of uniform they were wearing?

6 A. Military uniforms.

7 Q. Do you have a good memory for different types of uniforms?

8 A. No.

9 Q. Did you recognise any of these soldiers in Prijedor on that date?

10 A. Yes.

11 Q. The ones that you recognised, where were they from?

12 A. From Prijedor.

13 Q. To your knowledge, what was the ethnic group of these soldiers that

14 you recognised?

15 A. Serbs.

16 Q. On that date in Prijedor, did you see any combat vehicles such as

17 tanks or amoured personnel carriers?

18 A. As far as I can remember, no.

19 Q. After this date that you were in Prijedor, did you have occasion to

20 go back to Prijedor after the Serb takeover?

21 A. Yes.

22 Q. On these subsequent trips to Prijedor, did you continue to notice an

23 increased number of soldiers or police in Prijedor?

24 A. Yes.

25 Q. On any of these subsequent trips to Prijedor did you see any combat

Page 2429

1 vehicles?

2 A. No.

3 Q. After the Serb takeover of Prijedor, did the Serbs also take over the

4 leadership structure in Kozarac?

5 A. In Kozarac?

6 Q. In the town.

7 A. No.

8 Q. So the officials in Kozarac remained the same?

9 A. Yes.

10 Q. As for the police in Kozarac, did all of the police remain or did

11 some of the police leave after the Serb takeover in Prijedor?

12 A. As far as I know, everybody remained.

13 Q. After the Serb takeover in Prijedor, did the Serbs in authority there

14 begin to give ultimatums to Kozarac?

15 A. Yes.

16 Q. What were these ultimatums that were given?

17 A. They were giving ultimatums to the effect that government and police

18 in Kozarac should sign a loyalty statement to -- a loyalty statement

19 to the government of Kozarac and take over the insignia, as far as I

20 can remember.

21 Q. To your knowledge, were there any type of orders or ultimatums given

22 that the people in Kozarac had to turn over weapons?

23 A. Yes, as far as I can remember, there were such ultimatums as well.

24 Q. How did you learn about these ultimatums which began after the Serb

25 takeover in Prijedor?

Page 2430

1 A. During that whole period in the month of May, there were negotiations

2 led between official government of Kozarac and Prijedor. Sometimes we

3 could even hear comments on the radio, and most often I heard it from

4 the people in Kozarac who would talk about it.

5 Q. What changes did you notice after the Serb takeover of Prijedor?

6 What changes did you notice in your ability to travel freely in the

7 area?

8 A. The changes were obvious in that there was an increased control at

9 the entry into Prijedor.

10 Q. When you say "increased control", what do you mean?

11 A. I mean that the military checkpoints that were at the entry between

12 the boundary line between Prijedor and Kozarac, they were stopping

13 people -- stopping vehicles, checking the documents, the luggage and

14 so on.

15 Q. What was the name of this control point, if you know?

16 A. It was the checkpoint at Orlovci.

17 Q. At what distance from Kozarac toward Prijedor was this Orlovci

18 checkpoint located?

19 A. Approximately, four kilometres between Kozarac to Prijedor.

20 Q. You indicated, I believe, that the soldiers were the ones who were

21 manning that checkpoint?

22 A. Yes.

23 Q. Did you know any of these soldiers manning that checkpoint?

24 A. Yes.

25 Q. These soldiers whom you knew, where were they from?

Page 2431

1 A. Most often from Prijedor.

2 Q. What was their ethnic group?

3 A. Serbs.

4 MISS HOLLIS: Your Honour, would you like to take the 4 o'clock break now?

5 THE PRESIDING JUDGE: Yes. We will stand in recess until 4.20.

6 (4.00 p.m.)

7 (The court adjourned for a short time)

8 (4.20 p.m.)

9 THE PRESIDING JUDGE: Miss Hollis, you may continue.

10 MISS HOLLIS: Thank you, your Honour. Your Honour, in this high tech

11 environment we operate in, there was a technical glitch earlier, so if

12 I could have the witness shown another portion of Prosecution Exhibit

13 195 which the technicians did not show earlier? So if we could begin,

14 please, with 195?

15 (To the witness): You are switched over to the video, Dr. Blazevic?

16 A. Yes.

17 Q. If we could stop here, please? Do you recognise this structure?

18 A. Yes.

19 Q. What is that structure, if that could be clarified at all, please?

20 A. This should be the cafe of Dusan Tadic.

21 Q. All right. If we could move ahead, please? If we could stop here,

22 please? Do you recognise this structure?

23 A. Yes, this was his house.

24 Q. When you say "his house", whose house do you mean?

25 A. Dusan Tadic's.

Page 2432

1 Q. Thank you. If you could please shut off the film? You were talking

2 about difficulties in movement after the Serb takeover of Prijedor.

3 You mentioned the Orlovci checkpoint as one area where it was more

4 difficult to pass through. Prior to the Serb takeover in Prijedor,

5 was there a checkpoint in the town of Kozarac?

6 A. Yes.

7 Q. Where was that checkpoint located?

8 A. The checkpoint was at the crossroads on the new Banja Luka road and

9 on the road from Kozarac to Trnopolje.

10 Q. If Prosecution 196 could again be put on the overhead projector?

11 Could you please point to the location of that checkpoint?

12 A. It ought to have been here.

13 Q. At the exact intersection?

14 A. Yes, at the intersection, here.

15 Q. Prior to the Serb takeover of Prijedor, who manned that checkpoint?

16 THE PRESIDING JUDGE: For the record, I suppose, that was where now? At

17 the intersection of the football -- intersection of the Prijedor/Banja

18 Luka highway and old, well, no -- that is that street we are not sure

19 of the name of.

20 MISS HOLLIS: Your Honour, the witness pointed at the intersection of the

21 main road that runs through Kozarac as it came past the football field

22 and crossed what is referred to as the new Prijedor/Banja Luka

23 highway, that intersection.

24 THE PRESIDING JUDGE: OK. Excuse me. I am sorry. Put the question

25 again.

Page 2433

1 MISS HOLLIS: Yes, your Honour. (To the witness): Prior to the Serb

2 takeover in Prijedor, who manned that checkpoint at that intersection

3 in Kozarac?

4 A. It was the police checkpoint.

5 Q. The police from where manned that checkpoint?

6 A. It was the police from Prijedor and Kozarac, as far as I know.

7 Q. So that was a mixed checkpoint with personnel from Prijedor and

8 Kozarac manning that checkpoint?

9 A. Yes.

10 Q. After the Serb takeover in Prijedor, who manned the checkpoint at

11 Kozarac?

12 A. Policemen from Prijedor.

13 Q. Did you know any of those policemen who manned that checkpoint after

14 the Serb takeover?

15 A. Yes.

16 Q. Those that you knew, what was their ethnic group?

17 A. Serbs.

18 Q. Were there any other checkpoints in Kozarac itself in the town?

19 A. Yes, there were Territorial Defence checkpoints.

20 Q. Where were those located?

21 A. As a rule, at all relevant crossroads, as far as I can remember.

22 Q. Who would man those checkpoints in Kozarac at the main crossroads?

23 A. Members of the Territorial Defence.

24 Q. When were these checkpoints established?

25 A. I cannot remember the time exactly. It could have been the end of

Page 2434

1 '91 or perhaps early '92.

2 Q. The ethnic group of the people who manned those checkpoints in

3 Kozarac?

4 A. The majority were Muslims but there were other ethnic groups.

5 Q. What other ethnic groups?

6 A. Well, say, Serbs or Croats.

7 Q. Was there any checkpoint located near the medical centre in Kozarac?

8 A. Not that I remember.

9 Q. Was there a time in Kozarac where people began to guard important

10 buildings in Kozarac?

11 A. No, I do not know about that.

12 Q. All right. What was the date that Kozarac was attacked?

13 A. 24th May.

14 Q. Do you recall what day of the week that was?

15 A. Sunday.

16 Q. Prior to this date, prior to 24th May, had you become aware of any

17 blockade of the town?

18 A. Yes.

19 Q. How did you become aware of this blockade?

20 A. Because I was turned back from the checkpoint at Orlovci and told

21 that I could not enter Prijedor.

22 Q. What date was this that this happened?

23 A. It was Thursday ---

24 Q. Why were you going -- I am sorry.

25 A. -- it was 21st May, I believe.

Page 2435

1 Q. When you went to this checkpoint to go to Prijedor, why were you

2 going to Prijedor?

3 A. I was going by car and that was for the veterinary clinic to get some

4 petrol at the petrol station in Prijedor which was the only one.

5 Q. What questions were you asked at the checkpoint at Orlovci?

6 A. I was asked where I was going to and I answered, "Prijedor". They

7 asked me, "Why?" I told them, and showed them the order or, that is,

8 at that time one had to have a certificate, a permission, to get a

9 certain quantity of petrol because there was a shortage of it, and

10 then I was asked where I was coming from and I told him "Kozarac" and

11 then he told me that I could not go through and that I had to go back.

12 Q. While you were at this checkpoint, did you see any other vehicles

13 which were allowed to pass through the checkpoint?

14 A. One vehicle did pass.

15 Q. What type of vehicle was that?

16 A. A passenger vehicle.

17 Q. Was that civilian?

18 A. A car.

19 Q. Was that a civilian vehicle?

20 A. Yes.

21 Q. Did you recognise the vehicle or anyone in the vehicle?

22 A. No.

23 Q. The people who were at the checkpoint at the time you were turned

24 back, what were they wearing?

25 A. Uniforms.

Page 2436

1 Q. Realising that you are not good with uniforms, do you recall what

2 kind of uniforms they were wearing?

3 A. I think military, at least some of them.

4 Q. At the time that you were turned back, did you know any of these

5 people at the checkpoint, any of these people in uniform?

6 A. One of them.

7 Q. The person that you knew, where was this person from?

8 A. He was from Kozarac or, rather, from Vidovici.

9 Q. Is that a village in Kozarac?

10 A. Yes.

11 Q. Do you happen to recall that person's name?

12 A. They called him Nedjo Jankovic.

13 Q. What was that person's ethnic group?

14 A. Serb.

15 Q. That same day that you were turned back from the checkpoint at

16 Orlovci, did you lose any public services?

17 A. Yes, perhaps it was before that, or slightly after that, the

18 telephone lines were cut off.

19 Q. On this same day you were turned back from Orlovci, did you notice

20 that Serbs in Kozarac were beginning to leave Kozarac?

21 A. Yes.

22 Q. How long did this Serb exodus of Kozarac continue?

23 A. Well, Thursday and Friday, as far as I know, and on Saturday.

24 Q. Were you able to ask the Serb inhabitants why they were leaving?

25 A. No.

Page 2437

1 Q. Why not?

2 A. I did not see them. I had only heard that they were leaving.

3 Q. As these days passed, when you saw the people in Kozarac did you

4 notice fewer Serbs among those people?

5 A. Yes, I remember that the story went, whether it was on Saturday

6 towards the evening, I think it was Saturday, that only two were still

7 in Kozarac.

8 Q. After you were turned back at the checkpoint at Orlovci, and the

9 phone lines were cut and the Serbs began to leave Kozarac, what did

10 you think was about to happen to Kozarac?

11 A. I did not understand the question. What do you mean "what happened"?

12 Q. After you were turned back at the checkpoint and the phone lines were

13 cut and Serbs began to leave Kozarac, what did you think would soon

14 happen to Kozarac?

15 A. Well, we thought that perhaps some attack on Kozarac might ensue or

16 something like that, that the army would try and enter Kozarac.

17 Q. Why did you think that?

18 A. Well, simply the place was surrounded. You could not leave it. Your

19 phones had been cut off. The Serbs were leaving and that was

20 something that was happening already, happening before, that we used

21 to see and because of the events that were taking place in Croatia or

22 in east Bosnia and Sarajevo.

23 Q. So these were familiar signs to you?

24 A. Yes.

25 Q. In preparation for this attack that you felt was soon to come, what

Page 2438

1 did you and your husband do on 21st May?

2 A. Well, we, first of all, for safety reasons and because in the first

3 place in the building of the clinic there was not a single safe room,

4 we started thinking about where we could go; and then we decided -- I

5 decided to go and report to the Health Centre in Kozarac or, rather,

6 to offer them my services, the Health Centre of Kozarac, if they

7 needed any help.

8 Q. What was your husband going to do in preparation for the pending

9 attack?

10 A. He decided to stay with people who were at the sawmill and said that

11 he could perhaps, since we had a car, a station wagon, that perhaps he

12 could stay there and help if there was anybody wounded.

13 Q. You have mentioned the sawmill, I think, twice now in your testimony.

14 If you could look at Prosecution 196 again and if you could point out

15 to the court where that sawmill is located?

16 A. The sawmill was right at the entry into Kozarac, when one would come

17 from Prijedor and turn towards the centre of Kozarac on the corner to

18 the left; and between the sawmill and the football field was the

19 veterinary clinic.

20 Q. Did you actually go to the medical centre on Thursday to begin

21 preparations there?

22 A. Yes.

23 Q. What type of preparations were done at the medical centre on the

24 21st?

25 A. Simply, there were several people there, there was a colleague of

Page 2439

1 mine and a couple of physicians from the medical centres, and we

2 simply tried to see in what way we could perhaps protect any of the

3 rooms in that medical centre in case shelling would take place, so

4 that we could gather in those rooms, and perhaps provide for some

5 protection and get ready for the functioning in that small space.

6 Q. Did you remain at the medical centre on 21st or did you go back home

7 on that date?

8 A. I believe I went back home.

9 Q. During this period between 21st May until 24th May, do you recall

10 hearing a radio broadcast in which the ultimatum for Kozarac was

11 restated?

12 A. Yes. Some ultimatums were repeated about the return of weapons. I

13 even think there were several of them. There was one that the

14 deadline was extended, or something like that.

15 Q. Do you recall when the deadline was?

16 A. I do not remember exactly, but I think that the final deadline was

17 sometime on Sunday.

18 Q. Do you know who was making this broadcast and repeating these

19 ultimatums?

20 A. The then authorities of the Prijedor municipality.

21 Q. When these broadcasts were made on the radio, do you recall if

22 anything was said about what would happen if the inhabitants of

23 Kozarac did not comply with the ultimatums?

24 A. There was -- it said that if they failed to do so, then the army

25 would have to take over Kozarac, to enter Kozarac.

Page 2440

1 Q. To your knowledge, did Kozarac comply with the ultimatum to turn in

2 weapons?

3 A. No, as far as I know.

4 Q. To your knowledge, what groups of people in Kozarac had weapons?

5 A. Well, in Kozarac policemen had weapons, both regular and Reserve

6 force, the Territorial Defence and some people had private arms.

7 Q. When you say the police, both the regular and the Reserve, are you

8 talking about regular and Reserve police?

9 A. Regular Reserve police, active duty and Reserve strength.

10 Q. You indicated that, to your knowledge, some private individuals had

11 weapons. To your knowledge, what kind of weapons were those?

12 A. Well, mostly hunting, as far as I know, hunting or perhaps pistols,

13 and what else could one have?

14 Q. Did you have weapons?

15 A. No.

16 Q. Did your husband have weapons?

17 A. No.

18 Q. On the afternoon of 22nd May and the night of 22nd and 23rd May, did

19 you hear or see any signs of fighting or attack from any areas close

20 to Kozarac?

21 A. Excuse me, what night?

22 Q. This would be the afternoon of 22nd May, Friday, and the night of

23 22nd/early morning of 23rd May.

24 A. Yes. On Friday afternoon, one could hear detonations from the

25 direction of Prijedor and later on one could even see the smoke and

Page 2441

1 flames rising from the area of hills in the vicinity of Prijedor.

2 Q. When you were seeing these smoke and flames, what time of the day or

3 night was this? Was this night of the 22nd, morning of 23rd?

4 A. Yes, it was the night of -- evening of 22nd and in the night between

5 22nd and 23rd May. So, Friday to Saturday, the night between Friday

6 and Saturday.

7 Q. How were you able to see these fires from Kozarac?

8 A. One could see it from the upper floor of the medical centre in

9 Kozarac.

10 Q. Did you use anything to assist your vision or were you looking with

11 the naked eye?

12 A. One could see it with the naked eye, but much clearer one could see

13 by using binoculars which Dr. Pasic had brought from his home.

14 Q. So you looked through these binoculars towards the fires?

15 A. Yes.

16 Q. Did you notice anything about the way the fires were spreading,

17 anything unusual to you?

18 A. Yes, the unusual thing about it was that in the beginning those fires

19 were uneven or, rather, I mean, sometimes on the hill tops, sometimes

20 at the foot of the hill, but then we began to see how the fire would

21 go ablaze in series, in sort of a string, one after the other, and we

22 assumed that somebody was setting houses on fire, one after the other.

23 Q. Could you tell us again what the area was in which you saw these

24 fires that appeared to be starting systematically?

25 A. These are areas which are, when you go from Prijedor towards Ljubija

Page 2442

1 on the hills which appear there, in that area, in the River Sana

2 valley, next to the river.

3 Q. Perhaps if you could look at Prosecution Exhibit 79? If we could put

4 that on the overhead and could you show the court the area in which

5 you saw these fires?

6 A. This ought to be this area, roughly speaking. (Indicated).

7 Q. That area is known to you as what area?

8 A. It was called Brdo or Hambarine.

9 Q. Thank you. On Sunday morning in Kozarac, in the morning on Sunday,

10 were you still free to move about as you wished?

11 A. Sunday morning, yes.

12 Q. In anticipation of the attack on Kozarac, had some sort of warning

13 signal been established for the inhabitants of Kozarac?

14 A. I cannot remember if it was official, but I do know that on Sunday

15 around noon when we heard the alert sounding off, when we heard it, we

16 realised it meant some immediate, some imminent, danger of an attack.

17 Q. Had there been some at least informal decision as to when that siren

18 would be sounded?

19 A. It could be that it was a decision to set the siren off when, I do

20 not remember, or possibly to sound them when the police leave the

21 checkpoint on the Banja Luka road. I remember that, because one

22 always assumed that as long as the checkpoint of the Serb police was

23 in Kozarac there would be no attack.

24 Q. On Sunday when the siren sounded, what did you do?

25 A. I went to the medical centre in Kozarac.

Page 2443

1 Q. At the medical centre who was there when you arrived or joined you

2 shortly after that?

3 A. Well, in the medical centre that afternoon, that day, I came there,

4 Dr. Idriz Merdzanic, Dr. Mensur Kusuran, Dr. Jusuf Pasic, my

5 colleague, another veterinary doctor, Dr. Hase Dzonlagic, a paramedic,

6 Mujozulic, a nurse, Sabiha Islamovic, and we were joined by some two

7 or three girls, Lejla Hrnic, a girl by the name of Gordana, I do not

8 know her surname, and several young men from the neighbourhood or,

9 rather, some men from the neighbourhood.

10 Q. These medical personnel that you have mentioned and the medical

11 assistants that you mentioned, to your knowledge, what was their

12 ethnic group?

13 A. They were all Muslims except Gordana.

14 Q. To your knowledge, what was Gordana's ethnic group?

15 A. She was a Serb.

16 Q. When did the attack on Kozarac actually begin?

17 A. Sometime around noon on Sunday.

18 Q. On Sunday, or in the days just prior to the attack on Kozarac, to

19 your knowledge, had there been any firing from Kozarac outward,

20 towards Serb positions?

21 A. As far as I know, not.

22 Q. To your knowledge, had there been any type of artillery or mortar or

23 cannons fired from Kozarac outward towards Serb positions?

24 A. No.

25 Q. What happened when the attack began on Kozarac?

Page 2444

1 A. The attack on Kozarac started suddenly with terrible shelling which

2 was so frequent that it seemed as though that thousands of shells are

3 falling at the same time, and soon after that we had the first wounded

4 people arrive.

5 Q. How long did this shelling of Kozarac continue?

6 A. It lasted the whole time while I was in Kozarac.

7 Q. That would have been until what date?

8 A. That would have been until Tuesday, May 26th.

9 Q. Was there any shelling in the immediate area of the medical centre

10 itself?

11 A. Yes, it seemed to us as though the whole time on purpose they were

12 shooting exactly the medical centre.

13 Q. Was the medical centre itself, the building itself, ever hit by the

14 shelling?

15 A. Yes.

16 Q. What areas of the building were damaged as a result of this shelling?

17 A. Due to the shelling, due to the shells that fell on the hospital

18 itself, on the building of the medical centre or nearby, all of the

19 windows were broken on the building, some parts of the building were

20 damaged, for example, the front plateau of the building and I remember

21 that a piece of the corner of the building was missing. I am talking

22 of the medical centre building.

23 Q. I am sorry. Could you please explain on the translation it says "the

24 front plateau of the building", what do you mean by "the front

25 plateau"?

Page 2445

1 A. As you enter the building itself, as you enter in front of the

2 building, there are several steps and then there is a wide plateau or

3 a porch, and from that part you enter the building itself where the

4 offices of some doctors are located, and on the other part there are

5 steps that take you to the labs of the medical centre.

6 Q. So then the damage you are taking about occurred on this plateau or

7 landing?

8 A. Yes. It occurred on the plateau or the building -- and the building

9 itself.

10 Q. When did the damage to the building occur?

11 A. I think it happened at night, the night between Sunday and Monday

12 morning.

13 Q. So this would have been the night of 24th/morning of 25th May?

14 A. Yes.

15 Q. You indicated earlier that the medical centre was set off somewhat

16 from other buildings around it. Was the location of the medical

17 centre well known to people in the larger Kozarac area?

18 A. I think so.

19 Q. At the time that the shelling of Kozarac began, what type of medical

20 supplies did you have in the medical centre to treat wounded people?

21 A. Almost none.

22 Q. What supplies you did have, where did you get those supplies?

23 A. The medicine and all of the material, necessary material, we used

24 what we found in the building itself. Later on, they brought us

25 medicine from the pharmacy in Kozarac.

Page 2446

1 Q. This was the pharmacy that you earlier identified on the video tape?

2 A. Yes.

3 Q. After the shelling of Kozarac began, were you able to see what other

4 inhabitants of Kozarac were doing, how they were reacting to the

5 shelling?

6 A. No, I could not see that.

7 Q. How long did you remain in the medical centre itself?

8 A. I remained until Monday.

9 Q. At that time where did you go?

10 A. On Monday, we were moved into a house that all of the inhabitants of

11 Kozarac called "motel", and it was located on the road that leads from

12 Kozarac to Mrakovica in that area of Kozarac.

13 Q. So this was the motel on the map, Prosecution Exhibit 196, located

14 above the Mutnik mosque?

15 A. Yes.

16 Q. Why did you move to this motel on Monday?

17 A. Because remaining at the medical centre was practically impossible

18 because it almost had no safe rooms and the purpose of -- there was no

19 purpose of remaining there any more because nobody could bring us the

20 wounded because of such frequent shelling without being wounded

21 himself while carrying the wounded.

22 Q. You mentioned that shortly after the shelling began wounded people

23 began to arrive at the medical centre. While you were at the medical

24 centre, how many wounded did you receive and treat?

25 A. I could not give you the exact number, perhaps 20 or around 20.

Page 2447

1 Q. What types of wounds did these people have?

2 A. Shelling wounds.

3 Q. What was the age group and gender of these wounded people?

4 A. Different age groups, and mostly men.

5 Q. The men who were brought in who were wounded, do you recall if any of

6 them were wearing uniforms?

7 A. No.

8 Q. You do not recall or they were not?

9 A. As far as I know, they did not have uniforms.

10 Q. Do you recall if any of them had weapons when they were brought into

11 the medical centre?

12 A. They did not have weapons.

13 Q. Did you know any of these wounded people who were brought to the

14 medical centre?

15 A. Yes, almost everyone.

16 Q. What was the ethnic group of the people that you knew?

17 A. Muslim.

18 Q. How many, if any, of these people died of their wounds before they

19 arrived or after they were at the medical centre?

20 A. At the building itself, one wounded died.

21 Q. What was the age group of this person?

22 A. Do you mean how old was he?

23 Q. Yes.

24 A. Maybe between 20 and 30 years.

25 Q. Did you know him?

Page 2448

1 A. I knew him from passing by. He was from Hrustici, I think.

2 Q. To your knowledge, what was his ethnic group?

3 A. Muslim.

4 Q. On Monday when you moved to the motel, did you move the patients

5 there as well?

6 A. Yes.

7 Q. How did you move them there?

8 A. With a truck.

9 Q. Was there any shelling while were you moving these patients to the

10 motel?

11 A. Yes.

12 Q. Were any of the trucks hit by shells?

13 A. I do not know that because I went -- I was the last one to leave the

14 medical centre with one of the drivers of the ambulance.

15 Q. To your knowledge, did any of the medical personnel remain behind at

16 the medical centre?

17 A. Not after me.

18 Q. When you moved to the motel, how long did you stay at that motel?

19 A. We stayed there until Tuesday morning.

20 Q. How many wounded did you receive after you had moved to the motel?

21 A. I do not know the exact figure, but there were many more than the

22 first, than the first day, maybe three times more, maybe 50 or more

23 people.

24 Q. What types of wound did these people have?

25 A. Shelling wounds.

Page 2449

1 Q. What was the age and gender of these wounded people?

2 A. The gender, there were men and women, children as well, elderly --

3 there was a mixed group.

4 Q. Do you recall if any of those wounded people were wearing uniforms?

5 A. I do not know, perhaps some of them had parts of some uniforms, but I

6 do not remember exactly.

7 Q. Did any of these people who were brought there have any weapons with

8 them when they came?

9 A. Nobody had arms.

10 Q. Did you know any of these people?

11 A. Almost everyone.

12 Q. What was the ethnic group of these wounded people?

13 A. Muslim.

14 Q. Did any of these people die either being brought to the motel or

15 while they were at the motel?

16 A. We had a lot of dead people there.

17 Q. What was the age group of the people who died?

18 A. It was quite varied; a child, a 12 year old child died and an elderly

19 woman that was perhaps 70 or 80 years old.

20 Q. The nature of the wounds of the people who were brought to you, what

21 types of wounds did they have?

22 A. Shelling wounds.

23 Q. And what physical injuries to their bodies did they have?

24 A. Mostly very serious wounds, either amputations of limbs, parts of the

25 bodies or completely shattered parts of the body.

Page 2450

1 Q. What type of medical supplies or equipment did you have to deal with

2 these persons who had amputations?

3 A. None.

4 Q. While you were at the motel what other group was also at the motel?

5 A. There were members of the police department in Kozarac; members of

6 the police departments in Kozarac.

7 Q. If you know, who was the commander of the police there at the motel?

8 A. Somebody who was called Osme.

9 Q. During the time you were at the motel did you ever overhear any

10 negotiations taking place between these police and Serb authorities

11 outside the town?

12 A. Yes.

13 Q. How were you able to overhear these negotiations?

14 A. The negotiations were led through some kind of a radio station, and

15 since it was in the building itself in the motel, at one point I was

16 present in one of the rooms ----

17 Q. How long ----

18 A. --- where the negotiations were led.

19 Q. I am sorry. How long did these negotiations continue?

20 A. I do not know that. Probably all night.

21 Q. Now the one time that you were present while negotiations were being

22 carried on, who was the spokesman for the people of Kozarac?

23 A. Osme.

24 Q. And who was he talking to or addressing over the radio?

25 A. I know that he talked with Simo Drljaca and with Zeljaja.

Page 2451

1 Q. How do you know that?

2 A. I know because in one part of the conversation we heard the comment

3 for us to be more quiet because at that moment he was talking to Simo

4 Drljaca, and the second time was because Osme yelled and requested to

5 talk to Zeljaja.

6 Q. What conditions, if any, were imposed on the inhabitants of Kozarac

7 in order for the shelling of the town to stop?

8 A. The conditions were to surrender members of police with their arms,

9 and if they go first then civilians would be allowed to leave Kozarac

10 in a column.

11 Q. When was this initial agreement or condition made, what time of the

12 night or day?

13 A. This was at night, after midnight, between Monday and Tuesday.

14 Q. How much time were you given to gather people?

15 A. I heard that they were given from, they were given 30 minutes to

16 prepare the police and to form a column that was supposed to leave

17 Kozarac.

18 Q. Then at the end of this 30 minutes what was to happen?

19 A. It was said that they would wait for further directions, and after a

20 certain time the connection was established again and we heard a

21 conversation again and they asked: "Has this been done?" Osme

22 replied: "Yes".

23 Q. What happened after that?

24 A. After that we heard again frequent shelling nearby and we heard that

25 the shells were falling on the road that led through Kozarac.

Page 2452

1 Q. If you could look again at Prosecution Exhibit 196, which is the map,

2 if that could be placed on the overhead, please. Now looking at the

3 motel area -- if that could please be reduced, thank you -- looking

4 at the motel area where you were, would you please point out to the

5 court where the people were to gather on the road?

6 A. It would be on this road here.

7 Q. On that section of the road?

8 A. (Indicated). Yes, at that part of the road.

9 Q. Then when the shelling began again, would you please show the court

10 where, in what area the shells were landing?

11 A. As I heard, in this part of the road.

12 Q. Did you actually hear this shelling when it began?

13 A. Yes.

14 Q. Did it sound as though it was very close?

15 A. Yes, it was in the immediate vicinity.

16 Q. Then I believe you indicated people came back into the motel and said

17 the shelling was occurring on that road?

18 A. Yes.

19 Q. Later on that morning, was a final agreement reached which would

20 allow the wounded and civilians to leave Kozarac?

21 A. Yes.

22 Q. What was this agreement? What was supposed to happen?

23 A. As it looked, I am not sure what the definite agreement was, but in

24 early morning hours on Tuesday a group of policemen got ready and they

25 decided to surrender. The whole time the negotiations were led to

Page 2453

1 allow us to take out the wounded people that at that time were in the

2 motel in Kozarac, and to allow us to transfer them into the hospital

3 in Prijedor. After them a column of civilians was supposed to follow.

4 Q. So early in the morning of 26th May did such a column begin to form?

5 A. Yes.

6 Q. Where did it begin to form? If you could again refer to the map.

7 A. It started forming exactly on this road here, up here.

8 Q. If that could be shown on the screen, please. Could you show us

9 again, please, where that column began to form?

10 A. In this part of the road.

11 Q. In what direction then did that column move?

12 A. It moved through the centre of Kozarac towards the Banja Luka road.

13 Q. And who was leading that column?

14 A. The police.

15 Q. After the police who was in the column?

16 A. As far as I know, our wounded people.

17 Q. How were the wounded to be transported?

18 A. In a truck and one ambulance vehicle.

19 Q. About what time of the morning, if you know, did this column form up

20 and begin to move down from the motel area?

21 A. I do not know exactly. It was early in the morning, perhaps 7

22 o'clock.

23 Q. Did you go with the column?

24 A. No.

25 Q. You indicated that the wounded were being transported in a truck and

Page 2454

1 an ambulance. Who were the drivers of these vehicles?

2 A. They were transferred in a truck and the ambulance vehicle. The

3 drivers, the driver of the truck was Fehim Sinanegic and the ambulance

4 vehicle was driven by my husband and they were the volunteers.

5 Q. When your husband left with that column driving the vehicle, when was

6 the next time you saw your husband?

7 A. In December '92.

8 Q. After this column moved out, who remained behind with you?

9 A. Nobody.

10 Q. So no other medical personnel remained behind with you?

11 A. I apologise. I did not understand. Medical personnel remained, the

12 medical personnel that came from the medical centre in Kozarac.

13 Q. So those individuals you have previously mentioned remained with you

14 at the motel when the column left?

15 A. When the column left, when we sent out the wounded, then we decided

16 to go back to the medical centre building in Kozarac, and since

17 shelling had almost ceased at that point to see what we are to do from

18 there.

19 Q. On the same date, 26th May, did you go to Trnopolje to attempt to

20 negotiate with the Serb authorities there?

21 A. Yes.

22 Q. Who went with you?

23 A. Dr. Idriz Merdzanic.

24 Q. Is he commonly referred to as Dr. Idriz?

25 A. Yes.

Page 2455

1 Q. Why did you want to confer with the Serb authorities in Trnopolje?

2 A. We wanted actually to try to establish contact with Serb authorities

3 and to let them know that we would like to remain in medical centre in

4 Kozarac until civilians leave Kozarac, so that we could help these

5 people if they should need help.

6 Q. Were you able to speak with the Serb authorities in Trnopolje?

7 A. No.

8 Q. So that then did you return back to the medical centre this same day,

9 Tuesday 26th?

10 A. Yes.

11 Q. How long did you stay in the medical centre?

12 A. We stayed until the afternoon when the army entered Kozarac.

13 Q. What happened at the medical centre that afternoon?

14 A. That afternoon the soldiers entered into the medical centre in

15 Kozarac, and then we had to leave the building.

16 Q. These soldiers who entered into the medical centre, how many soldiers

17 came into the area where you were?

18 A. At first two soldiers.

19 Q. Did you hear any of these soldiers talking or saying anything?

20 A. Yes.

21 Q. Did you recognise the dialect or accent as a local dialect or as a

22 different dialect?

23 A. No, they spoke in Ekevica dialect.

24 Q. That dialect is spoken where?

25 A. In Serbia.

Page 2456

1 Q. What happened after these two soldiers came into the area where you

2 were?

3 A. They asked us where are our weapons, our wounded. They searched us.

4 Q. Did you have any weapons?

5 A. No.

6 Q. What were these soldiers wearing?

7 A. Uniforms.

8 Q. After they asked you these questions, what happened then?

9 A. They ordered us to collect all medicines that were at the entrance

10 into the building. They were spread all over the entrance and those

11 were the medicines that were brought from the pharmacy in Kozarac.

12 They ordered us to load those medicines into the truck which we have

13 done, and after that we left the building, the medical centre in

14 Kozarac. They took us towards the centre of Kozarac.

15 Q. These two soldiers who came into the area where you were, you said

16 they spoke with Serbian dialects. Did you know either of these

17 soldiers?

18 A. No, not at that time.

19 Q. Did you subsequently learn the name of one of those soldiers?

20 A. Yes.

21 Q. When was it that you learned the name of one of those soldiers?

22 A. One of those two soldiers came again to Trnopolje, maybe even two

23 times, and at that time spoke to us and introduced himself.

24 Q. And what was his name?

25 A. Ljubomir or Ljubo Stojanovic.

Page 2457

1 Q. Did Stojanovic tell you where he came from?

2 A. Yes, he said he was from Belgrade.

3 Q. During the time that you were at the medical centre, was Gordana

4 still there with you? Was she one of the individuals with you?

5 A. Yes.

6 Q. Do you recall the soldiers asking Gordana to leave the building with

7 them?

8 A. Yes, immediately after they entered one of the soldiers asked her,

9 called her and asked

10 her to come out, and she came back after about, perhaps, half an

11 hour.

12 Q. What was her condition when she returned?

13 A. She was distressed, almost hysterical.

14 Q. Did she tell you what had happened while she was gone?

15 A. We asked what had happened and where had they taken her, and all she

16 said was that she had to show them her flat.

17 Q. That she had to show the soldiers her flat?

18 A. Yes.

19 Q. Did they tell her why they wanted to see her flat?

20 A. Yes, so that they would not touch it. That is how she put it.

21 MISS HOLLIS: Your Honour, this may be a good point to stop.

22 THE PRESIDING JUDGE: We will stop. I want to talk with the lawyers about

23 the delayed transmission equipment just a moment. So, perhaps the

24 Doctor could leave. You are excused for the day. You should return

25 tomorrow at 10 a.m. please.

Page 2458

1 (The witness withdrew).

2 THE PRESIDING JUDGE: The delayed transmission equipment is operative, I

3 understand, and instructions are being prepared for we lay persons who

4 have difficulty sometimes with technical equipment, but the

5 instructions are being prepared so that we will know how to work

6 together with them. The instructions will be completed tonight,

7 probably about 6.30 p.m. So if Counsel is either in the building or if

8 you want to send someone over and see Miss Featherstone, she will be

9 able to give us those instructions. If not, you may wait until

10 tomorrow morning and pick them up from her. I think it would be

11 helpful tomorrow morning for us to talk a few minutes about how we

12 might handle matters that might arise because of the need for the

13 delay transmission commitment.

14 So, unless there are other matters that need to be brought to

15 the attention of the Trial Chamber at this time, we will adjourn

16 until tomorrow at 10 a.m.


18 (The court adjourned until the following day).