Tribunal Criminal Tribunal for the Former Yugoslavia

Page 4296




4 Tuesday, 30th July 1996

5 (10.00 a.m.)

6 THE PRESIDING JUDGE: Mr. Niemann, would you like to call your next

7 witness, please?

8 MR. NIEMANN: Mr. Tieger.


10 MR. TIEGER: Your Honour, the next witness is Hase Icic.

11 MR. KAY: Your Honour, I have a blank screen.

12 MR. TIEGER: I have the same situation here as well.

13 MR. HASE ICIC, called

14 THE PRESIDING JUDGE: Sir, would you please take the oath that is being

15 handed to you?

16 THE WITNESS [In translation]: I solemnly declare that I will speak the

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

18 THE PRESIDING JUDGE: Thank you. You may be seated.

19 Examined by MR. TIEGER


21 MR. TIEGER: Thank you, your Honour. (To the witness): Sir, what is your

22 name?

23 A. My name is Hase Icic.

24 Q. In what year were you born?

25 A. November 3rd 1948.

Page 4297

1 Q. Where were you born, Mr. Icic?

2 A. I was born in the village of Hrnici on the border of Trnopolje.

3 Q. What is your nationality?

4 A. Bosniak Muslim.

5 Q. Did you grow up in the area of Trnopolje?

6 A. Yes.

7 Q. Where did you attend school?

8 A. One part in Trnopolje and the rest of the primary school in Kozarac.

9 Q. At the Rade Kondic school?

10 A. Yes.

11 Q. Mr. Icic, did you serve in the JNA?

12 A. Yes, I have.

13 Q. When was that?

14 A. End of '67 and I also served through 69, that is the 68.

15 Q. After your military service, did you become involved in work in

16 Germany in approximately 1970 as a construction worker?

17 A. Yes.

18 Q. Was that your occupation until shortly before the war in 1992?

19 A. Yes.

20 Q. Did you still consider Trnopolje, Trnopolje area, your home?

21 A. Yes.

22 Q. Did you build a house in the Trnopolje area?

23 A. Yes.

24 Q. During the years you spent in Germany how often would you return home

25 to Trnopolje?

Page 4298

1 A. Every 15 days, sometimes even every week, over the weekend.

2 Q. How long would you stay?

3 A. Sometimes just over the weekend, and often times the whole week.

4 Q. When you did return home did you stay inside the house or did you

5 tend to go out?

6 A. I was at home the least, because I needed to find supplies in

7 Kozarac, and friends.

8 Q. When you did see your friends or go for supplies, where would you go?

9 A. To Kozarac.

10 Q. Mr. Icic, do you know Dule Tadic?

11 A. Yes.

12 Q. How long have you known him?

13 A. Since the school days.

14 Q. Do you know the members of his family?

15 A. Yes.

16 Q. Did you go to school with any members of his family?

17 A. Yes, with Mladen.

18 Q. Did you play together with Mladin as children?

19 A. Yes, we played soccer in the soccer field.

20 Q. As you grew up and before you became involved with your work in

21 Germany, did you continue to see Dule Tadic in Kozarac regularly?

22 A. Well, we would meet, we would pass each other with the company that

23 Dule Tadic kept.

24 Q. During your regular visits home during the time you were in Germany

25 or working in Germany, when you went to Kozarac for supplies or to

Page 4299

1 cafes did you also continue to see Dule Tadic regularly?

2 A. Yes.

3 Q. Would you sometimes be in the same cafes together sitting a few feet

4 apart?

5 A. Yes.

6 Q. During the years you knew him, did you see him sometimes with a

7 beard?

8 A. Yes.

9 Q. Did you see him sometimes without a beard?

10 A. Yes.

11 Q. Were you familiar with his appearance both with and without a beard?

12 A. Yes.

13 Q. Mr. Icic, in late April 1992 did you return home to visit Trnopolje?

14 A. Yes.

15 Q. On that visit were you able to return to Germany to resume work?

16 A. No.

17 Q. Why not?

18 A. Well, all bridges towards Croatia were destroyed.

19 Q. Were you in the Trnopolje area when the attack on Kozarac began on

20 May 24th?

21 A. Yes.

22 Q. Could you hear the shelling of the Kozarac area?

23 A. Yes.

24 Q. Did people from the area of Kozarac flee toward Trnopolje?

25 A. Yes.

Page 4300

1 Q. Was that a few people or a large number of people?

2 A. A large number.

3 Q. After the attack on Kozarac began, was there an announcement that the

4 people of the area of Trnopolje should surrender weapons?

5 A. Yes.

6 Q. Were weapons collected and turned over to Serbian forces?

7 A. Yes.

8 Q. As far as you are aware, were all the weapons that people in the area

9 of Trnopolje possessed turned over?

10 A. Yes.

11 Q. Did you see what was collected?

12 A. Yes.

13 Q. What was that?

14 A. Well, it was very little, several M48 rifles which belonged to the TO

15 members, and some hunting arms and then, you know, there were these

16 rifles that you shoot birds with.

17 Q. OK. Are those air rifles?

18 A. Yes.

19 Q. Did you remain in the area of Trnopolje until June 14th?

20 A. Yes.

21 Q. On that day did Serbian forces come to the area of Trnopolje to

22 collect Muslim men?

23 A. Yes.

24 Q. What did you see on that day? Who came in? How many Serb forces,

25 what kinds of vehicles?

Page 4301

1 A. I could not see all of the Serb forces, but I saw a tank that was

2 sitting in front of my house, and the soldiers who ordered that men be

3 separated from women, also boys older than 16. They took them to a

4 truck that was behind the tank.

5 Q. Were you taken on that truck?

6 A. Yes.

7 Q. Then were you taken to a collection point in the area of Trnopolje?

8 A. We were taken in front of the house of Hamid Sivac in Sivci.

9 Q. From there were you and other men placed on buses and taken away from

10 the Trnopolje area?

11 A. Yes.

12 Q. Where were you taken?

13 A. They took us to Keraterm.

14 Q. Where were you held in Keraterm?

15 A. Yes.

16 Q. In what part of Keraterm were you held, Mr. Icic?

17 A. In room No. 2.

18 Q. How long did you remain in Keraterm?

19 A. Approximately until 7th or 8th June.

20 Q. What were the general conditions in Keraterm like during the period

21 of time you were held there?

22 A. Bad, very bad.

23 Q. Can you describe the conditions?

24 A. You know, there was nothing to lie on, except the concrete. A few

25 people had palettes that remained from the warehouse and then the

Page 4302

1 toilets were all plugged up and it all stank. There was no water to

2 wash and there was almost no food, and when the food arrived it was

3 not enough for everybody.

4 JUDGE STEPHEN: There seems to be some confusion of dates.

5 MR. TIEGER: Miss Sutherland was just pointing that out, your Honour.

6 Thank you. Mr. Icic, may I ask you again, until approximately what

7 date did you remain in Keraterm?

8 A. In Keraterm I stayed until 7th or 8th of July.

9 Q. Thank you, sir.

10 A. I do not know the exact date.

11 Q. Were prisoners regularly called from the rooms in which they were

12 held and beaten or tortured?

13 A. Yes.

14 Q. Were prisoners regularly called from their rooms and killed or

15 disappeared?

16 A. Yes, both.

17 Q. Mr. Icic, were you interrogated while in Keraterm?

18 A. Yes.

19 Q. What kinds of questions were you asked during your interrogation

20 there?

21 A. You know, almost none. They started with my explaining to them what

22 my heritage, my forefathers and so on.

23 Q. Did they take a statement from you?

24 A. Yes, but I did not sign it.

25 Q. At some point during the interrogation did they ask you about weapons

Page 4303

1 or politics?

2 A. About the weapons at the very end, whether I had any weapons.

3 Q. On approximately 7th or 8th July where were you transferred to?

4 A. In Omarska camp.

5 Q. Approximately how many other prisoners from Keraterm were transferred

6 with you?

7 A. A whole bus, approximately 40 to 50 detainees.

8 Q. What was the nationality of those prisoners?

9 A. Muslims and Croats.

10 Q. Were some of them members of the Reserve Police, as far as you were

11 aware?

12 A. Yes.

13 Q. About what time did you arrive in Omarska?

14 A. On 7th or 8th July, I do not remember exactly.

15 Q. About what time of the day was that, if you recall?

16 A. Around noon, around noon.

17 Q. Were guards or soldiers or other Serb forces waiting for you when the

18 bus arrived?

19 A. Yes.

20 Q. Where did the bus stop?

21 A. When the bus came to a stop they were already, one could say,

22 prepared, welcome.

23 Q. In what part of the camp was it that the bus stopped?

24 A. Between the dining room and that large red building with the door

25 towards the white house.

Page 4304

1 Q. Using that pointer which is located to the right of the console, can

2 you show us the approximate position where the bus stopped?

3 A. [The witness indicated on the model] Approximately here.

4 Q. After the bus stopped how were the guards or soldiers positioned?

5 A. They lined up like, sort of, a cordon, and the prisoners had to go

6 through it. I had to go through it, between them.

7 Q. Where did that cordon run from, from the bus to where?

8 A. Towards the entrance to the white house.

9 Q. How were the prisoners called off the bus?

10 A. One by one, easily.

11 Q. What happened as you and the other prisoners got off the bus and went

12 toward the white house?

13 A. At the moment when I was called out, I had to get off the bus and to

14 start walking towards the white house. I went between the guards who

15 were in civilian clothes or police uniforms who were holding different

16 objects and they were hitting from all sides.

17 Q. When you got to the white house where were you placed?

18 A. I was placed in the last room on the right.

19 Q. Other than the prisoners you had arrived with, were there other

20 prisoners in that room when you arrived?

21 A. No.

22 Q. Do you know whether or not there had been prisoners in that room

23 before your arrival or where those prisoners went?

24 A. At that time I did not know.

25 Q. After you and the others were put in that room, were you again

Page 4305

1 called out from that room?

2 A. Yes.

3 Q. Where were you sent?

4 A. We had to go to interrogation.

5 Q. How were you called out when you were sent to interrogation?

6 A. The same way pretty much as when we were getting off the bus, one by

7 one.

8 Q. Was there also a cordon, that is, two rows of guards leading from the

9 white house toward the area where you were interrogated?

10 A. Yes, it was the same cordon, but not as many, some had left.

11 Q. Did you go alone or were you escorted by a guard when you went to

12 interrogation?

13 A. I had to go with a guard who walked in front of me.

14 Q. What happened as you went through the cordon?

15 A. They hit me again.

16 Q. Did you make any effort to run or walk faster to avoid the blows?

17 A. I could not because he would not let me go any faster.

18 Q. Where were you interrogated?

19 A. In the room above the restaurant, the last one to the left.

20 Q. What questions were you asked when you were interrogated?

21 A. Nothing.

22 Q. What happened during the interrogation?

23 A. He had in front of him a statement from Keraterm and he read it out

24 to me.

25 Q. Did he ask you anything about it?

Page 4306

1 A. He asked me whether I had anything to add.

2 Q. Did you?

3 A. No, I had nothing to add.

4 Q. After the interrogation was over, where were you sent?

5 A. I was returned to the white house.

6 Q. Did you go by yourself or were you again escorted?

7 A. Escorted by another guard who was next to the interrogator the whole

8 time.

9 Q. Were you again beaten as you went from the interrogation back to the

10 white house?

11 A. No, this one did not allow that.

12 Q. After you returned to the white house, did you return to the same

13 room you had been in before?

14 A. No, I was returned to the last room on the left.

15 Q. After you returned from interrogation, Mr. Icic, at some point did

16 Serbs enter your room?

17 A. Yes.

18 Q. Were you and the others in your room ordered to do anything?

19 A. Yes.

20 Q. What were you ordered to do?

21 A. To lie down on our stomach, with our arms stretched over our heads

22 and with three fingers together because that is how the Serbs pray.

23 Q. Was there enough space for all of you to lie stretched out in this

24 fashion?

25 A. Why, not enough for all of us to stretch out, but we had to make

Page 4307

1 enough room so that our hands are free and so that those three fingers

2 can be seen.

3 Q. After you and the others had taken this position, what happened?

4 A. Then Serbs entered, walked over us, jumped, looked to see if the

5 fingers were in the proper position, if not, they would strike them

6 with a rifle butt and shouted with happiness.

7 Q. Were they shouting anything in particular?

8 A. "Be a great Serb, you Serb".

9 Q. Did any of the Serbs who came in have knives?

10 A. Yes.

11 Q. Were they using those knives?

12 A. Yes.

13 Q. What were they doing?

14 A. They cut, they slashed the clothes on our backs.

15 Q. Were some of the prisoners cut as well?

16 A. Yes.

17 Q. Were you cut?

18 A. No, I was not cut, but they slashed my leather jacket and the sweater

19 under it.

20 Q. So the leather jacket protected you from actually having your body

21 cut?

22 A. Yes.

23 Q. When one of the Serbs who came in cut your jacket, did another one

24 react to that?

25 A. Yes, he felt sorry for the jacket because he had been waiting for

Page 4308

1 such a jacket for a long time.

2 Q. Did he say anything to the person who had cut up the jacket?

3 A. He swore at him but he, nevertheless, took the jacket although it was

4 cut.

5 Q. Were they cutting the clothes and the prisoners in any particular

6 way?

7 A. Well, they were making crosses on our backs.

8 Q. After those persons left the room, were you and the others let alone

9 for a period of time that day?

10 A. Yes, for a certain period of time.

11 Q. Later on did someone come into the room?

12 A. Yes.

13 Q. Who was that?

14 A. Krkan.

15 Q. Did you know at that time who Krkan was?

16 A. No.

17 Q. Had you heard about Krkan from anyone in the white house that day?

18 A. Yes.

19 Q. How did you learn about Krkan?

20 A. At the time before anybody tortured us, a girl called Hajra Hodzic

21 entered the room and next to me was sitting a friend who knew her, and

22 she told him a story and also told him to beware of Krkan because he

23 was the one who called out.

24 Q. Did you later find out what Krkan's position in the camp was?

25 A. He was the head of the guard shift or the Commander.

Page 4309

1 Q. Did Krkan bring anything with him?

2 A. Yes.

3 Q. What was that?

4 A. He brought a clean sheet of paper and a pencil.

5 Q. Did he instruct the prisoners what they were to do with that paper

6 and pencil?

7 A. Yes, he told us that each one of us was to sign his name on a sheet

8 of paper, and to turn over all the belongings he had on him, that is,

9 money, foreign exchange, jewellery.

10 Q. Did he indicate whether or not what benefits prisoners might receive

11 from contributing their valuables?

12 A. Yes, he said if the amount would be enough, we would be spared any

13 further torture.

14 Q. Was each prisoner somehow to indicate how much he had individually

15 contributed?

16 A. Yes.

17 Q. How were you supposed to do that?

18 A. Each one of us was to put down all that he had turned over and the

19 amount of money next to his name.

20 Q. Then did Krkan leave?

21 A. He left immediately after telling us what to do.

22 Q. Later on did he return?

23 A. Yes.

24 Q. Had the prisoners put their names on the piece of paper?

25 A. Yes, we all signed our names and I signed my name and surname. I

Page 4310

1 signed.

2 Q. Were there any valuables or gold or jewellery on the table?

3 A. There was nothing.

4 Q. Why had not the prisoners in your room surrendered any valuables or

5 gold?

6 A. Because all that had been taken away in Keraterm already.

7 Q. So there were no valuables on the table and there was a list of

8 prisoners names with nothing written next to it?

9 A. Nothing, apart from the names of prisoners.

10 Q. Did Krkan say anything when he saw there were no valuables?

11 A. No, nothing.

12 Q. Did he take the list with him and leave?

13 A. Yes, he took the list and left.

14 Q. Later on, Mr. Icic, did a group come to the white house?

15 A. Yes.

16 Q. Was it still daylight or was it already dark by that time?

17 A. It was in the evening.

18 Q. How did you become aware that a group was coming?

19 A. One could hear it from the adjacent room.

20 Q. Were they in the adjacent room or were prisoners saying that a group

21 was coming?

22 A. One could hear from the adjacent room how they were saying, "Here,

23 the executioners are coming".

24 Q. When this group came into the white house, what did they first start

25 to do?

Page 4311

1 A. They were carrying something with them. They brought some implements

2 and set up lighting in the hallway.

3 Q. Was there a light in your room?

4 A. No.

5 Q. As the members of the group were in the process of doing that, were

6 you able to see them?

7 A. Yes, we could watch them at leisure, I could do that.

8 Q. Was it normally dangerous in camp or risky to look at guards or

9 soldiers?

10 A. It was not dangerous until they would order you not to look. Until

11 such time one could look, one could watch, as long as one wanted to.

12 Q. Was there an order not to look on this occasion?

13 A. No.

14 Q. Did Krkan come back?

15 A. Yes.

16 Q. Did he say anything to the prisoners in your room?

17 A. While they were putting up that lighting he did not say anything.

18 They only talked among themselves, the group that had arrived.

19 Q. Were you able to see how many members of that group there were?

20 A. There were five of them and Krkan was the sixth.

21 Q. Did you recognise any of those five persons?

22 A. Yes.

23 Q. Did you recognise any of them as people you had known before the war?

24 A. Yes.

25 Q. Who did you recognise because you knew them before the war?

Page 4312

1 A. I recognised Dule Tadic, Simo Kevic, because them I knew before the

2 war.

3 Q. So you recognised Dule Tadic and Simo Kevic?

4 A. Yes.

5 Q. Did you recognise any of them as people you had known or seen in

6 Keraterm?

7 A. No, the two of them I knew from before the war and others -- the

8 other two I recognised because they used to come to Keraterm daily.

9 Q. Who did you recognise as people you knew from Keraterm?

10 A. There was Banovic and one called Duca, he was in Keraterm day after

11 day after day.

12 Q. You said there were five people, did you recognise the fifth person?

13 A. Yes, the fifth one I did see but I learned his surname while they

14 were talking amongst themselves.

15 Q. What surname did you hear used for this person while they were

16 talking?

17 A. Yes, they called him "Babic".

18 Q. After some sort of improvised lighting system was set up, did someone

19 say they would be calling prisoners out of the room?

20 A. Yes, Krkan came to the door and told us that now he would start

21 calling out and every person called out was to come out.

22 Q. Did he begin calling prisoners out?

23 A. Yes.

24 Q. Were the prisoners called out in any particular order?

25 A. In sequence down the list that we had made ourselves.

Page 4313

1 Q. When a prisoner was called and left the room, could you see in which

2 direction he went?

3 A. Yes.

4 Q. Where was that?

5 A. He was taken to a room on the left, a small room at the end of the

6 corridor.

7 Q. After each prisoner was called out and went toward the small room at

8 the end of the corridor, could you hear what was happening in that

9 room?

10 A. We heard blows.

11 Q. Could you hear the sounds of prisoners crying in pain or screaming?

12 A. No.

13 Q. Did you know what was happening in there?

14 A. No, all we heard were blows.

15 Q. After each prisoner was called out and you heard the sounds of blows

16 coming from that small room at the end of the corridor, did you see

17 the prisoners again?

18 A. I saw them every time when a prisoner would be beaten up because they

19 would throw him out into another room, the first one that we had been

20 to when we got off the buses, the room -- across the room in which I

21 was.

22 Q. After a period of time did the group that had come to the white house

23 and was calling prisoners out take some kind of break?

24 A. Yes.

25 Q. About how many prisoners had been called into that small room by that

Page 4314

1 time?

2 A. Between 10 and 15 prisoners.

3 Q. Where did the group go?

4 A. They went to the area in front of the white house, out there.

5 Q. Do you know what they were doing out there? Could you hear what they

6 were doing?

7 A. I heard them. They were drinking, holding toasts.

8 Q. In addition to drinking or at least to making toasts, were they

9 discussing anything?

10 A. Yes, they were discussing the further roles, what would each one of

11 them do next.

12 Q. Mr. Icic, you indicated that you heard the name of Babic used during

13 discussions between members of this group?

14 A. Yes.

15 Q. During the period of time they were setting up the light or when they

16 were outside talking, did you hear any other names used by members of

17 this group to other members of the group?

18 A. Well, they used their proper names, the whole group.

19 Q. What names do you recall hearing?

20 A. I do remember, they were simply talking. They were outside. We were

21 very quiet, there was not a sound inside, and we listened to their

22 conversation and we heard that this was going to do this, "Babic will

23 do that because he is a specialist in that", and so on.

24 Q. What names do you recall? What names were used?

25 A. "Dule" they used, "Babic", "Simo". They used all the names that I

Page 4315

1 had already mentioned before.

2 Q. After being outside, did the group return back to the white house?

3 A. Yes.

4 Q. Did they resume calling prisoners out from your room again?

5 A. Yes.

6 Q. Did the time come when your name was called?

7 A. Yes.

8 Q. What did you do when your name was called out?

9 A. I came to the door and looked to the right. It was the exit from the

10 white house.

11 Q. Why did you look to the right if all the prisoners had been going

12 left?

13 A. Yes, I turned left but I looked right.

14 Q. What did you see when you looked right?

15 A. Well, I saw two guards at the entrance to the white house.

16 Q. When you paused and looked right, what happened?

17 A. Krkan pulled me to the left.

18 Q. Toward the small room at the back of the corridor?

19 A. Yes.

20 Q. As you stepped toward or into the doorway of that small room, what

21 did you see?

22 A. Then I faced a group of people.

23 Q. As you were moving into the room ----

24 A. When I entered the room in front of me directly face to face was Dule

25 Tadic standing.

Page 4316

1 Q. Was there anyone near him?

2 A. Yes, yes.

3 Q. Who was that?

4 A. Simo Kevic.

5 Q. As you entered the room were you ordered to do anything?

6 A. Yes.

7 Q. What was that?

8 A. I had to greet them Serb way.

9 Q. What was it you were told to say?

10 A. I had to say, "God be with you, heros".

11 Q. After you did that what happened?

12 A. Well, one of them immediately put a noose around my neck.

13 Q. I am sorry, one of them put a -- our translation here is not

14 completely clear. What was it that was put around your neck, Mr.

15 Icic?

16 A. A noose around the neck. You know what it looks like?

17 Q. After that noose was put around your neck, what happened?

18 A. He pulled it tight and I was pulled, and at the same moment one of

19 them dealt me such a heavy blow on my back that I fell on my stomach.

20 Q. After you fell on your stomach what happened?

21 A. And then they went on beating me.

22 Q. What were they beating you with?

23 A. All sorts of things, with those implements they had with them as they

24 were setting up the lighting.

25 Q. What kind of implements were those?

Page 4317

1 A. Well, they had a whip made of a cable which ended in iron balls, they

2 had an iron rod, they had a wooden bat and some rubber sticks special

3 for the purpose.

4 Q. How tight was the noose around your neck during this time? Were you

5 struggling to breathe?

6 A. I had no air.

7 Q. Were you able to scream?

8 A. No.

9 Q. At some point was the noose loosened a bit?

10 A. Yes, when they would loosen it a little bit they would beat more

11 because they could see I was alive.

12 Q. At some point during this process did you lose consciousness?

13 A. Yes.

14 Q. Did you regain your consciousness that night?

15 A. Yes, several times, but only briefly.

16 Q. In the morning did you recover your consciousness?

17 A. In the morning I was a little bit more conscious.

18 Q. Where were you in the morning?

19 A. I was lying among other battered people in that room in which I was

20 when I had got off the bus.

21 Q. What was happening when you regained consciousness in the morning?

22 A. Well, it was then that one of the guards entered, walked over us, and

23 looked to see how many were dead among us.

24 Q. Did the guard walk on you?

25 A. Yes, he put his foot on me.

Page 4318

1 Q. What happened when he did?

2 A. I let a cry of pain to which he responded, "He's alive but not for

3 long".

4 Q. What happened to those prisoners who were determined to be dead?

5 A. They carried them out. They took them away.

6 Q. Who carried them out?

7 A. Other prisoners.

8 Q. Prisoners who were not from your room?

9 A. Yes.

10 Q. Mr. Icic, that evening or the evening following, did you again hear

11 the sounds of beatings?

12 A. Yes.

13 Q. Where were those sounds coming from?

14 A. They were coming from outside, from in front of the white house.

15 Q. Was a man by the name of Hrvat called from your room?

16 A. Yes.

17 Q. Did he ever return to the room?

18 A. No.

19 Q. Did you continue to hear the sounds of beating after he was called

20 out?

21 A. Yes, one could go on hearing the sounds of beating.

22 Q. In what position were you in the room at this time? Were you

23 standing or lying?

24 A. I could not stand up. I was on the floor on my back. That was the

25 only position I could be in. My head and my shoulders were partly on

Page 4319

1 another body.

2 Q. In what direction were you facing?

3 A. In the direction of the door.

4 Q. How far from the door were you?

5 A. Not far from the door.

6 Q. So you were lying on your back with your head and shoulders off the

7 ground against another prisoner?

8 A. Yes.

9 Q. Was there any lighting in the hallway at that time?

10 A. In that moment when I was looking out to the hallway only the hallway

11 was lit with some source of light from the outside, or maybe there

12 were some improvised light, in other words, only the hallway was lit.

13 Q. At some point did you hear the sounds of people approaching the

14 doorway?

15 A. Yes, I heard as people were approaching and cursing.

16 Q. After you heard that cursing, what did you see?

17 A. I saw as they drag a beaten up person.

18 Q. What did they do with that person?

19 A. They sort of threw it in the room at my feet.

20 Q. How many people dragged that beaten up person into your room or to

21 the room and threw him in?

22 A. Two of them.

23 Q. Did you recognise either of them?

24 A. Yes, the first one.

25 Q. Who was that?

Page 4320

1 A. Dule Tadic.

2 Q. After Dule Tadic and the other man threw the beaten up man into the

3 room, did either of them say anything?

4 A. Yes, Dule Tadic said, "You will remember, Sivac, that you cannot

5 touch a Serb or say anything to a Serb".

6 Q. At that point did you know who he was referring to when he used the

7 name "Sivac"?

8 A. At that moment I was not sure who he was referring to, because there

9 are several people named "Sivac".

10 Q. Did the person who had been thrown into the room say anything or ask

11 for anything?

12 A. Yes, he asked for water.

13 Q. Did someone try to give him some water?

14 A. Yes.

15 Q. Was he able to drink it?

16 A. No.

17 Q. In the morning were you able to see who that person who had been

18 thrown into the room was?

19 A. Yes, when it became light.

20 Q. Who was it?

21 A. My old friend and cousin, Sefik Sivac.

22 Q. On that morning did anyone come to see the condition of the prisoners

23 or who was dead?

24 A. Yes, Krkan came.

25 Q. What did he want to know?

Page 4321

1 A. He wanted to find out the names of the people who were either dead or

2 who could not move.

3 Q. Did you tell him who Sefik Sivac was?

4 A. Yes.

5 Q. What did you say?

6 A. I said that this was Sefik Sivac, the owner of the cafes, BMW and De

7 Luxe, in Kozarac.

8 Q. Where was the BMW cafe located?

9 A. In Prijedor, at the marketplace.

10 Q. Later on did other prisoners speak to you about saying this to Krkan?

11 A. No, the other prisoners told me that I was crazy because I told him

12 that. I did not care. I was just waiting to be finished off.

13 Q. Had Sefik Sivac been in your room before he was thrown into your room

14 by Dule Tadic and the other man?

15 A. No.

16 Q. Do you know where he had been before that?

17 A. No.

18 Q. Did Dule Tadic and Sefik Sivac know each other?

19 A. Yes.

20 Q. Had they been friends at one time?

21 A. Yes, for a time.

22 Q. Were they on good terms before the war began?

23 A. Not before the war.

24 Q. Why not?

25 A. Because Sefik threw him out of his cafe Luxe.

Page 4322

1 Q. That morning was Sefik Sivac removed from the room along with other

2 dead prisoners?

3 A. Right away. He was carried out together with the other ones who were

4 either dead or unconscious.

5 Q. Mr. Icic, on the two nights you saw Dule Tadic in the white house do

6 you recall what he was wearing?

7 A. A camouflage uniform.

8 Q. Do you recall whether or not he had a beard or was clean shaven?

9 A. He had a beard.

10 Q. Long or short?

11 A. Not too long, short-ish.

12 Q. A couple of days after Mr. Sivac was taken from the white house, were

13 you and other prisoners taken from the white house and put outside?

14 A. We were taken in front of the white house so that they could clean up

15 the stench -- you could not just endure it any more.

16 Q. So the guards took you out of the white house?

17 A. Not me. I was taken out by my fellow inmates who had not been beaten

18 yet.

19 Q. They assisted you out?

20 A. Yes.

21 Q. The reason you were taken out of the white house was because the

22 guards could not stand the stench any more?

23 A. Yes.

24 Q. Where did you sit once you were taken out of the white house on that

25 day?

Page 4323

1 A. In front of the white house -- should I point?

2 Q. Sure, if you do not mind.

3 A. [The witness indicated on the model].

4 Q. Thank you. That was your first opportunity to see Omarska camp other

5 than the times you had been going through the cordon of guards?

6 A. Yes.

7 Q. What did you see as you sat there?

8 A. I saw, in fact, I saw a real confusion. Some people were running

9 towards the dining room and the other ones were running towards them

10 in the opposite direction.

11 Q. Did you see any other prisoners?

12 A. Yes, at the bottom of the green part there, the guards with large

13 fire hoses were bathing the prisoners, the inmates.

14 Q. Were these prisoners clothed? Were they dressed?

15 A. No.

16 Q. They were naked?

17 A. Yes, they were naked.

18 Q. You said they were "bathing" the prisoners -- at least the

19 translation was "they were bathing the prisoners with large fire

20 hoses" -- what was happening as the fire hoses were being directed at

21 these prisoners?

22 A. Yes. Well, some were falling down because of the force of the water

23 from the hoses.

24 Q. Where was that happening?

25 A. Away from the white house where the green part was and where the

Page 4324

1 bushes were.

2 Q. If you can just show us where it is? That would be easier. Thank

3 you.

4 A. [The witness indicated on the model] It was around here.

5 Q. Mr. Icic, did you later learn that a relative or a friend had seen

6 you sitting in front of the white house?

7 A. Yes.

8 Q. Did they then organise an action to get you out of the white house?

9 A. Yes.

10 Q. To do so, was it necessary to bribe a Serb official in the camp?

11 A. Yes.

12 Q. Did you learn how much money was demanded for your release?

13 A. Yes.

14 Q. How much was that?

15 A. In fact, I ended up coming out for 100 Swiss francs, but because

16 several of my friends were involved in this, some were asked for 100

17 deutschemarks, some for 200 and a Serb actually was asking for 200

18 deutschemarks.

19 Q. Your friends were able to raise 100 Swiss francs?

20 A. Yes, 100 Swiss francs.

21 Q. Did that prove enough to get you moved from the white house to

22 another part of the camp?

23 A. Yes.

24 Q. Where were you moved to?

25 A. I was transferred to the large red building in the last small room

Page 4325

1 called the electric workshop.

2 Q. Did you remain there until you were transferred to Manjaca?

3 A. Yes.

4 MR. TIEGER: Thank you. I have nothing further.


6 MR. KAY: Thank you, your Honour.

7 Cross-Examined by MR. KAY

8 Q. Mr. Icic, if I could clarify a number of matters with you? When you

9 left Keraterm and arrived at Omarska, the first building that you were

10 held in, was that the white house?

11 A. Yes.

12 Q. How long did you stay in the white house for overall?

13 A. I stayed the whole time, from with the arrival to Omarska until the

14 day when they bought me -- my fellow inmates bought me for those 100

15 Swiss francs back.

16 Q. Can you tell me how many days that was, if you know?

17 A. I do not remember exactly how many days. But I arrived approximately

18 either on 7th or 8th and I left, I came out on 13th or 14th. That is

19 what I can say.

20 Q. Thank you. You were part of a group of prisoners that had been

21 transferred from Keraterm?

22 A. Yes.

23 Q. What was this group of prisoners from Keraterm made up of, who were

24 you? You told us you were Muslims and Croats, but what was the

25 background of this group?

Page 4326

1 A. The people were for the most part from the Ljubija mine.

2 Q. The number of people from the Ljubija mine, can you tell me that?

3 A. They were -- almost all of them were from there.

4 Q. You had not worked at the Ljubija mine. Do you know ---

5 A. No.

6 Q. -- why you were included in that group?

7 A. I do not know -- to date, I do not.

8 Q. But you were then transferred into that white house. If I could just

9 consider the layout of the interior of that house with you? As you

10 go through the door, there are two rooms on the right and two rooms on

11 the left, is that right?

12 A. Yes.

13 Q. At the end of the hallway there is an area which is an unfinished

14 wash room or shower area?

15 A. That was simply a small room, smaller than the other ones.

16 Q. That room had no tiles on the floor, would that be right?

17 A. I had no time to look around to see if it had tiles or not.

18 Q. When you arrived in the white house, as you went through the door you

19 were put in the second room on the right, is that right?

20 A. Yes, yes.

21 Q. Did you know at that time as to whether there were other people

22 inside the white house with you?

23 A. At that moment, no, because I was -- I, in fact, ran into the white

24 house between the guards that were beating me.

25 Q. After you had arrived, how soon was it before you were taken for

Page 4327

1 interrogation?

2 A. Until we were all in the room and we were followed by a man who

3 started calling us out.

4 Q. From what you say it seems then that you were amongst the first to be

5 questioned from that group who arrived from Keraterm?

6 A. Yes, yes.

7 Q. Can you remember what time of day it was that you arrived at the

8 white house?

9 A. I arrived at the white house around noon.

10 Q. You went for your questioning, do you know what time that was?

11 A. Immediately after -- when we were all off the bus, there was a short

12 break and we had to go to the interrogations.

13 Q. You went accompanied by a guard to an interrogation in another

14 building, is that right?

15 A. When I went to the interrogation I followed the guard who would not

16 allow me to walk fast.

17 Q. How long did your interrogation take?

18 A. Not a long time.

19 Q. But before this interrogation took place, you had been beaten on two

20 occasions, when you arrived at the white house and also ---

21 A. Yes.

22 Q. -- when you left the white house?

23 A. Yes.

24 Q. Had you been beaten in the room of the white house as well?

25 A. In the white house I was not beaten until after the interrogation and

Page 4328

1 I was not beaten even after the interrogation, and the only times that

2 anything happened was when they walked over us or stepped over us.

3 Q. When you returned from your interrogation you were then put in

4 another room and am I right in saying, from what you describe, as you

5 enter the white house it is the second room on the left, so at the end

6 of the building?

7 A. Yes.

8 Q. Were there other prisoners already in that room when you arrived?

9 A. No, there were only the ones who arrived that day, together with me

10 from Keraterm.

11 Q. So, when you were put in that new room in the white house, how many

12 people were in that room at that stage?

13 A. At that moment when I arrived from the interrogation there was only

14 myself and two more.

15 Q. As you moved through the white house at this time, were you able to

16 tell how many other people were in the building itself? You knew of

17 the people who were in the first room you were put in, but what about

18 the other two rooms at the front of the white house?

19 A. I was not looking. I had no time to look.

20 Q. Why was that?

21 A. Well, a guard was leading me, was taking me there.

22 Q. The very small room at the end of the hallway in the white house, can

23 you recollect if people were in that room?

24 A. No, it was empty, the one at the end of the hallway.

25 Q. You referred to a lady who was also within the white house?

Page 4329

1 A. Yes.

2 Q. Can you tell us where she was placed in the building?

3 A. She told us that she was in the first room to the right.

4 Q. When you say "the first room to the right", that is as you enter the

5 front door, is that right?

6 A. Yes.

7 Q. Having been put in that second room on the left, did others come and

8 join you in that room?

9 A. Yes, all of the ones who were interrogated that day joined me in that

10 room.

11 Q. How many people came into that room by the night time?

12 A. Almost all of us came there. A few of them were left. They were not

13 interrogated.

14 Q. So that is somewhere between 40 to 50 people, is that right?

15 A. About 40 people, 40, 45, somewhere there. I do not know the exact

16 number.

17 Q. Had they, some of them, come in in a state of bad physical condition

18 having been beaten?

19 A. At that moment we were still not in a bad physical shape. Those were

20 the blows in passing.

21 Q. Others seemed to have received similar treatment to you, the beating

22 when they arrived and the beating when they left to go to their

23 interrogation?

24 A. More or less almost all fared the same, perhaps a blow more or less,

25 but pretty much everybody the same.

Page 4330

1 Q. The condition of this building at this time, would it be right to say

2 that it was in extremely poor condition because of the stench ---

3 A. Yes.

4 Q. -- and what it had been used for?

5 A. I do not actually know what it was used for, but I remember it by --

6 according to me, on that day it seemed as if those two rooms were

7 prepared especially for us.

8 Q. Some 40 of you in that second room on the left at the back of the

9 building was, presumably, a very cramped space to put that number of

10 people within?

11 A. Yes, yes, it was cramped. We were one on top of each other, like

12 sardines.

13 Q. Yes, this is not a big building and these are not big rooms that we

14 are talking about?

15 A. They were paying no attention to that.

16 Q. Yes. When the night time came had you had any opportunity for food

17 that day in Omarska?

18 A. No, in the white house I never ate anything.

19 Q. So when you were in the white house you were not given an opportunity

20 to go to the restaurant building?

21 A. No, I was not leaving the white house until the day when they took us

22 in front of the white house in order for it to be cleaned. I had not

23 left the white house.

24 Q. By this time you had spent a month and a half in these detention

25 camps, is that right?

Page 4331

1 A. You mean Keraterm and Omarska, both?

2 Q. Yes.

3 A. Approximately that time.

4 Q. Yes. You knew the kind of regime that you were under?

5 A. Yes.

6 Q. It was a regime where you were kept in fear?

7 A. Yes, it was a regime of terror.

8 Q. It was a regime where it was dangerous for you to disobey orders?

9 A. Yes, it was dangerous. If an order is given out, you had to obey it.

10 Q. A danger for you to know too much -- to know the guards, for

11 instance?

12 A. Yes, that was dangerous for everyone, not just me, anybody who was in

13 Omarska or Keraterm.

14 Q. This was a place where you could not look about and be curious to see

15 what was happening around you?

16 A. It depends on the position you are in.

17 Q. Because if one of the guards caught you being curious, you were in

18 immediate risk of being injured?

19 A. It depended on the guard too. There were those who really, who were

20 enjoying for you to see him before he starts torturing you. They

21 seemed to have been taking pleasure from torturing.

22 Q. Did you know at this time that Krkan's shift was a shift that was

23 regarded by people in Omarska as being the worst shift?

24 A. While I was in Omarska, I found out only when I left the white house,

25 I heard that Krkan's was one of the worst shifts.

Page 4332

1 Q. The rooms that you were in in the white house had doors, is that

2 right?

3 A. These rooms where I was had only openings, whereas the doors had been

4 taken away.

5 Q. Were there not doors that were closed on the rooms so that you were

6 kept in the rooms?

7 A. While I was in these two rooms there were no doors, that is, door

8 panes were not there.

9 Q. So you include within that the room that was the second room on the

10 right-hand side?

11 A. The second one to the right and the second to the left, it was either

12 whoever was in one of those two places could see from one room to

13 another.

14 MR. KAY: Your Honour, that is a convenient moment.

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

16 (11..30 a.m.)

17 (Short Adjournment)

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

19 MR. KAY: Thank you, your Honour. Mr. Icic, I would like you to look at

20 this photograph and perhaps if we can have called up on the screen

21 22-22? It is Exhibit 240 produced earlier by the Prosecution. I do

22 not know if we are able to get 22-22? I do not think the technicians

23 are able to do it, so perhaps if that photograph can be placed on the

24 overhead projector so that the Court can see it?

25 THE PRESIDING JUDGE: What Exhibit is that, number?

Page 4333

1 MR. KAY: Exhibit 240, your Honour. Mr. Bos has another here. So if Mr.

2 Bos could put that on the monitor? Thank you. This is a photograph,

3 Mr. Icic, taken in the white house from the room which is the second

4 room on the right as you enter. You can see on that photograph that

5 there is a door with an enclosed panel at the bottom, glass above.

6 This door is affixed to that room where you were first placed. You

7 can see across the corridor what would be the first room on the left

8 and there is also a door to that room. What I put to you is this,

9 that there were doors on those rooms in the white house. What do you

10 say about that?

11 A. Why, nothing. They might have put them later on.

12 Q. They were not there then when you were in the white house?

13 A. I did not see them.

14 Q. Because what I also suggest to you is that, in fact, these doors were

15 shut whilst you were in your rooms in the white house?

16 A. This door was never shut to those two rooms.

17 Q. Very well. What I want to talk to you now about is what happened

18 after you were beaten in the room and your clothing slashed and Krkan

19 had attempted to extort money from you. After that had happened, you

20 say that men entered the white house with lighting and other

21 equipment. What do you mean by that, what sort of lighting?

22 A. Well, they did not come in with lighting. They came in with gear,

23 with equipment for lighting, so as to set up lighting in the hallway.

24 Q. Why was lighting being put in the hallway?

25 A. They must have known that. I did not know it, why did they put the

Page 4334

1 lighting in the hallway.

2 Q. Because this was night time and it was dark, is that right?

3 A. Yes.

4 Q. There was no electric light within your rooms?

5 A. No, not in my room.

6 Q. So far as you could tell, the other rooms?

7 A. In other rooms, neither in the room across there was no light either.

8 Q. The room where you went to be questioned, if you could identify that

9 room again to us, which room it was as you entered the white house

10 through the front door?

11 A. There were no interrogation rooms in the white house.

12 Q. You described, though, going into a room where others had been and

13 where beatings took place upon you as an individual?

14 A. That was -- I described that from the bus together with my

15 colleagues, those who had arrived with me, got to the last room on the

16 right, but that was not the interrogation room. The interrogation

17 room is in a completely different building.

18 Q. Yes, I understand that, but you describe during the night time being

19 taken to another room having been called out?

20 A. Yes, when I was called out, but that was not the interrogation room.

21 That was the beating room.

22 Q. If you could then identify to us as you walked through the front door

23 which room you would call the "beating room"?

24 A. Right, as you enter the white house it was the room at the end of the

25 corridor.

Page 4335

1 Q. On the left or right?

2 A. Straight.

3 Q. So the small room at the end of the corridor?

4 A. Yes, that was that small room.

5 Q. That room was a very small room indeed, not much bigger than a shower

6 cubicle?

7 A. Well, I would not say a shower cubicle. A shower cubicle is very

8 small. Since I work in construction, I know how large a shower booth

9 can be, 60 by 80, not more than that.

10 Q. Yes, but the room where you say you were called into and beaten by

11 five or six men, are you saying that that is the room at the end of

12 the corridor?

13 A. I said that is the room at the end of the corridor where we were

14 taken in one by one that evening and beaten up.

15 Q. So what was the lighting used for?

16 A. Well, presumably, so that they could see. Those who beat us, so that

17 they could see what they were doing.

18 Q. This room would have been a room that was with a screen from the

19 hallway, so that you had to go through a doorway to get into it?

20 A. It had nothing, no screen.

21 Q. Was it just an open area at the end of the corridor?

22 A. Yes, it was simply like these other rooms, it also would have doors,

23 but it did not have a door. There was no panel or, at least, I did

24 not notice it. At any rate, there was no obstruction.

25 Q. When you were beaten in this area, how many people were in that area

Page 4336

1 with you?

2 A. When I entered that room, there was nobody else but those who beat me

3 and myself.

4 Q. So how many people would that put in that area?

5 A. Well, as a matter of fact, five of them and myself as the sixth one.

6 Q. How exactly were you beaten?

7 A. That I did not see. I had no time to see that.

8 Q. You described having a noose around your neck and you fell to the

9 floor. This was a way of holding you or restraining you with the

10 rope around your neck, is that right?

11 A. Yes, one of them was holding me with a noose which was very tight,

12 and I was struggling for air and the rest I could not see.

13 Q. How long after that beating that took place in the room when your

14 clothing had been slashed with knives did this take place? How long

15 after that?

16 A. Well, the slashing of clothes did not happen after this event. It

17 was before. It was while there was still daylight.

18 Q. Yes, I know that and that was, in fact, my question. What I wanted

19 to know was the gap between the two incidents that took place.

20 A. That I could not tell you. One of the incidents took place in day

21 time and the other one at night.

22 Q. The earlier incident involving the slashing of the clothing concerned

23 Krkan's guards and his shift, is that right?

24 A. I did not see those people, whose shift it was, and who were those

25 people, I do not know.

Page 4337

1 Q. But Krkan seemed to have been involved because he was the one who was

2 asking you to write down your names and what money or valuables you

3 had on the sheet of paper?

4 A. Yes, he was always the one calling out.

5 Q. This group that attacked you in this room included someone called

6 Duca, is that right, or Duca?

7 A. Yes.

8 Q. Also known by you as Dule?

9 A. No, I never knew him as Dule.

10 Q. Are you sure about that?

11 A. I am 100 per cent, I never even knew that he was Dule. I knew that

12 that was Duca from Orlovci, but he could -- he could have also been

13 Dule. It was possible because Serbs used it as an abbreviation, Dule,

14 Dusko. I mean, all those could be one and the same name.

15 Q. Have you not referred to him in a statement written by you in your

16 own hand as "Dule, known as Duca"?

17 A. Well, maybe when I was writing that it is a slip of the hand but, to

18 my mind, it is all the same.

19 Q. What I am interested about is why you should be so concerned to say

20 that that is a slip of the hand and not something you would have used

21 as an expression?

22 A. Well, normal expression for a man is if you know his full name, if

23 you were friends with him, if you socialised with him, but I never

24 did, neither were we friends, nor we socialised. I met him as a bad

25 man in Keraterm who came daily.

Page 4338

1 Q. But are you trying to conceal from us the fact that Duca was called

2 by you "Dule" because of this case?

3 A. No.

4 Q. Because what I will do is I will show you this statement written by

5 you in your own hand on 12th February 1993 where you refer to that.

6 This will be D28, your Honour.

7 MR. BOS: D27.

8 MR. KAY: D27. [To the witness]: Do you remember writing this in

9 February 1993, Mr. Icic?

10 A. Yes.

11 Q. At the end of the statement you will see it is numbered 200, is that

12 a signature of yours? Perhaps you would like to look at the very last

13 page that is stamped page 200?

14 A. Yes, yes.

15 Q. That is your signature, is it not?

16 A. Yes, but that is not my statement.

17 Q. What do you mean it is not your statement?

18 A. Well, you see when I came out of the camp I live in a town where

19 there are very few people from Yugoslavia, and the doctor advised me

20 to talk about the whole incident otherwise I would go crazy, and I

21 said, "I have no one to talk to" and he said, "Well, then take a pen

22 and write it down".

23 So I wrote it down but it was not a statement. I just wrote

24 it as if to have some something to remember as a memento, but I could

25 write this down on 200 pages had I written it as a statement, every

Page 4339

1 detail in all the incidents. But this does not cover all the

2 incidents, everything that I went through while in the camp. This is

3 only a part of it. This is the smallest, the tiniest part of the

4 truth that I experienced in the camps, and that I wish to survive so

5 as not to forget it.

6 Q. Let us look then at what you said was the truth, because on page 166,

7 if you turn over the first page, you, in fact, wrote in your hand

8 there that it was the truth, did you not?

9 A. Yes.

10 Q. Perhaps you would read that out what it means in your own language?

11 A. It is the truth for me all. That I wrote down here is the truth but,

12 of course, you can twist words as you like. A word can be -- one word

13 can be interpreted in a thousand ways.

14 Q. But these are your words on these pages, they are not my words, are

15 they?

16 A. These are my words ---

17 Q. Yes.

18 A. -- which have a meaning for me.

19 Q. Perhaps then if you would just turn to page 178 and see what that

20 meaning was concerning Duca. To be fair to you, so that the whole

21 thing is put in full context, can you see that the paragraph that

22 begins, is it ,"Oko 22", the first paragraph on the page?

23 A. Yes.

24 Q. Perhaps if you would just read out that whole paragraph so that we

25 can see what you said there? Read it out in your own language, then

Page 4340

1 it will be translated back to us.

2 A. "Around 2200 a new group of torturers came again, and they were

3 preparing torture for us. As there was no electricity, they would put

4 the generator in the corridor and a lamp bulb so that they could light

5 the corridor and the small room which was the torture room for them.

6 "They took the list which dammed Krkan had compiled and

7 called out one by one and tortured him. That group of Chetniks was

8 composed of six which included Dule Tadic from Kozarac, Simo Kevic

9 from Orlovci, a tyre repairer, one Banovic from Prijedor, Dule called

10 'Duca' from Prijedor and Dragan Babic from Babici near Kamicani.

11 "Amid the guards were the guards Krkan and two brothers,

12 Kvocka. The moment they would called out one, a noose would be thrown

13 around his neck so that he could not shout, whereas others would start

14 beating with different objects, rods made of some flexible" -----

15 Q. That is all we need at this stage so that the full text concerning

16 the names was read out. You see, I was interested in you saying in

17 here that Duca was also called Dule?

18 A. Yes, some people called him that in Keraterm. I knew him as "Duca"

19 and most people knew him as "Duca".

20 Q. Yes, but why were you trying to avoid admitting that to us in this

21 courtroom, that you knew him as "Dule" and saying it was a mistake or

22 saying it was not intended? Why?

23 A. I did not want to avoid it and I am not avoiding it now. To my mind,

24 it is the same, "Dule" and "Duca".

25 Q. OK. How long was it then that this group of men attacked you?

Page 4341

1 A. Well, not attack. It was I already described it. They brought me.

2 I greeted them. They tightened the noose around my neck and beat me

3 up. How long it took, I do not know.

4 Q. That seems to have been your fourth beating that you had had since

5 arriving at the camp, is that right?

6 A. That was the first real beating. The other thing was beating along

7 the way, on the way.

8 Q. By this stage you must have been in a very poor physical condition,

9 is that right?

10 A. Well, I would not say very poor, but I was in a poor condition.

11 Q. Presumably, again when you were called out you knew what was in store

12 for you, you were in great fear?

13 A. As a matter of fact, I did not know what was in store for me, but I

14 heard beatings and I saw all those people thrown out. So that I could

15 assume that the same thing was in store for me as for them.

16 Q. Later on after your beating you have told us about an occasion when

17 you say Dule Tadic came into your room and said, "You will remember,

18 Sivac, that you cannot touch a Serb or say anything to a Serb", is

19 that right?

20 A. He did not come to my room. He stayed in the doorway when they threw

21 in in front of my feet Sefik Sivac.

22 Q. You say that you recognised that first person as being Dule Tadic?

23 A. Yes.

24 Q. Is that because you saw him?

25 A. Sure.

Page 4342

1 Q. Is that what you were telling us about earlier today, that you saw

2 him?

3 A. I saw him then.

4 Q. You see, in this statement here you actually say that you identified

5 Dule Tadic by his voice. If you turn to the next page, page 179 ----

6 A. I also heard him.

7 Q. Perhaps so that you can have an opportunity to deal with this, you

8 can read out the last paragraph that begins, is it "Nekako" or

9 "Nekako", the last paragraph on page 179?

10 A. Yes.

11 Q. Perhaps if you can just read out that bit that is on the page, the

12 full paragraph in your own language?

13 A. The last one you mean, from "Hrvat" or?

14 Q. A few lines above there right at the beginning so that we have the

15 whole paragraph. Can you see that?

16 A. Yes, I do. "It could have been the third night, around the midnight,

17 I was awake once again and thirsty. A guy gave me a few drops of

18 water and I was refreshed. Outside the Chetniks indulged in orgies

19 and I heard them calling out again somebody called Hrvat. That night

20 they killed him and then they threw in an industrious lad who asked

21 for water but had no time to drink it because he died. I heard the

22 one throwing him in swear, and I recognised Dule Tadic's voice because

23 he swore this in the same way that night when they beat me. In the

24 morning I saw that the killed man was Sefik Sivac. All around there

25 were dead who were being taken out by other prisoners".

Page 4343

1 Q. Yes, when you wrote about this you did not say that you saw Dule

2 Tadic at all, did you? You said that you recognised the voice?

3 A. I had heard a voice before while he was swearing and I saw him the

4 moment when he was throwing Sefik at my feet.

5 Q. What you heard being said was those words about "You will remember,

6 Sivac, that you cannot touch a Serb or saying anything to a Serb".

7 That is what you were talking about hearing, is that right?

8 A. Yes, "You will remember, Sivac, that you may not say a word to a Serb

9 or lay a finger on a Serb", something to that effect.

10 Q. In this statement here that you have just read out to us, you say

11 that it was in the morning that you knew the killed man was Sefik

12 Sivac? You described him earlier as an industrious young man; what

13 your words were, "In the morning I saw that the killed man was Sefik

14 Sivac".

15 A. Yes. I recognised him in the morning and then I was positive that it

16 was he. At the moment when they threw him in, I was not sure that

17 that was he, but he was not industrious, he was a worthy man, a big

18 man. An industrious man is a man who works a lot and things like

19 that, and the word I meant was that he was a very big man.

20 Q. So there was some doubt in your mind that caused you not to be able

21 to recognise the man when he was put in the room, is that right?

22 A. At that moment that is quite correct, I did not recognise him at that

23 moment.

24 Q. Is that because the room was in darkness?

25 A. It could also be that.

Page 4344

1 Q. Is that because it was difficult for you to recognise someone in

2 that room with no electricity at night?

3 A. There was no light in that room at night, and it really was difficult

4 to see the face of a beaten man. But when the day broke there was

5 enough light to see.

6 Q. When you say about this lighting equipment that was brought into the

7 white house that night that you were beaten, is that true? Did that

8 really happen?

9 A. It did happen and I shall never forget it. I will not forget my

10 broken ribs and pain and the painful bones that I still suffer from

11 today.

12 Q. I understand that. What I am asking you about, however, is the

13 lighting because in this statement that we have been looking at you

14 say that the lighting was run by a generator, is that right?

15 A. Yes, not a dynamo generator. It was the one that was used in a car

16 or dry batteries.

17 Q. So the lighting was poor, was it, unless you had some sort of

18 artificial light to enable you to see what was happening?

19 A. There was enough to light the corridor, and they also lit that small

20 room. Now, whether there were two lamp bulbs there in the small room,

21 I did not see that, but at any rate they were well lit, both the

22 corridor and the small room.

23 Q. So it is not a generator that was being used to power the light, it

24 was a car battery, is that right?

25 A. Yes. Yes, and that was a car battery or a truck battery.

Page 4345

1 Q. In relation to these matters, you have given many interviews to the

2 press and media? Have you been on television about these matters, Mr.

3 Icic?

4 A. Yes, but not on television. This incident was not discussed. The

5 television was interested in what men worth 100 francs looked like.

6 Q. Yes, but you have spoken to, is it, Monika Gras? Have you been on

7 one of her television programmes or a couple of them?

8 A. Yes.

9 Q. You have given interviews to journalists, is that right?

10 A. It is.

11 Q. You see, what I am suggesting to you is that you did not recognise

12 Dusko Tadic in the white house on these occasions that you have

13 described?

14 A. You have the right to say that I had not been to the white house, but

15 I claim that he was in these two incidents.

16 Q. You saw the arrest of Dusko Tadic on television, is that right?

17 A. I did not see the arrest itself because I was working.

18 Q. No, but you watched it on television when you got home from work that

19 night?

20 A. Only briefly during the news.

21 Q. You have also watched programmes about Omarska that have been made?

22 A. Not much, very little. I had no time.

23 Q. But you have spoken to television journalists; Penny Marshall is

24 another one you have spoken to, is that right?

25 A. Yes, Mrs. Marshal came to see me not long ago, but we had never

Page 4346

1 mentioned Tadic or even the incident. She asked me if I was going to

2 The Hague and we just chatted. She came to my company, she came to

3 see where I worked, and we did not discuss this case.

4 Q. Do you know who I mean by witness K in this case? I do not want the

5 person's name.

6 A. Witness K, yes, I do remember.

7 Q. Is she your sister-in-law?

8 THE PRESIDING JUDGE: Excuse me, before the witness answers, just one

9 moment.

10 MR. KAY: Yes, your Honour.

11 THE PRESIDING JUDGE: Wait. Do not answer. Can you hear me?

12 THE WITNESS: I am not familiar with witness K. Yes, I can hear you.

13 MR. KAY: I can appreciate, your Honours, there has been a change.

14 THE PRESIDING JUDGE: Just one minute. OK. The witness has changed since

15 I took my earphones off.

16 MR. KAY: The status of the witness has changed, K, which I was advised of

17 this morning.


19 MISS HOLLIS: Yes, your Honour. We informed the Defence this morning that

20 as of yesterday witness K had indicated her willingness and her wish

21 to testify publicly. We will be providing her name and the statement

22 without redactions to the Defence today.

23 THE PRESIDING JUDGE: OK. You have not advised the Court or have you?

24 MISS HOLLIS: No, your Honour.

25 THE PRESIDING JUDGE: We have entered an order on August 10th, I guess, of

Page 4347

1 last year granting the protective measures that the Prosecutor had

2 asked for.

3 MISS HOLLIS: Yes, your Honour.

4 THE PRESIDING JUDGE: OK, fine. If it is fine with the parties, let us

5 discuss it.

6 MR. KAY: I do not know the name yet which is why I am still using the

7 initial. [To the witness]: But is it right that she is your

8 sister-in-law?

9 MR. TIEGER: I am sorry, your Honour, I think we are entering into ----

10 THE WITNESS: No, she is not my brother's wife.


12 MR. TIEGER: I am just a little confused about where we are now as I

13 imagined we would have to be in the light of the answers. I understood

14 that we may or may not be talking about the same person when K is

15 referred to.

16 THE PRESIDING JUDGE: From what Miss Hollis tells me, the K that was

17 referred to in the order of August 10th 1995 now wishes to testify

18 openly and freely. So, if that is the wish of the party who intends

19 on offering that witness, then that may be done. So at this point I

20 have no questions. It is up to Mr. Kay, I suppose, to elicit from the

21 witness what he wishes. If there is no objection, then we can go

22 ahead. My only concern was that a witness who was the subject of

23 protective measures, a request made by the

24 Prosecutor, would be identified and then unbeknown to the Chamber, at

25 least, that request has been withdrawn. That is fine.

Page 4348

1 MR. KAY: Your Honour, I will leave this area.

2 THE PRESIDING JUDGE: No further questions. You may go into the area, Mr.

3 Kay, if you wish.

4 MR. KAY [To the witness]: You have made claims that 30 to 40 people were

5 being killed in the white house each night that you were there, is

6 that not right?

7 A. I believe that there was more.

8 Q. Yes, but whilst you were there?

9 A. While I was there more people were killed. They were carried away.

10 Whether they were dead, they were really killed, they never came

11 back, none of them or none of the ones who were carried away from the

12 white house. That is why I assumed they are dead.

13 Q. But that would have been almost your entire room?

14 A. Almost the whole room emptied out, almost the whole room.

15 MR. KAY: Thank you. I have no further questions, your Honour.


17 MR. TIEGER: Thank you, your Honour.

18 Re-Examined by MR. TIEGER.

19 Q. Mr. Icic, you were asked whether or not you knew why you were

20 included among the group of people taken from Keraterm to Omarska.

21 You indicated that, to this day, you really do not know why.

22 A. No, I do not.

23 Q. When you were interrogated in Omarska, did the person questioning you

24 note in your statement that you had been a worker in Germany, that you

25 had come home to visit and then had been unable to return?

Page 4349

1 A. Yes.

2 Q. What was his reaction when he saw that?

3 A. Well, he smiled.

4 Q. Your Honour, may I have this photograph marked as the exhibit next in

5 order for identification, please. It will be Exhibit 279. Mr. Usher,

6 may that be shown to the Defence, please. Mr. Icic, do you recognise

7 that photograph as showing a portion of the white house and, in

8 particular, showing a portion of the small room at the end of the

9 corridor?

10 A. Yes, except those things, the tables, it was not there. It was all

11 empty.

12 Q. I would tender 279 for admission, your Honour, and ask that it be

13 placed on the Elmo.

14 THE PRESIDING JUDGE: Any objection?

15 MR. KAY: No objection, your Honour.

16 THE PRESIDING JUDGE: Exhibit 279 will be admitted.

17 MR. TIEGER: Can we focus in a little more closely toward that rear room?

18 Perhaps a little farther back. Mr. Icic, the room at the back end of

19 the corridor is the beating room you referred to earlier?

20 A. Yes.

21 Q. We can see the left wall and the rear wall in that photograph, is

22 that right?

23 A. Yes. Yes.

24 Q. Does the rear wall extend farther to the right and then is there

25 another wall on the right?

Page 4350

1 A. Yes, there off to the right and then there is another wall.

2 Q. Is that room the size of a shower cubicle, at least shower cubicles

3 in your experience?

4 A. No, you would rather say the size of a bathroom.

5 Q. Is there room in that -- is there space in that room for six people

6 to be inside and to move about, at least to move their arms?

7 A. In that room there was space for me to fall down and for them to beat

8 me. How they behaved there, how they moved, I did not see that and

9 how they arranged it.

10 Q. Mr. Icic, referring to other parts of the white house, you indicated

11 that you did not observe either that there were not doors or you did

12 not observe doors on the second room to the left, the second room to

13 the right in that small room we just discussed. Do you recall whether

14 or not there were doors on the first rooms to the left and right?

15 A. Yes, there was a closed door on the first room.

16 Q. Was that the same type of door that we have seen in these

17 photographs?

18 A. Yes, half glass door.

19 Q. Just to clarify one or actually two incidents that Mr. Kay asked you

20 about a few moments ago. When you had returned from interrogation and

21 a group of people came in and were jumping on your backs and cutting

22 your clothes ----

23 A. Yes.

24 Q. Do you know whether or not Krkan was there at that time?

25 A. Krkan was in the hallway.

Page 4351

1 Q. After that was over and sometime later did Krkan return with the

2 paper and pencil?

3 A. Yes, only after some time, he came with paper and a pen.

4 Q. You were asked some questions about a person that you had seen in

5 Keraterm known as Duca. You did not know Duca's real first name or

6 last name, is that right?

7 A. No, I did not. I do not know it now either.

8 Q. Was it your understanding that Duca could be a nickname for a number

9 of first names?

10 A. Yes.

11 Q. I also want to ask you about one other incident that Mr. Kay referred

12 to, and that was the occasion when Sefik Sivac was thrown into your

13 room. First of all, before Mr. Sivac was thrown into the room, did

14 you hear something in the hallway?

15 A. Yes, I heard a curse and some kind of quarrel or they were really

16 cursing, they were discussing when they were beating.

17 Q. After you heard that cursing was Mr. Sivac then thrown into your

18 room?

19 A. Yes, after that they dragged him in and they threw him.

20 Q. You mentioned that there was no light in your room. Was the hall

21 ----

22 A. There was no light.

23 Q. Was the hallway and doorway better illuminated than the interior of

24 your room?

25 A. The hallway was lit and it was lit well.

Page 4352

1 Q. Were you able to see the face of the first man who dragged Mr. Sivac

2 to the room and threw him in as he stood at the doorway?

3 A. Yes.

4 Q. Was that man Dule Tadic?

5 A. Yes, I am sure it was Dule Tadic.

6 Q. Was it after Mr. Sivac was thrown in that you heard Dule Tadic say

7 something?

8 A. Yes, at that time he said those words that for Sefik to remember that

9 Serbs cannot be touched or be said -- and then he left.

10 Q. So first you heard the cursing, then Mr. Sivac was thrown in?

11 A. Yes.

12 Q. Then you heard the words about Sivac?

13 A. Yes. Yes.

14 Q. Mr. Icic, you have told us about the account which you wrote in 1993

15 about some of the experiences you had in Omarska and Keraterm. Are

16 you a professional writer, Mr. Icic?

17 A. No. I never wrote anything and this I wrote only not in order not to

18 go crazy.

19 Q. Are you a criminal investigator?

20 A. No.

21 Q. Are you a historian?

22 A. No.

23 Q. Were you trying to write an account for courtroom purposes?

24 A. No. That would look completely different.

25 Q. So, for example, when you wrote about the incident with Sefik Sivac,

Page 4353

1 did you write each and every detail of what happened that particular

2 night?

3 A. No, I did not write down every detail. It would be too long.

4 Q. Did you write down each and every basis for why you knew it was Dule

5 Tadic who threw Mr. Sivac in the room?

6 A. I did not write down. I did not write down why. It was an

7 abbreviated form, so that I have it with me, on me. The reason, I

8 could just assume why they did it, but what I knew I did not have the

9 need to write down.

10 Q. Mr. Kay asked you if you spoke to journalists such as Monika Gras and

11 you indicated you did?

12 A. Yes.

13 Q. He asked you if you saw the arrest of Dusko Tadic or were aware of

14 the arrest of Dusko Tadic, and you indicated that you were aware of

15 it?

16 A. I found out from television, from the news when I came back home from

17 work. I was surprised.

18 Q. The account you wrote about your experiences or some of your

19 experiences in Omarska and Keraterm, however, was written before Mr.

20 Tadic was arrested, is that not right?

21 A. A lot before.

22 Q. Before you were ever contacted by any journalists?

23 A. Before I was not even thinking about that, that I would get in touch

24 with anybody.

25 Q. It was in that account that you recorded that Mr. Tadic and others

Page 4354

1 had beaten you in the small room of the white house and that Mr. Tadic

2 had thrown Sefik Sivac into the room, is that correct?

3 A. Yes.

4 Q. Let me ask you a question I did not ask you earlier. Mr. Icic, do you

5 see Dule Tadic in court today?

6 A. Yes.

7 Q. Can you point him out and tell us what he is wearing, please?

8 A. He is in a green jacket with a tie between two policemen.

9 Q. May the record reflect the identification of the accused, your

10 Honour?

11 THE PRESIDING JUDGE: Yes, the record will reflect that the witness

12 identified the accused.

13 MR. TIEGER: May I have just a moment. Nothing further, your Honour.


15 MR. KAY: Nothing arises, your Honour.

16 Examined by the Court.

17 JUDGE STEPHEN: Witness, we have seen some photographs of the inside of

18 the white house, and those photographs show nice, clean white walls.

19 Was that the condition of the white house when you were there?

20 A. At that time the condition was as if it was a very messy

21 slaughterhouse, stench and blood, urine and beaten up people, blood

22 sprayed on the walls, horror. That was how the rooms in the white

23 house looked in reality.

24 JUDGE STEPHEN: Thank you.

25 THE PRESIDING JUDGE: I have just one question and it relates to the dates

Page 4355

1 about which you testified. What was the date, as best you can

2 recall, you left Keraterm?

3 A. 7th or 8th, I am not sure about that. I cannot say the exact date,

4 7th or 8th July.

5 Q. Of July 1992?

6 A. 1992.

7 Q. Did you come to Omarska immediately after leaving Keraterm?

8 A. Immediately.

9 Q. The beating that you have testified about, am I correct that that

10 occurred a few days after you arrived at Omarska?

11 A. The beatings happened the same night.

12 THE PRESIDING JUDGE: I have no further questions. Mr. Tieger? Mr. Kay?

13 MR. KAY: No, your Honour.

14 THE PRESIDING JUDGE: Is there any objection to this witness being

15 permanently excused?

16 MR. KAY: No objection, your Honour.

17 THE PRESIDING JUDGE: Mr. Icic, you are permanently excused. You are free

18 to leave. Thank you very much for coming. We will stand in recess

19 now for lunch until 2.30.

20 (12.55 p.m.).

21 (Luncheon Adjournment).



24 (2.30 p.m.) PRIVATE

25 THE PRESIDING JUDGE: Miss Hollis, will you call the next witness?

Page 4356

1 MISS HOLLIS: Thank you, your Honour. Before I call the next witness,

2 referring to the matter we discussed this morning, as I indicated,

3 witness K has indicated to me last evening that it is now her wish that

4 she testify in public with no protective measures in place. For that

5 reason, I request that that portion of the decision in August that

6 relates to providing protective measures for witness K be withdrawn or

7 rescinded. If the Court approves that, then I am prepared at this time

8 to provide the Defence with the name of the witness, confirming the name

9 of the witness, and also with a statement without the prior redactions

10 that we had.

11 THE PRESIDING JUDGE: Very good. Do I need to hear from the Defence on

12 that? No.

13 MR. WLADIMIROFF: No objection whatsoever, your Honour.

14 THE PRESIDING JUDGE: Very good. Yes, Miss Hollis, that request will be

15 granted and that portion of decision granting protective measures to K

16 at the request of the Prosecutor will be modified, at least, or

17 withdrawn, treated appropriately.

18 MISS HOLLIS: Thank you, your Honour.

19 THE PRESIDING JUDGE: I appreciate your advising the Chamber. In that way

20 we do not have to be concerned about that matter. Of course, the Chamber

21 is delighted that the witness will come forward and we will hear from

22 the witness in open court.

23 MISS HOLLIS: Yes, your Honour. Your Honour, it appeared this morning that

24 we were being somewhat dilatory in advising the Chamber. I apologise.

25 We simply were not aware it might come up in cross-examination and we

Page 4357

1 wanted to have the completed package before we notified you.


3 MISS HOLLIS: Your Honours, witness 52 in the order you have will not be

4 called at this time, instead witness 54 will be called. So, your

5 Honour, at this time the Prosecution would call Ermin Strikovic.

6 THE PRESIDING JUDGE: Has the Defence been advised of the change in order?

7 MISS HOLLIS: Yes, your Honour.


9 THE PRESIDING JUDGE: Mr. Strikovic, would you please take the oath that is

10 being handed to you?

11 THE WITNESS [In translation]: I solemnly declare that I will speak the

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

13 (The witness was sworn)

14 THE PRESIDING JUDGE: Thank you. You may be seated.

15 Examined by MISS HOLLIS

16 Q. Sir, would you please state your name?

17 A. Ermin Strikovic.

18 Q. Your date of birth?

19 A. 15th July 1957.

20 Q. What is your nationality or ethnic group?

21 A. Muslim.

22 Q. What is your place of birth?

23 A. Zenica.

24 Q. What part of Bosnia is Zenica located?

25 A. In the central part.

Page 4358

1 Q. At this time if we could retrieve Prosecution Exhibit 78, please? If

2 that could be provided to the witness, please? Sir, if would look at

3 that and then if that could be placed on the overhead projector? If we

4 could zoom in on the central part, please? Sir, would you point to

5 where Zenica is located?

6 A. Here.

7 Q. Thank you. Please be seated. Sir, did you live in Zenica until you

8 were 13 years old?

9 A. No, until my 13th.

10 Q. Until your 13th birthday?

11 A. Yes.

12 Q. Then did you move to the Puharska area of the town of Prijedor?

13 A. Yes.

14 Q. In 1985 did you move to the town of Kozarac?

15 A. Yes.

16 Q. Did you live in Kozarac until May 1992?

17 A. Yes.

18 Q. Did you serve in the JNA from 1984 until 1985?

19 A. Yes.

20 Q. What were your duties?

21 A. I was a truck driver.

22 Q. Where were you stationed?

23 A. I did not serve my military in Bosnia. I was in Kovin near Belgrade

24 for training and after that I was posted to Kerestinec near Zagreb.

25 Q. During your service in the JNA did you become familiar with JNA

Page 4359

1 uniforms, weapons, vehicles and equipment?

2 A. Yes.

3 Q. Sir, what is your marital status?

4 A. Married.

5 Q. What is your wife's name?

6 A. Azra Blazevic.

7 Q. What was her prior occupation?

8 A. Veterinary doctor.

9 Q. What was your prior occupation?

10 A. A traffic engineer.

11 Q. Where did you work?

12 A. In a company called iron ore mines Ljubija, truck and vehicle

13 maintenance.

14 Q. Did the Ljubija iron ore mine also own the mines in Tomasica and

15 Omarska?

16 A. Yes.

17 Q. Sir, if you know, what is the distance from Prijedor to Omarska?

18 A. I know.

19 Q. What is that distance?

20 A. 22 kilometres.

21 Q. What would be the average driving time from Prijedor to Omarska under

22 normal conditions?

23 A. 45 minutes by bus, passenger car 30, 35 minutes, depending on the

24 traffic conditions.

25 Q. What is the distance from Kozarac to Omarska?

Page 4360

1 A. 12 kilometres.

2 Q. What would be the normal driving time under normal conditions?

3 A. Under normal conditions, about 20 minutes.

4 Q. What were your duties at the Ljubija iron ore mining company?

5 A. I was the technical manager of the car park of the part of the company

6 called Autoservis.

7 Q. How long did you work at that company?

8 A. Nine years.

9 Q. Where was your place of work?

10 A. The headquarters were in Prijedor.

11 Q. Were most of your business and social friends and acquaintances

12 located in Prijedor?

13 A. Yes, most of them.

14 Q. Did you know many of the people who lived in Kozarac?

15 A. I did not know many people in Kozarac.

16 Q. Did you know Dule Tadic?

17 A. No, I did not.

18 Q. In March 1992, do you recall being told to set up a plan to bring iron

19 ore from the Omarska mine to the Tomasica mine?

20 A. I remember a plan was to be drawn for the reconstruction of the

21 already existing road, industrial access road, between Omarska and

22 Tomasica.

23 Q. Who ordered you to draw up this plan?

24 A. My superior, Bozo Grbic.

25 Q. What was his position in the company?

Page 4361

1 A. He was the manager of that part of the company.

2 Q. You indicated that the plan involved reopening an industrial access

3 road between Tomasica and Omarska?

4 A. Yes.

5 Q. The plan would call for what type of vehicles to use that road?

6 A. It was to be used for heavy duty mining mechanization used to

7 transport iron ore.

8 Q. After that project was underway, did other high level persons consult

9 with you about the progress of the project?

10 A. Yes.

11 Q. Were they interested in when the project would be finished?

12 A. Yes, they were.

13 Q. Who were these individuals?

14 A. Ostoja Marjanovic, general manager of the company, Stevan Tubin,

15 principal co-ordinator, traffic co-ordinator -- company traffic

16 co-ordinator.

17 Q. The three men that you mentioned in relation to this plan, Mr. Grbic,

18 Mr. Marjanovic and Mr. Tubin, what was the ethnic group of these men?

19 A. They were Serbs.

20 Q. Did any of these three men hold high office in any political party?

21 A. Yes.

22 Q. Who was that?

23 A. Ostoja Marjanovic was one of the leaders of the SDS.

24 Q. You were told that this road would be used for what purpose?

25 A. To transport the iron ore between Omarska and Tomasica.

Page 4362

1 Q. Was that road opened in March 1992?

2 A. Yes.

3 Q. At this time if I could offer to the Court another map, Prosecution

4 Exhibit 280, for identification? This map is similar to Prosecution

5 Exhibit 79, but it shows an area further south and it is a different

6 series. We do have a copy for the Defence and we will provide three

7 copies for the Judges. Sir, if you could take a moment to look at that

8 map and orient yourself as to the location of that industrial road you

9 were discussing? Then if Prosecution Exhibit 78 could be removed from

10 the overhead projector and Prosecution Exhibit 280 for identification

11 placed on the projector, please? Sir, if you could show us where that

12 road ran that was reopened?

13 A. [The witness indicated on the map].

14 Q. If you could put the pointer on that and hold it on there while we

15 locate it on the cameras? Then if you could show you us the route that

16 that road took?

17 A. [The witness indicated on the map].

18 Q. What was that road following beside?

19 A. The railway tracks.

20 Q. Sir, you may be seated. Thank you.

21 THE PRESIDING JUDGE: Is there any objection to 280?

22 MR. WLADIMIROFF: No, your Honour.

23 THE PRESIDING JUDGE: Exhibit 280 will be admitted.

24 MISS HOLLIS: After that road had been opened, did you have an opportunity

25 to examine that road?

Page 4363

1 A. Yes, twice.

2 Q. At the time you examined it, did you find any evidence that that road

3 was being used by heavy vehicles?

4 A. No, it did not -- this road surface did not look as if any heavy duty

5 vehicles had used it.

6 Q. Did you later learn what that road was being used for?

7 A. Yes.

8 Q. What did you learn? What was it being used for?

9 A. To transport people to the Omarska camp.

10 Q. How did you learn that?

11 A. With a considerable number of people, I was also transported along

12 that road to Omarska.

13 Q. Sir, several days before the attack on Kozarac, did you become aware

14 of a blockade of the town of Kozarac?

15 A. Yes.

16 Q. On 26th May, do you recall being at the motel in Kozarac that was

17 being used as a temporary medical centre?

18 A. Yes.

19 Q. Do you recall surrender terms being agreed upon at that time?

20 A. Yes, yes, I remember some of the conditions.

21 Q. Were you part of the column that surrendered on 26th May 1992?

22 A. Yes.

23 Q. What was your function?

24 A. I was the driver of the ambulance.

25 Q. Who was at the head of that column?

Page 4364

1 A. It was a private passenger car, a Mercedes.

2 Q. Who were the passengers in that car?

3 A. Kozarac police.

4 Q. Then you followed after that car in your ambulance?

5 A. Yes.

6 Q. Did you drive your ambulance from Kozarac to the hospital in Prijedor?

7 A. Yes.

8 Q. Along the way what happened with the car with the police officers in

9 it?

10 A. The column was stopped on the Kozarac/Prijedor road next to a bus stop

11 we used to call Limenka. One of the officers of the army waiting there

12 let through the car that I was driving and another car behind me, and

13 the Mercedes with Kozarac police was stopped at that bus stop.

14 Q. How far was that bus stop from the main business area of Kozarac?

15 A. From the commercial centre in Kozarac, about a kilometre and a half.

16 Q. After you had reached the Prijedor hospital with the ambulance, were

17 you then taken to the Prijedor police station and then on to Keraterm

18 camp?

19 A. Yes.

20 Q. Then on the next night, 27th May, were you taken to Omarska camp?

21 A. Yes.

22 Q. Do you recall how many buses of detainees were taken on that occasion?

23 A. I cannot give you the accurate number. I could not count them but

24 there were quite a number of them, about 10.

25 Q. When you arrived at Omarska camp and got off the buses, did you and

Page 4365

1 the others have to go through a line of men in uniforms?

2 A. Yes, yes, we had to.

3 Q. What kind of uniforms did you see?

4 A. I saw blue camouflage uniforms. I saw dark blue uniforms. They wore

5 berets on their heads.

6 Q. These blue camouflage uniforms and dark blue uniforms, were these

7 uniforms you had ever seen before?

8 A. No, I have never seen them before.

9 Q. As you went through the line, did you hear any of the men wearing

10 those uniforms speaking?

11 A. Yes, I heard them speaking.

12 Q. When you heard them speaking, were they speaking a local dialect or a

13 non-local dialect?

14 A. They spoke some other dialect.

15 Q. Did you recognise the dialect?

16 A. Yes.

17 Q. What was that?

18 A. From Serbia.

19 Q. How were you able to recognise that?

20 A. In Bosnia-Herzegovina one does not use the ekavski dialect. It is

21 characteristic only of the territories of Serbia and Montenegro, and

22 that was the dialect that they spoke, the ekavski dialect.

23 Q. What was being done to you and the other detainees as you went through

24 this line?

25 A. They were swearing, using filthy language, insulting us, swearing,

Page 4366

1 saying, "Why did you surrender? Why did you not fight, but it is easier

2 this way, it will be easier to kill you this way", and things like that.

3 Q. Were any of the detainees being beaten as you went through the line?

4 A. Yes.

5 Q. How long were you held in Omarska camp?

6 A. 72 days.

7 Q. The first night that you were in the camp, do you recall an incident

8 involving a man named Ahil?

9 A. Yes, I remember the incident.

10 Q. Did you know Ahil from before the camp?

11 A. Yes, I did.

12 Q. Do you know his last name?

13 A. No, I do not.

14 Q. What was his occupation?

15 A. I know he worked for the police in Kozarac on the eve of the war.

16 Q. What happened to him during this incident?

17 A. He was with me in the room that they put us when we arrived in

18 Omarska, and I guess that he was afraid or, perhaps, physically

19 unstable. He starting shouting, "This is never going to be Serbia, this

20 is Bosnia". He said or, rather, he shouted, "This is Bosnia", and at

21 that moment the room was entered by a man dressed in a uniform. I knew

22 him from before -- we used to call him "Cigo" -- and he began to beat

23 Ahil and ended by dealing him a blow with the automatic rifle or, more

24 precisely, with the rifle butt which hit Ahil's head.

25 Q. How long did he beat Ahil?

Page 4367

1 A. For about 15 minutes.

2 Q. What happened after that?

3 A. Ahil fell down, and he was lying quite still on the ground and Cigo

4 left the room.

5 Q. Did Cigo come back?

6 A. A little later Cigo returned and dragged Ahil's body into the

7 corridor.

8 Q. Did you see Ahil again the next morning?

9 A. Yes.

10 Q. Where did you see him?

11 A. He was lying on the grass next to the white house.

12 Q. What was Ahil's ethnic group?

13 A. Ahil was a Muslim.

14 Q. If you know, what was Cigo's ethnic group?

15 A. I do know he was a Serb.

16 Q. Sir, during the time you were at Omarska camp, did it appear to you

17 that Cigo was a camp guard or was a visitor to the camp?

18 A. Cigo was an occasional visitor to the camp.

19 Q. At some point after your arrival at Omarska, were you held in the

20 workshop building?

21 A. Yes.

22 Q. If you could take that pointer and simply point to and touch the

23 building you referred to as the workshop building?

24 A. [The witness indicated on the model].

25 Q. Thank you. While you were being held in the workshop building, were

Page 4368

1 you held in a room where a man named Vasif Alihodzic was also held?

2 A. Yes.

3 Q. Had you known him before you came to Omarska camp?

4 A. Yes, I knew him. We were friends.

5 Q. What was his profession?

6 A. He was the owner of a small transportation company.

7 Q. Was he called out of the room that you were both in at some point?

8 A. Yes, he was called out.

9 Q. Did you ever see him again after that?

10 A. No, I never saw him again.

11 Q. What was his ethnic group?

12 A. He was a Muslim.

13 Q. Were you at some point held in a room where a man named Sejad Sivac

14 was also held?

15 A. Yes.

16 Q. Had you known Sejad Sivac before you came to Omarska camp?

17 A. We were close friends.

18 Q. What was his occupation before he was brought to the camp?

19 A. He was a veterinarian.

20 Q. Where was he from?

21 A. He was from the hamlet of Sivci.

22 Q. What was his ethnic group?

23 A. He was a Muslim.

24 Q. Was Sejad Sivac taken out for interrogation two times in Omarska camp?

25 A. Yes, he was called out.

Page 4369

1 Q. What was his condition when he returned from his first interrogation?

2 A. I can say that he returned in a normal shape. He was not beaten up.

3 He looked normal.

4 Q. What was his condition when he returned from his second interrogation?

5 A. After the second interrogation he could not enter back into the room

6 by himself. He was carried into the room by others.

7 Q. Did you see any injuries, wounds or bruising on his body at that time?

8 A. Yes, I saw it because I personally dressed him.

9 Q. What did you see?

10 A. Black marks on the back, dark red haemorrhages in the area of the

11 kidneys, again bruises on his legs.

12 Q. How long was it before Sejad Sivac could walk again after this

13 beating?

14 A. It took five or six days. I do not remember exactly.

15 Q. Was he called out again at some later time?

16 A. Yes.

17 Q. Do you recall how much later he was called out?

18 A. Approximately two weeks after the second interrogation.

19 Q. Do you recall when he was called out?

20 A. Yes, I remember it. That was exactly on July 27th at 1400 hours --

21 1420 in the afternoon.

22 Q. How is it that you can remember that so precisely?

23 A. At that time when he was called out he left his personal belongings to

24 me and he stepped out. I knew he was not going to come back and that is

25 why I asked people around me what date it was and what time it was.

Page 4370

1 Q. Did you see anything happen to him as he left the room?

2 A. I did. Immediately when he reached the door he got a kick into his

3 chest by the soldier who called him out.

4 Q. Did you see anything after that?

5 A. The doors closed. You could not see anything after that.

6 Q. Did you ever see your friend again after that date?

7 A. I never saw him again.

8 Q. Sir, again the first name of your friend was what?

9 A. Sejad Sivac.

10 Q. Were you taken to Manjaca from Omarska?

11 A. Yes.

12 Q. How long were you held at Manjaca?

13 A. From August 6th 1992 until December 14 the same year.

14 Q. Where did you go from Manjaca camp?

15 A. To the collection centre in Karlovac.

16 Q. Prior to the attack on Kozarac on 24th May 1992, were you a member of

17 any anti-Serb military or paramilitary organisation?

18 A. No.

19 Q. Were you a member of any organised anti-Serb resistance group?

20 A. No.

21 Q. After the attack on Kozarac on 24th May 1992, did you become a member

22 of any such group?

23 A. No.

24 MISS HOLLIS: No further questions.

25 THE PRESIDING JUDGE: Cross-examination, Mr. Kay?

Page 4371

1 MR. KAY: No cross-examination, your Honour.

2 THE PRESIDING JUDGE: Is there any objection to Mr. Strikovic being

3 permanently excused?

4 MR. KAY: There is not.

5 THE PRESIDING JUDGE: Sir, you are permanently excused. Thank you very

6 much for coming.

7 (The witness withdrew)

8 MISS HOLLIS: At this time we would call Hakija Elezovic.

9 THE PRESIDING JUDGE: Mr. Tieger has gone to see if the next witness, I

10 presume, is available because I guess that was a record, Miss Hollis.

11 You should be given an award. I think Mr. Niemann is second after you

12 in terms of time.

13 MISS HOLLIS: Yes, your Honour. We are not trying for awards ---

14 THE PRESIDING JUDGE: I am sure you are not.

15 MISS HOLLIS: -- but we got all the relevant information, I think

16 THE PRESIDING JUDGE: Good, thank you.


18 THE PRESIDING JUDGE: Sir, would you please take the oath that is being

19 given to you?

20 THE WITNESS [In translation]: I solemnly declare that I will speak the

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

22 (The witness was sworn)

23 THE PRESIDING JUDGE: Thank you. You may be seated.

24 Examined by MISS HOLLIS


Page 4372

1 MISS HOLLIS: Thank you. Sir, would you please state your name?

2 A. Hakija Elezovic.

3 Q. What is your date of birth?

4 A. February 1st 1940.

5 Q. What is your nationality or ethnic group?

6 A. Muslim.

7 Q. What was your place of birth?

8 A. Trnopolje.

9 Q. Was that in the town of Trnopolje or in a hamlet nearby?

10 A. Well, that was the hamlet of Elezovici.

11 Q. How far was the hamlet of Elezovici from Trnopolje town?

12 A. About one kilometre.

13 Q. How long did you live in Elezovici?

14 A. My whole life, up until now.

15 Q. What was the nationality or ethnic group of the inhabitants of

16 Elezovici?

17 A. The population of Elezovici was Muslim.

18 Q. Sir, was the hamlet called Elezovici because it was mostly members of

19 the Elezovic family who lived there?

20 A. Yes.

21 Q. As for the town of Trnopolje itself, what was the ethnic composition

22 of the town?

23 A. It was mixed. There were different nationalities.

24 Q. How far was Elezovici from Prijedor?

25 A. About eight kilometres.

Page 4373

1 Q. How far was it from Kozarac?

2 A. Six kilometres.

3 Q. What was your previous occupation?

4 A. I was a fisherman. I was working in the fishing industry.

5 Q. Where did you work?

6 A. In the ponds of Sanicani.

7 Q. Of Sanicani?

8 A. Sanicani.

9 Q. How long did you work there?

10 A. I worked from '63 till '92, 29 years.

11 Q. At this time if we could have Prosecution Exhibit 280 put back on the

12 overhead projector, but first hand it to the witness, please? Mr.

13 Elezovic, if you would take a moment to look at that map and find the

14 fish farm where you worked and also where Elezovici was located. Then

15 if that map could be placed on the overhead projector? Sir, if you

16 could show us, first, the fish farm where you worked?

17 A. Here it is. This is the railway station, Kozarac and Trnopolje

18 altogether, and then this is where I lived, here.

19 Q. Could you hold that for a moment, sir, where you lived?

20 A. Here.

21 Q. Thank you very much. Thank you, sir. If those maps could be returned

22 to the Registrar? Mr. Elezovic, when the attacks began in opstina

23 Prijedor did you have three children, two sons and one daughter?

24 A. Yes.

25 Q. What were the names of your sons?

Page 4374

1 A. The older was Salih and the younger -----

2 THE INTERPRETER: Sorry, I did not hear that.

3 MISS HOLLIS: What was the name of your younger son?

4 A. Samir.

5 Q. What were your sons' dates of birth?

6 A. Salih was born in '64, April 27th.

7 Q. Samir was born when?

8 A. 73, also in April. I do not quite remember the date.

9 Q. During the time that you lived in Elezovici, did you ever travel into

10 the town of Kozarac?

11 A. Yes. I did.

12 Q. Why would you go there?

13 A. There was an office there, there was a market and then my wife also

14 had her family in Kozarusa and so ----

15 Q. If we were to talk about an average, monthly average, how often would

16 you go to Kozarac in a month?

17 A. I cannot quite say. Sometimes I would not go at all, sometimes five

18 or six times.

19 Q. Did you know Dule Tadic?

20 A. I knew him from sight, but up until the conflict I did not know him

21 really. I just know him from the sight.

22 Q. How long had you known him by sight?

23 A. Maybe five or six years.

24 Q. When you went to Kozarac was he someone you would see frequently,

25 occasionally, or seldom?

Page 4375

1 A. Not every time I went, but I would see him.

2 Q. Did any of your children know Dule Tadic?

3 A. Yes, my older son knew him well. They even were friends.

4 Q. Did your older son, Salih, ever talk to you about Dule Tadic?

5 A. Yes, but it was not -- I was not too interested in that.

6 Q. Were you aware if Dule Tadic had any kind of businesses in Kozarac?

7 A. Yes, I knew he had a cafe.

8 Q. Do you recall where that cafe was located?

9 A. I do remember.

10 Q. Where would that be located in Kozarac?

11 A. That was a location as you went up the main street on the right-hand

12 side as you walk from the direction towards Mrakovica, up from the

13 school a little bit.

14 Q. Do you recall what business or businesses were located on the opposite

15 side of the street from his cafe?

16 A. On the other side of the cafe were -- there was a hair salon, I think

17 there was a pharmacy, as I recall, and a book store or something like

18 that.

19 Q. Did you ever go to his cafe?

20 A. Yes, on one occasion only.

21 Q. During the time that you knew Dule Tadic to see him, did you ever see

22 him with a beard?

23 A. Yes.

24 Q. Sir, at this time I would ask you to look around the courtroom and see

25 if you see Dule Tadic from Kozarac in the courtroom, and if he is, I

Page 4376

1 would ask you to point to him?

2 A. I see him.

3 Q. Would you tell us also where he is seated?

4 A. On the left-hand side between the two policemen.

5 MISS HOLLIS: Your Honour, I would ask a correct identification of the

6 accused?

7 THE PRESIDING JUDGE: Yes. The record will reflect that the witness

8 properly identified the accused.

9 MISS HOLLIS: Sir, you indicated that at the beginning of the attack on

10 Kozarac you had two sons, Salih and Samir. Had your son Salih been

11 mobilized as a reserve officer when the conflict in Croatia began?

12 A. Yes.

13 Q. How long did he serve as a reserve officer in the JNA?

14 A. Not even a month and a half, about one month and 10 days.

15 Q. Why did he leave?

16 A. Why he left, because he saw that it was no war, that it was leading

17 nowhere.

18 Q. Before the attack on Kozarac, were the non-Serb inhabitants of the

19 Trnopolje area ordered to turn in their weapons?

20 A. Yes.

21 Q. What were you told?

22 A. Yes.

23 Q. What were you told?

24 A. To turn in weapons, who had it.

25 Q. Did you have any weapons?

Page 4377

1 A. I had a hunting rifle, but it was from, belonged to the company so I

2 returned it. It was not my own so I returned it to the director.

3 Q. Did you turn this hunting rifle in before or after the attacks began

4 in your area?

5 A. I returned it before.

6 Q. Did your sons have any weapons?

7 A. No, nobody.

8 Q. Were you and the members of your family at home when Kozarac was

9 attacked?

10 A. Yes, we were all there.

11 Q. Did Salih later go to Kamicani to see if his girlfriend and her family

12 were all right?

13 A. Yes.

14 Q. Was Salih then captured and taken to Omarska camp?

15 A. Yes.

16 Q. Except for Salih, did you and the rest of your family remain in your

17 home until 9th July 1992?

18 A. Yes.

19 Q. Did you have refugees in your home?

20 A. Yes.

21 Q. From what villages or hamlets had these refugees come?

22 A. From Kozarusa.

23 Q. What was the ethnic group of these refugees?

24 A. Muslims.

25 Q. Were you aware of the detention camp that had been opened at

Page 4378

1 Trnopolje?

2 A. No, I was not aware of what was going on.

3 Q. But you were aware that the camp had been opened?

4 A. I knew that.

5 Q. How far was this camp from your home?

6 A. About one kilometre, thereabouts.

7 Q. Did your wife and other inhabitants of Trnopolje take food to the

8 detainees at the camp?

9 A. Yes.

10 Q. Did this continue until the inhabitants in your area began to be

11 rounded up and taken away as well?

12 A. Yes.

13 Q. When did the cleansing in the Trnopolje area begin?

14 A. July 9th, around 5 o'clock in the afternoon.

15 Q. That was your particular area?

16 A. That was the area up until Rajici and Matici and Elezovici and

17 Trnjani.

18 Q. Had the other areas already been cleansed by that time?

19 A. Yes.

20 Q. Sir, on 9th July were you and your children helping Serb neighbours in

21 their field before the Serbs soldiers came?

22 A. Yes.

23 Q. On that day did the soldiers come to your home and force you and your

24 son Samir to join a column that was going down the road toward Trnopolje

25 camp?

Page 4379

1 A. Yes.

2 Q. How large a column was that?

3 A. I cannot quite know, but I believe it was around 300 people.

4 Q. What were the gender and age groups of the people in that column?

5 A. From 16 to 70, men.

6 Q. Did you recognise any of the men who forced you to leave home and

7 escorted you in that column?

8 A. Yes.

9 Q. Who did you recognise?

10 A. I recognised Minja Kecen from Sanicani, there were his colleagues, and

11 then one other person from Zmijanac, but I do not remember his name.

12 Q. You said you recognised Mijo Kecen? What was his first name?

13 A. Mija Kecen, the son of Bogoljub Kecen.

14 Q. The first name was Minja?

15 A. Minja, but I think that the real name is Miroslav, I am not sure.

16 Q. What was the ethnic group of these two men that you recognised?

17 A. Serbian.

18 Q. What were the men wearing who forced you from your home and were

19 escorting you in this column?

20 A. They had infantry weapons. They had arms and they had uniforms,

21 different. They had both SMB and camouflage uniforms.

22 Q. Were you walking in this column with your son Samir?

23 A. Yes.

24 Q. What happened as you walked in this column to Trnopolje camp?

25 A. Just before the camp, there was a hamlet, Reljici, and first they

Page 4380

1 brought out Esad Mujgic and then my son Samir, Edhem Elezovic and Amir

2 and Halil, the two sons, and then they shot them, about three metres

3 away from me.

4 Q. Sir, did you see them when they shot your son and these other men?

5 A. Yes.

6 Q. Did you see who it was who shot your son?

7 A. Yes.

8 Q. Who was that?

9 A. Minja from Zmijanac and some others that I do not know.

10 Q. Sir, when your son was taken out from the column, did you have the

11 opportunity to say anything to your son before he was taken away?

12 A. No, I was just looking him in the eyes and he was looking back.

13 Q. Did you have an opportunity to go to your son after he had been shot?

14 A. No, because we moved on another five or six steps and then stopped.

15 Q. What was being done to the other people in the column when these men

16 had been pulled out and shot?

17 A. Nothing -- they were picking out other people, a lot of people were

18 killed there, about 30 at that time.

19 Q. So other people were taken out of the column and killed along the

20 route?

21 A. Yes, they were killed.

22 Q. When you arrived at Trnopolje camp, were you put on to buses and taken

23 to Omarska camp and then from there sent on to Keraterm?

24 A. Yes.

25 Q. How long were you held in Keraterm?

Page 4381

1 A. About 10 days, not longer. I do not know if it was even that long.

2 Q. If I could have Prosecution Exhibit 201 shown on the computer? Sir,

3 what room were you held in at Keraterm?

4 A. Room No. 2.

5 Q. How many men were held in that room with you?

6 A. It was over 500 people.

7 Q. While you were at Keraterm were there people being held in other rooms

8 there?

9 A. Yes, there were. I think there were four rooms there.

10 MISS HOLLIS: If that could be handed to the witness, please?

11 A. Here.

12 THE PRESIDING JUDGE: What Exhibit is that, Miss Hollis?

13 MISS HOLLIS: Your Honour, that is Prosecution Exhibit 201. Sir, do you

14 recognise what is depicted in that photograph?

15 A. I do. This is a warehouse in Keraterm, the warehouse for tiles,

16 things like that.

17 Q. That is where you were taken?

18 A. Yes.

19 Q. While you were at Keraterm were you ever interrogated?

20 A. Yes.

21 Q. Did that interrogation take place in a room on the first floor of the

22 Keraterm camp building?

23 A. Yes, to the left. You pass by No. 1 and then go upstairs.

24 Q. If that photograph could be placed on the overhead projector, please?

25 A. This is where I went upstairs and here they interrogated me.

Page 4382

1 Q. Sir, if you could show us that again?

2 A. Here was a staircase, the stair went up and it is up here where they

3 interrogated me.

4 Q. When you were taken in for interrogation, who did that interrogation

5 at Keraterm?

6 A. Radakovic, the Director of the National Park, Kozarac National Park.

7 Q. Was there anyone else present?

8 A. Dule Tadic was his bodyguard.

9 Q. What happened during that interrogation?

10 A. Well, they interrogated me, then mostly about my son, and that I was

11 responsible for his leaving the army, for deserting, and they began to

12 beat me. Dule began to -- first he kicked me with his foot and I fell.

13 Then he went around the table and continued to beat me on the back and

14 on the chest.

15 Q. You said that Dule first kicked you with his foot and you fell? Where

16 did he kick you?

17 A. From the chair. Up here in the chest.

18 Q. When he kicked you in the chest, how did he kick you, was it a regular

19 kick or was it a different kind of kick?

20 A. That master's kick.

21 Q. What do you mean by that, "a master's kick"?

22 A. Well, he was not -- he did not just kick me, he sort of fooled around

23 then and, I mean, he waited for me to relax a little bit and then he hit

24 me.

25 Q. When he kicked you was he facing you straight on or did he kick you

Page 4383

1 from the side with his body to the side?

2 A. Then when I fell down he came round, because he was on the other side

3 of the table, so he went around the table to approach me and continued

4 hitting me.

5 Q. When you say he was hitting you, what was he hitting you with?

6 A. With his feet.

7 Q. Did he continue to kick you the same way throughout this beating?

8 A. Well, one would say that, yes, with his feet.

9 Q. Had you ever seen this kind of kicking before, this kind of kicking

10 and fighting?

11 A. I have seen it in films and such like.

12 Q. What kind of films were these where you saw this kind of kicking?

13 A. Well, karate, judo.

14 Q. Sir, how long did this beating last with Dule Tadic kicking you?

15 A. Well, it could be about a couple of minutes, and the interrogation

16 altogether lasted for about half an hour.

17 Q. Was Mr. Radakovic joining in on this beating of you?

18 A. Radakovic was in the room. He interrogated me.

19 Q. Did he also beat you?

20 A. No, he did not. He simply grinned and laughed as this one was beating

21 me.

22 Q. You said that when they were interrogating you and talking to you,

23 they were talking mostly about your son. That was your son Salih?

24 A. Yes, Salih.

25 Q. What did they say about your son Salih?

Page 4384

1 A. That I was responsible, that I advised him to leave the army.

2 Q. Did they say anything about you meeting your son or being reunited

3 with your son?

4 A. Yes, Radakovic said, "Sentenced to death" and he said, "You will have

5 an opportunity to see him in Omarska", that I was going to Omarska.

6 Q. During this incident when Dule Tadic was beating you, in total

7 throughout this incident, how long did you look at Dule Tadic?

8 A. Well, all the time.

9 Q. Were you able to see him clearly?

10 A. Yes.

11 Q. What was he wearing on that occasion?

12 A. He had a police uniform on then.

13 Q. Did he have any weapons on his person?

14 A. A pistol.

15 Q. Do you recall, did he have any facial hair or was he clean shaven?

16 A. Well, shorter beard than usually.

17 Q. What injuries did you suffer from that beating?

18 A. My ribs were broken.

19 Q. Did you suffer any other injuries in addition to your ribs being

20 broken?

21 A. Kidneys, and I have headaches.

22 Q. Did you have any difficulty breathing after that interrogation and

23 beating?

24 A. Yes.

25 Q. Do you recall an incident that occurred in room 3 at Keraterm later

Page 4385

1 that day after Dule Tadic beat you?

2 A. Yes, in room 3, one could hear noise, fires being shot, intensive

3 fires. I mean, it looked like some substantial weapons, like machine

4 gun or something like that. Many people were killed that day, and that

5 Zigic took part in that.

6 Q. Did you actually see what was happening or you simply heard things

7 during the night?

8 A. One could hear it and afterwards I saw blood, several hours later it

9 had not been washed away.

10 Q. Do you know who it was who were being held in room 3?

11 A. I knew three brothers from Rakovcani.

12 Q. You say that several hours later you saw blood outside. Was that the

13 next day that you saw blood outside?

14 A. The next day when I started for Omarska.

15 Q. It was the next day then that you were taken to Omarska camp?

16 A. Yes.

17 Q. When you arrived at Omarska camp were you and other detainees with you

18 forced to line up against a building?

19 A. Yes.

20 Q. In what position did you have to place your hands and fingers?

21 A. Three fingers against the wall like this.

22 Q. What was done to you and the other detainees after you were up against

23 the wall with your hands in that position?

24 A. They beat us, all of us, but that building helped me because when he

25 hit me, it was Cigo, and I fell down and I threw up all this coagulated

Page 4386

1 blood and then I could breathe more easily.

2 Q. You say it was Cigo who hit you. Had you known Cigo from before

3 Omarska camp?

4 A. Yes, I know he was born in Omarska and was a taxi driver in Prijedor.

5 I did not know him particularly well but I have known him for quite

6 sometime.

7 Q. Where were you taken after this beating?

8 A. To the white house.

9 Q. In what room were you kept in the white house?

10 A. Well, it was not a room really. It was a toilet-come-bathroom, but it

11 was not completed. There were two rooms on one side, two on the other

12 and straight ahead was the bathroom.

13 Q. So this toilet or bathroom you were kept in was at the very end of

14 the hall in the white house?

15 A. At the end.

16 Q. There were two rooms on the left and two rooms on the right?

17 A. Yes.

18 Q. When you were put into that bathroom area, how crowded was that room?

19 A. There were 30 of us, in a small area, 30 of us. It was packed. We

20 did not have enough air to breathe.

21 Q. Were you able to sit down or lie down in that room?

22 A. Well, we could not sit down, all of us, nobody could lie down.

23 Q. You said that you could not breathe. Were there any windows into that

24 room?

25 A. There was a small window in the middle of the room, rather high up,

Page 4387

1 and it was closed and we were asking from us money so they could buy

2 beer and then they would open the window for us.

3 Q. Who was asking you money to buy beer and then they would open the

4 window?

5 A. The guards, camp guards.

6 Q. While you were in this small room crowded together like that, did

7 anyone in that room die

8 from the conditions in there?

9 A. Yes, I do not know his name. He was rather fat and that must be why

10 he died, and there was another one -- another one also.

11 Q. Sir, you indicated that when you first arrived at Omarska camp you

12 were beaten by a man you knew as Cigo. Do you recall another occasion

13 when Cigo beat you in Omarska?

14 A. Yes, another time in the white house he forced me to kneel down and

15 bark like a dog, and then I was barking and he pushed the barrel into my

16 mouth and said, "Oh, you want to bite me, do you?"

17 Q. What did he do to you then?

18 A. He broke my teeth down there.

19 Q. Your bottom teeth in front?

20 A. Yes, in front.

21 Q. After you arrived at Omarska did you on any occasion see your son

22 Salih?

23 A. Yes, I saw him once queuing for lunch.

24 Q. Were you able to talk with him when you saw him?

25 A. No.

Page 4388

1 Q. Do you recall the first occasion that you were taken to the building

2 that had the kitchen and you were taken there for interrogation?

3 A. Yes, I do.

4 Q. Sir, what happened to you when you got to the top of the stairs in

5 that building?

6 A. Well, they brought me to the top of the stairs and there was a group

7 of people up there and they immediately started beating me. I had

8 barely lifted my head at the top of the stairs, somebody hit me and

9 kicked out my front, upper front teeth.

10 Q. Did they continue to beat you after that?

11 A. Yes, they beat me up but I still could walk. They beat me and then

12 they left me, and then I went to the end, to the room at the end, to the

13 left and that is where I was.

14 Q. When you went into that room for interrogation and they asked you

15 questions, were you able to answer those questions?

16 A. Not right away, and then he said, "Well, talk. Has your tongue been

17 cut out?" but my mouth was full of blood so I simply could not talk for

18 a while.

19 Q. What were the kind of questions they were asking you during this

20 interrogation?

21 A. What was the organisation, who was arming it, who had I voted for.

22 They were simply looking for a reason to beat us.

23 Q. After that interrogation were you taken back to the white house?

24 A. Yes.

25 Q. About an hour later were you called out again for interrogation?

Page 4389

1 A. Yes.

2 Q. When you went up the stairs of that same building for the second

3 interrogation, what happened to you?

4 A. Then at the top of the stairs there were more army. Radakovic was

5 watching and said, "Oh, you are back to get it" and he hit me and I fell

6 down, and they took me back to the white house and they did not take me

7 for any further interrogation, only up the stairs and then a policeman

8 took me to the white house.

9 Q. Mr. Radakovic who was up the stairs, is this the same Radakovic who

10 interrogated you at Keraterm?

11 A. Yes.

12 Q. When you were taken back to the white house, where were you taken?

13 A. To the white house, upstairs to the right.

14 Q. When you were taken back to the white house, to the white house where

15 you had been held before, were you taken into the white house at that

16 time?

17 A. They took me in for interrogation. When I came back from the

18 interrogation for the second time, they did not take me in. The second

19 time they took me to beat me again.

20 Q. Where did they take you to do that?

21 A. From the white house, there was tall grass there. There were some

22 holes, and there were about 10, up to 10, soldiers beating. There was

23 already a heap of dead and that is where I saw my son being beaten. I

24 knew those five or six people who were there. Dule was the first to

25 meet me. He started with his foot and said, "Now you have come to the

Page 4390

1 right place", and began to beat me and my son was crying, "Let my old

2 man go", and then he got after my son, and when I started standing up

3 somebody struck me on the neck and I fell again. I received a very

4 severe blow and then I was unconscious for quite some time.

5 When I came too, and they were already loading the dead, and I

6 must have been unconscious for an hour or two. There were very many

7 dead. There was my son and Sivac, the veterinarian, what is his name,

8 Sivac, I have forgotten his name, but I know he was the veterinarian.

9 They were already lying one on top of the other. Then I recognised Redo

10 and then a football player. They were dead already. They were very

11 many dead there. The truck was full of dead.

12 Q. Sir, did you know a man named Zuhdija Turkanovic?

13 A. Yes, Turkanovic, Turkanovic was there too. Yes, I saw him as well.

14 Q. Did you know a person named Nedibov Duracak?

15 A. Yes, Nedib's son, that is a football player, and he was lying there

16 dead, Nedibov Duracak.

17 Q. Sir, if we could go back for a moment? You said that they brought you

18 to the white house, an area where there was tall grass. Was that to the

19 side of the white house, behind the white house? Where was that

20 located?

21 A. Behind the white house, right where that bathroom was, on the side

22 where the bathroom was.

23 Q. As you came around to the back of the white house, what did you see?

24 A. I saw them beating people, a group of those, all soldiers, and Dule

25 with them in camouflage, in camouflage clothes, military uniform, he had

Page 4391

1 a baton, and fighting. They were not firing off their rifles. They

2 were simply beating people.

3 Q. Sir, when you came around the back and saw Dule Tadic and the others

4 beating the people there, did you recognise your son at that time?

5 A. Yes.

6 Q. Then Dule Tadic began to beat you as well, is that correct?

7 A. Yes.

8 Q. When he was beating you, how was he beating you?

9 A. With the foot in the stomach.

10 Q. These feet to the stomach, was this the same sort of kick that he had

11 used in Keraterm camp?

12 A. Why, yes, they were similar, those kicks. He really knew how to use

13 his feet.

14 Q. During this incident when you saw Dule Tadic behind the white house,

15 do you have any idea how long it was you were actually able to look at

16 him?

17 A. Well, it was not long, five or six minutes. When my son said to let

18 me go, not to beat me, he left me and then got after my son with a

19 pistol and then my son fell. After that I was struck very badly. There

20 was a severe blow and I lost consciousness.

21 Q. When you saw Dule Tadic on that day, do you recall if he was clean

22 shaven or if he had facial hair?

23 A. His beard was longer than in Keraterm, not really big beard but it was

24 like that.

25 Q. Sir, you said that when you regained consciousness they were loading

Page 4392

1 the bodies. When you regained consciousness, who were you lying next

2 to?

3 A. I was lying near my son and Sivac and that Turkanovic, those who were

4 near me, and then I recognised immediately those who were killed before.

5 There were bodies all over the grass. There were very many of them.

6 They loaded a truck full of them.

7 Q. Did you recognise any of the people who were loading the dead bodies?

8 A. Yes, they were those people from the camp, Samir Hodzic, he was the

9 one who took my son and Sivac. There was another one, I know he had

10 bread in Prijedor. He was an Albanian, I believe. He took me, he and

11 this Hodzic took me, to the white house when it was all over and they

12 dumped me in the first room.

13 Q. When you saw them loading your son, you said Samir Hodzic was loading

14 your son, did you notice what Samir Hodzic was wearing on his feet?

15 A. He was bare foot, and then he took a pair of footwear and put them on.

16 Q. Whose footwear did he take?

17 A. My son's, Salih's.

18 Q. After he took that footwear, did he say anything to you about wearing

19 your son's shoes?

20 A. Well, yes, I told him to take them.

21 Q. So then after this, after you regained consciousness, you were taken

22 back into the white house, is that correct?

23 A. Yes, they took us in there. The guards did not even notice. There

24 was a guard who paid no attention. He was sitting up there. There was,

25 to the left there was a small room where I was before, and that is where

Page 4393

1 we spent two days and then the International Red Cross was to come and

2 then they took us altogether and took us away.

3 Q. So when you were taken back into the white house you were not taken to

4 the small room at the end of the corridor, to the toilet area?

5 A. No. No.

6 Q. You indicated that you were taken away from Omarska when the

7 International Red Cross was to come, where were you taken from Omarska?

8 A. Trnopolje, not from Omarska, to the hangar, from the white house to

9 the hangar.

10 Q. When you left Omarska camp, when you were taken from Omarska camp, you

11 were taken to Trnopolje camp, is that correct?

12 A. Yes.

13 Q. How long were you held at Trnopolje camp?

14 A. Until August 21st.

15 Q. While you were at Trnopolje camp, did you know any of the guards at

16 the camp?

17 A. Yes.

18 Q. Do you recall the names of any of those guards that you knew?

19 A. Well, I knew Mladen Baltic, Djurdjevic, then Mladen Karajica, Baltic,

20 Cavic -- I knew them.

21 Q. You indicated that you knew someone called Karajica. Had you known of

22 a family known Karajica prior to your being taken to the camp?

23 A. Yes, I did.

24 Q. What were the names of the Karajica men that you knew?

25 A. I know Sveto Karajica, Sreto's father, Mladen was son. Well, there

Page 4394

1 were quite a number of them. I do not know the names of each one of

2 them, but I know them. I cannot remember them now.

3 Q. So you know a Sveto Karajica?

4 A. Eldest, the oldest among them. He was older than I am.

5 Q. Was his name Sveto or Sreto?

6 A. Sreto is his son, Sreto is Sveto's son. Sreto is Mladen's father.

7 Mladen is quite young, like my son.

8 Q. How many sons did Sveto have?

9 A. Two, Sreto and another one. I cannot remember his name.

10 Q. Sreto had how many sons?

11 A. He had two sons, Mladen and another one. I have forgotten his name.

12 Q. You indicated that you also knew guards at Trnopolje whose name was

13 Cavic?

14 A. Yes.

15 Q. Do you know the first name of any of those guards named Cavic?

16 A. Oh, there were three or four Cavics, this one, the shortest one, he be

17 the worst.

18 Q. The shortest one. Do you know where he lived?

19 A. I do.

20 Q. Where was that?

21 A. The side of Trnopolje, towards Petrov Gaj, perhaps about a kilometre

22 from the camp at Trnopolje.

23 Q. Do you know with whom he lived?

24 A. His mother.

25 Q. Do you know where his mother worked?

Page 4395

1 A. In the paper and pulp factory in Prijedor.

2 Q. The Cavics who worked at the camp, did they live in the Trnopolje

3 area?

4 A. Yes.

5 Q. You indicated that you left Trnopolje on 21st August. Did you become

6 part of a large convoy that ultimately went to Vlasic Mountain?

7 A. Yes.

8 Q. At some point on Vlasic Mountain, were the men in the buses that were

9 part of your group told to get off those buses?

10 A. Yes, when we came near Vlasic, up to Vlasic, there were three bus

11 fulls of men and they were all unloaded there.

12 Q. Were you also told to take all of your personal belongings with you?

13 A. They told us we did not need any things and that they could stay on

14 the bus.

15 Q. After you were taken off the bus with these other men, did you manage

16 to get on a truck that was part of the large convoy and so continue with

17 the convoy?

18 A. Yes.

19 Q. Then you ultimately arrived in Bosnian government territory?

20 A. Yes, to Travnik.

21 Q. Sir, prior to the attacks in opstina Prijedor, were you a member of

22 any anti-Serb military or paramilitary organisation?

23 A. No, never. I was not a member of any organisation, never. I have

24 never been a member of any organisation. I did not meddle in politics.

25 I simply did my job.

Page 4396

1 Q. What permanent injuries or medical problems do you have as a result of

2 the beatings and treatment that you received in the camps?

3 A. Well, I have frequent headaches and nightmares. I have kidney

4 complaints. My arm hurts when I try to raise it.

5 Q. Sir, you have testified that you had both your upper and lower teeth

6 knocked out at the camps. Have you now had those teeth replaced?

7 A. Yes.

8 Q. Sir, you earlier identified Dule Tadic in this courtroom. The man that

9 you identified in the courtroom, is that the man who beat you in

10 Keraterm?

11 A. Yes.

12 Q. Is that the man who beat you and your son in Omarska camp?

13 A. Yes.

14 MISS HOLLIS: No further questions.

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

16 (4.00 p.m.)

17 (The Court adjourned for a short time)

18 (4.20 p.m.)

19 THE PRESIDING JUDGE: I apologise for the delay. We have been

20 communicating in an effort to resolve some of the technical problems

21 that we are trying to provide, with the technical facilities I should

22 say, that we are trying to provide for the parties in order to continue

23 to receive testimony.

24 So, that is the reason for the delay. I apologise.

25 Cross-examined by Mr. Kay.

Page 4397

1 THE PRESIDING JUDGE: Miss Hollis you had concluded direct had you?

2 MISS HOLLIS: I had your Honour.

3 THE PRESIDING JUDGE: Very good cross-examination, Mr. Kay?

4 Cross-Examined by MR. KAY

5 Q. Mr. Elezovic, you told us that while you were at Keraterm you were

6 interviewed by a man called Radakovic. Did you know him before that

7 interview?

8 A. I could not hear? I did not understand the question well. Did I know

9 Rade?

10 Q. Radakovic, the man you said who interviewed you at Keraterm?

11 A. Yes.

12 Q. Did you know him before that interview?

13 A. Yes, I knew him. I did not associate with him.

14 Q. So you knew his name?

15 A. I knew him as a director of the National Park.

16 Q. When did you learn his name as being Radakovic?

17 A. I found it out from the prisoners who were there.

18 Q. So, his name has been told to you by someone else?

19 A. Yes.

20 Q. You describe the man who was with him as being Dule Tadic. You said he

21 was his bodyguard. What did you mean by that?

22 A. Yes, because he was with him. He did not beat me, only Dule beat me.

23 Q. Were you told the name of that man by other people?

24 A. For Dule Tadic?

25 Q. Yes.

Page 4398

1 A. I knew Dule Tadic from sight, but I heard that he wrote threat letters

2 to himself. Apparently, Muslims were writing it against him but,

3 apparently, there were controls so people knew it was him who wrote

4 letters on his own behalf and that is the man. That is how I knew him.

5 Q. Did you know the name of Dusko Tadic after the interview, that he had

6 been there with Radakovic?

7 A. I knew him from before.

8 Q. You do not seem to have known Dusko Tadic very well, is that right?

9 A. No, I did not associate with him, but I knew of him, I knew him.

10 Q. You mentioned something about threatening letters that had been in the

11 newspaper, and that ----

12 A. I do not know that it was in the papers. I heard from people that

13 they were threatening him, but he was, apparently, that they were all

14 good people, and so it turned out that he wrote his own letters but I

15 did not know. I asked who he was and they said, "This is the man".

16 Q. That must have been at a time quite near to the attack on Kozarac in

17 1992?

18 A. That was in '91 or '92 which is before the conflict.

19 Q. So it comes to this, that in 1991 until this matter of the threatening

20 letters you did not know Dule Tadic?

21 A. I knew his face but I did not know his name. It was of no interest to

22 me at that time, like many other people that I did not have any contact

23 with.

24 Q. But after the threatening letters you say that you learnt his name

25 from other people?

Page 4399

1 A. Yes, I heard that name Dule, Dule, but I did not know who he was until

2 people pointed him to me.

3 Q. So it seems from what you tell us then that you had not spent any time

4 with Dule Tadic, you and he had not been in the same company together?

5 A. No, I never was in company with him.

6 Q. When you are in Omarska, you see again Radakovic?

7 A. Yes.

8 Q. Radakovic did not interview you in Omarska. He just happened to be in

9 the ----

10 A. No.

11 Q. --- interrogation centre?

12 A. He was in a first room as you come up the stairs.

13 Q. So you came across this man in the two places, Keraterm and Omarska?

14 A. Yes.

15 Q. After you had been interviewed, you then went to the white house but

16 were taken around the back of the white house where you have told us

17 that you were badly beaten by Dusko Tadic, is that right?

18 A. In Keraterm, it was Dusko who beat me, not in Omarska.

19 Q. In Omarska were you telling us that Dusko Tadic beat you after you had

20 been interviewed the second time and you were taken around the back of

21 the white house?

22 A. I was taken there from the interrogation which was upstairs where the

23 kitchen was and then behind the white house, and there was a group of

24 people that were beating and Dule Tadic with them.

25 Q. Can you give us the names of any other people who were in that group

Page 4400

1 who were beating prisoners?

2 A. I do not know the names.

3 Q. You did not know or recognise any of them?

4 A. The faces, sort of, but not the names. They were mostly people from

5 Omarska.

6 Q. The number of people who were being beaten when you were taken to the

7 back of the white house, how many people were receiving these beatings?

8 A. There were about 50, 60 people, a lot of people. There were dead

9 people, alive, there were people groaning, showing signs of life. They

10 were not shooting. They were just beating them with sticks.

11 Q. That is what I want to ask you about. This does not seem to have been

12 a place where knives or guns were being used to kill people, is that

13 right?

14 A. No, just some hard objects.

15 Q. Out of the people who seem to have survived this, it comes down to

16 you, is that right?

17 A. It looks as if, from what had been planned behind the white house, I

18 passed out and that saved me. I have a knife stab wound on my leg and I

19 did not even notice when it happened.

20 Q. But of those people who were there receiving this beating, only you

21 survived, is that what you understand to be the case?

22 A. Yes.

23 Q. At some stage you notice one of the prisoners who has no shoes?

24 A. That was when I came to later when they were loading the dead.

25 Q. That was another prisoner called Hodzic, is that right?

Page 4401

1 A. Yes, Hodzic.

2 Q. But from what you had told us before, it was intended that you would

3 be killed, is that right?

4 A. Yes.

5 Q. Because instead of being at Keraterm, here you were in Omarska when

6 this is taking place?

7 A. Yes.

8 Q. When you say that you regained consciousness, it was only two

9 prisoners who were left there, is that right?

10 A. No, there were more. They had not picked them all up. They were

11 loading them up at that time. I think that there were about four

12 prisoners who were loading them up.

13 Q. Thank you. That is, in fact, what I was asking you about, the number

14 of prisoners who were alive who were moving the bodies. That was four

15 of them, but there were no more guards or soldiers or anyone else around

16 who had been doing the beatings?

17 A. There was a driver there.

18 Q. When you say "a driver", that is the driver who is in the truck who is

19 to move the bodies, is that right?

20 A. Yes.

21 Q. You then move back to the white house where you are put in one of the

22 rooms, is that right?

23 A. Yes.

24 Q. Did you walk there? How did you get into the white house?

25 A. That Hodzic helped me and another, one Bahti. I think he was an

Page 4402

1 Albanian. He was driving the bread truck around.

2 Q. When you are in that room, did Hodzic have your son's shoes on at that

3 stage?

4 A. When I started towards the white house, he had them on. He put them

5 on when he was loading the bodies. I -- Bahti said, "Lie down" and

6 then he said, "We will take you back when we are done".

7 Q. But of all the other bodies that were there that you have told us

8 about, there were other pairs of shoes, presumably, on those bodies?

9 A. I do not know why he took it from my son.

10 Q. Yes, it seems a coincidence that it is you and they are your son's

11 shoes that he has got on?

12 A. Maybe that is also because they were cousins, maybe as a souvenir.

13 Q. So Hodzic is a cousin of your son?

14 A. Yes, that was my family.

15 Q. So Hodzic would also be related to you, a relative of yours?

16 A. Yes, he would be my relative.

17 Q. So it seems from all this that happened, of the people doing the

18 beatings, all you can identify by name is Dusko Tadic, is that right?

19 A. Yes.

20 Q. The only person to survive as a witness was you, is that right? You

21 see, have you been told a story by someone else, Mr. Elezovic, about

22 what happened behind that white house and come to tell this court as if

23 it was your own experience?

24 A. You mean that I am making it up, this story?

25 Q. Yes, that you were not there.

Page 4403

1 A. I lived through all that.

2 Q. When you said Zigic had been to room 3 in Keraterm and there was

3 machine gunning of people in that room, you did not know that Zigic had

4 been there, did you because you did not see him?

5 A. I did not see him, but people who knew him said that he was the worst

6 there and then the two twin brothers, Banovic. I was there but I did

7 not see what they were doing.

8 Q. No, and you did not see Zigic taking part in that, is that right?

9 A. No, I did not.

10 Q. What I am suggesting to you, you see, is this, that someone has told

11 you that Dule was there on an occasion when your son was killed?

12 A. Dule also beat me there together with my son, with a group of people.

13 He was not alone.

14 Q. From what you tell us, it was intended that you would be killed, that

15 you were in the right place now to be killed?

16 A. Yes.

17 Q. When you left the white house, you were put in another part of Omarska

18 camp, another room, is that right?

19 A. Yes.

20 Q. Was that room in the larger building we see on the model in the middle

21 of the court?

22 A. Yes, it is.

23 Q. Can you remember whereabouts in the building you were then at the end

24 of your stay in Omarska?

25 A. As you go up the stairs, I think it is the second door to the right.

Page 4404

1 Q. Would that have been called room 15?

2 A. I do not know how it was called, maybe it was, but it was the second

3 room and across from it, it was something like a Red Cross. There was

4 the person without an arm who worked there. He was from Petrov Gaj.

5 Q. There is one other matter I need to question you about and it is this.

6 Is it correct that you have seen programmes on television about Omarska

7 camp and the arrest of Dusko Tadic?

8 A. No, I did not see it.

9 Q. You have not spoken to Monika Gras yourself, given television

10 interviews?

11 A. No, no. I do not know who I spoke to -- I did give a statement, a

12 statement in Goettingen -- I think it was Kellerman.

13 Q. Have you given interviews to newspapers, to The Times of London?

14 A. It could be, on several occasions I did.

15 Q. Have you been interviewed for television programmes?

16 A. Yes, for ZDF once.

17 Q. Have you seen on television programmes about Omarska camp?

18 A. No, I have not seen them.

19 Q. You did not watch the Monika Gras film?

20 A. I did not see it.

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


23 MISS HOLLIS: Thank you, your Honour.

24 Re-Examined by MISS HOLLIS

25 Q. Mr. Elezovic, you indicated that you had known Dule Tadic by sight in

Page 4405

1 Kozarac, is that correct?

2 A. Yes.

3 Q. And that then there was an incident involving some letters, and after

4 that incident did someone you knew point Dule Tadic out to you?

5 A. Yes.

6 Q. So at that point in time you linked the face with which you were

7 familiar with the name?

8 A. Yes, yes, that is it.

9 Q. This face was the face of a person you had seen on occasions prior to

10 that in Kozarac?

11 A. Yes.

12 Q. That is the person in this courtroom today, the accused you pointed

13 out earlier?

14 A. Yes.

15 Q. Mr. Elezovic, when you told this court the story about you being taken

16 behind the white house, seeing your son being beaten, you being beaten

17 and then awakening to find your dead son beside you, were you lying to

18 this court?

19 A. No.

20 Q. Were you telling them the truth?

21 A. I was telling the truth. Unfortunately, it is truth.

22 Q. When you said when you were in Keraterm the accused that you pointed

23 out beat you, were you lying to this court?

24 A. I did not lie, nothing.

25 Q. When you saw that man in Keraterm, did you recognise him as Dule Tadic

Page 4406

1 from Kozarac?

2 A. Yes, I did.

3 Q. When you saw that man in Omarska beating you and your son, did you

4 recognise him as Dule Tadic from Kozarac?

5 A. Yes, and I knew that I was finished.

6 MISS HOLLIS: No further questions.

7 THE PRESIDING JUDGE: Mr. Kay, do you have additional questions?

8 MR. KAY: Nothing arises, your Honour.

9 THE PRESIDING JUDGE: I have a few questions, Mr. Elezovic.

10 Examined by the Court

11 THE PRESIDING JUDGE: You testified that the population in Trnopolje was

12 mixed, both Serbs and Muslims, is that correct?

13 A. That is true. There were other nations. There were Croats,

14 Ukrainians, Poles. There were different nations in Trnopolje.

15 Q. Do you know what percentage of the population in Trnopolje was Serb

16 and what percentage was Muslim?

17 A. There was more Muslims.

18 Q. You testified that the Trnopolje residents were told to turn in their

19 weapons. Were Serbs as well as Muslims told to turn in their weapons,

20 as far as you know?

21 A. No, when Serbs were the ones who were arming themselves, only the

22 Muslims.

23 Q. You also testified that the cleansing began on July 9th, 1992, and

24 that were you helping Serb neighbours in their field when the soldiers

25 came to take you. What were the ----

Page 4407

1 A. Yes, that day.

2 Q. --- nature of the relations between Serbs and Muslims in Trnopolje at

3 that time? Did they get along? Were there tensions?

4 A. There were tensions, but we saw what was coming.

5 Q. When did you see what was coming?

6 A. When they started shelling, when they attacked Kozarac, when they

7 cleansed part of Kozarac, they left us until the end, more than a month.

8 To live normally -- it was not normal, you could not go anywhere. What

9 supplies of food you had, that is what you had to eat, you had to help

10 them, you had to work and so on.

11 Q. Was there any shelling of Trnopolje?

12 A. Just a few shells around the mosque fell. I do not know how many.

13 Q. When did that start, if you know?

14 A. In May, 23rd, 24th. I do not know the date exactly.

15 Q. Before the shelling in Kozarac, what were the relations like between

16 Serbs and Muslims? Did you get along?

17 A. Yes, everybody got along well. Before the conflict the life was good,

18 everything was normal.

19 THE PRESIDING JUDGE: Will we hear, Miss Hollis -- if my memory is correct,

20 at least I have not heard a lot about Trnopolje -- more about what

21 happened in Trnopolje? We have heard a lot about what led up to the

22 conflict in Kozarac and Prijedor.

23 MISS HOLLIS: Yes, your Honour.

24 THE PRESIDING JUDGE: So I can stop asking questions?

25 MISS HOLLIS: No, your Honour, you can ask as many as you like. We hope to

Page 4408

1 have more information.

2 THE PRESIDING JUDGE: I have no further questions. Do you have additional

3 questions in the light of my questions?

4 MISS HOLLIS: Thank you, your Honour.

5 Re-Examined by MISS HOLLIS.

6 Q. Mr. Elezovic, prior to 9th July when Elezovici and that particular

7 area were cleansed, to your knowledge had other villages, other hamlets,

8 near you such as Sivci been cleansed?

9 A. Yes, that happened before us.

10 MISS HOLLIS: Thank you.


12 MR. KAY: Nothing arises, your Honour.

13 THE PRESIDING JUDGE: Is there any objection to Mr. Elezovic being

14 permanently excused?

15 MR. KAY: No, your Honour.

16 THE PRESIDING JUDGE: Mr. Elezovic, you are permanently excused. You are

17 free to leave. Thank you for coming.

18 (The witness withdrew).

19 THE PRESIDING JUDGE: Miss Hollis, do you need any redaction -- no.

20 MISS HOLLIS: Given the current circumstances of the witness, no, your

21 Honour.

22 THE PRESIDING JUDGE: Thank you. Very good. Mr. Niemann?

23 MR. NIEMANN: Yes, your Honour, the Prosecution calls Said Grozdanic.

24 Mr. Said Grozdanic, called.

25 THE PRESIDING JUDGE: Sir, would you please take the oath there.

Page 4409

1 THE WITNESS [In translation]: I solemnly declare that I will speak the

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

3 THE PRESIDING JUDGE: Thank you. You may be seated.

4 Examined by Mr. Niemann.

5 Q. Would you please state your full name?

6 A. My name?

7 Q. Yes.

8 A. Said Grozdanic.

9 Q. When were you born?

10 A. 2nd January '67.

11 Q. Where were you born?

12 A. Gornji Garevci Kozarac.

13 Q. Were you raised in this area?

14 A. Yes.

15 Q. Did you live there up until 1992?

16 A. Yes.

17 Q. How far is Gornji Garevci from Prijedor?

18 A. Seven kilometres and two kilometres north of the road to Kozarac.

19 Q. Were you arrested after the attack in the Kozarac area in 1992?

20 A. Yes.

21 Q. When were you arrested?

22 A. 25th May, '92.

23 Q. When you were arrested where were you taken?

24 A. Keraterm.

25 Q. You were taken to Keraterm by bus, were you?

Page 4410

1 A. Yes.

2 Q. How long did you stay in Keraterm?

3 A. Two days.

4 Q. After that where were you taken then?

5 A. The camp at Omarska.

6 Q. While you were at the camp in Omarska were you interrogated?

7 A. Yes.

8 Q. Were you beaten at any stage when you were at this camp?

9 A. Yes.

10 Q. Prior to being taken to the Omarska camp, were you a member of any

11 military or paramilitary organisation?

12 A. No.

13 Q. What is your ethnic origin or nationality?

14 A. I am a Muslim Bosniak.

15 Q. While at Omarska camp, for how long did you stay at the camp?

16 A. From 27th May until 21st August, as far as I can remember.

17 Q. And that is of 1992?

18 A. Yes.

19 Q. On 6th August 1992 were a large number of the prisoners called out of

20 the Omarska camp?

21 A. Yes.

22 Q. What happened to these prisoners that were called out on that day, on

23 6th August '92?

24 A. When they were called out I did not know where they were then, but I

25 heard from guards that some had gone to Manjaca and others to Trnopolje.

Page 4411

1 Q. On this day did a large number of the prisoners that had been kept at

2 Omarska, were they bussed off to another place?

3 A. Yes.

4 Q. Approximately how many prisoners were left in the camp after these

5 people left in the buses?

6 A. 180.

7 Q. Were you included in that group of 180 remaining prisoners?

8 A. Yes.

9 Q. After the majority of the prisoners had left the Omarska camp, what

10 happened to you then?

11 A. The first thing we had to do was to clean up the camp. Secondly,

12 during the night beds had arrived, so we made beds. That is what

13 happened the first day.

14 Q. These beds, they arrived from outside of the camp, did they, by a

15 truck?

16 A. They must have. There was some kind of a truck. I did not see where

17 it had come from, but I saw the truck full of beds and it was there

18 while we were taking the beds in.

19 Q. Where did you make up the beds?

20 A. It was the building together with the kitchen which was in Omarska.

21 It was from the east as you enter that building. I remember that. There

22 were some offices there. There was a garage there, but that was the

23 second door, the first door of the garage.

24 Q. Were you told why you had to make up these beds after the other

25 prisoners had left? Did anyone tell you why you were doing it?

Page 4412

1 A. No.

2 Q. Did you later find out why you were making up these beds?

3 A. We did not learn it but we could guess why, so that it would look

4 better for the journalists when they came, so as to disguise what had

5 happened in Omarska.

6 Q. Had you been told that journalists were coming to Omarska camp?

7 A. Yes.

8 Q. Were you permitted to sleep in these beds once you had made them up?

9 A. Not the first time, we were not allowed. Sometimes it was allowed,

10 sometimes it was not allowed.

11 Q. Did anything happen with the supply of food and rations to you after

12 the majority of the prisoners had gone?

13 A. They began to give us then two times a day, and then we did not have

14 to run for food any more because they ordered us, when we were going for

15 meals, to walk slowly, so that when the journalists came that we had to,

16 that we were to say that we had been in the camp for two or three weeks

17 and ----

18 Q. I am sorry. Were you told by the guards at the camp what you were to

19 say to the journalists about the camp, what sort of a camp it was?

20 A. Yes.

21 Q. What were you told to say?

22 A. When the journalists would come they told us to mind what we were

23 saying, what we would say, because we were still in their hands, so

24 that, how shall I put it, so that they could still do with us whatever

25 they liked or ----

Page 4413

1 Q. Who was it who told you this, do you remember?

2 A. Zeljko Meakic came many times. I did not know his name but I learnt

3 it after the long time that I spent in Omarska. He used to say that we

4 had been here for two or three weeks and that we had to eat twice a day,

5 that nobody had laid a finger on us until then and that we would be

6 released within seven days, that we were there only for interrogation

7 purposes.

8 Q. These things you were told to tell the journalists if asked?

9 A. Yes.

10 Q. Apart from the making up of the beds, were the prisoners that were

11 retained behind in Omarska required to do other things in terms of

12 cleaning up the camp?

13 A. Yes, we cleaned the white house, the hangar, moved the flower tubs,

14 those concrete pots, well, whatever, just to disguise it.

15 Q. When you say about the concrete pots, where were these concrete pots

16 located?

17 A. They were between the hangar and the kitchen on the pista.

18 Q. Where were the pots moved?

19 A. I remember that we moved them, but why and how did we move them, I do

20 not remember because it did not matter then why should I move it. I

21 only know that we had to do it.

22 Q. You say that you had to clean up the white house. What did you

23 discover when you went into the white house that had to be cleaned?

24 A. Not I, I did not go to clean the white house. I saw others go to

25 clean it, but these buildings are about 50 metres one from the other. I

Page 4414

1 did not go there, the others did. What did they clean there? I did not

2 ask them what they did there. All I saw was go in to clean it, but why

3 ----

4 Q. Were you there in Omarska camp when the journalists arrived?

5 A. Yes.

6 Q. Did you discover where these journalists had come from?

7 A. No.

8 Q. Did you know whether they were Serbian or from Yugoslavia, from the

9 former Yugoslavia?

10 A. Once one could see that they came, they spoke in a language I could

11 understand, and they all spoke like that. So, presumably, they were not

12 foreign journalists because they all spoke our language. Then one was

13 shooting, recording, how you had to say that everything is all right.

14 When foreign journalists came they would have an interpreter and you

15 knew they were foreign. On a couple of occasions they came when they

16 spoke the language that I understand Serbo-Croatian and they talked

17 there.

18 Q. So you say that some of the journalists that came spoke your language

19 and others used interpreters?

20 A. Yes, some did not need interpreters, because when he comes he asks you

21 when an interpreter comes, then you hear because when the journalist who

22 asks questions he speaks a foreign language and the interpreter asks you

23 what he asks you, and then you reply. When one who speaks my language

24 comes, then presumably he is not a foreigner.

25 Q. OK. On 21st August 1992 did you then leave Omarska camp?

Page 4415

1 A. Yes.

2 Q. Did you go to Manjaca?

3 A. Yes.

4 Q. How long did you stay in Manjaca for?

5 A. Until December 14th. I cannot remember the date. I know it was

6 December, but was it 14th or the 16th?

7 Q. So about mid-December. Did you then leave Manjaca camp and did you go

8 to Karlovac?

9 A. Yes.

10 MR. NIEMANN: No further questions.

11 MR. KAY: No cross-examination, your Honour.

12 THE PRESIDING JUDGE: Is there any objection to Mr. Grozdanic being

13 permanently excused, Mr. Kay?

14 MR. KAY: No, your Honour.

15 THE PRESIDING JUDGE: Sir, you are permanently excused. You are free to

16 leave. Thank you for coming. You may leave now.

17 THE WITNESS: Thank you.

18 (The witness withdrew).

19 THE PRESIDING JUDGE: We have five minutes remaining until the time that we

20 typically adjourn, and we thought we would not hear from another witness

21 but address two other matters. The first has to do with the request of

22 the Defence to have a short recess after the Prosecutor concludes its

23 case in-chief. I believe you had requested a week or two weeks, Mr.

24 Wladimiroff, is that correct?

25 MR. WLADIMIROFF: That is correct, your Honour.

Page 4416

1 THE PRESIDING JUDGE: We have considered that and that -- what is the

2 position of the Prosecutor? I do not know that you had a position, did

3 you?

4 MR. NIEMANN: We have no position on it, your Honour.

5 THE PRESIDING JUDGE: That request will be granted. So when the Prosecutor

6 concludes its case in-chief we will then recess for two weeks in order

7 for the Defence to use that time. The other matter related to, this had

8 to do with the request of the Prosecutor to interview alibi witnesses

9 during that recess. As I recall, the Defence did not oppose that and

10 the Defence and the Prosecutor had met, discussed this matter and it had

11 been agreed that the Prosecutor could interview those witnesses with the

12 Defence counsel present, as I recall.

13 MR. WLADIMIROFF: We set up the conditions.


15 MR. WLADIMIROFF: Well, we have discussed the matter and it was clear.

16 THE PRESIDING JUDGE: OK. The motion then of the Prosecutor that is

17 outstanding regarding supplementing the response to the alibi notice,

18 will be granted in so far as you need not respond until after you have

19 spoken with the alibi witnesses. How much time do you think you will

20 need thereafter, Mr. Niemann, to file the notice regarding any rebuttal

21 witnesses? If you wish, you may confer and advise us tomorrow morning.

22 MR. NIEMANN: If I may, your Honour, yes.

23 THE PRESIDING JUDGE: OK. Judge Stephen was suggesting that I ask you

24 whether you have a better estimate of when you would conclude your

25 evidence-in-chief. I added up the numbers just a few minutes ago and I

Page 4417

1 have come to 47 hours, if I accept the time that you have listed. How

2 does that sound?

3 MR. NIEMANN: Our position is ----

4 THE PRESIDING JUDGE: You need whatever time is listed on your witness

5 list, or will you be not calling some of those witnesses?

6 MR. NIEMANN: There are a couple of witnesses we may not call, your Honour,

7 but our estimate at the moment I think is still around about the second

8 or the third week.

9 THE PRESIDING JUDGE: You might take a look at your witness list and

10 perhaps tomorrow morning you can give us an estimate of how much time is

11 needed. We are not suggesting that you in any way curtail your

12 evidence, but we were just wondering what was your estimate as we stand

13 now.

14 Very good. Are there any additional matters we could use the

15 two minutes for?

16 MR. NIEMANN: There is one additional matter, your Honours. I am not sure

17 whether or not it is going to affect these proceedings in any way, but I

18 think it is appropriate that I should raise the fact that it is

19 suggested that there may be difficulties operating in Bosnia during the

20 period of the election from 1st to 21st September. I just raise that at

21 this point because at least the Office of the Prosecutor has been put on

22 notice that all resources in Bosnia will be utilized for that purpose at

23 that time, and they are not in a position to accommodate any of our

24 requirements. I know this is a Defence matter but I raise it at this

25 stage.

Page 4418

1 THE PRESIDING JUDGE: Are you suggesting you may have some difficulty

2 interviewing then the Defence witnesses? If we do recess the end of

3 August or the first week in September for one to two weeks, are you

4 saying that you may not be able to accomplish that?

5 MR. NIEMANN: We have certainly been put on notice in terms of our other

6 activities in Bosnia, that during that period the resources of IFOR and

7 other agencies are so fully committed with the election lead-up to it

8 that they will not be able to accommodate any of our requirements.

9 Whether that impacts upon these proceedings or whether it impacts upon

10 the Defence I am not able to say, but I raise it because it is a matter

11 which has been drawn to our attention.

12 THE PRESIDING JUDGE: Those are matters over which we have absolutely no

13 control. I imagine we will look at the newspapers along with you, but

14 let us see what develops as we move into the month of August and perhaps

15 we will have a better read as to it.

16 We will adjourn then until tomorrow at 10 a.m.

17 (5.30 p.m.).

18 (The court adjourned until the following day)