1 Monday, 28th October, 1996.

2 (10.00 a.m.)

3 (Open session)

4 DUSKO TADIC, recalled.

5 Examined by MR. KAY, continued

6 THE PRESIDING JUDGE: Mr. Tadic, you understand that you are still

7 under the oath that you took on Friday to tell the truth?

8 THE WITNESS [In translation]: Yes, I do.

9 THE PRESIDING JUDGE: Thank you. Mr. Kay, you may begin.

10 MR. KAY: Thank you, your Honour.

11 Q. Mr. Tadic, at the end of the proceedings on Friday you were

12 telling us about events at the beginning of April of 1992. You

13 had told us about your wife leaving Kozarac on that day.

14 I would like you to tell us now where she went on that day of

15 1st April 1992?

16 A. My family left for Banja Luka.

17 Q. When you say your "family", was that your children as well as

18 your mother?

19 A. My wife, my daughter Valentina, my daughter Aleksandra and my

20 mother Staka.

21 Q. When they went to Banja Luka did you travel with them?

22 A. Yes.

23 Q. How did you travel to Banja Luka on that occasion?

24 A. We travelled in a van.

25 Q. Whose van was that?

26 A. It was my brother's van, my brother Ljubomir. It was a white

27 van, Volkswagen van.

28 Q. Did your family stay in Banja Luka on this occasion?

1 A. Yes, I went back and they stayed.

2 Q. From Banja Luka did they travel elsewhere?

3 A. Yes, they went to the village of Kozice in the vicinity of

4 Sanski Most.

5 Q. What was the reason for going to Kozice?

6 A. Well, the main reason was a general feeling of unsafety in the

7 territory of Kozarac which lasted for a longer period of time.

8 So, simply, I saw that many people were leaving Kozarac and me

9 and my wife were concerned about our children. I was living in

10 Kozarac alone with my old mother (who was quite sick at that

11 time) and my three year old daughter and another daughter and my

12 wife. So the place I was at that moment was at the centre of

13 Kozarac. It was quite an awkward position in view of the

14 circumstances in Kozarac at that time.

15 At that time there was some kind of mobilization going

16 on in Kozarac. People were being called up, and most of the

17 families knew where they would go to find shelter in case of

18 war. Those who had a place to go, they left, they mostly left.

19 People who had relatives abroad, either in Germany or Slovenia

20 or elsewhere, people were leaving in coaches, by cars, and by

21 planes. There used to be a regular service Banja Luka/Belgrade

22 by plane at that time.

23 So, I did not manage to find out whether I should go

24 to seek for a shelter in case of war and I could see that there

25 were intensive preparations going on for the protection of the

26 population, but nobody informed me about that. So, I felt

27 somehow isolated and, in view of those circumstances, I had to

28 leave.

1 Q. What was the connection with Kozice?

2 A. My brother Mladen was the best man of Majkic, the priest, and

3 because of that relation, that connection, he used to visit our

4 house from time to time and we visited each other. Why Kozice?

5 I think my wife could give you an answer because she had made an

6 agreement with Majkic's wife. They were on very good terms, the

7 two of them, and I think that was the only reason. Maybe also

8 because several days before our departure there had been an

9 incident in Kozarac. I do not know what holiday it was, but at

10 one moment the priest's wife came to my house. She was holding

11 a several months old baby in her arms and she was crying. I did

12 not understand what was going on and I just know that my mother

13 went to see her and they went to their home.

14 When I came back to see what had happened, she told me

15 that that day unknown persons had tried to remove the flag from

16 the church, and that she was threatened that she would be killed

17 and that she had to take off that flag. So she did not know

18 what to do, her husband was not at home at that time. I know

19 that she informed the police about that, and I know that police

20 from Kozarac arrived and the situation somehow calmed down.

21 Anyhow, similar incidents were all too frequent for men to feel

22 safe.

23 Q. In evidence in this Court we heard the allegation that was

24 reported as a result of other people telling others that you had

25 attempted to set fire to the Serb Orthodox church in Kozarac.

26 Is there any truth in that?

27 A. No. I never tried to do such a thing and it never occurred to

28 me to do something like that, and I think that no one ever tried

1 to set the church, the Orthodox church, on fire -- no one.

2 There used to be a similar story and I was surprised to learn --

3 actually I learnt it here for the first time -- the story about

4 this attempt to burn down the church, but there was a similar

5 story in connection to that.

6 Q. Did you go to Kozice with your family or did you return to

7 Kozarac?

8 A. I did not go with them right away. I know that I visited them

9 in the village of Kozice once. My wife and my family were

10 staying with the parents of Veselka Majkic, the priest's wife,

11 not with his parents but with her parents. I know that her

12 mother lived there with a younger sister and I know that

13 Veselka's father was living in Austria at the time. So

14 I visited them, I do not know exactly when, but I visited them

15 once and I returned.

16 Q. Whilst your family were away during this time, did you continue

17 to run the cafe bar in Kozarac?

18 A. Yes, I did. The cafe was open all the time throughout that

19 period, some six months before the beginning of war operations

20 in the Prijedor territory. I had one waiter working for me.

21 I think that his name was Elvir or Elvis Softic. It was a young

22 man and he worked for me very long and the last six months he

23 worked alone. I trusted him. He had a key of my cafe, so if

24 I was absent he would open the cafe himself. He ran it all by

25 himself. There were no problems whatsoever.

26 Q. Did there come a time when your family returned from Kozice and

27 rejoined you in Kozarac?

28 A. Yes, on 29th April, they came back. I was surprised. I was not

1 expecting them, but they thought that danger had been gone, that

2 the situation has improved in Kozarac. However, quite opposite

3 actually happened. On that day when I arrived there was a

4 general chaos in Kozarac. I do not remember seeing civilians in

5 the street. Everybody was armed, and it was really a chaos. It

6 was not easy to recognise which soldiers belonged to which

7 army. You could see all kinds of insignia. You simply could

8 not tell who was with whom.

9 Q. How long did they stay in Kozarac for on this occasion?

10 A. They stayed in Kozarac until 3rd May. I say 3rd May because on

11 that day another incident occurred, an incident which was just

12 too much for everybody in Kozarac. I remember that on that day

13 my wife, I think it was Sunday or weekend, I do not know exactly

14 which day, and she was with her parents in Vidovici on that day,

15 and I was at home with my mother. All of a sudden I heard

16 people screaming, and I got out to find out what was happening

17 and neighbours panicked. Everybody was all of a sudden in

18 shelters and I asked what was going on, and then they said that

19 a tank had arrived near Kozarac and there was a danger of

20 imminent war. So I went to the lower part of Kozarac down the

21 street of Marsala Tita and near the triangle which has been

22 shown here quite often. I saw on the Prijedor/Banja Luka road a

23 tank which was pointing to Kozarac.

24 Q. Did you on that particular day leave Kozarac with your family?

25 A. Yes, I did, but before that several incidents had happened which

26 made me leave Kozarac. When I saw the tank, when I talked to

27 some people and I realised everybody was armed, there was a

28 group of armed people standing next to Bosko Dragicevic's house

1 and there was general chaos.

2 I went to see the priest, Majkic. I asked him what

3 was going on because he was closer to the event, and he did not

4 know anything about what was going on. I asked some other

5 people and they told me that a kind of incident had occurred and

6 then we tried to do something. People asked us to do something.

7 They told us, "Well, you are Serbs. You should do something".

8 I said, "OK, we will try to do something".

9 So we went, he and I went, along a road near the

10 church and we got to the main Banja Luka/Prijedor road, and we

11 set off in the direction where the tank was and we were moving

12 from the direction of Banja Luka towards Prijedor, but after 100

13 or 150 metres from the right side of the road some unknown

14 persons ordered us to go back. They said, "You should go back

15 otherwise we will shoot". We were afraid so we went back.

16 Later on, I was thinking I really do not know why we

17 went because it was quite dangerous and at that moment I did not

18 fully realise the extent of the danger. So we went back to his

19 house and he suggested that we should leave; that would be the

20 best thing. So I left. I went back to my house and my wife had

21 come back from the village of Vidovici in the meantime together

22 with my children. We packed very quickly. We went back to

23 Majkic and we all got into his car. There was a lot of panic

24 going on. I remember I did not take anything with me, no

25 clothes. We were eight in his car. It was a Jugo 45 type of

26 car.

27 Q. Did you own a car at this time?

28 A. No, I did not have a car. I used to own a car in the period

1 when I was working in Banja Luka for about three years. I had a

2 Visa Citroen. I sold it when I left for Libya and after that

3 I never owned a car.

4 Q. The priest's car that you referred to, that zastava, did you all

5 fit in this car, the eight of you?

6 A. Well, because we did not have any belongings with us, we just

7 got in very quickly. It was a big haste and the priest was

8 driving and I was sitting at the front passenger seat and behind

9 there was my mother, my wife, my daughter Valentina, Aleksandra,

10 and the wife of the priest was also sitting there, Veselka and

11 her daughter who was several months old. We were all very

12 cramped. I was at the front so I did not really feel that.

13 Q. Which route did the car take out of Kozarac?

14 A. Well, since we realised, we knew, that the tank was at the

15 entrance to the town of Kozarac, we thought that it was

16 impossible to take that road. So we took the old Banja Luka

17 road in the direction of Banja Luka, and we thought that we

18 could get to the main Banja Luka/Prijedor road and continue our

19 journey towards Banja Luka because the old road is parallel to

20 the new one, and there are several spots where you merge. So we

21 went along that road and after 100 metres we were stopped.

22 Q. The old road you referred to, does that run past the church?

23 A. Yes.

24 Q. If you took that road in the direction of Banja Luka, it at some

25 stage comes close to what is called the new Banja Luka/Prijedor

26 highway, is that right?

27 A. Yes, most of it runs parallel with that road, very close, maybe

28 some 100 metres at some spots or maybe 50, but on many spots

1 when you drive towards Banja Luka, the two roads merge.

2 Q. Did you try to get on to the new highway towards Banja Luka?

3 A. Yes, that was the idea. After maybe 500 metres driving in the

4 direction of Banja Luka along the old road, you could pull into

5 the main, into the new Prijedor/Banja Luka road. I do not

6 recall exactly the name of that spot, but that is what people

7 mostly did when they travelled to Banja Luka because it is

8 closer for about one kilometre as opposed to when you go to the

9 junction, Prijedor/Banja Luka.

10 Q. Were you able to get out of Kozarac and travel to Banja Luka on

11 that road?

12 A. No, I was surprised because after 100 metres we were stopped, as

13 I told you. The priest talked to the man who was standing in

14 the middle of the road, that side road. I knew that young man

15 who was standing there. He was holding a rifle and he had a

16 uniform, a military uniform. It was Bahonjic and I think his

17 name is Sead, I am not quite sure, but I knew him very well

18 because he had a private business for production of coffee

19 machines. So I knew him very well and he sold me the coffee

20 machine for my cafe.

21 He was standing there. He pointed his rifle and he

22 said that he was under orders not to let us leave Kozarac. So

23 I asked him once again. He first talked to the priest. He was

24 standing some 20 metres away. So I opened the door and I asked

25 him, I begged him, to let us leave, and I said, "I will just

26 drive my wife and children. I will come back. If you want me

27 to stay here, I will come back. There is no problem". He said,

28 "No, we are under orders no one should leave Kozarac". "Who

1 ordered that?" He said, "I do not know". He did not want to

2 answer my question.

3 So at that moment I realised that on the left side

4 there was a large group of people standing behind a shelter and

5 I said, "Well, OK. I will go to the police to ask for the

6 permission to leave Kozarac", and he said, "Well, please do

7 so".

8 We went along the road. I do not know the exact name

9 of that street, maybe Omladinska or Pionirska. Anyway, it

10 is the street that leads to the hospital in Kozarac, the health

11 centre. At the health centre it turns left and goes to the main

12 street, Marsala Tita, which leads to Mrakovica. So we went

13 along that road, in the direction of the police station, which

14 is in the main street, Marsala Tita Street, but we did not stop

15 there because there was a huge group of people standing in front

16 of the police station and everybody was armed. We simply could

17 not stop.

18 So I saw that many people were carrying weapons and

19 there were vehicles were passing by and you could no longer tell

20 there was any kind of order at that time. People were driving

21 both on the left and the right side of the road. It was a

22 general chaos. So we drove on in the direction of Mrakovica and

23 I remember that they tried to stop us near the village of

24 Rajkovici. I know there was a well at that spot which was some

25 kind of monument, so a soldier wearing the same uniform as the

26 previous one tried to stop us. But this one had a

27 semi-automatic rifle and he also had a hand held rocket launcher

28 fixed to his rifle. I knew that man too. It was Salkanovic.

1 They called him "Salkan", but I do not know his real name.

2 So he tried to stop us, but we just drove past very

3 fast and went on in the direction of Mrakovica. So, we were

4 travelling towards Mrakovica, via the village of Podgradje. We

5 arrived in Gradiska and then from Gradiska we set on in the

6 direction of Banja Luka where we arrived in the evening. I know

7 that we drove some 150 kilometres that day.

8 Q. Just to help those listening to the evidence in this case, if

9 I can just identify a number of those streets that you referred

10 to? You referred to leaving the old road and going up towards

11 the health centre in Kozarac. Is that a road that is at right

12 angles to the old road and virtually opposite the church itself?

13 A. Yes. That road goes past the house of Marinko Konjivoda on the

14 right side, Mirko Grahovac's house on the left side, Bestalic

15 Meho's house, and it leads right to the entrance of the health

16 centre in Kozarac and at triangles it turns left and merges with

17 the main street, Marsala Tita Street.

18 Q. I do not have a photograph of that street immediately to hand,

19 but you may remember when a witness was giving evidence, an

20 anonymous witness, that he looked at a photograph of that street

21 but was unable to identify it. Was that the street you were

22 referring to?

23 A. Yes.

24 Q. The direction that you took out of Kozarac towards Mrakovica and

25 that would have been up Marsala Tita Street and the continuation

26 of Marsala Tita Street out of Kozarac, is that right?

27 A. Yes. Yes. Marsala Tita Street goes on and it passes the

28 villages of Dera, Rajkovici. It goes past the youth settlement,

1 Benkovac, and it leads to Mrakovica which is the top of the

2 Kozara mountain. From Mrakovica, you turn left from where you

3 can only take a macadam road and after a couple of kilometres

4 there is an asphalt road. So the road leading from Gradiska to

5 Banja Luka, that is the road Banja Luka/Bosanska Gradiska which

6 we used to take when travelling to Belgrade. It is a main road.

7 Q. When you arrived at Banja Luka, where did you go to stay?

8 A. We went to my brother's place, Ljubomir's place.

9 Q. Is it right that he has an apartment in a block of flats in

10 Banja Luka?

11 A. It was not really an apartment. It was some sort of provisional

12 accommodation. It was not a real apartment. It was in basement

13 and there was also -- there was only one room in that basement

14 which served both as the kitchen and bedroom. There was also a

15 bedroom, a sort of makeshift bathroom improvised by my

16 brother. I know that he moved there after the earthquake in

17 Banja Luka.

18 Q. What I had asked you about was where your brother Ljubo lived in

19 Banja Luka, what sort of accommodation he had?

20 A. Exactly what I just described, that is where he lived, and the

21 settlement is called Starcevica. Those were really -- it was a

22 basement unit.

23 Q. Did you stay with your brother Ljubo or did you go to live

24 elsewhere?

25 A. We all spent the night there. It was very late when we arrived

26 and the priest did not have a place to go. We suggested that he

27 stayed. It was risky. We did not know what was going to go

28 on. We did not know what was happening on the other roads, how

1 you could get to Sanski Most. You could get there through

2 Mrkonic Grad. He himself did not know at the time where he was

3 going to go, to his parents or somewhere else. So, simply, we

4 did not know what was going on. He stayed the night and the

5 next day he left. I later found out that he went back to

6 Omarska.

7 Q. Did you continue to stay with your brother Ljubo or did you go

8 to live elsewhere?

9 A. We spent several days at my brother's and throughout that time

10 my wife and myself cleaned up another residential unit in Koste

11 Jarica Street which was not in a very good condition. We tried

12 to make it livable where we could move in for a longer period of

13 time.

14 Q. I would like you now to look at some photographs, Exhibit 62A

15 and B, please? Defence 62A and B. If those photographs

16 actually could be put straightaway on the monitor? We see on

17 the left-hand side a photograph of a house with a gate in front

18 of it. Do you recognise that building?

19 A. Yes.

20 Q. What is that building?

21 A. That is a house in Koste Jarica Street in Starcevica settlement

22 in Banja Luka where I moved my family in.

23 Q. How did you come to stay in this house?

24 A. Myself and my family and my brother had a friend, Nihad Alic --

25 he was a salesman like my brother -- and in the course of time

26 we all met. He was in very -- he had a very good relationship

27 with my brother Ljubomir and he used to come to Kozarac in

28 earlier times quite a lot, especially -- he had offered to my

1 brother for us to move into that house. The previous residents,

2 that is, the owners, the woman had left, she went abroad, and

3 her husband had died or was killed, I do not remember exactly,

4 so Nedim had the key and they offered us to move there. The

5 house had -- it was about 50 metres, maybe less, down the road.

6 We met and he showed us this place.

7 Q. Which part of the house did you move into?

8 A. We moved into the basement which can be seen on the right-hand

9 side of the photograph.

10 Q. To get to the basement where would you find it in the house?

11 A. If you look at the left-hand side photograph you can see an

12 improvised gate there. You would turn right and go around. You

13 would come to the entrance from the side.

14 Q. Is the house itself standing on a slope?

15 A. Yes. The front side, if you look at the left-hand side

16 photograph, that is -- this is all flat, the yard and the path,

17 but in the back of the house the ground slopes down on a

18 decline, and about 50 metres down there is a little creek and it

19 is sort of grown in, overgrown.

20 Q. Looking at the photograph D62B, which is the one on the

21 right-hand side, what does that show?

22 A. It shows the basement which you can see on the left-hand side

23 photograph, but it is part of the same structure, of the same

24 building. In that period, while I was staying with my brother,

25 I tried to clean up, make it livable. My friend, Hamdija, who

26 was a professional in there, we first painted the kitchen and

27 that living area, so-called, even though only the kitchen really

28 existed, it was ready to be lived in, and the rest of the

1 structure was pretty useless. So we tried to make it usable.

2 So I was interested in putting there my wife and my

3 mother. But, under normal circumstances, in normal conditions,

4 nobody would live there. The windows were broken on the side.

5 People had broken into the building several times while the

6 owner was abroad. That was one of the reasons why Nedim offered

7 us to move there because the very presence would deter people,

8 and there were several break-ins that were happening in that

9 area. So it was beneficial for them too.

10 To the left from the entrance there was a large room

11 which was about half of the square area of the house. There was

12 a sofa and armoire, but everything was dirty and we kept

13 cleaning it and it had a bad stench. So I moved the family in,

14 but every time I would come we kept cleaning and cleaning out.

15 I remembered behind that living room area there was a room where

16 they had a large cooler. I -- we found a freezer. We found a

17 lot of spoiled food in there. So it gave a terrible stench.

18 I know that throughout the time we stayed there we

19 kept cleaning it out and we never finished. There was no

20 bathroom there. I heard my wife say that the conditions were

21 good, but it is not right. Maybe they were better than what

22 they had in the village of Kozice, maybe. I know that there was

23 no bathroom in this house and the toilet was improvised. When

24 we wanted to take a bath we would go to my brother's or to our

25 friend's, to the family (redacted).

26 Q. Did your family move into this accommodation with you or did you

27 live elsewhere?

28 A. As I said, I was staying in Banja Luka all up until we moved

1 them in and then I went back to the Kozarac. On the right-hand

2 side photograph on that tree you can see an iron bar, and that

3 was a TV antennae that I put up right away so that my family

4 could maybe watch television. At that time we had no TV, but we

5 found the antennae so I just installed it. Later, my brother

6 brought a TV so we could watch it.

7 But, in general, they were bad conditions. We were

8 embarrassed to invite anybody so that they could see where we

9 lived. I had a lot of friends in Banja Luka but I did not

10 invite them. They all knew that I lived very well in Kozarac,

11 and for me it was embarrassing to be here.

12 Q. You said you arrived in Banja Luka on 3rd May. About what would

13 the date have been that your family moved into that

14 accommodation in Koste Jarica street?

15 A. I think it was 6th May, several days, three or four, maybe it

16 was 7th May, but I think it was 6th. I also know well that

17 there is also a well there to the right because nothing inside

18 really worked. It seems to me that people -- they must have

19 been taking baths outside.

20 Q. When they moved in on 6th or 7th May, what did you do?

21 A. On the same day I went back to Kozarac, because my cafe was

22 still open, and the young man that I told you about, Elvir, my

23 waiter, he knew that I was not coming. He had a key. He would

24 open up and he knew his job. He was keeping the books, and so

25 I just joined him and we continued. Also, we had a special

26 relationship. He was not asking many questions where I was

27 going, when I was coming back, and I was not very strict towards

28 him. So we got along very well. So my presence or absence did

1 not interfere with the work. He knew his job, even if there was

2 -- if we ran out of beverage, he would go to Adil Jakupovic,

3 Sefik Arnautovic, and he would take care of it.

4 Q. You had returned to Kozarac; did there come a time when you

5 eventually left Kozarac?

6 A. Yes, I left Kozarac 23rd May '92.

7 Q. I would now like to ask you some questions about that period

8 until 23rd May 1992. Did you visit your family in Banja Luka on

9 occasions during that time?

10 A. Yes, I did. As I said, I trusted this young man and it was no

11 problem for me to leave. He had the keys both to the cafe and

12 to my house and to the garage where there were supplies of

13 alcoholic and other beverages. I often went mostly because

14 I always took something with me. Once we -- when we first left

15 Kozarac, we almost took nothing with us, very few things,

16 especially when the children's things, they had no clothes.

17 There was nothing in Banja Luka. I also remember that I took

18 bedding. All there was in that house, everything was really

19 neglected, and we only had one blanket so you had to fold it

20 underneath and over your head so that you could fall asleep.

21 There were no conditions there. So I very often went there and

22 took things with me.

23 It was difficult because I did not have a vehicle. We

24 had to find a way, a bus or a truck, or find somebody who was

25 going. So that is how I was going there. But, mostly I would

26 not stay there; I would go and then I would come back the same

27 day or the next. I was not staying there.

28 Q. Your brother Ljubomir described taking a TV set and a terrier

1 dog back to Banja Luka on your behalf. Was that right?

2 A. Yes, yes, that is right, but it was not one terrier. It was two

3 of them. They are small dogs. Maybe they were three weeks or a

4 month old. One he took and one we left with the family where we

5 stayed in Banja Luka, but I had a large terrier which was their

6 mother.

7 Q. That is all I think we need to know about it for the moment. It

8 was just the fact of it rather than the dog family history.

9 During this period until 23rd May, we know from evidence that on

10 29th April 1992 there was the takeover in Prijedor and the

11 Crisis Staff was formed in Prijedor. I want to ask you now

12 about this period of time from 29th April until 23rd May. Is it

13 right that there were a series of meetings that took place

14 between the new authorities in Prijedor and representatives from

15 Kozarac?

16 A. Yes.

17 Q. Those meetings concerned a series of ultimata that had been

18 given to Kozarac. Were you aware of these ultimata?

19 A. Yes, I knew, but all that started by takeover of the power.

20 I first found out and it was a shock to me. To a degree, one

21 could understand the takeover of power, but I was shocked when

22 I saw that the next day some people were turned back. They

23 could not go to work. Some said that they were turned back at

24 Orlovci and some said, "We could not go there; there are flags

25 hanging around town".

26 That is the first shock. That is what shocked the

27 population, the general population, who was not familiar with

28 this. But then I think that the whole thing went on for much

1 longer, even before the takeover, and that the official

2 authorities in Kozarac knew about it but not the general

3 population. But, after the takeover on 29th April until

4 23rd May, there were several additional meetings and there were

5 these ultimata that were coming from the Crisis Staff in

6 Prijedor. I heard about them and I know about the ultimatums

7 that were given to the police force in Kozarac, to the regular

8 police. They were not directed to the civilians and the TO and

9 the reserve police. I heard only about the ultimatums sent by

10 the police in Prijedor to the active police force in Kozarac.

11 Q. Is it right that there were a number of delegations from the

12 municipality of Kozarac, and citizens who were part of the

13 municipality met those within the Crisis Staff in Prijedor to

14 discuss the state of affairs with them?

15 A. I am not that familiar about this first period, after the

16 takeover. Later, when I joined the civic forum, I found out,

17 talking to people, that these negotiations went on for a long

18 time, and there were representatives of Local Commune of Kozarac

19 taking part and the representatives of the police force, and

20 they were talking to the people from the municipalities.

21 But, Kemal Susic told me that these negotiations were

22 interrupted at one point, maybe about two weeks before the

23 hostilities began. He told me that they had formed a citizens'

24 forum which would be non-partisan. There may have been some

25 party members in it but, by and large, they organised and they

26 wanted to join the negotiations precisely because the

27 negotiations between the local authorities in Kozarac and in

28 Prijedor had been interrupted.

1 So, Kemal Susic and other citizens who before that had

2 no active part in the Local Commune, they visited me and they

3 asked me if I would join the same forum. I asked them about the

4 reasons for it and they told me what was going on before. That

5 is why they wanted to come and try to help in that situation.

6 Q. Do you know why it was that the citizens forum approached you to

7 join them and take a part in their discussions?

8 A. The reason was a simple one. They said, Kemal Susic explained,

9 I had contact and we talked and, first of all, they knew who my

10 father was, that he was a well-known person in the municipality

11 and they thought that I could help as his son. Also they said

12 that they would also invite Bosko Dragicevic. His son was the

13 first President of the Kozara municipality earlier, and so they

14 were talking about the possibility of creating a mutual trust.

15 They said that they would also invite several other

16 people who were non-Muslims in Kozarac. I agreed with that but,

17 frankly speaking, at first I was not sure. I did not know about

18 the real goals of this forum. I was afraid that all people

19 would be manipulated by any which party. It was risky to get

20 involved because you did not know what was behind it. We did

21 not know what was going on at the very top. We did not know

22 about the previous negotiations. We just knew that there were

23 ultimatums, that there was something going on in that respect.

24 So we went to Prijedor with quite a bit of -- with

25 many unknowns. We knew one thing. We wanted to quiet down the

26 situation, to improve relationships with Prijedor and Banja Luka

27 and we thought of no other things.

28 Q. I can tell the translators are working at great speed to keep

1 up with you, Mr. Tadic. If you could speak a little bit slower

2 because they are trying to interpret every word. I can tell

3 they are moving very quickly.

4 THE PRESIDING JUDGE: Mr. Kay, what was the date that Mr. Tadic

5 joined the citizens' forum or civic forum?

6 MR. KAY: I will ask that question. Thank you, your Honour. [To the

7 witness]: Can you tell us when it was you decided to join the civic

8 forum as a result of Kemal Susic approaching you?

9 A. I think it was 10th May. In the period between 10th and 23rd

10 May we met twice in Prijedor. I remember that the last time

11 when we met, it was 20th May. The first meeting I do not recall

12 exactly, but it was during that period of time.

13 Q. That is the first meeting that you would have attended that you

14 cannot recall the date, is that right?

15 A. Yes, I cannot say if it was 11th or 12th, but it was that first

16 meeting, and then we -- after we had an agreement, we did

17 certain things and then another meeting followed which was on

18 20th May.

19 Q. In both of these meetings that took place, did you play any

20 active role?

21 A. Yes, I did. I took Kemal Susic's invitation very seriously.

22 Then when I saw who the other members were, I really started

23 believing the good intentions. Those were people who were not

24 involved in the war. They were interested in business or

25 sports, the communal living, so these were the people with whom

26 we lived. They were my neighbours or my brothers, the people

27 from the centre of Kozarac, who were considered to be the

28 natives. There was Jusuf Pasic, the doctor, Kemal Balic,

1 Hamdija Kahrimanovic, Dragoje Pupovac from Kozarusa. Bosko

2 Dragicevic was present at the first meeting, but then refused.

3 Ilijaz Memic was also representing the Local Commune and then he

4 also refused to come to the second meeting and he fled abroad

5 with his family. He was a representative of the SDA and the

6 Local Commune.

7 Q. At the first meeting what was discussed between the various

8 bodies who were present and represented? What was the purpose

9 of the meeting?

10 A. I think that first it should be explained how the meeting came

11 about.

12 Q. If you could actually answer my question first about the purpose

13 of the meeting?

14 A. The subject was the ultimatum that was given to the police and

15 security situation in the area of Kozarac, the Local Commune.

16 The Local Commune of Kozarac was part of the Prijedor

17 municipality. The main institutions were in the city of

18 Prijedor however you felt about it, and there was a municipal

19 Crisis Staff that was instituted there and they had the superior

20 authority. They took over all power. At that time the civilian

21 government did not function the way it used to.

22 Q. The representations made by the people from the civic forum in

23 Kozarac, were they representations and were they presented in a

24 way that you supported and agreed with?

25 A. Well, we had arrived there because we wanted to hear about what

26 the problem was because we did not really know what the problem

27 was, and they told us what the problem was. It was exposed by a

28 person whom I met there for the first time, by Simo Drljaca, a

1 new chief of the Prijedor police. He mainly had the floor

2 although the meeting was also attended by the Commander of the

3 municipal Crisis Staff, Milomir Stakic and Mico Kovacevic, who

4 was the President of the Executive Council, was also there, the

5 President of the SDS, Simo Miskovic. There were several people

6 in military uniforms which I had never seen before.

7 But mainly the problems were the relations between

8 Kozarac police and Prijedor police, and that is why Simo Drljaca

9 had the floor most of the time. He explained everything in very

10 strict terms, and he said what the problems were and they did

11 not want to talk about that, and they said who we were

12 representing and so on. "How will you implement what we agree?"

13 and so on. The only power at that time in Kozarac, it was in

14 Memic's, Ilijaz Memic's hands. So they did not know whether

15 everything we can agree would be implemented.

16 So I know that Simo Drljaca explained, exposed, his

17 requests. He asked that active policemen sign loyalty to the

18 new government in Prijedor, to the police chief, that insignia

19 be changed and uniforms, or otherwise people who are fully

20 employed there with the police, then they should leave the

21 police and give back the weapons. Those were his main requests,

22 requests of the Chief of Police in Prijedor, Simo Drljaca. He

23 explained his requests and he also issued some kind of

24 ultimatum. He said that it was the order of the Banja Luka

25 centre of public safety, headed by Zupljanin.

26 Q. The delegation that you were asked to join from the civic forum

27 in Kozarac, did you have an agreed policy amongst yourselves?

28 Did you actually have any power amongst yourselves to respond or

1 to in some way comply with this ultimatum from Prijedor?

2 A. Well, that precisely was the big problem. We didn’t have any

3 authority, not that I knew of. Maybe some people did have some

4 kind of instructions but they did not say anything about them.

5 There was a very serious problem because in case we should come

6 to an agreement, how could we possibly implement it? So the

7 only person who had some authority in Kozarac at that time was

8 Ilijaz Memic, also Bosko Dragicevic. Bosko Dragicevic was a

9 member of the Executive Council of the Local Commune and Ilijaz

10 Memic was a representative of the SDA. They refused to

11 co-operate. Bosko Dragicevic justified himself by being very

12 busy and Memic simply packed his things and fled abroad, so we

13 just -- we remained stranded. Anyhow, there was a possibility

14 to do something. That is why members of the forum suggested a

15 meeting of the Assembly of the citizens of Kozarac which was

16 held, and they explained to them the requests issued by the

17 Municipal Assembly in Prijedor.

18 I did not attend that Assembly, but we agreed that we

19 should go to Prijedor once again. I think it was on 20th May

20 that we went back to Prijedor and had another meeting. The same

21 people attended the meeting, municipal Crisis Staff from

22 Prijedor.

23 Q. The meeting in the Assembly in Kozarac, the people's Assembly,

24 can you recollect when that took place?

25 A. It was held after our first meeting in Prijedor. It was the

26 usual procedure, because after the meeting we managed somehow to

27 find an agreement. We agreed that the ultimatum should be

28 postponed because the Chief of Police in Prijedor, Drljaca, he

1 had said what the exact date should be to implement the

2 ultimatum. So we managed to postpone it until the next meeting

3 which took place on 20th. Our representatives told that to the

4 citizens in Kozarac, to the Assembly, and a new meeting took

5 place then.

6 Q. If I can just ask you about the Citizens Assembly in Kozarac?

7 You said that you did not attend that meeting. Can you

8 recollect what the reason was, why you were not there?

9 A. To be frank, I simply could not. I was not allowed. I trusted

10 people whom I went with but they were also afraid. Many of them

11 were being threatened by some individuals. They were treated as

12 some sort of traitors in case anything should be agreed. So

13 I simply could not go to that meeting.

14 But Kemal Susic informed me about the meeting and the

15 results. He came to see me after that, and he told me nothing

16 special happened, people dominated there, the same people who

17 had attended other meetings in Prijedor, and they simply stuck

18 to their proposals. Some new people appeared, people who had

19 not lived in Kozarac before that. There was a major who came to

20 the meeting. I think that his name was Menkovic,

21 Mirsad Menkovic, and Kemal told me it was unbelievable what was going

22 on at the Assembly. Some groups insisted that the weapons

23 should not be given back and that the loyalty should not be

24 signed. There were people who were looking for a compromise.

25 Anyhow, the situation was very difficult.

26 Q. At this stage, it was obviously well-known that it had been a

27 Serb takeover of power in Prijedor, and you referred to your

28 difficulties in being able to attend that meeting. Was that

1 because lines were being drawn now between Serbs and the Muslims

2 far clearer than they had been in the previous time?

3 A. Well, the takeover in the municipality of Prijedor did create a

4 certain animosity towards us who were living in the centre of

5 Kozarac, a certain mistrust, because it all took place quite

6 unexpectedly in Prijedor. It was a shock for everybody, because

7 the local government was in the hands of the SDA, a Muslim party

8 in Prijedor, and something like a coup had happened. Of course,

9 people no longer believed anyone. They would simply turn their

10 heads away because it was difficult to believe, to trust,

11 someone, they identified the power with someone who had done

12 something terrible.

13 They sided us somehow with them, identified us with

14 them. So what I was trying to do, I was just trying to help, as

15 far as it was possible for me, because I was from the centre of

16 Kozarac because my parents had been living there and I thought

17 that I could do something, and it was my duty to do something.

18 But, as I say, there were many groups of people who were

19 spreading lies. I don’t know if it was all on purpose, but

20 simple people were disappointed.

21 Power had been taken away and, on the other hand,

22 everybody was acquiring weapons in Kozarac. The weapons were

23 being openly sold and you no longer knew whom to trust. There

24 was a general feeling of insecurity, and those who were not

25 organised in some units, paramilitary units, or police units,

26 they simply turned away to their own families and they just

27 cared about that. They wanted to shelter their families and

28 that was the life, that was the situation in Kozarac until

1 May '92. There was very little communication between people at

2 that time.

3 Q. The second meeting that took place in Prijedor, can you tell us

4 what was discussed at that meeting and what the atmosphere was

5 like on the 20th May?

6 A. Well, that meeting did bring some hope that things would be

7 solved at the level of the Kozarac Local Commune, because

8 Drljaca said, although he had already said that ultimata that

9 had been issued came from Banja Luka, from the centre of

10 security services, but he denounced that because he said at

11 the second meeting, "OK, well, you do not have to change

12 insignia but you have to sign loyalty".

13 So there was some kind of progress and we said, "Well,

14 OK, when it comes to insignia, then the police in Kozarac don’t

15 have to wear hats either". So you had a possibility of putting

16 the insignia on other parts of the uniform. But, anyhow, we

17 managed to obtain for those insignia not to be changed. But

18 there was a compromise because hats were no longer worn. That

19 was some kind of progress.

20 But the municipal staff, there was always someone --

21 there was a representative of the military who mentioned the

22 problem of paramilitary units in Kozarac, because in the

23 area of Kozarac there had been several incidents, mostly on the

24 Prijedor/Banja Luka road. People would stop columns of soldiers

25 that were coming back from the front in Croatia, and sometimes a

26 Serbian reserve soldier would be arrested by a group of, I do

27 not know, Suljo Kosuran or someone else, and they would be

28 detained. So it was very unsafe to walk around Kozarac for

1 everyone, everybody who belonged to either the JNA or the

2 Krajina army.

3 So, as I say, some steps had been made, but the

4 problem was the signing of loyalty. Drljaca did say that if the

5 chief of the Banja Luka police allows, then loyalty would not

6 have to be signed. So those were the discussions that we had,

7 and we wanted to go to Banja Luka around 20th, 21st May, in

8 order to reach any kind of agreement. So, aside from that

9 ultimatum, there was an agreement also that people who were not

10 allowed to carry weapons and who were walking around with

11 weapons had to store their weapons at home.

12 So there was a kind of agreement but, as I say, our

13 group was not allowed to do anything. We could just listen to

14 the proposal and propose something, but we were not in charge.

15 We could not say, "OK, it is going to be implemented" because

16 there was a very strict group of people in Kozarac, people with

17 criminal records, such as Suljo Kusuran who had a group of

18 people under weapons. That was this Cirkin person, I do not

19 know his name, but he was in Kozarusa, who also had a criminal

20 record. They just organised some groups themselves and they

21 were doing everything they pleased. So that created an image of

22 Kozarac. Well, whether the official authorities of Kozarac

23 could prevent such kind of organising of people, that was a

24 question.

25 I remember that they were saying that some 20

26 policemen were ready to sign loyalty, but when those

27 paramilitary groups heard about that, they said, "If you sign

28 loyalty, you would be liquidated, you and your families". So

1 that was some sort of capitulation at that time. There were

2 always some individuals who exacerbated the situation and which

3 we had all found ourselves.

4 There was a group of people in Prijedor a group headed

5 by Duca Knezevic. There was a group in Omarska. They

6 communicated among themselves. It was some sort of competition

7 which went to the expense of the man in the street.

8 Q. In that period from 20th May, the second meeting that took place

9 in Prijedor, and 24th May, the day of the attack on Kozarac, was

10 there any opportunity for the representatives from the civic

11 forum to report back to the Citizens Assembly in Kozarac?

12 A. Yes, I think that the civic -- the last Citizens Assembly in

13 Kozarac was held on 21st May '92. We had previously agreed in

14 Prijedor that the Assembly would be attended by a representative

15 from the Crisis Staff, and we were told that Simo Miskovic would

16 attend the Assembly together with Dragan Savanovic, who was at

17 that time Vice President of the municipality and Deputy

18 Commander of the municipal Crisis Staff.

19 They attended the Assembly and I was not present at

20 the meeting. I did not want to be with them because I thought

21 that people would identify me with them, and I think that they

22 were not honest in front of those people. Although Simo

23 Miskovic was trusted by the people in Kozarac because his father

24 used to work as a policeman in Kozarac, he lived there for a

25 very long period of his life and he knew many people in

26 Kozarac. I know he knew Sefik Arnautovic, who was a prominent,

27 respectable citizen in Kozarac. So people trusted him. People

28 believed that he would do something, but I think that he himself

1 was not in the position to do anything special, because he had

2 the Commander of the municipal Crisis Staff behind him and all

3 the military leadership.

4 I know that that meeting was held, but, later on people

5 described to me what had been happening there. There were some

6 disagreements and there was a verbal conflict. I do not know

7 what was being suggested by the representative of the Crisis

8 Staff, but at that time all relations with the Crisis Staff in

9 Prijedor were severed. I remember that, and my neighbours told

10 me, that the same Major Mirsad appeared and he said, "I would

11 rather kill myself than be forced to sign any kind of loyalty to

12 Prijedor. That would be a total capitulation". So they created

13 an unhealthy atmosphere.

14 So they voted that the weapons would not be given

15 back, that the loyalty would not be signed, and the police of

16 Kozarac had previously indicated that if the citizens of Kozarac

17 should decide so, they would sign loyalty. But, as I say, under

18 the pressure of those extremists, that did not happen. So all

19 we could do was try to organise a meeting in Banja Luka. We did

20 have a meeting. I talked with Susic again and with Balic and we

21 had the intention of going to Banja Luka, but it was all too

22 late.

23 Q. The ultimatum that was eventually delivered to Kozarac was the, an

24 ultimatum with a deadline of noon on 24th May 1992. Were you

25 aware of that fact?

26 A. No, no. I do not know whether there was exact time very strict

27 ultimatum. Maybe it had been issued, but I do not know. The

28 meetings which we attended were also attended by the

1 representatives of the military in Prijedor and the police. But

2 there was a general chaos at that time. I did not know who the

3 persons in charge were, who members of the Crisis Staff were.

4 Anyway, we were not aware of that ultimatum. That is

5 why we thought, that’s why we wanted to go to Banja Luka, to

6 try and ask for mercy from the President of the security

7 services centre. So there was an attempt. There was an

8 ultimatum, but it was not the last one because the municipal

9 Crisis Staff would always come up with some new conditions. So

10 I don’t think that we would have achieved anything, and the

11 conflict -- the new problems were being created every day.

12 I remember there was a very serious incident in

13 Kozarac on 22nd May. My neighbours told me, "Switch off your

14 lights, there would be shelling", and when I came out of my

15 house I saw people in shelters, and women and children were in

16 shelters and I saw some people in uniform. All of a sudden,

17 I realised how many people were carrying weapons and people whom

18 I had never seen before with weapons carried arms. I was quite

19 shocked to see all that.

20 I was not afraid personally of my neighbours, but

21 among those people in uniform there were many people with

22 criminal records, people who had spent 10 or 15 years in prison,

23 so there was a big risk. So that night, around 10 o'clock,

24 I remember that Suljo Kusuran's group of people seized weapons

25 from two JNA soldiers on the road to Prijedor/Banja Luka. My

26 neighbours told me later on, Adil and Meho Beslagic, that they

27 had seized one sniper and one automatic rifle.

28 Those people went on to Prijedor and they informed

1 their superiors, and that evening there was an order to give

2 back the weapons otherwise Kozarac would be shelled. I was told

3 that by Fikret who was standing in front of my cafe. His cousin

4 told me that we should switch off the lights and that within the next

5 25 minutes something could happen.

6 And I remember there was a black out. There was no public

7 lighting, but I had no place to go. I did not know where

8 I should go because, from some previous conversations with my

9 neighbours, I saw that there was a list of shelters and my name

10 was not there. My family was not on that list, and I did not

11 know what could happen if there really is a shelling.

12 So, in view of such circumstances, I did what I was

13 told to do. I was standing in front of the cafe with Fikret and

14 many people were hiding in shelters. There were vehicles

15 passing by, vehicles that I had never seen before, camouflage

16 colours, along Marsala Tita Street. There was no normal traffic

17 any longer. People were carrying weapons, a lot of people.

18 I do not remember seeing any civilian except for those who were

19 in shelters. I remember I took a bottle of spirits to those

20 people because I knew those shelters. I used to play there as a

21 child.

22 Q. Did you remain in Kozarac?

23 A. Yes, I did, but that evening I said to myself, "I should leave,

24 I should flee this town", because I realised that evening in

25 case there is a conflict, I would stand no chance. I would have

26 no chance to flee. So that evening I stayed in a cafe of my

27 neighbour until midnight, with my neighbour Jakupovic, and then

28 I went back home and that evening I slept in my cafe on a

1 chair. I actually slept on the floor and I fell asleep. I do

2 not remember whether I was really sleeping or not. Anyhow, that

3 is how.

4 Morning came and I did not know what had happened, but

5 I heard that everything had been taken care of, and weapons that

6 had caused the incident had been returned. But you never know,

7 you never know whether something similar could happen once

8 again. It was in the air. It was difficult to understand that

9 such an incident over two rifles could bring about a war. But,

10 anyhow, that evening I realised that it was possible.

11 Q. Did you decide then to leave Kozarac?

12 A. Yes, that evening.

13 Q. When did you leave Kozarac?

14 A. That evening I knew I should leave as soon as possible. I did

15 not know when. The next morning when I saw that Relja Trivic's

16 family was packing -- sorry, Trivo Reljic, Reljic Trivo is the

17 man's name -- his family was packing and leaving Kozarac and I

18 asked whether I could go with them and he said, "OK".

19 I did not know what kind of situation was on the road

20 Prijedor/Banja Luka, but after that incident there was a big

21 question whether I could leave Kozarac at all. I spent the

22 whole night thinking how I should leave the town, whether on

23 foot. Then when I saw them packing, I thought that I could

24 perhaps go with them. I did not have a car at that time. I did

25 not have any friends in Kozarac who were not Muslims.

26 Q. Was it only you living in the Tadic family home at that time?

27 A. Yes, I was alone. Well, for a long period of time I had changed

28 the place I slept. When I came back to Kozarac it was -- it was

1 difficult. I slept in my brother's part of the house.

2 Sometimes I would sleep in our family house and sometimes

3 I slept in the garage. I kept changing that because I was

4 afraid. I was afraid that something might happen to me while

5 I am asleep.

6 Q. Who else was in Trivo Reljic's car when you decided to leave

7 Kozarac with him?

8 A. I agreed with him that we should meet in front of the house. It

9 was just opposite my house. He was with his wife and his two sons.

10 Before we left, I just took the register plates from my house.

11 I am afraid that a similar thing might happen when we tried to

12 leave Kozarac with the priest on 3rd May. That is why

13 I suggested to him that I should go on foot and I did not want

14 him to have the same problem.

15 So, I set on along the Marsala Tita Street. I went

16 that part of the road on foot because there were checkpoints

17 there, military checkpoints, of the army from Kozarac. But

18 I passed them and nobody told me anything. I waited for them on

19 the main Banja Luka/Prijedor road and they arrived in their car,

20 zastava 750, and they then took me in their car.

21 I know that before they arrived, an active policeman,

22 Zijad Basic, left in his car. It was also a zastava one, a

23 green zastava. He was living in Kozarac but he was working in

24 Prijedor.

25 Q. So what time was this then that you left your house and went

26 down Marsala Tita Street?

27 A. I remember next to my house, the part which has been shown here

28 several times, there is a restaurant and next to the restaurant

1 there are several shops and several shops are across the

2 street. I remember at that moment in the morning shops were

3 being opened, so it could have been half past 8, 9 o'clock.

4 I saw Mirka Kesic who was opening her shop and I also remember

5 seeing Nasiha -- I think her family name is Susic -- and she was

6 just opening a shoe shop. So it could have been around

7 8 o'clock in the morning.

8 Q. You referred to taking a register. What do you mean by that,

9 what is that?

10 A. Well, it is actually cashier from my cafe, and it was also a

11 book like a ledger where you would enter all records of

12 beverages and so. They have similar things in shops and it was

13 used in my cafe. All other things that I had were quite too

14 big, like a coffee machine or TV set, but it was all very heavy

15 to carry. I did have some games, but they were all heavy to

16 carry. So it was a very expensive thing and I remembered it so

17 I took it with me.

18 Q. When you moved from the house and you went down to the highway,

19 did Trivo Reljic pick you up in his car?

20 A. Yes, he did.

21 Q. Who else was in that car?

22 A. His wife, his two sons and he. I know we were crammed in the

23 car, but we left. I remember that before we left I had left my

24 jacket because I did not want to leave the impression with the

25 people who were on the road, the soldiers, that I was actually

26 leaving Kozarac. So I took off my jacket and I only had a

27 t-shirt on. It was a bright summer day. I was afraid that

28 something would happen, something that I had felt previously,

1 that I would be prevented from leaving.

2 Q. You referred to the checkpoint in Kozarac that you wanted to get

3 through. Was that between your house and the new Banja

4 Luka/Prijedor highway?

5 A. Yes. That checkpoint was in existence for a very long period of

6 time. It was next to the veterinarian station and it was on the

7 main road, not far from the Jela factory in Kozarac. But at

8 that time when I arrived it was moved closer to the centre of

9 Kozarac.

10 Q. Just so that we have this clear, was that before you actually

11 get on to the highway itself? So if you turned off the highway

12 and went into the main road in the direction of Marsala Tita

13 Street, was the checkpoint in that section of road off the main

14 highway?

15 A. I will try to describe it.

16 Q. If you could just identify it briefly?

17 A. Well, if you go along Marsala Tita Street in the direction of

18 the main road, Prijedor/Banja Luka, the only street after you

19 have passed my house that turns left in the direction of the

20 church, so from that turn some 100 metres on the left there was

21 a checkpoint with soldiers carrying weapons.

22 MR. KAY: Thank you very much. Your Honour, that is a convenient

23 moment.

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

25 (11.30 a.m.)

26 (The Court adjourned for a short time)

27 (11.50 a.m.)

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

1 MR. KAY: Thank you, your Honour.

2 Q. Mr. Tadic, can you remember to speak a little bit slower because

3 the interpreters, I must stress, have to listen exactly to what

4 you say and think in two languages and report it to us. So can

5 you remember that, to speak slower? Perhaps if I go like that

6 and move my hand, that is an indication to speak a little bit

7 slower. Thank you.

8 A. I will try.

9 Q. Where did the car of Trivo Reljic then pick you up after you had

10 left Kozarac?

11 A. Around 8 o'clock in the morning. As I said, around the period

12 of time when the stores were opening in Kozarac.

13 Q. I actually asked when.

14 A. On May 23rd 1992.

15 Q. The car that picked you up, which direction did it travel in?

16 A. We were moving out of Kozarac in the direction of Prijedor.

17 Q. Was that on the new highway or the old highway?

18 A. Yes, we were moving along the new highway Prijedor/Banja Luka.

19 Q. Were you stopped during the course of that journey?

20 A. We slowed down twice on the highway. The first time we thought

21 that we would be stopped on the same road near the village of

22 Koncari. That is where was that well-known Suljo Kusuran,

23 "Kole", and he had stopped a military vehicle there and was

24 controlling the documents. We used that moment and just sped up

25 past that.

26 The second time we slowed down at the checkpoint in

27 Orlovci. We did not quite come to stop, but we slowed down and

28 then we went on. I remember at the checkpoint Orlovci I saw

1 there was a lot of military, and I recognised somebody

2 I knew from before. There was Bogoljub Kovac. I think he had a

3 moustache, I remember.

4 Q. The first place that you told us about involving slowing down

5 where Kusuran, otherwise known as "Kole" was, how far from the

6 point where you enter the new road from Kozarac was that first

7 place?

8 A. As you go from Kozarac to the new highway?

9 Q. Yes.

10 A. Somewhere -- I think there is about six kilometres distance.

11 Q. When you went through ----

12 A. Six kilometres from Kozarac and about one kilometre, maybe two,

13 to Orlovci. I think it is the last village with the Serb

14 majority population, Koncari, as you move towards Kozarac from

15 Prijedor.

16 Q. Did you arrive in Prijedor?

17 A. Yes, that highway Prijedor/Banja Luka goes on to Bosanski Novi

18 and on the same road, a couple of kilometres, and Reljic Trivo

19 with his family stopped off so that I could get off.

20 Q. Where did you get off the car?

21 A. It was on the same road Prijedor/Bosanski Novi across from the

22 railroad station and next to a store, I think it was the

23 "Autoparts", the store that sells that, and I got off there,

24 and they went on to the village of Svodna.

25 Q. What time was that?

26 A. I do not know how much time elapsed, somewhere, 8.00, 8.30, in

27 Kozarac. It could have been 9.30. We were moving fairly slowly

28 because it was an old vehicle and I do not know how much Trivo

1 was using it, not much, some -- because of the fuel. I do not

2 know if you know how zastava 750 looks like. It is a very small

3 car and maybe it was 20 years old.

4 Q. Where did you go in Prijedor?

5 A. On that part of the road there is an unofficial railroad

6 crossing, so I crossed it and I went into the street. I think

7 the name of the street was Preradovica, I am not sure, but

8 I went straight to Jelena Gajic who is my wife's sister.

9 Q. Was she at home or at her place of work that you saw her?

10 A. No, she was at home, both she and the children, also the mother

11 of her husband was there and there were some neighbours. So

12 there were a lot of people there.

13 Q. Did you stay there long?

14 A. Well, I stayed quite a while. I had a coffee. I had something

15 to eat. I did not have time in Kozarac, so I was a bit hungry.

16 Q. What had happened to the cash register?

17 A. The cash register was small but pretty heavy, so I could not

18 carry it, so it went with Trivo. I went in August of '93, so

19 Trivo was keeping it in this village, Svodno, so later he gave

20 it back to me.

21 Q. You said that you stayed at Jelena Gajic's place for quite a

22 while. Did there come a time when you left her place where she

23 lived?

24 A. They told me that there was a train to Banja Luka leaving around

25 12.00, so I went there. I told them about the circumstances of

26 my leaving Kozarac. I managed to escape and that I was going to

27 my family in Banja Luka.

28 Q. Did you go down to the railway station and catch that train at

1 Prijedor station?

2 A. Yes, the train was already there and it was fairly full. There

3 were people that I knew from before. They were people from

4 Kozarac, from Prijedor. It was packed to capacity. Everybody

5 was wondering if it was going to get going at all. Then around

6 12.00 we heard shells, so we were wondering whether it was going

7 to get going. You could sense those shells flying over the

8 city.

9 The train started after 12.00, and we were all

10 apprehensive, all the way through to Banja Luka, whether it

11 would stop somewhere, it would arrive there, but we all made it

12 to Banja Luka. I remember along the road it was a strange

13 feeling. The tracks were going past the Serb and Muslim

14 villages, but at the end when we got to Banja Luka we had a

15 complete picture of what was going on behind us and it is

16 something that stays in memory.

17 As we were passing, for instance, through Trnopolje,

18 I saw around crowds, people who were alongside the tracks with

19 machine guns, with guns, and then you saw that they had the

20 insignia of the Muslim army, of the Bosnian Army, and the same

21 picture, the same script was in Serb villages, people lying

22 around facing each other and facing the tracks, so that you

23 could see the relationships that were going on at the time. In

24 Ivanjska, that is where the Croats make a majority, they had

25 different insignia, so everybody was armed. So on the train

26 I saw different nationalities.

27 So I think that most people around me felt like me.

28 It did not matter which army would stop you, Serb or Muslim or

1 Croat, and unload us. The train travelled very slowly.

2 Finally, we got there. We stopped and alighted once, and we

3 were thinking, we would wondering. There was a fear among

4 people. The people were not talking much.

5 Q. At what time did the train arrive in Banja Luka?

6 A. Somewhere around 2.00 o'clock in the afternoon.

7 Q. On its way had it stopped at other stations between Prijedor and

8 Banja Luka?

9 A. Yes, the train would stop regularly, but once there were stop

10 lights and it stopped but it would -- there were stations,

11 Petrov Gaj, Trnopolje, Omarska, Ivanjska and Banja Luka.

12 I think those are all the stations where the train stopped.

13 Q. When you arrived in Banja Luka where did you go?

14 A. I only remember that at the exit I greeted Esad Tadzic who is a

15 school friend of my brother. He used to be the President of the

16 municipality in Prijedor. So he was with his wife. We greeted

17 each other. We knew each other well. The families knew each

18 other from before. We just shook hands. We said nothing that

19 is interesting. There was silence, some apprehension and a very

20 strange feeling. He grew up in Kozarac and lived in Prijedor,

21 and I was born and grew up in Kozarac and we both ended up in

22 Banja Luka. I assumed also that he had fled.

23 Q. So where did you go in Banja Luka?

24 A. I went on foot to Starcevica settlement. I came to my brother

25 and told him that I was alive, that I had just arrived from

26 Prijedor and then I went to my family which lived in Koste

27 Jarica Street.

28 Q. What time did you arrive at the place where you were staying in

1 Koste Jarica Street?

2 A. That was in the late afternoon.

3 Q. Having arrived there, did you stay there or did you go anywhere

4 else?

5 A. I stayed there very briefly. I had a strange feeling and I

6 thought that I had to go somewhere. There were several reasons

7 for it. First, I wanted to take a bath. I wanted to eat.

8 I wanted to relax and it was not possible in that house. It had

9 almost nothing there. The food supplies and the money that my

10 wife and my mother had was all spent during their period in

11 Banja Luka. So the relationships were breaking down between

12 Bosnia and Herzegovina and Yugoslavia, and my mother was getting

13 the pension from Belgrade and it stopped and so she had nothing

14 left. They were without money. They had nothing. I had the

15 daily intake from the cafe and that was it.

16 So I suggested, I remembered my friend,[redacted], and we

17 went there. I wanted to have a good meal and I knew that they

18 were rich and I wanted to take a bath, so we went there.

19 Q. You say that you wanted to go there. How far away from the

20 place where you were in Koste Jarica was the place where [redacted]

21 lived?

22 A. It was quite a while, quite a distance, five or six kilometres,

23 the other side of town. It is a family house. It is on a

24 transit road of a completely different part of town.

25 Q. Did you go there with the rest of your family?

26 A. Yes, the whole family came along and we went on foot.

27 Q. So that would be your mother Staka, the two children and your

28 wife Mira?

1 A. Mother Staka, Mira and two children, yes.

2 Q. What time did you get to the [redacted] house?

3 A. It took a while and we carried the younger daughter between us.

4 She was three years then and my mother was not well. She had

5 gangrene on her toe. So it was almost dusk when we arrived. It

6 was already the evening.

7 Q. Who was at the [redacted] house?

8 A. [redacted]

9 [redacted] In other words,

10 the family was there. Only he was living in one part of the

11 house and in another one his brother with wife and mother lived

12 in the other side. He only lived with his wife and daughter.

13 Q. So how long did you stay in this house?

14 A. I was not sure whether I was going to spend the night there.

15 I was not thinking about it. I was not sure that he was going

16 to keep me there. I did not know what was going to happen in

17 the meantime, but [redacted] remained as he was before. So we spent

18 the night and we left only the next evening, towards the

19 evening.

20 Q. Was the house that they were living in a change from the place

21 that you and your family were staying in in Koste Jarica Street?

22 A. It was an exceptional house, very well appointed. The family

23 [redacted] did not have money in the bank, but all the money that

24 they were making, both he and his father, was invested into the

25 house. [Redacted]

26 [Redacted] So, they were quite well

27 off. [Redacted]

28 [Redacted]

1 Q. The next day is 24th May 1992. At what time did you leave that

2 house?

3 A. Sometime in the afternoon, late afternoon.

4 Q. Where did you go?

5 A. We went to our house where we were living in Koste Jarica

6 Street. That was our reality, so we went back there.

7 Q. The rest of that day, where did you spend that?

8 A. I spent with my family thinking about what to do next.

9 I tried -- I wanted my family to spend as little time there as

10 possible because the conditions were terrible. So we were

11 sitting in front of the house. There was always stench so you

12 could never clean out that inside. There were some old things.

13 I remember that for days and days we cleaned, and you just could

14 not clean it out. So we were sitting in front of the house.

15 Then I installed the antennae so that we had some conditions for

16 living.

17 We were planning what to do next and I said, "We will

18 visit with friends, we will eat there, we will sleep here". We

19 will try to find a job for my wife. That was the short term

20 plan that we had. Other things we did not think about at the

21 time.

22 Q. 24th May was the day that Kozarac was attacked. During the next

23 five days did you go into Kozarac? Did you return to Kozarac at

24 all?

25 A. During the conflict in the Kozarac area, I did not go. The

26 first information I heard on radio and television. I remember

27 well that after about four or five days TV Banja Luka showed

28 what was going on precisely in or around Kozarac. I remember

1 Kotlovaca -- that is on Mount Kozara -- and they were showing --

2 that was where people went. They said that they -- the

3 extremists burnt down a mountain lodge. Those were the first

4 information -- that was the first information I saw on

5 television. So, in a way I was following the news, mostly

6 through television. They had their own view of events and I had

7 left that town a few days ago, but the television had its own

8 version of the truth.

9 I remember well that they said that there was an

10 agreement of sorts between the Crisis Staff and the Local

11 Commune of Kozarac, that there was an agreement -- that there

12 was an agreement between the two authorities that the buses

13 would be sent to Kozarac by the authorities in Prijedor to take

14 out civilians and that this was all part of the agreement

15 between the Crisis Staff and the Local Commune authorities.

16 Q. When did you first return to Kozarac, having left it on

17 23rd May?

18 A. I think it was 1st June 1992.

19 Q. I want to ask you about that period between those two dates of

20 23rd May and 1st June. How did you spend your time?

21 A. I spent my time with the family. For the most part, we cleaned

22 the house. You just could not clean it out. That was one

23 thing. On the other hand, in agreement with Jovo Samardzija, who

24 was getting his pension in Banja Luka, I wanted to see that my

25 mother was also receiving it there. She was registered in

26 Prijedor municipality, so because she suddenly left the

27 municipality she was cut off.

28 So I went to the veterans' organisation. I had to

1 open a bank account, and then had it forwarded to Belgrade.

2 I registered my family with the Red Cross in Banja Luka. Then

3 they were surprised how come there was a refugee from the

4 Prijedor municipality. After an interview with the

5 administrative worker at the Red Cross there, he said, "Yes,

6 I will put you in with the refugees from Livno because so far

7 nobody has reported from the Prijedor region. You are the first

8 one". So we finally got a status.

9 So that is the business that I finished until

10 1st June. Then we were visiting our friends. We visited with

11 Nikola Petrovic, a long time friend. I have known him since the

12 secondary school. He was going out with my wife's friend who

13 was also a nurse. So we knew each other through those

14 contacts. Also, he was an athlete, so we also met while we were

15 training together. So we went there. We had lunch with him.

16 After that we visited my uncle, Risto Vokic.

17 I visited him primarily because we said that we were trying to

18 find a job for my wife as a nurse in a hospital. He had some

19 influence in Banja Luka. He said that he would see. We were

20 all at his place and I remember he returned us in his car

21 to Starcevica. He was at the time driving a zastava 101 model.

22 So then we were dealing with trying to fix the house

23 and visit with old friends, and pretty much on a daily basis

24 I would go, if I went to my brother's, who had a business in the

25 same settlement, Starcevica, in Milosa Duica Street, and then we

26 would also often go to Jovo Samardzija. He was a long time

27 friend of my father's and we would go there to have coffee and

28 that kind of thing.

1 Almost every night I was spending in my brother's

2 company. At that time they were securing that area, that one

3 part of that street and then another part, and I remember that

4 on one occasion they did a silly thing. They put some tree

5 trunks there and some policeman ran into it with his car, and so

6 they were criticised. They were civilian defence.

7 Q. You referred there to a brother, which brother is that?

8 A. I mean Ljubomir.

9 Q. 1st June then is the first day that you returned to Kozarac.

10 Did you go with anyone or were you by yourself?

11 A. From the moment when myself and my brother heard that the war

12 operation in Kozarac area had stopped and you could find that

13 out through the radio and newspapers, they said that the

14 conflict was over, that the extremists had surrendered. In

15 other words, they made it known that there was peace in the

16 area, and my brother insisted that we go there. He had a store

17 there and he had had a delivery of goods right before the war

18 and that cost a lot of money. I was not eager. I was, kind of,

19 disappointed but he always insisted day after day.

20 Q. Would that be your brother Ljubomir again?

21 A. Yes, at that time, for the most part, I spent time with him. He

22 was living about a kilometre away and he was spending the time

23 in that street, Milosa Duica, where I lived. He had his

24 business there because he was living at his mother-in-law's and

25 that was really an emergency residence, and he was spending time

26 at his wife's place where she was with her children.

27 Q. How did you travel to Kozarac then on 1st June?

28 A. We took a train.

1 Q. What time did you leave?

2 A. We went in the morning. I cannot recall, but they were running

3 often, frequently, around 5.00 and 6.00, and I think that that

4 was the only means of transportation that was used at the time.

5 Q. Which station did you go to?

6 A. We first arrived in Omarska, the town of Omarska. Then we did

7 not know what circumstances are, what the conditions are, in the

8 area. We asked people and there were a lot of people wearing

9 arms in the area. Mostly, people were talking about the events,

10 that it was the war had started. Then we were asking around,

11 what was the way to Kozarac? I did not know too many people in

12 Omarska because there was never much communication between

13 Omarska and Kozarac.

14 Q. What was the reason for going to Omarska railway station?

15 A. There was no other way. The train stopped in Omarska and there

16 was no other way to get to Kozarac. That was the only way. My

17 brother had a car, but it was very risky to use it. It was a

18 Ford which he had bought in Germany and there was always

19 something amiss with it.

20 Q. We have heard that the railway station for Kozarac town is, in

21 fact, at Trnopolje? Was there any reason why you did not go on

22 the train to Trnopolje?

23 A. Yes, it was not possible to go from Trnopolje to Kozarac. You

24 would have had to walk for six kilometres. That was the only

25 reason. In other words, it was much farther.

26 Q. Going to Omarska then, what time did you get off the train?

27 A. Somewhere maybe around noon we got to Omarska. Then we asked

28 around what the conditions were, how we could get to the centre

1 of Kozarac? Then some people pointed us in some kind of a

2 headquarters, and we asked whether we could go to the place

3 where we lived. They said it was not their authority; it was a

4 regional Crisis Staff in Omarska. They called it headquarters

5 or staff. It was really a one room where a uniformed officer

6 was sitting and he said that the Kozarac was -- that in the

7 Lamovita Crisis Staff is where we should find out about

8 Kozarac.

9 So we went there on foot and there, at least, I knew

10 someone. I remember a waiter, Nenad Rakic, and I asked him, "Is

11 there war in Kozarac?" He said, "No, no, it is all over, there

12 are almost no people left". I was surprised, "How come?" He

13 said, "Well, they were all evacuated".

14 Then my brother and I went to the village, Timarci or

15 Babici, I do not know what the official name is. That is where

16 my waiter lived, Milenko Timarac.

17 Q. You said that this would have come under the Lamovita Crisis

18 Staff. Where was that situated?

19 A. It was in a Local Commune there. Previously -- I think it was

20 the first time that I saw -- I visited a Local Commune there.

21 It was like a youth centre there and they said, "This is where

22 the regional Crisis Staff is which has authority over Kozarac.

23 It is all -- Kozarac is part of that". I do not know. It was

24 exclusively a military formation. I remember that there was a

25 municipal Crisis Staff and then some people explained that now

26 they had the absolute authority there.

27 Q. Did you see Milenko Timarac?

28 A. Yes, we went to Timarac, to his house. We asked him, we said

1 that we wanted to visit the house. He knew that I had a cafe,

2 but he used to work there as a waiter but not the last six

3 months. He agreed, and he said, "But you need a permit. You

4 have to get a certificate for fuel", and then we agreed that

5 I would look for that. So we went back to Lamovita. I went to

6 the Local Commune because my brother was not officially

7 registered there. I had a personal ID. I told them that

8 I lived in Kozarac, and I told them that I am going to request

9 them to go to Kozarac to visit my family house.

10 Q. When you went to Lamovita and first of all saw Milenko Timarac,

11 about what time was this?

12 A. Well, it was all around -- between 12.00 and 1.00 p.m.

13 Q. When you went to the local Crisis Staff at Lamovita, what time

14 would that have been?

15 A. Well, right after that we did that relatively fast. The village

16 of Timarac is very close to Lamovita. It was all very quickly

17 maybe. We left around 2 o'clock for Kozarac, not later than

18 that.

19 Q. What vehicle did Milenko Timarac have?

20 A. Milenko had a zastava 101, white in colour. It was in a bad

21 state of repair, but it served the purpose.

22 Q. Is that a saloon car?

23 A. No, it is a luxury car. I know that he used to live in Sisak,

24 in Croatia, before the war, so he never changed his plates. It

25 was always on his car.

26 Q. In that car were you able to travel into Kozarac?

27 A. Yes, first we got the permit, I mean the certificate for the

28 fuel. It was recorded somewhere and I know that the Secretary

1 of the Local Commune, Drago Milencic issued me that. I met

2 other people there and they told me that the Commander of the

3 Crisis Staff there was Vinko Kos and he issued approval for me

4 to get the fuel. So we went to the petrol station in Lamovita.

5 We got the fuel and we went to Kozarac. We took the old

6 Prijedor/Banja Luka road.

7 Q. When you entered Kozarac were you able to pass into it without

8 difficulty or were you stopped on the way?

9 A. There was a spot where they had some kind of control, unofficial

10 control. It was in the direction of Kozarac when you leave

11 Lamovita, but we stopped somewhere along the road and two more

12 passengers joined us, Boza and Mirko Grahovac whom we knew from

13 Kozarac. They were coming from the village of Lukici. They

14 were also going to Kozarac on foot. So we gave them a lift and

15 we arrived in Kozarac together.

16 Q. You said that you were stopped at a point. Who was running that

17 point? Who controlled that point?

18 A. Well, honestly, I do not know. It was a person in uniform, half

19 uniform, half civilian clothes. He had an M48 rifle and there

20 were some other villagers standing with him. They were not

21 really organised and there was an obstacle on the road, a tree

22 trunk. That is why I am saying it was an unofficial

23 checkpoint. They did not know what they really wanted when they

24 stopped us. They did not ask us anything. They just asked us

25 where we were going. I told them that we were going to Kozarac

26 and they said, "OK, you can go to Kozarac".

27 Q. Did you visit the family home on this occasion of 1st June?

28 A. Yes, I did. Before I visited the house on the road next to the

1 church where there used to be a checkpoint Grahovac and his wife

2 got out, and they went to their family house and we went to the

3 centre of the town to our family house.

4 Q. At what time did you get to the Tadic family house?

5 A. Well, it could have been about 3.00 o'clock, 3.00 p.m. I know

6 that we had been, that we were travelling for about one hour,

7 hour and a half. We just drove through Kozarac, the three of

8 us. We went to -- I remember we went in the direction of the

9 fire station. Then we went back when we saw what was happening

10 there, what had happened there, that a lot of it had been

11 destroyed. So we went back to the factory, Jela factory,

12 and that is where I saw an acquaintance of mine. It all lasted

13 very short because when we went back Kozarac was in a pitiful

14 shape. It was not so much destroyed, but there was a stench in

15 the air. There was no electricity at that time. So later on in

16 my house I saw in my freezer that all the food that I had had

17 been spoiled, there was some cattle around. It was difficult to

18 explain such a feeling, but you could feel something in the air,

19 you could feel that something was unhealthy in the air. We did

20 not see many soldiers. I saw several people, that was all. All

21 along the road I just saw that unofficial control near Lamovita

22 and later I did not see anyone when we were going there or when

23 we were coming back.

24 Q. For how long did you stay in the area of Kozarac on this visit?

25 A. Well, one hour, an hour and a half. We wanted to do something

26 useful. My brother wanted to do something about his business

27 premises. He wanted to protect something. I tried to shut down

28 the area because everything was laying open and things were

1 scattered around. So I first established the situation. So

2 during that first visit to our family house we realised that the

3 house had not been really destroyed but the front part of the

4 house where there were business premises of my brother, there

5 was a huge opening, a huge hole of maybe a shell. The part of

6 the house where I had been sleeping for several months, that is

7 the part of the house that belongs to my brother Mladen, there

8 was a hole in the roof which had been made by a shell, and a

9 shell had fallen in front of the house and damaged the terrace.

10 So it was quite a pitiful shape. My cafe was damaged.

11 Everything was more or less damaged. It was a rather

12 sophisticated kind of interior in the cafe. So when windows

13 were smashed and doors were smashed, everything was just laying

14 open. The town itself was ghostly.

15 Q. Had anything been removed from either your house or your cafe

16 premises or Ljubo's business premises so far as you could tell

17 on this visit?

18 A. Not at that time. Well, I did not check details. I did not

19 really think about that. I just saw that most of the valuable

20 equipment in my cafe was OK. So that the coffee machine was

21 damaged, but it was still usable. The TV set was still there

22 because I had two TV sets, one in my house where I was living

23 and the other in the cafe, in my business premises. I had two

24 games machines. Most of it was OK. The property had been

25 damaged, but it was still usable.

26 Q. Did you take anything with you from the house when you left it

27 after this visit?

28 A. I took only, as far as I can recall, my stereo chain, the one

1 I was using in my cafe. It is very expensive equipment.

2 I spent DM4,500 on that. So I thought I should take that.

3 I put it in Milenko's car although he protested, but I could not

4 take anything else except for that. It did not take up too much

5 space.

6 Q. A stereo chain, what is that?

7 A. Well, that is it, that is a musical equipment stereo system

8 without musical boxes, without loud speakers, they were too big

9 to carry. I remember I left that with Milenko Timarac in his

10 house and that equipment stayed in his house for quite a while.

11 I do not remember when I took it to my family house.

12 Q. When did you arrive at Milenko Timarac's house? What time was

13 that?

14 A. Late in the afternoon, very late. I do not recall what time it

15 was, but I know we did not stay too long in Kozarac. There was

16 an incident in the street with my brother and it was quite

17 unsafe. We were there as civilians. Milenko warned us, he told

18 us that we should not stay there too long. Then it was not

19 difficult when you were wearing civilian clothes, if people see

20 you wearing civilian clothes. There was a chaos in the street

21 at that time. There were very old men in uniforms, men aged 75

22 and young men as young as 18. The situation was rather awkward

23 and as a civilian it was not wise to walk around the street.

24 My brother had a kind of incident at that time, and the

25 person warned us. He told us it was still an area under

26 military operations. I forgot to say that in addition to the

27 cash register, I took my hunting rifle and my other rifle from

28 the house, after the warning of this officer who told us it was

1 quite risky to move around. Before that incident we did not

2 have any weapons with us.

3 Q. You referred then to the cash register. As I understood your

4 evidence, you told us that the cash register was taken when you

5 left Kozarac on 23rd May?

6 A. Yes.

7 Q. The weapons that you have referred to, did you take them on the

8 23rd May or the visit on 1st June?

9 A. On 1st June. On 23rd May I did not have any weapons with me.

10 Even the handgun that I had for which I had a permit was not

11 there. I had left it with my wife in Banja Luka because during

12 her stay in Banja Luka the place was attacked two times. A

13 window was smashed and they wanted to rob the house. So once

14 after I had left the gun with my wife, she was keeping the gun

15 although she could not really handle it, she was not strong

16 enough. So I left it with her.

17 Q. I would like to ask you now about weapons. What weapons did you

18 own at this time?

19 A. Well, after 1985 I filed a request, an application, and I was

20 allowed and consequently I bought a gun, a 765, zastava make,

21 and I kept it at home mostly. Except for that weapon, my brother

22 who had spent the last four months of 1991, my brother Mladen,

23 he stayed in Kozarac quite a few times. He had some problems

24 with his wife in Munich. So he tried to come back and live in

25 Kozarac. That was his idea. He was in the process of building

26 his business premises, so he would spend a long time in Kozarac

27 with his daughter. Because he was a hunter he brought a hunting

28 rifle and that hunting rifle was always in the house. He was

1 the owner of the hunting rifle. At the end of 1991 I got an

2 automatic rifle from a deserter whose name was Mile Kusota.

3 Q. The hunting rifle that you referred to then which belonged to

4 Mladen, did you take that from the house on 1st June?

5 A. Yes, I did take it with me, but it was useless. It used to be a

6 very expensive rifle. He had bought it in Munich. It cost him

7 between DM6,000 and DM7,000. It had some decoration on it as

8 far as I can remember. So I took it, although I could not

9 really use it. You could take it apart, so it was quite safe.

10 Children could not use it. Even adults who did not know how to

11 use it could not really use if they did not have the mechanism

12 which I kept always apart. It was not in my house, but when my

13 brothers were not in Kozarac I was using their parts of the

14 house and I was keeping an eye on it. So his rifle was always

15 there in his part of the house. So I took apart that mechanism,

16 firing mechanism, from the rest of the rifle and I could not

17 find that mechanism. It had disappeared. Someone had taken it

18 away. I think that it was gold plated, that mechanism.

19 Q. The automatic rifle you told us about that you had got at the

20 end of 1991, did you take that away on 1st June?

21 A. Yes, I did.

22 Q. Did you take both of those weapons to Lamovita with you?

23 A. Well, first we went to Milenko's house where I left the hunting

24 rifle because it could not be used anyway, and I took the

25 automatic rifle with me to Banja Luka.

26 Q. What time then did you leave Lamovita to continue your journey

27 to Banja Luka?

28 A. Well, we did not go to Lamovita. I do not know whether

1 I mentioned that. Milenko, from his house there are two roads.

2 The village of Timaraci is between the road, the main Banja

3 Luka/Prijedor road and the old Prijedor/Banja Luka road,

4 somewhere in the vicinity of the village of Jakupovici. So

5 there are several roads that you can take if you want to go to

6 the main Prijedor/Banja Luka road from that village. So he took

7 us along a village road, a village street, which joins the main

8 road somewhere after Kamicani. So he took us there and he took

9 us in his car to the junction Lamovita/Omarska road and

10 Prijedor/Banja Luka road. There is a junction there and there

11 is a petrol station there on the right-hand side, and that is

12 where we waited for about 15 minutes. So after we arrived in

13 the village of Timaraci we did not go back to Lamovita. That

14 is what we did when we were coming to Kozarac.

15 Q. So where did you go having finished your business in Timaraci?

16 A. We hitchhiked a vehicle and went to Banja Luka. I believe it

17 was a lorry. I know that Milenko Timarac waited with us until

18 we left because he was not sure that we would be able to leave.

19 At that time there was no bus service functioning and he said,

20 "I will wait with you if you manage to leave OK. If you do not

21 you can come back to my place and stay overnight", but we left.

22 It could have been around 5.00 or 6.00 p.m. We had been waiting

23 for a long time.

24 Q. At what time did you arrive in Banja Luka?

25 A. In the evening.

26 Q. Did you return to the place where you were staying in Koste

27 Jarica Street?

28 A. Yes.

1 Q. Having visited Kozarac on this occasion, when did you next

2 return to Kozarac?

3 A. I just have to mention that when we came back to Banja Luka,

4 I know that my brother told me at that time that we should have

5 a uniform, and we were wondering because it was difficult to

6 move around without a uniform. So he gave me a uniform because

7 it was quite difficult to move around the town itself, let alone

8 leave Banja Luka. So I stayed there for a while, very briefly,

9 and then I left for our family house where we were living at

10 that time in Koste Jarica Street and I stayed there.

11 Q. When did you next return to Kozarac?

12 A. I think it was after the visit to Trnopolje and before my

13 mobilization in the reserve police force. I cannot recall the

14 exact date. I could guess, but I know when I visited Trnopolje

15 and I know when I was mobilized. I know that this visit took

16 place in between, roughly between the 8th, 9th or 10th June

17 1992.

18 Q. Let us deal first of all then with the visit to Trnopolje. When

19 did take place?

20 A. The visit took place on Saturday, 6th June 1992.

21 Q. Why did you go there?

22 A. After the conflict ended and after my brother and I visited our

23 family house in Kozarac, Jozo Samardzija kept insisting, asking

24 that someone should go with him to Trnopolje because he had met

25 some people from Kozarac in Banja Luka and he had heard that

26 many people from Kozarac were in Trnopolje and that his sister

27 was among them. She used to live in the village of Kamicani

28 before. So he kept asking us every day. At the beginning

1 I kept refusing and my brother refused too. So my brother said

2 that I should do it. He was an old man and he needed, he

3 insisted that we helped him. That is why I accepted. Although

4 I visited him several times and I told him, "OK, I am ready" or

5 "I can go now", and then he said he would not feel very well.

6 So that is how we met, at least four or five times before we

7 went, and it was all after the military operations, after the

8 conflict was over. So we postponed the visit several times.

9 Then that weekend I told him", "Well, if you do not want to go

10 today I am not going to go", so he accepted.

11 Q. On the day that you went was it just the two of you?

12 A. Yes, just the two of us. That morning I talked to my brother

13 and I told him that I had accepted to go. I told Jovo that he

14 should get ready. Then I went home, took my weapon, my uniform

15 and came to get Jovo who was waiting for me in the street and

16 that is how we went.

17 Q. So what time did you leave then to go to Trnopolje?

18 A. Before noon.

19 Q. How did you travel from Banja Luka to Trnopolje?

20 A. First we went on foot from Starcevica to the railway station.

21 It is very far from Starcevica, five or six kilometres, and

22 since he is an old man he walked very slowly and with

23 difficulty. Then we went to the railway station, Banja Luka,

24 and we took a train to Trnopolje. I think we arrived in

25 Trnopolje around 1.00 p.m.

26 Q. When you arrived at Trnopolje did you realise at that time where

27 the collection centre or camp was located in the village?

28 A. No.

1 Q. When you arrived at the railway station where did you go?

2 A. We went to the centre of Trnopolje where the Local Commune

3 should have been or what used to be the centre of the village.

4 It is the road Trnopolje/Kozarac or vice versa, the main road.

5 We got there and the usual thing is to ask in a cafe. So we

6 went to a cafe in the centre of the town. I do not know whether

7 it was Hilmo's cafe. Anyway, we asked and we realised that

8 there were some people there from the Red Cross and some

9 soldiers as well. So we talked to them and they wanted to see

10 our identification cards which we showed to them. We told them

11 who we were, where we had come from and Jovo explained whom he

12 was looking for. They said there were no problems, that he can

13 go and look for that person. So we stayed there for about an

14 hour, maybe an hour and a half, not more than that. We just

15 stayed there for an hour. For most of the time we were just

16 waiting for the train at the railway station and we were coming

17 back.

18 Q. How were you dressed on this visit?

19 A. I was wearing civilian clothes underneath, jeans and a t-shirt,

20 and the uniform that my brother had given to me is like an

21 overall, it is a kind of uniform, but the one that you wear on

22 top of another uniform. The colour is that of a camouflage

23 type. I know it was yellow in colour and spotted yellow and

24 brown. It was a very thin uniform that you can easily put on

25 your normal clothes.

26 Q. Did you take any weapon with you?

27 A. Yes, I had the automatic rifle with me.

28 Q. Did you go up to the site of the former school in Trnopolje and

1 where the cinema was, the hall, and visit the place of the

2 collection centre?

3 A. Well, at that moment I did not know what the collection centre

4 was, and I did not know about the division that I have heard

5 about here. Jovo and I met people whom we knew from before.

6 Many people, many neighbours knew me. They did not know Jovo

7 but I talked to them. We greeted each other, kissed each

8 other. I remember seeing Ferid Gujnic in the street, Osman

9 Turkanovic. We kissed each other. They were curious to know

10 what was going on. I asked them what had happened because I was

11 surprised to find them there. They had been living in the

12 centre of Kozarac and all of a sudden they were there. I had

13 heard on the news in Banja Luka that people were being

14 transported and all of sudden I saw my neighbours in Trnopolje.

15 Then I asked them, "Well, what will you do?" They asked me what

16 was going to happen, and I just could not give them any answer.

17 People gathered around me. They wanted to know what would

18 happen and I told them I did not know. Anyhow, I knew there was

19 a war going on. That is what I told Ferid. I remember seeing

20 my neighbour Refko, a barber. All of a sudden I was called by

21 Zujic Mujo who was a paramedic who used to work in the hospital

22 before the war with my wife. So he called my name. He was

23 standing there at the spot where a surgery was and that is where

24 I also saw Jusuf Pasic, a doctor. They were wearing white

25 doctors' uniforms. I also saw my former waiter Goga who was

26 wearing a white coat. I had a coffee with them. They prepared

27 something. Mujo wanted absolutely that we should have a cup of

28 coffee. So we had a cup of coffee and Mujo asked me -- I knew

1 that he had been born in Banja Luka and that he was living in

2 Banja Luka for a long period of time. He was only married in

3 Kozarac. When he heard that I was in Banja Luka and that I was going

4 back on the same day, he said that he would give me his

5 brother's address and he wanted me to tell his brother where he

6 was. So he wrote his brother's name and his address on a piece

7 of paper, his address in Banja Luka, and I promised that I would

8 pay him a visit and that I would tell him where he was.

9 I remember I had a long conversation with Osman

10 Turkanovic there, because his sister used to work as a nurse

11 with my wife before the war. So I asked him how he was. He

12 said that he would be leaving soon and things like that. It all

13 happened very quickly. Jovo was with me all the time. He was

14 walking around asking people where his sister was. Then he said

15 that he heard that his sister had left. Then I asked, "But what

16 happened to those people? Where did they leave to Zenica?"

17 They said they left in convoys to Zenica. That was one of the

18 first convoys used for transportation of people. Those people

19 were supposed to go to Banja Luka, but apparently, and such was

20 the information, the police in Banja Luka would not allow them

21 to get off the train in Banja Luka. So the train went on in the

22 direction of Zenica.

23 At that moment Jovo did not exactly know what had

24 happened with his sister. So the first information we received

25 was several days after when we were in Banja Luka. Rekko's

26 wife, Sabiha Fazlic, told him about what happened, she is from

27 Kozarac. She said that she was in Banja Luka on the same train

28 with his sister. She said that the train had slowed down and

1 people were supposed to get off, but the police were shooting

2 and they did not allow the train to stop. So she jumped off the

3 train, but his sister could not jump because she was an old

4 woman. So that is how she ended up in Zenica. Jovo later on

5 enquired about her with the Red Cross, and then later on he

6 managed somehow to get in touch with her.

7 Q. So what time did you actually leave Trnopolje from the railway

8 station?

9 A. Not later than 3.00 p.m. We stayed there for about an hour

10 talking to those people standing in the street mainly, and when

11 we realised there was no point in waiting we left. I remember

12 that I caught some -- I found some cigarettes and gave them to

13 those people. I remember giving some cigarettes to an old

14 friend of mine Kulasic Sahib. I am not a smoker, but we asked

15 some other people for cigarettes and we gave them to those other

16 people. I told them that I could not find cigarettes for them.

17 I remember we talked to a lady. There is a house next to the

18 railway station and Jovo was talking to that woman. He was

19 asking about his sister. So he spent sometime, a long time, I

20 do not know how long, maybe half an hour, an hour. We were

21 sitting there in front of the railway station waiting for the

22 train. I believe we were the only passengers at that moment

23 from Trnopolje.

24 Q. At what time did you arrive back in Banja Luka?

25 A. Around 4.00 o'clock, 5.00 p.m. I cannot tell you the exact

26 time, but it was in the afternoon.

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

28 THE PRESIDING JUDGE: We will stand in recess until 2.30.

1 (1.00 p.m.)

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1 (2.30 p.m.)

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

3 MR. KAY: Thank you, your Honour.

4 Q. I would like to ask you now about the second visit to Kozarac in

5 this period when you were living in Banja Luka. First of all,

6 why did you make another visit to Kozarac during this period?

7 A. Well, the first time we saw that our family house was filled

8 with precious things that we wanted to evacuate from there.

9 There were large quantities of drinks that my brother Ljubomir

10 brought to his discount, and at first there were still things in

11 my house that I wanted to rescue, plus in my residence I had my

12 clothing. Everything I had remained there. That was the only

13 reason for us to go back to Kozarac again. There was no other

14 reason.

15 Q. How long after the visit to Trnopolje that you have told us

16 about was it?

17 A. I thought about it a long time, and I am really sure now that it

18 happened, I think, that we were in Trnopolje on Saturday,

19 Sunday. Together with my brother we visited Mujo Zujic's

20 brother in Mala Carsija. I told him where his brother was in

21 Trnopolje, and then the next day, the following day, we went to

22 Kozarac. So it could have been Monday, 8th or 9th June 1992.

23 Q. On this occasion did you visit Kozarac on your own or were you

24 with anyone?

25 A. No, I always moved around with my brother. I was not mobilized

26 then, and it was not good to move around without papers. My

27 brother was known around Banja Luka. So, in any event, had

28 I been arrested, it would not have been that dangerous because

1 at that time during my stay in Banja Luka it was dangerous to

2 move about the city. There were some groups in all key

3 locations. If you passed across the bridge of the River Vrbas,

4 the bus would be stopped. There would be controls. People were

5 off loaded or people would go in and there was general chaos in

6 the city. Both in the city and wherever else I went, I went

7 with my brother, never by myself.

8 Q. What time did you leave Banja Luka on this occasion of the

9 second visit?

10 A. I think it was in the afternoon, as far as I can recall. We

11 also took the train to Omarska, to the railway station in

12 Omarska. Then we took the same road and went to the village of

13 Babici or Timarci.

14 Q. Who did you see in that village at Timarci or Babici?

15 A. We first went on foot to the junction of the road

16 Lamovita/Omarska and Banja Luka, that was the main road, and I

17 remember a van passed -- it was not a van, it was a military

18 jeep type of vehicle -- and they gave us a lift to the vicinity

19 of that village.

20 We arrived there in the afternoon into Timarci.

21 I found Milenko Timarac. I know it was pretty late. He said

22 that we should stay with him, so we agreed and we stayed. We

23 stayed in his house. There was his father, mother and brother

24 and wife.

25 Q. So did you stay overnight with him?

26 A. Yes, yes. We stayed the whole night. I remember they had night

27 watchers at the entrance of their house. They were telling

28 stories about that they did not take part in the attack of

1 Kozarac, that they were defending their village, that one of the

2 people in the village was killed. There was a shell that fell

3 in the vicinity and he died of a heart attack. He was --

4 Milenko's father also knew my father well and he respected him

5 before the war, before this war.

6 Q. The next day then, which would have been a Tuesday, where did

7 you go?

8 A. We did not go to Kozarac right away. We thought that everything

9 was as usual, as before. We met a few people and they said,

10 "Don't worry, nothing will be touched in your house". When we

11 were first in the house we saw some signs, "This is Serbian",

12 because a lot of people who were taking part in this knew about

13 the house, so there were signs "Don't touch", and such.

14 We ourselves thought that everything would be all

15 right, that nobody touched anything there. So, at first we did

16 not go to that house right away. We were looking for a truck.

17 That is, Milenko took us to Omarska and we found a truck there.

18 We made a deal with a private truck driver. I know that it was

19 a private truck businessman. He had a truck business before the

20 war. So we did not go right away, maybe an hour or two we

21 stayed, and then when we arrived we realised that the house was

22 not in the condition we left it in at the time of the first

23 visit.

24 Q. If I can just stop you here and get some timings? Do you know

25 when it was that you left Babici or Timarci?

26 A. In the morning.

27 Q. Do you know what time in the morning?

28 A. Early in the morning, I do not exactly recall. I never wore a

1 watch on me, so .....

2 Q. How did you get from Timarci down to Omarska?

3 A. In Pile's car.

4 Q. Is "Pile" another name for Milenko Timarac?

5 A. Yes, it is Milenko Timarac also known as "Pile", and he was

6 known as "Pile" because he had a chicken farm before the war in

7 Croatia broke out. "Pile" means "chicken" in English.

8 Q. When you went to Omarska where exactly did you go?

9 A. We went to the marketplace, that is, the livestock market which

10 is in the central part of town. Milenko knew some truckers and

11 he brought over a man and he said, "Why don't you make a deal?"

12 I know that my brother paid for this because I did not have the

13 money, and I remember that it was 50 deutschemarks.

14 Q. Do you know the name of the trucker that you spoke to?

15 A. I do not remember. I saw him for the first time then.

16 Q. So you did not know him before?

17 A. No, I did not. I did not know people in Omarska. I had no

18 business there. That is why we asked Pile to come with us.

19 Q. When you made the arrangement with the trucker, what time was it

20 that you left Omarska?

21 A. It is hard for me to say, but I think around noon.

22 Q. Leaving Omarska with the trucker, was that you and your brother

23 Ljubomir?

24 A. Myself, my brother Ljubomir and this trucker, and we went to

25 Kozarac.

26 Q. At what time did you arrive in Kozarac?

27 A. Around 1 o'clock in the afternoon.

28 Q. When you arrived on this occasion in Kozarac, did you go

1 straightaway to the family home in Marsala Tita Street?

2 A. Yes.

3 Q. When you arrived at the family home, was it in the same

4 condition as it had been the few days before when you went

5 there?

6 A. I know that when we were going from Omarska to Kozarac we were

7 taking the highway, the main road. After Kamicani, we took the

8 old road. So, we passed by the church and came to the centre of

9 Kozarac. So, it was not in the same condition. It was very

10 different -- not only my house; I saw that many things changed.

11 Along the road we saw smoke rising from houses. They were

12 burning -- I had not seen that before -- and the house was

13 pillaged. Many things were missing from there. What I saw in

14 my cafe, and I mostly wanted to come to Kozarac for the cafe,

15 because all the things of value were there, they were new things

16 -- it had only be opened for about a year -- there was almost

17 nothing evident. Whatever could have been -- could be taken

18 away was taken away.

19 The interior was made in such a way that you could

20 dismantle things. My brother and myself dismantled the ceiling

21 part and then there were some marble parts that we could take

22 down. My brother thought that he would find his crates of beer

23 still full, but he found nothing. Mostly, it was his crates and

24 that ceiling. I found a few -- some glassware and there were no

25 alcoholic drinks at all left, even though I had large supplies

26 before the war. I had hard liquor and I had others.

27 Q. How long did you stay at the family home on this occasion?

28 A. Maybe two hours at the most, so we were in a hurry. We did not

1 stay long.

2 Q. Did you load up the truck with any property from the house?

3 A. Yes, my brother as far as his valuables were concerned, he was

4 only able to load up those empty crates that were -- it was a

5 mid-sized truck, and my effects were taking up the smallest

6 part. It was all -- it was mostly the ceiling construction and

7 some parts of the bar. That was mostly it. I also found some,

8 not so much clothing, but some bedding, some linens, in the

9 house which I had not managed to take out before. So there was

10 not much that we could take with us which was of value, which

11 was worth taking. Had I known what the condition the house

12 would be in, I never would have gone there to begin with.

13 Q. What time did you leave Kozarac on this occasion?

14 A. Sometime in the afternoon.

15 Q. During that period whilst you were there, did anything happen

16 that sticks out in your memory?

17 A. No. Kozarac was -- the centre of Kozarac had not changed that

18 much. The truth is I was not looking around much. When I went

19 upstairs in my house the other roofs seemed intact. For the

20 most part, it seemed intact, Kozarac was not destroyed. It

21 mostly looked bad because it was abandoned, so it looked -- we

22 could see children's clothing hanging on clothes lines around

23 the houses. We saw livestock as they wander about. It was just

24 a bad impression, but I could see few soldiers. Sometimes

25 somebody would pass by, but they would be people that I saw

26 for the first then.

27 Q. Were there any civilians in Kozarac at this time whom you knew?

28 A. Yes, there was the family Coprka, Stoja and Drago, because they

1 are exactly at the corner of the Orthodox church, and Mirko

2 Grahovac and his wife. I saw no other inhabitants, even though

3 at the centre of Kozarac Muslims and Croats and Serbs all lived

4 there, but now it was abandoned.

5 Q. Did you take all those goods that you had got from the family

6 home back to Banja Luka?

7 A. Yes.

8 Q. Was that on the same truck that you had hired in Omarska?

9 A. Yes.

10 Q. At what time did you arrive back in Banja Luka?

11 A. Well, it was already dusk when we got there.

12 Q. During this period were you mobilized?

13 A. No, I was not mobilized.

14 Q. During this period had you taken part in any of the cleansing

15 activities, as they are called, in that area of Kozarac?

16 A. No, I never saw anybody there. When I got to Kozarac, during

17 the first visit or second visit, there was nobody there. I did

18 not know what was going on around there, but in the centre of

19 Kozarac I saw no one except for these two families that

20 I mentioned. The first time Grahovac came with us and the

21 second time there were only those two families that lived in

22 Kozarac. I do not know if anybody else lived there.

23 Q. When, in fact, were you mobilized?

24 A. I was mobilized exactly on -- I reported on 15th July 1992, and

25 the mobilization was June 16, 1992.

26 Q. Just looking at what I have seen on transcript here, it says you

27 were "mobilized exactly on -- I reported on 15th July and the

28 mobilization was on June 16, 1992". When did you report for

1 your mobilization?

2 A. I reported on 15th June to the office -- not July, June -- and

3 then I was mobilized on 16th June. That was my first day on

4 duty. It was Monday when I reported. In fact, at first I was

5 not paying attention. I was not sure whether 15th was the day

6 of mobilization or 16th because the procedure was such that

7 I was not fully aware of it. Afterwards, when I looked at my

8 military booklet, my first day of duty was June 16.

9 Q. How did it come about that you were mobilized on this date?

10 A. I saw first that there would be problems with mobilization when

11 I reported my family to the Banja Luka Red Cross. I also wanted

12 to report myself as a refugee, but that -- I could not do that.

13 There were already some laws passed that I was not aware of.

14 I had never been in the reserves. I had never been

15 part of any military exercise. So I did not know the procedure,

16 how things were done. But in the Red Cross they told me, "No,

17 there is no way, you cannot report. First, you have to report

18 to the military office and then they will determine your

19 status". That is when I reported my family there. Then they

20 said, "You first have to report to the military", and that was

21 in Prijedor. I had to report there.

22 Besides, during that period of time in Banja Luka,

23 I met Vokic Radovan, my cousin. I asked him -- I met him twice

24 and once in the city, in town, and on the street -- and I asked

25 him, "Can I get mobilized? Can I when I want so that I do not

26 go to the military?" He said, "You have to join something,

27 whether the military or somewhere, or else you will be

28 arrested", and that is what was going on.

1 There were instances when people were arrested,

2 especially if people had certain mobilization locations in their

3 military booklets, because in May and June they had -- they

4 would call up people, that there were mobilizations. So,

5 everybody who had their location had to report. So, I did not

6 have that. In 10 years I was doing private business. I was

7 moving around often, and that was for the military office. That

8 was inconvenient because they could not follow my movements,

9 plus I did not know the full procedure in order to be at the

10 military's disposal.

11 Q. So to which body were you eventually mobilized?

12 A. I was mobilized in the reserve police force. As I said, I met

13 Radovan Vokic and I asked him if he could help me. He was an

14 active policeman and I found out that I had to report to the

15 military office either in Prijedor or in Banja Luka. I did not

16 want to go back to Prijedor. I thought that I would settle my

17 affairs in Banja Luka, that I would find a job for my wife.

18 At that time you could leave a certain residence only

19 with permission of the military. Vokic promised that he would

20 do something, that he would talk to the police Commander.

21 I know that my brother put in a word for me. Vokic and myself

22 were not very close, but we were family and he said that I

23 should come, and I went.

24 Q. Which brother was this?

25 A. It is always Ljubomir when I talk about Banja Luka. I had an

26 older brother, Stojan. He was also never mobilized. He was

27 hiding all the time, and up-to-date he has not been mobilized

28 for some -- in some way he was able to avoid this. Precisely

1 because of that I know that this older brother was arrested in

2 Banja Luka, so Ljubomir had to go and get him out. It was also

3 a rule that if one of the brothers was on the frontline, then

4 the others did not have to go. So the authorities had some kind

5 of understanding in those matters.

6 Q. The period you are talking about when you met Radovan Vokic and

7 there was discussion about your mobilization, how long before

8 16th June did that occur? Can you give us an idea of the time?

9 Can you also speak slowly as I know that the interpreters are

10 having difficulty keeping pace?

11 A. The second meeting in Banja Luka took place after our arrival

12 and the evacuation of our things from Kozarac and the

13 mobilization itself. The next time I met Vokic was in my

14 uncle's apartment, Risto Vokic's apartment, and he promised once

15 again he would do anything so that I would be accepted in the

16 reserve force of the traffic police. So I was trying to be

17 mobilized in a unit which had nothing to do with the war

18 whatsoever which would not take part in the war operations.

19 I knew from before that traffic police did not take any part in

20 war operation, nor was it planned.

21 Q. When you talk about the traffic police, in which town would that

22 traffic police be based?

23 A. My obligation, as I told you, I had to be mobilized in the

24 Prijedor municipality. That was the only possibility, either

25 the military or the police. There was not a third possibility.

26 So, when I speak about the police, I speak about the Prijedor

27 police.

28 Q. So did there come a time when you travelled to Prijedor to take

1 up your mobilization with the reserve traffic police?

2 A. Yes, I went to Prijedor on Monday. I was met there by Vokic in

3 front of the police building. He took me to the centre of the

4 Prijedor police, and I remember that on that day I first met

5 Duro Prpos, and before that I met with Dusan Jankovic who was

6 the chief of the police at that time.

7 So we first had to talk to him. He had to give his

8 permission. He asked me why I had not taken part in the war,

9 where I had been at that time. He was rather angry with me and

10 Vokic said, "Well, let it go, there will be enough time for

11 that". So he tried to explain to me that I had been in a very

12 difficult situation, and I know that Jankovic accepted my

13 mobilization quite reluctantly, and I know that on that occasion

14 I also met Stevo Lazic who also worked with the Prijedor

15 police.

16 After that conversation with Jankovic, though, he gave

17 his approval for my being mobilized in the police and I insisted

18 to be mobilized in the traffic police. Then Vokic introduced me

19 to Djuro Prpos and Djuro Prpos said, OK, he needed people and

20 that is how I was accepted in the reserve force of the traffic

21 police.

22 Q. On Monday, 15th June, at what time did you leave Banja Luka?

23 A. Early in the morning.

24 Q. How did you travel from Banja Luka to Prijedor?

25 A. By train.

26 Q. Can you recollect at what time you arrived in Prijedor?

27 A. I left very early, I think it was before 6 o'clock in the

28 morning. So I arrived in Prijedor before 7.00. I remember that

1 the opening hours of the office was around 7 o'clock.

2 Q. When was your first day of duty in the reserve traffic police?

3 A. The first time I was on duty on 16th June 1992 in Orlovci on the

4 Prijedor/Banja Luka road.

5 Q. At that stage your family was still in Banja Luka, is that

6 right?

7 A. Yes, they were still in Banja Luka, but before my departure for

8 Prijedor, before my mobilizations, we knew, we were aware, that

9 we could not have any status in Banja Luka. My wife received an

10 answer that she could not find a job in Banja Luka and that she

11 had to report in Prijedor for a job. So if you were not either

12 mobilized in the police or the military, you could not have any

13 status at all. You could not have any rights whatsoever. So

14 each employee had to bring a kind of certificate that his or her

15 spouse was either mobilized either in the police or in the

16 military. Mobilization was the criteria for all the rights and

17 the status.

18 Q. When you travelled to Prijedor on Monday, 15th June, was that

19 you on your own or were your family with you?

20 A. I travelled alone to Prijedor.

21 Q. At that stage did you have any accommodation or any place to

22 stay in Prijedor?

23 A. No, I did not have anything, I did not know. At first I did not

24 know whether I would be mobilized in the traffic police or

25 regular police or somewhere else. I was not quite sure, and

26 I did not even know whether I would be mobilized in the unit

27 which suited me. So, the situation was quite uncertain for me.

28 I did not know what would happen. So that evening when

1 I arrived on 15th, I know that I spent the night at Radovan

2 Vokic's place. He left his address. He said that he would be

3 there for a certain period of time. So, because I did not have

4 any address, so they asked me for something. So I spent the

5 night in his flat in the Pecani neighbourhood.

6 Q. Was that the only night that you spent at his flat or did you

7 spend other nights there?

8 A. That was the only night I spent at his place. I did visit him

9 several times later on, but that was the time when I spent a

10 night at his place. Vokic was absent very often. He was always

11 away on business, travelling, whether in Banja Luka or

12 elsewhere, so that is why I did not want to stay there overnight

13 and my wife was alone at home, so I did not quite like -- I did

14 not feel like being there alone. That is why I would sleep when

15 I had to stay overnight with Martin and Mileva Dzaja at their

16 place. It is an old couple, and it was much easier for me to

17 stay overnight at their place.

18 Q. Did there come a time when accommodation was given to you in

19 Prijedor?

20 A. Yes.

21 Q. Can you recollect when that was?

22 A. Well, between 20th or on 21st or 22nd June 1992 I visited

23 Prijedor town hall and there was a clerk there and I asked him

24 for accommodation. I said I was working for the Prijedor

25 police. It was a kind of condition, a requirement, for

26 accommodation. So I showed him my booklet which testified that

27 I had been mobilized, and I discussed with people from the

28 Crisis Staff. He referred me -- he sent me to the Pecani

1 neighbourhood and he told me that there is a commission in

2 charge there. He said that I would find an apartment there. He

3 did not give me an exact address, but he said that those people

4 in that commission were in charge of making lists of apartments

5 available so that I should see with them. That is what I did.

6 I went to Pecani and I was looking for those people for

7 sometime. I did not know exactly where they were, but then

8 I found out and I found them at Pecani No. 2, building No. 2,

9 B2.

10 Q. Were you eventually given a flat by the commission?

11 A. Yes, when I got into that flat there were three members of the

12 commission sitting there and they were making, kind of, a list

13 of the inventory that they had found in the flat. I told them

14 I had a paper, a certificate, from the municipality which said

15 that I had no accommodation and that I should be helped. I told

16 them what the problem was. They said, OK, they just had to

17 register all the property that was there. At that time the flat

18 was already half empty, but whatever there was I had to sign for

19 it. There was a kind of a report.

20 Q. Were you given that flat on a temporary or a permanent basis?

21 A. Well, I was never really given that flat. They told me I should

22 call back and they told me to sign the paper and I signed it.

23 So, the first decision, written decision, that I received was at

24 the beginning of 1993. I realised at that time that the flat

25 was not on my name. What it says was only "Hasan Tulundzic" and

26 January was the first month that I had to pay the rent for. So

27 I had to pay the rent on his behalf as well as the utilities,

28 and that is what I did. Nothing was really on my name, so at

1 that moment I realised that the flat was not on my name and I

2 was not familiar with the regular procedure, and I did not know

3 how it should have been done.

4 I did not think about whether I should make an

5 official request to have the apartment officially allocated to

6 me. So, that was never really done, but they knew I was living

7 there by the very fact that I later on received an order to move

8 out and the address was there in that order.

9 Q. Did your family eventually move into that flat and did you all

10 start living there in Pecani, in Prijedor?

11 A. Yes. I first brought my wife from Banja Luka to Prijedor and

12 she spent two days cleaning up the apartment. She packed some

13 things. I do not know how, but she managed to get in touch with

14 the cousin of the owner of the flat, with the previous owner of

15 the flat. I think she contacted her by telephone. So they made

16 an agreement that she should pack certain things and send them

17 to her.

18 So I remember that my wife just spent those two days

19 packing things. She was looking for some clothes and things

20 like that. So she had finished in those two days and I remember

21 I helped her. So the last day we were packing things,

22 I remember I found a vehicle and we loaded all the things in

23 that vehicle and took those things to that woman who lived near

24 the hospital in Prijedor. I know they were looking for some

25 other things as well. There was a table that she wanted, some

26 flower pots, palm trees, very big, but she said that she had no

27 place for that so she said that it can remain. It could remain

28 in the apartment.

1 Q. So what was the date, it you can remember it, or how long after

2 you started your mobilization was it that you moved into the

3 flat in Prijedor?

4 A. I moved in on 27th June 1992. My wife had come earlier and I

5 had already had a key as of 20th, but we moved in after we had

6 tidied up the place. So we arrived very early by train from

7 Banja Luka, my wife, my children and my mother. I met them at

8 the railway station in the morning and we went to the apartment

9 in Pecani and we were living there as of that date.

10 Q. Martin Dzaja whom you mentioned, how often did you stay at his

11 place until you moved into the flat?

12 A. I spent three or four nights at his place. The first time it

13 was with my wife, I think it was -- I believe on 17th June. It

14 was the second day of my duty. I spent that night at Dzaja

15 Martin's place with my wife. I had gone to pick up my wife and

16 I brought her there. When I arrived, I learned that in the

17 hospital in Prijedor they had issued some kind of declarations

18 at that time. You had all kind of strange laws at that time.

19 Everything was in relation with the mobilization and things like

20 that.

21 So, because my wife had worked in Kozarac before,

22 I learned that it was a kind of declaration whereby by 20th June

23 all those who wanted to work should report to their workplace,

24 and that is why I went to fetch her and I brought her to

25 Prijedor, otherwise she would have lost the job for ever.

26 Q. You told us that you were given the key on 20th June. Were you

27 staying at the flat before your family came to live there on

28 27th?

1 A. No, I was not. I slept at Martin and Mileva's place for a

2 couple of nights. I do not remember exactly how many. The

3 first time, as I told you, was with my wife when she came to

4 Prijedor. We went there together. After that, I spent several

5 nights at their place on my own. I know that Martin was always

6 there, and his wife would go to sleep to her neighbour, a Muslim

7 woman, who was afraid to be alone, whose husband had died some

8 time before, and that was the reason why he was alone also. So

9 it was OK with him.

10 He was always a bit afraid of weapons, and I would

11 leave my weapon when I was not on duty at his place. He was a

12 little bit afraid because he was a Croat and he was afraid that

13 he might be arrested if anyone should find that weapon at his

14 place. But, anyhow, there were no problems.

15 Q. You told us that Martin Dzaja was a Croat. Was he an old family

16 friend of the Tadic family?

17 A. We had known each other for a very long time. We knew each

18 other through my wife's sister. He was the uncle of the sister of

19 my wife. Anyhow, they were related.

20 Q. Is he an old man? Do you know what age he is?

21 A. Yes, yes, he is an old man. Well, maybe he is 70, 70 years of

22 age, maybe more. He is very sick and he looks much older. He

23 was retired very early. He had worked in a factory, in a food

24 factory, and I had known him for very long and we were on very

25 good terms all the time.

26 Q. When your family moved to Prijedor, did you continue to work

27 within the reserve traffic police at the checkpoint at Orlovci?

28 A. I never stopped working. I was working from 16th June and I had

1 regular duties and I always went to work and I was never absent

2 from work. It was like a job because it was paid and I think

3 the traffic police was the only force that was, whose members

4 were being paid. That was one of the main -- that was the main

5 reason why I worked there. It was our only source of money at

6 that time because my wife could not get a job right away,

7 although she reported on time.

8 So I managed to register my mother in Banja Luka with

9 the war veterans' association because we thought we would stay

10 there, but then we moved to Prijedor. So again I had to repeat

11 the whole procedure and my brother helped me. So we had to

12 cancel residence in Banja Luka and report again in Prijedor. So

13 throughout that period she never received any pension. She did

14 not receive pension until September. So that was our main

15 source of income.

16 Q. When did your wife eventually get a job in Prijedor?

17 A. She got a job actually twice. At the beginning of August

18 I think she was offered a job, but she refused to work. I went

19 to the hospital to have some talks with people there, because

20 she was given a job in a psychiatric asylum which was very

21 difficult and it did not suit her and she did not want to work

22 with mental patients. So some weeks passed in the meantime, and

23 then I went again and I asked people again and she was

24 eventually accepted in the Prijedor -- to work in the Prijedor

25 hospital. I know the manager was Ljuban Jankovic.

26 Q. When you were doing your duties at Orlovci for the reserve

27 traffic police, did you work as part of a unit of three

28 policemen?

1 A. Yes.

2 Q. What were the names of the other policemen who were in your

3 unit?

4 A. Duty -- the shift Commander, Commander of my shift, was Miroslav

5 Brdar and my colleague was Miroslav Cvijic. So the three of us

6 worked together on the same shift.

7 Q. Did you know either of those men before you started working with

8 them on 16th June?

9 A. No, I did not know them before.

10 Q. We have looked in this courtroom at duty lists showing the times

11 that you were working at the Orlovci checkpoint as well as the

12 dates. Did you miss any days of work that you should have

13 undertaken at the checkpoint?

14 A. No, never. I was never absent. We all paid much attention to

15 that because, first of all, we did not want and never occurred

16 to us to make a simple mistake in our work because it was very

17 easy for us to be removed from such a post. We all cared, we

18 all cared a lot, about working in the traffic police.

19 So, if people were absent, it means that they were

20 again -- they could be easily mobilized because at that time

21 there were a lot of war operations going on in the area of

22 Gradacac. So people who worked for the traffic police were

23 lucky that they were working there because they knew that they

24 would not be sent to the frontline.

25 Q. We have heard that the Commander of the reserve traffic police

26 was Djuro Prpos. As a Commander who controlled the reserve

27 traffic police, what sort of discipline did he have with those

28 policemen who worked under him?

1 A. He was very strict. I was not accustomed to such kind of

2 discipline, military discipline, because I had never been in the

3 reserve, because I did not know what it meant. Even when I was

4 doing my regular military service, I did not have any special,

5 any particular obligations, any particular training in relation

6 with discipline. So I was not quite familiar with the way

7 things functioned there.

8 But Djuro Prpos was a professional, first of all. We

9 were all reserve policemen and he was the only professional

10 there. So he knew what he wanted. He was very strict, yes.

11 I did not know him before, so I did not have any idea of what

12 kind of a man he was. He himself was very disciplined, very

13 strict. We did not have any private talks. We would run into

14 each other in the town and greet each other, but there was a

15 certain distance between us. I never had a chance to have a

16 drink with him or a coffee. During that time I simply never had

17 an opportunity for that.

18 He was keeping a distance with us. He was strict,

19 very strict. We accepted that because we knew that it was

20 better for us that way. He behaved towards us as an active

21 policeman. We had a similar treatment. We were receiving a

22 salary which was quite adequate, given the circumstances. You

23 could live on that.

24 Q. We heard from a lady called Radoslavka Lukic that she lived near

25 the checkpoint at Orlovci, and your brother Ljubomir pointed the

26 lane near the tree that took you to her house. Did you have any

27 contact with her whilst you were working at Orlovci?

28 A. Yes, I did. I had known her from before, from the elementary

1 school, and when I arrived in Orlovci I did not know who her

2 husband was and I did not know where she lived, but when I

3 arrived there I saw that she was travelling from Prijedor to

4 Orlovci, and she told me that she lived in Orlovci. I knew her

5 very well, but I did not know that she was actually living in

6 Orlovci. So that is how we became closer.

7 She very often needed us, not only she, there were

8 residents of Orlovac who had to travel to Prijedor. There was a

9 woman there who had to travel almost every day to the market.

10 She took her dairy products to the market. There was a nurse

11 living in Donji Orlovci and who was also travelling every day to

12 Prijedor. So we met each other every day at the Orlovci

13 checkpoint. It was when she was either going to work or coming

14 back from work. We would often -- we had to stop their vehicles

15 because we had to stop every single vehicle passing through the

16 Orlovci checkpoint. So we always stopped them.

17 Sometimes there would be 20 vehicles in a column

18 because we had to check them. When it comes to military

19 vehicles, there was military police who were working next to us

20 and they had the same type of duty with the military vehicles.

21 So, I knew the residents very well. Sometimes they would bring

22 us coffee to the checkpoint. They were grateful to us because

23 the only means of transport was actually hitchhiking or

24 bicycles. But at that time there was no buses, and all vehicles

25 available were being used for transport of soldiers to Gradacac

26 or elsewhere and those vehicles were quite damaged because of

27 the transport of military units.

28 Q. She told us that on occasions you would often stop a vehicle and

1 arrange that the driver who had been stopped would have to take

2 her as a passenger. Did you do that for her as well as other

3 people?

4 A. Yes, it was common for all people who lived there, not only for

5 those who lived there, but there were people, for example,

6 travelling to Banja Luka who had arrived to Orlovci from

7 Prijedor and they were waiting for transport to Banja Luka, and

8 that is how it worked. It was a very busy road for private

9 transport, private cars, and for transport of goods because it

10 was the main communication between the Krajina, the Knin

11 Krajina, and Serbia. So it was a quite busy road. So, Slavica,

12 yes, I saw her almost every day. I think that was the person

13 whom I saw most frequently in Orlovci.

14 Q. At this time, as you have told us, you were living in Prijedor.

15 How did you used to travel to your duty point at Orlovci from

16 the centre of Prijedor?

17 A. Well, I would have to leave half an hour before the beginning of

18 my shift. So I would go to the police station in the centre of

19 the Prijedor town. We would report there for duty. The shift

20 changed in front of the building of the Prijedor police. Brdar

21 was in charge of some kind of procedure for the changing of

22 shifts. So I did not meddle into that, but I know that he was

23 receiving some orders, whether from the Commander or his deputy,

24 but anyhow he always had some kind of instructions as to what we

25 should do, how we should behave.

26 There was this vehicle, police vehicle, which would

27 take all three of us there. Brdar was shift Commander, and that

28 is how we went to work. That was the regular procedure and

1 nothing unusual happened. It was quite organised. We had

2 patrol orders, warrants. So each time we finished our shift,

3 the number of kilometres would be entered in that book. So we

4 were not allowed to drive more kilometres than normally

5 necessary. He would have been responsible for that. He was

6 responsible for the vehicle, fuels and so on. We had to be very

7 careful with fuel at that time.

8 Q. You said it was a police vehicle; was that a civilian vehicle

9 used by the police or was it marked as a police vehicle?

10 A. It was a police vehicle. It was a blue Golf with a radio

11 station built in. That is how we maintain communication. That

12 was the main means of transportation. In principle, we could

13 not use the vehicle if there was some incident in Orlovci

14 without clearing it with the centre; we could not do anything.

15 So Brdar kept communications through this radio station and that

16 is where he got instructions for his work. The vehicle was

17 always parked at the very checkpoint facing the side of the road

18 towards Banja Luka.

19 Q. Travelling in the vehicle from the SUP in Prijedor to take you

20 to the checkpoint, what would then happen to the vehicle once

21 you had arrived at Orlovci?

22 A. The vehicle was parked, the door open and a window wound down so

23 that we could hear any communication via the radio station so

24 that we could keep the communication open. Then we would go

25 about doing the job that we were in charge of from before. We

26 knew what our duties were. It was the control of civilian, both

27 passenger and freight, traffic around Karlovac. So, our duties

28 were exclusively with the civilian control. We had -- we were

1 not authorised to control military vehicles or people in

2 vehicles who had been mobilized to the military.

3 Sometimes we would stop a civilian vehicle, and if the

4 driver would show a military booklet, we could not control him.

5 We were not allowed to. Then we would call over the military

6 police and then they would do the control of those vehicles and

7 those passengers. We were working exclusively the control, the

8 transportation of goods and passengers in the civilian sector.

9 The military police, it is true, had higher authorities. They

10 could control both the civilian and the military traffic on that

11 road, Orlovci/Prijedor. We had no right to control the

12 military.

13 Q. The military unit that you have referred to at Orlovci, was that

14 at the same number of officers as you? Was that three soldiers

15 or was it a different number?

16 A. No, mostly it was two soldiers, two military policemen. They

17 wore military police uniforms.

18 Q. So did the police car remain at Orlovci with you whilst you were

19 on duty at that checkpoint?

20 A. No, they did not have a vehicle. Their shifts were different

21 than ours. I do not remember exactly where their shifts were

22 changed but, for the most part, they were transported by some

23 vehicles. I think they had trucks, maybe a Pitzgauer. I do not

24 know where they had their duties, but they had strange shifts

25 and they had nothing to do with us.

26 Q. I am actually talking about the police car, did that remain at

27 Orlovci with you whilst you were on duty?

28 A. The translation, it was a military vehicle.

1 Q. Hence the different answer, but I will repeat the question

2 again. Did the police car remain at Orlovci with you?

3 A. Yes, yes.

4 Q. At the end of your shift did you return in the police car back

5 to the police station in Prijedor?

6 A. No, the vehicle -- after our duties, we would go back to in

7 front of the police station and the shift was changing in front

8 of the police station. We would show up early. We would

9 leave -- that means the shift that was to take over, they would

10 arrive early in front of the police station. So it could not

11 happen that we would arrive there and not be met by somebody.

12 The shift would then be done very fast. In the meantime, the

13 military police would be on duty because they had authority to

14 control both the civilian and military traffic. So, our absence

15 was not really felt very much during that period of time.

16 Q. So did you go back in the police car to the police station in

17 Prijedor?

18 A. Yes, it was always done that way.

19 Q. Was there any right or was it part of your duties that you could

20 leave Orlovci during your shift and travel somewhere else in the

21 police car?

22 A. No, there was not a chance of that taking place. This is what

23 we were told right away by the Commander and then Brdar also,

24 the chief of the shift, so that we could not do anything like

25 that. Brdar was a very serious man perhaps because his wife's

26 father had been a traffic policeman for 30 years, and maybe

27 through living with them he gained knowledge about how things

28 were happening. So, I do not know, but things were not

1 happening that way.

2 Q. You told us that you arrived for your shift half an hour early

3 to the police station to report. At the end of the shift how

4 long did it take before you were officially at the end of your

5 duty?

6 A. Excuse me, can you repeat that question?

7 Q. At the end of your shift, when you had returned to the police

8 station, was there a period of time that you had to wait at the

9 police station as part of a handover before you were officially

10 discharged?

11 A. Brdar would do the change of duty. When we were -- when we

12 would come back in the vehicle in front of the police station,

13 the police, the next shift would go immediately off to their

14 duty. Brdar would always stay and do the paperwork. I know

15 that he filed reports and that he communicated in that respect

16 with the police. It was not my duty to stay around. Sometimes

17 we worked 12 hours, sometimes all night. I was just looking to

18 go back home as soon as possible.

19 Q. When you were off duty from the police station, were you able to

20 go free wherever you liked? Were you able to spend your free

21 time away from the police out of the area travelling around or

22 going wherever you wanted?

23 A. You could not travel that easily. Every movement -- for every

24 move, you had to report to the authorities. If you had

25 something sudden, you had to call up, you had to report to the

26 policeman on duty and tell them where you would be because our

27 duty was to be present at the address where we lived. So that

28 in case of unexpected, anything unexpected, we would be there at

1 a moment's notice. I am not saying you could not leave, but you

2 had to ask the authorities. If you wanted, for instance, to go

3 somewhere the next day, you always had to get some kind of a

4 certificate, some kind of a paper.

5 Q. Perhaps at this stage if we could look at Exhibit 332A and B?

6 If 332 in the English form can be put on the overhead monitor

7 and the defendant have the version in Serbo-Croat? You have

8 there, Mr. Tadic, a version in Serbo-Croat which we can see is a

9 document signed by Simo Drljaca. It is a document issued by

10 Prijedor SUP and saying that Dusko Tadic is authorised to travel

11 between Prijedor, Kozarac and back, Palanciste, for the purpose

12 of transporting firewood and items from the house. It is a

13 document that is dated but it is unclear, according to the

14 translation, when in June 1992 this date refers to. Are you

15 able to help us with this?

16 A. I now remember, regardless of what it says here. It was on the

17 first day when I came to Prijedor. Since I had proved that

18 I lived in Kozarac, Marsala Tita Street, No. 36, I requested

19 from the Chief of Police, I asked for a document so that I can

20 go and evacuate certain items from my house. That was on the

21 first day upon my arrival in Prijedor on the Monday, the day

22 before I started my duty. That was the practice then. This is

23 what you needed to get if you were to leave Prijedor on any

24 basis. They always said, why, the purpose of it.

25 Q. So the date you are referring to would be 15th June 1992?

26 A. Yes. Yes, absolutely certain.

27 Q. Was this certificate to be used on that date or could it be used

28 on another date?

1 A. This certificate was used on that date.

2 Q. So did you go to Kozarac on that date of 15th June from Prijedor

3 to collect firewood and items from the house?

4 A. Yes.

5 Q. What would have been the purpose of going on that particular

6 date, the day before your official first duty date, to Kozarac

7 to collect items from the house?

8 A. The purpose was that I knew that I would be busy later, so

9 I wanted to use the opportunity. I evacuated, kept evacuating

10 things from my house throughout that year. I did not have an

11 opportunity to have special vehicles. As I said, my brother

12 paid for that one and even on that day I asked the man, I never

13 paid him, and on this occasion I evacuated, removed, some of my

14 belongings to Palanciste with my aunt Sava Vokic.

15 Q. We heard evidence earlier in the trial from Sava Vokic. Did she

16 live in that district of Palanciste?

17 A. Yes. She lives in Velika Palanciste in a large house by

18 herself.

19 Q. What goods did you collect from the Tadic family home then on

20 that date when you went to her house?

21 A. Where it says that the permission is for items from the house,

22 plus firewood, but again I did not know what I would find

23 there. I learned from my previous experience that I did not

24 know what was going to be there. On that day, I took some

25 garden chairs from my cafe, so that is what we were using in the

26 summer. Then some clothing because, in principle, it was very

27 difficult to move the clothing. So there were some children's

28 clothing and then I made bundles with white sheets. So that

1 was, basically, what I took. It was not that much.

2 Q. How were the goods transported on that day?

3 A. By truck.

4 Q. Whose truck did you use?

5 A. It was Savanovic Slobodan's who used to live in Kozarac earlier,

6 but I do not know at what period he moved to Prijedor with his

7 wife, and I did not engage him specially. I just ran into him

8 and I told him that I was going to Kozarac and he said, "Oh,

9 yes, that would work for me too". I did not know that he was a

10 professional trucker, but I used the opportunity to put some of

11 my belongings there. I could not afford a special delivery. So

12 when he was loading things from where he was working before the

13 war, I also added some of my own. He worked in a building

14 across where the same apartment block where Trivo Reljic worked,

15 and his wife worked in a pharmacy in Kozarac, so they worked

16 above it in the Marsala Tita Street.

17 Q. In this period that you were working at checkpoint Orlovci, was

18 there another occasion when you went back to Kozarac to collect

19 items or goods from the family home?

20 A. Yes.

21 Q. Can you tell us when that would have been?

22 A. That was the beginning of July, I think.

23 Q. On that occasion did you have a certificate such as the one we

24 see there?

25 A. Yes, yes, but that time I actually engaged this man because

26 I met him while working at the Orlovci checkpoint, Brane

27 Koncar. I think he was a private trucker and he was from the

28 village of Kalanj near Orlovci. I asked him, and we went to

1 Kozarac together. We moved some goods to my relative Jankovic,

2 very near Orlovci. I do not know what the name of the village

3 is, I think Vlacine or something, maybe one kilometre from where

4 we held the post at Orlovci.

5 Jankovic, Dragoje, he is my distant relative. Our

6 mothers are sisters. So he accepted to take some stuff. It was

7 mostly some building supplies that in '92 I was preparing to

8 finish the top part of my business premises, and it was an

9 amount of construction supplies with which I was going to finish

10 the attic part. Then I also brought the freezer unit and the

11 stove, a wood stove, and I remember at that time I also brought

12 a terrier dog. Then he kept it throughout that time. Then I do

13 not know what happened. That was the mother of those two

14 terrier puppies, the hunting dogs.

15 Q. Is that the Dragoje Jankovic we heard evidence from a few weeks

16 ago?

17 A. Yes, yes.

18 Q. When you left those goods at his place, how long did they remain

19 there for?

20 A. Those goods stayed there all the way up to '93.

21 Q. The goods that you took to Palanciste, to Sava Vokic's home, how

22 long did those goods remain there?

23 A. I apologise. Not all things stayed there till '93. I took the

24 freezer and wood stove earlier, but the building supplies -- I

25 do not know what the exact translation of that word is -- but

26 that was -- that remained there. I needed it in Kozarac, so

27 that remained there.

28 Q. You mentioned a man called Brane Koncar who helped you on the

1 other visit in July. Do you know how many people called Brane

2 Koncar there are in that region of Prijedor?

3 A. I know that there are several. I do not know exactly. I know

4 one Brane Koncar who used to live in Kozarac, but it is not the

5 one. The one from Kozarac is very tall. He is about 1.9 metres

6 tall, but Brane Koncar that I referred to, he is from the Kalate

7 village and he is roughly my age ----

8 Q. Did you know another ----

9 A. --- and I think he is blondish.

10 Q. --- Brane Koncar who worked at the hospital?

11 A. No.

12 Q. In relation to these trips for which a certificate was issued,

13 you have got this one still amongst your possessions. Was there

14 any reason for keeping that document?

15 A. There was a reason, yes. First of all, we had a practice to

16 keep all the documents of this kind to track the origin of these

17 goods, because there were some machinations, that is, people

18 were looting in Kozarac. It was very desirable to have a

19 document stating the origin of your property. I know that

20 I bought these building materials towards the end of '91. I had

21 those documents too. I know when I was preparing it and many of

22 my neighbours knew about it. They knew why I was preparing

23 this. This is why I have kept this material.

24 There were different kinds of controls. During 1992

25 certain commissions were established which went around to the

26 centre of Prijedor or municipality and later we also did it,

27 I did it later. We would inventory all the property that was

28 undocumented. When we would -- the owner, if we found some

1 materials and some property, we would ask for an explanation,

2 where it came from. Then we made the reports and if they could

3 not document it, it could be taken away from them. This is why

4 I kept this documentation. I kept those materials all the way

5 up until '93. That was one reason. The second, if you wanted

6 to sell some of them, you again had to prove the origin of it.

7 Q. At what stage did your duties finish at checkpoint Orlovci?

8 A. I stopped working at Orlovci in the early August and I moved to

9 the Most Na Sani.

10 Q. We have seen the checkpoint Orlovci official duty plan which

11 contains your duty for 3rd August as being on the River Sana, on

12 the bridge. Did you work there for only one shift or more than

13 one shift?

14 A. I only worked at that time and that was again with Cvijic.

15 Brdar was not with us, only Miroslav Cvijic. After that,

16 I think that it was on 6th we stopped working at the police, and

17 Cvijic and I went to talk with the Commander, and then we were

18 transferred to work with the police, the general police.

19 So we continued to work, but we were secured -- part

20 of security detailed for the Security Centre building, and we

21 continued to work there another few days, maybe, until 10th or

22 11th August '92 and Cvijic remained on that duty for some time

23 longer and I was transferred to secure the railway and bus

24 station in Prijedor, where I worked until the end of August 1992

25 and the beginning of September.

26 Q. I want to look at that period as a whole from the beginning of

27 June until the beginning of August 1992. During that time did

28 you ever visit the camp at Omarska?

1 A. No.

2 Q. During that time did you ever visit the camp at Keraterm?

3 A. No.

4 Q. You have referred to the single visit with Jovo Samardzija at the

5 beginning of June 1992. During that period of time did you ever

6 visit the camp at Trnopolje again?

7 A. Do you mean between June and August?

8 Q. June and the middle of August 1992.

9 A. No, I did not.

10 Q. The flat that you told us about in Prijedor in Pecani that you

11 moved into on 27th June 1992, did you continue to reside in that

12 flat for the rest of the year?

13 A. Until the end of 1992 I continued to live in Pecani, B2, third

14 floor. I have to say that in all my life I have not been to the

15 Ljubija ore mine before, during or after the war in the Prijedor

16 municipality area. I never set foot in there. I was never

17 there officially, privately. I was not forced to go there.

18 I had no business there. So I never went there.

19 Q. In August 1992, did you apply to open a cafe bar in Prijedor?

20 A. Yes.

21 MR. KAY: Your Honour, that is actually a convenient moment before

22 I enter into a completely new subject.

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

24 (4.00 p.m.)

25 (The Court adjourned for a short time)

26 (4.20 p.m.)

27 THE PRESIDING JUDGE: Mr. Kay, you may begin.

28 MR. KAY: Thank you, your Honour.

1 Q. You told us that you worked after you had been with the reserve

2 traffic police for other stations within Prijedor police

3 station, and you gave those details. When did you start working

4 for the Kozarac police?

5 A. I started working for the Kozarac police as of September 1992.

6 Q. How did the transfer from the Prijedor police to the Kozarac

7 police occur?

8 A. It was a matter of procedure relating to our activities on the

9 revival of Kozarac. It was not only transformation of the

10 police station in Kozarac, the transformation of the police

11 station in Prijedor into police station in Kozarac, but it was a

12 process related to the establishment of the Local Commune in

13 Kozarac. It did not happen all at once. There were quite a few

14 difficulties in relation to that.

15 Q. When did you start to become involved then with the return to

16 Kozarac and the revival of the town of Kozarac?

17 A. First, activities in relation to the return to Kozarac were

18 launched by a certain number of residents of Kozarac who at that

19 time were living in Prijedor as refugees, displaced persons.

20 Q. Who were those people?

21 A. Well, what happened at the beginning, at first, we did not know

22 what kind of perspective my native town had, the town where

23 I wanted to return very soon, but at the beginning of August

24 1992 an information was made public that the municipal Crisis

25 Staff has reached a decision that Kozarac would not be resettled

26 and that no one would return there.

27 So, in view of those circumstances, I met with many

28 people from Kozarac there. I first met with Bosko Dragicevic

1 and then I also met with Ivo Rajkovic and many others who were

2 living in Kozarac. I also met some neighbours of mine of Muslim

3 nationality. I used to run into them throughout that summer,

4 and I talked to them, we exchanged opinions, we consulted with

5 each other, and I also talked to Meho Beslagic about that.

6 I talked to former President of the Court in Prijedor, Tadzic

7 Hamzalija, and we were just discussing the activities that would

8 be adequate at that time. So we said that nothing would happen

9 if we do not undertake something.

10 So, while in Orlovci, I several times met the

11 Commander of the regional Crisis Staff, Vinko Kos, who was very

12 cynical and whenever he passed the Orlovci checkpoint he would

13 ask me, "Where is your Kozarac? Kozarac has come to nothing

14 now. We are the power. We will be deciding about your fate",

15 and so on.

16 So, when this public information was given that

17 Kozarac would not be resettled, we became active, several, five

18 or six of us, me, Bosko Dragicevic, Goran Babic, Ivo Rajkovic,

19 and many others. Many Muslims were also involved in that, but

20 they avoided direct contact with the Prijedor municipalities.

21 Because of their former experience, they did not want to meet

22 those people who were then in power in Prijedor.

23 But everybody was informed of that, and we were trying

24 to undertake something so that that should be -- that could be

25 avoided. Lamovita was just a village which consisted of 20

26 houses and did not have a sewer system, nothing. It was absurd,

27 the situation, where that village was becoming more important

28 than Kozarac which had several thousands of houses, several

1 thousands of telephone numbers. The elementary school in

2 Kozarac was one of the biggest elementary schools in Bosnia and

3 Herzegovina, and Kozarac itself is over 200 years older than

4 Prijedor. So we were all emotionally involved in that and we

5 simply could not allow it to happen.

6 So, there was an initiative which was launched by us,

7 Bosko Dragicevic and several other people. We know that other

8 villages such as Balte, Vidovici and Podgradje, that there were

9 some Serbian residents still living there and that those people

10 were actually the only residents of the Kozarac Local Commune.

11 So we had a meeting with the President of the

12 Executive Council of the Prijedor municipality, Mico Kovacevic,

13 and he said, "Well, it is a decision of the Executive

14 Committee. There is nothing to be changed". But then we wanted

15 to contact the then President of the SDS, and he told us that

16 there was a procedure, except that the problem was that at that

17 time in the territory of the municipality of Prijedor Kozarac

18 did not have its representatives in Prijedor. So people from

19 Kozarac could by no means influence decisions which were being

20 reached for them. The absolute power from the beginning of the

21 conflict until the end of 1992 was in the hands of Crisis

22 Committees, the municipal Crisis Committee and the regional

23 Crisis Committee.

24 So, I learned that the municipality had been divided

25 into regional Crisis Staff who had its Commanders and its

26 delegates to the municipal Crisis Committee who was in charge of

27 everything, all kind of decisions. They had an absolute power

28 at that moment, both civilian and military.

1 We talked to Simo Miskovic and at that time in the

2 summer of 1992 they were not active at all. The political

3 parties were not working, not only the SDS, but other parties as

4 well, the Party of Reforms and so on. So we became active and

5 we went to the village of Balte. I remember that we first went

6 to Kozarac. I did that in addition to my duties in August, so

7 whenever I was free I had talks and then we would go together to

8 Kozarac.

9 I remember we contacted Mirko Grahovac several times

10 who had a tractor so we would visit those villages in his

11 tractor. We discussed the situation, and we knew that such was

12 the procedure after the Second World War. So we were driving

13 along macadams. We did not -- nobody had a car and even if we

14 had had a car there was no fuel. So the situation was very

15 problematic.

16 So, we went to those villages and we informed people

17 about that decision, and we told them that Kozarac would simply

18 disappear if nothing was done. People were, of course, against

19 that because they knew Kozarac, although it had been destroyed,

20 had infrastructure, very valuable infrastructure, telephones and

21 everything that was necessary for an urban area.

22 So, we met in Prijedor and I remember we were received

23 by the then Vice President of the Executive Council of the

24 municipality and who was also a member of the municipal Crisis

25 Staff, Bosko Mandic, whom I have known before as a sportsman.

26 He knew me as well, but when we met there were over 50 of us

27 present at that meeting and he was surprised.

28 He said, "I did not know that you were 50 in Kozarac,

1 people both of Muslim and Croatian nationality. I thought that

2 you were only two or three". That is how that meeting was

3 held. Some people of Croatian nationality attended those

4 meetings as well, and they asked whether they could go back and

5 live in Kozarac. They addressed the question to that person.

6 There were no people of Muslim nationality, but they

7 were also active and they wanted something to be undertaken in

8 that respect, especially the former President of the Court in

9 Prijedor, and then a neighbour of mine, Beslagic, and so on.

10 Q. You are going very fast again, Mr. Tadic, and all this

11 information has to be absorbed and translated. So if you could

12 go more slowly, all right? What was the date then that this

13 idea that Kozarac had a chance of being revived came about? Can

14 you tell us that?

15 A. Well, we -- at that time we were not aware, we did not know,

16 whether the municipal Crisis Staff would alter their decision.

17 Miskovic told us that there was a procedure through which we

18 could alter that, but we needed a forum of citizens who were

19 interested in that, so we needed a formal application.

20 We did not know much about that because I talked, for

21 example, to Vinko Kos and he was telling me that there was

22 simply no way. They even had some agreements that Kozarac

23 should be completely destroyed, levelled, and I personally

24 became aware of that and I would not have reacted that fast had

25 I not seen that machines were in Kozarac and that the

26 destruction of Kozarac had already began.

27 I remember seeing at the beginning of August on the

28 right side of the road between Koncari and Kozarac and also on

1 the main road Prijedor/Banja Luka, at the beginning of August,

2 some 20 houses had been already completely destroyed. There was

3 nothing there. The area had been cleared out by the earth

4 moving equipment. So he told me that the same was awaiting the

5 left side of the road and that they were planning to have some

6 military barracks there.

7 I asked him, "Why?" I failed to see any reason for

8 that. I simply could not understand that people who had taken

9 over power in Prijedor, I mean, the regional Crisis Staff in

10 Lamovita, I could not understand their intentions, but such were

11 their intentions and they proposed that because Zivko Kos was a

12 member of the regional Crisis Staff in Lamovita, and he was a

13 member of the SDS in Kozarac, in the Local Commune of Kozarac.

14 He was the only person from the area, from the former Local

15 Commune in Kozarac, and at that time there were no deputies in

16 the municipality.

17 So those people were supposed to represent the

18 interests of the Kozarac Local Commune. I was surprised to hear

19 that. So we took an initiative of our own, some 20 of us from

20 the centre of Kozarac, and we had the first meeting between 10th

21 and 13th August in the building of the Municipal Assembly,

22 Prijedor. We made an official request to have the decision

23 altered, the decision which had been reached by the Executive

24 Council of Prijedor.

25 Bosko Mandic told us that he would inform the local

26 board of our request and the President was Mico Kovacevic, and

27 that we would receive an answer within several days.

28 Q. We have seen a document dated 15th August 1992 which set out a

1 constitution for the SDS party in Kozarac. How did that come

2 about that the SDS party at that time was establishing itself

3 within the town of Kozarac?

4 A. I would ask, if possible, to have a look at that document.

5 I can explain, but it would be much easier because it was ----

6 Q. Just stop there.

7 A. --- an usual document.

8 Q. Exhibit 333, please. There is an (A) and (B), I think. If the

9 English can be put on the overhead monitor and the Serbo-Croat

10 in front of the defendant?

11 A. I think there is another document.

12 Q. There is of the same date and if we could have Exhibit 149?

13 A. Because that document has more details about everything.

14 Q. Perhaps then that 333 can be taken off the monitor and just put

15 on one side down here and if you can 149 and the English version

16 of 149 put on the monitor?

17 A. I think that these documents can be understood only if they are

18 looked at as a whole, because it is difficult -- it does not

19 mean much, one without the other.

20 Q. This document, the one we are now looking at, Exhibit 149, has a

21 number of names written upon it. It records that the decision

22 taken at an Assembly of the SDS on the date of 15th August was

23 that you would be President of the Kozarac local board of the

24 SDS. How did it come about that you were to be President as a

25 result of the decision?

26 A. It is about the following. Based on an initiative of a member

27 of the Executive Council, Bosko Mandic, he explained to us what

28 the procedure was if we wanted to re-establish, if we wanted to

1 start again, the Local Commune. We could not undertake anything

2 before the decision of the Executive Council in Prijedor is

3 altered, because that decision said clearly that the Local

4 Commune in Kozarac did not exist. So, several days later we

5 went there again, Bosko Dragicevic, myself and several other

6 people, and they showed us a document by which the former

7 decision was revoked.

8 So, it was written on that document that they were

9 agreeable as to re-establishment of the Local Commune in

10 Kozarac. At that time nothing functioned in Kozarac. There was

11 no Local Commune and Local Commune did not have its regular

12 bodies. There was no Executive Board of the Local Commune.

13 There was not any political party which could represent people

14 in Kozarac.

15 Q. So did you form a local board of the SDS in Kozarac as a way of

16 attempting to influence the decision that had been taken in

17 Prijedor by the party in that town?

18 A. Yes, exactly. Without an organised approach, it was not

19 possible to alter the decision. They gave us their approval as

20 to the initiative on the work of the Local Commune in Kozarac.

21 However, we knew that the representatives of the SDA from

22 Kozarac were no longer active in Prijedor, and the SDA in

23 Prijedor was in existence, but the same went for other political

24 parties. Two people who were active before were Zivko Kos and

25 Vinko Kos, but they had no interest in that whatsoever. They

26 were a member of the Crisis Staff at that time and they even

27 expressed their disapproval as to the work of the Local Commune

28 in Kozarac.

1 So, in order to have anything done, we had to have a

2 Citizens Assembly in the Local Commune of Kozarac, regardless of

3 their number. So that is how we convened Citizens Assembly and

4 it was held on 15th August 1992. It was attended by the then

5 Vice President of the municipality, Dragan Savanovic, because we

6 wanted to give it some sort of legitimacy.

7 Here it says, "Chairman, Goran Borovnica". He was

8 instituted formally because he had certain merits from the war,

9 and there was a proposal of a certain number of people because

10 we did not have any experience in the war and we did not have

11 anything to be proud of. So, Goran Borovnica accepted to be

12 Chairman, but only for that Assembly. He was acting as Chairman

13 until the President of the Local Commune in Kozarac was

14 elected.

15 At the beginning of the meeting, the President of the

16 Assembly was elected. It was Bosko Dragicevic. Such was the

17 procedure. After the President of the Assembly was elected, he

18 put up an agenda and on the agenda was the initiative to create,

19 to establish a local board of the SDS in Kozarac. On the same

20 day, in order for everything to be legitimate, the Assembly of

21 the Local Commune elected the local board.

22 At that time there were not enough members of the SDS

23 from the area of Kozarac, and that is why here you have a number

24 of 15, but we did not have anyone else. So we proposed 14

25 people, because we simply could not find the 15th one.

26 Q. Were you appointed as President of the local board of the SDS

27 for Kozarac by authorities outside Kozarac, say, Prijedor or

28 elsewhere, or were you the choice of those who were present at

1 that meeting?

2 A. I told you what the procedure was. Vice President of the

3 municipality, Dragan Savanovic, was there and he was watching

4 the meeting, and then a certain number of people proposed for

5 the President of the Assembly -- and that Bosko Dragicevic was

6 elected. After that, they voted for the President of the local

7 board of the SDS and its members, members of the local board.

8 That is why I was not appointed. I was chosen. Here

9 you have decision on elections for the Kozarac local board of

10 the SDS, not a decision on the appointment, but election. It is

11 true that there are many things in this paper, but you should

12 look at them separately, but everything was done step by step,

13 but in one day. That is why here you have decision, elections

14 and then appointment.

15 Q. You sometimes have an appointment after an election, you see,

16 which is why I asked the questions I did.

17 A. No.

18 Q. Let us look at Exhibit 333. Here we see a document that is

19 headed: "A decision on the constitution of the Kozarac branch

20 of the SDS". On this date of 15th August 1992 the acting

21 President is cited as being Goran Borovnica.

22 A. Yes, it all happened on the same day. That is why I told you

23 that you should look at these documents in parallel. There may

24 be something unclear here, because everything took place on the

25 same day, at the same meeting, at the same session. They

26 elected the President of the Assembly of the Local Commune, and

27 the Assembly of the Local Commune then proposed establishment.

28 It was a constitutional Assembly at the same time. They

1 suggested that the local board of the SDS should be

2 established.

3 This might be somewhat unusual, but there was not any

4 other way because in Kozarac at that time there were not enough

5 members of the SDS. So, if 200 people from the SDS had been

6 present, it would be different, but at that time you only had

7 about 14 people. So this is a legitimate decision. I remember

8 it very well. It might be unusual, but the Assembly of the

9 Local Commune, that is, the totality of the population living

10 there, they established the Local Commune of the SDS.

11 Q. We have covered this already. So I want to turn now to the

12 Kozarac Commune where you were appointed Secretary of the

13 Commune. If we can look at document Exhibit 334?

14 A. I apologise, but I wish to add something in relation to

15 paragraphs 2, 3, 5 and 6 -- 2, 3, 4, 5 and 6.

16 Q. Maybe we will come back to that. I do not want to get bogged

17 down too much in the detail of that as I do not see it as being

18 important.

19 A. But I have to tell you that in paragraph No. 3 which states that

20 the local board of the SDS at that time was verified by the

21 Citizens Assembly, that it had taken over the responsibilities

22 and duties of the Council of the Local Commune of Kozarac, but

23 at that time there was no Council. So the local board of the

24 SDS by a decision of the Assembly of the Local Community took

25 over responsibility of the Council of the local board which was

26 established in October 1992. That is all I wanted to add.

27 Q. Thank you. Let us go to Exhibit 334. If the English can be put

28 on the monitor and the Serbo-Croat in front of the witness.

1 This is a document where we see that the Chairman of the

2 Citizens Assembly that you told us about, Bosko Dragicevic,

3 signed it. It concerns a meeting of 22nd August 1992. It is a

4 decision on the resumption of work of the Kozarac Local

5 Commune. Is it right again that this was part of the procedure

6 that was attempting to start work to revive Kozarac after the

7 impact of the war?

8 A. Yes, exactly. This document and these decisions here were

9 preceded by some meetings, meetings that were held on 15th

10 August 1992, without what meetings it would have been impossible

11 to reach any kind of decision whatsoever. On the basis of this

12 decision the municipal Crisis Staff in Prijedor could react.

13 They were sent one copy and they were thus forced to revoke the

14 decision, the first decision in relation to the Local Commune in

15 Kozarac, because this decision was based on previous meetings.

16 Q. When did they revoke that decision in Prijedor?

17 A. The decision was revoked after we sent this decision, our

18 decision. We had had talks previously in the Prijedor town

19 hall, but after we established the local board of the SDS and

20 after we elected the President of the Council and the President

21 of the Local Commune Assembly, we had a basis, a grounds for our

22 request. Here, and this is the most important of our decisions,

23 it says, "After the war operations in the territory of Kozarac

24 the Kozarac Local Commune resumed its work." That was the result

25 of everything that had happened before. They simply could not

26 do anything against this particular decision. They simply had

27 to alter their previous decision, and by "they" I mean members

28 of the municipal Crisis Staff.

1 Q. If we look now at Exhibit 335 dated 31st August 1992, if the

2 English could be put on the monitor and the Serbo-Croat in front

3 of the defendant.

4 A. I forgot to tell you, you have here the signature of Bosko

5 Dragicevic. You have to ask yourselves why there is no mention

6 of Goran Borovnica here. He was only Chairman at one session

7 until the President of the Local Commune was elected, that was

8 Bosko Dragicevic and he worked as the President of the Assembly

9 until the end of '92. In '93 that was the highest political

10 function within the Local Commune.

11 Q. I think you have made that clear to us, that at the initial

12 meeting someone who was a local figure, and you told us about

13 him being involved in the war, had to take the chair for the

14 meeting and then appointments were made as a result of the

15 elections afterwards.

16 Looking at document 335, we can see here that this is

17 a programme for the local board of the SDS in relation to events

18 within the Local Commune. Again, this date of 31st August 1992,

19 was it important because decisions were able thereafter to be

20 made relating to improvement of the condition of the town of

21 Kozarac?

22 A. Well, this decision was part of decisions, previous decisions

23 which began as of 15th August. It was not maybe done very

24 professionally, because we were never really politically active

25 in relation to the work of the Local Commune. So, this may not

26 be very professional, but we did have a written basis for

27 activities that followed in the Local Commune in Kozarac. On

28 31st August 1992 not all bodies of the Local Commune in Kozarac

1 functioned. There was a period which preceded the real work of

2 the Local Commune in Kozarac.

3 Q. If we could look at Exhibit 151, and again if the English could

4 be put on the monitor and the Serbo-Croat in front of the

5 defendant. This is a document dated 9th November 1992, but it

6 refers to the decision on 31st August and refers to the election

7 of the Kozarac Local Commune Secretary on 9th November. Can you

8 tell us about this document which refers to the earlier dates,

9 and in paragraph two refers to the competition of 9th September

10 1992: "Dusko Tadic from Kozarac has been appointed Kozarac Local

11 Commune Secretary"?

12 A. Yes. This decision refers to the decision of 31st August 1992,

13 and relates mainly to the work of the Local Commune. It is

14 impossible for a local commune to function without a secretary

15 of the Local Commune, a fully employed secretary of the Local

16 Commune. A secretary was always a professional position, but it

17 had nothing to do with the party activity, the work of the

18 political parties. I do not know whether you have a decision on

19 the competition. The decision on the appointment was preceded

20 by competition for the position of the secretary to the Local

21 Commune. That competition is mentioned here in paragraph two.

22 So on the basis of the competition of 9th September 1992, Dusko

23 Tadic from Kozarac has been appointed for the Local Commune

24 Secretary. So there had been competition before. Anybody could

25 apply for that position, but I remember that period very well.

26 That competition was open and it was publicly announced in

27 Prijedor on the books, such was the procedure. So it was

28 publicly announced, but nobody applied for it simply because

1 people had no interest whatsoever to go and work in Kozarac in

2 view of its state.

3 I remember I was the only one who showed any interest

4 in taking up that position. So the decision on the appointment

5 of the Kozarac Local Commune Secretary was reached by the

6 Assembly of the Kozarac Local Commune, the very same Assembly.

7 I mean all the citizens, all the residents, of the Kozarac Local

8 Commune. Here you have mention of the President of the Assembly

9 of the Local Commune which was always the highest body in the

10 Local Commune. At that time the President was Bosko Dragicevic,

11 and he was the Chairman at that meeting when I was elected

12 Secretary to the Local Commune.

13 All these decisions relate to the beginning of the

14 work of the Kozarac Local Commune. It was the period of August

15 1992, and during that period there were not many people who were

16 interested in doing anything in Kozarac. In respect to June

17 1992 the time of my first visit, it was already -- it had

18 changed. It was something like we have seen here on video. It

19 was not the same place, the same place I visited the first time

20 I went there. It was systematically destroyed, although it was

21 in the jurisdiction of the municipal Crisis Staff. There were

22 some people who were providing security, but there were also

23 many military formations in Kozarac at that time who were

24 ostensibly protecting the town, but ----

25 Q. At this time were you also involved with the Kozarac local

26 police as well as starting this project of working in Kozarac

27 trying to restore the town?

28 A. Yes, from early September 1992, maybe that is why it is unclear

1 in the documents, but it is a procedure when at the beginning of

2 September I became part of the revival of Kozarac and I still

3 had duties with securing the railway and bus station in

4 Prijedor. So that I was often and for the most part in the

5 field all day. So, if I was on duty at the bus station in

6 Prijedor, at say 9.00 o'clock in the evening, so the whole

7 morning I would spend in Kozarac with these assistants and then

8 I would come to duty and then after a while I just could not

9 take it any more. That whole activity started in August and

10 then finally physically I was just not able to do it any more.

11 So that was the reason why I moved from the police, from the

12 Prijedor police to the Kozarac police, because it was not

13 possible to leave the police. Had I left then I would have been

14 mobilized, I would be would have been conscripted. It would not

15 have been possible to interrupt the duties as a policeman.

16 Q. When did you cease working for the Kozarac local police?

17 A. I stopped working exactly on 19th November 1992. However, the same

18 month though, I think it was on 6th November, I got days off

19 from the Commander of the police station because I was involved

20 in different committees, different commissions, which worked on

21 the revival. It was about markings which is what we saw. There

22 were circles with crosses. The first action that we had was the

23 protection of the structures that were in the centre of

24 Kozarac. The only way to do it legally was to form a municipal

25 commission that was to find out the conditions of the

26 residential fund in Kozarac. Blue, red and white signified

27 the -- and the difference in colours as you may have been able

28 to see -- each colour signified a certain degree of

1 destruction. This work was done by the Municipal Commission

2 from Prijedor, and it was the precondition for any kind of

3 reconstruction of these structures. So that was taking a

4 picture of the conditions of the residential buildings, and this

5 was the first time -- the centre of Kozarac was not destroyed.

6 Maybe there were damages, maybe 20 per cent, but 80 per cent of

7 the damage that ensued happened later in the period between June

8 1992 and the end of August 1992.

9 Q. At this time which really begins from the middle of August 1992

10 when you are attempting to restore Kozarac and onwards, did you

11 have refugees coming into the area of Kozarac?

12 A. That was another reason why we raised our voice against those

13 activities, simply because we were surprised when we saw from

14 the beginning of July 1992, I worked at the checkpoint Orlovci,

15 I saw the refugees coming through. It was true that they had

16 been expelled from their own homes where they used to live

17 before, but it is also true that they could have moved into the

18 centre of Kozarac. I still claim that had those people moved

19 there Kozarac would not have been destroyed. It is true that

20 people who never lived there would have now been living there,

21 but it would not have been destroyed.

22 So the regional Crisis Staff of Trnopolje organised

23 this activity and they moved some people in that area of

24 Trnopolje. As I said, before the regional Crisis Staff had been

25 formed and the one in Trnopolje was covered and overnight they

26 brought a decision that their area comprised from the railroad

27 tracks to the main road to Kozarac, and the centre of Kozarac,

28 which was the most valuable, was now belonging to the regional

1 Crisis Staff in Lamovita who decided that it was not going to be

2 revived. So they never wanted to protect it and they never had

3 any intentions of protecting it. So if you look at Hrnici, Suhi

4 Brod and the other parts there, that is where people live. That

5 is where in July and August people were moved in, organised by

6 the regional Crisis Staff of Trnopolje thinking that it was

7 incumbent upon them to do so.

8 Q. Because you were Secretary of the Local Commune, did that count

9 as a form of work obligation that meant that you did not have to

10 be mobilized for the military and undertake military duties?

11 A. Yes. That was the reason which followed out of all these

12 activities. It would not have been possible to work as a

13 Secretary of the Local Commune and continue working in the

14 police. But from the takeover of power in Prijedor and on,

15 I was getting more and more an impression that there was a

16 split, a schism. The SDS had no activity. They stopped

17 their activity and the Crisis Staff took over all activities.

18 Because of the events, the dominant positions were occupied by

19 the military personnel, by officers, and the war zones and the

20 war effort was given the highest priority. Everything else was

21 neglected.

22 As far as the work duties are concerned, I have to say

23 one more thing. One of the reasons maybe why I was not

24 mobilized before June 16th 1992 -- there are several reasons.

25 One of the reasons is that I acted the way I did, in other words

26 I was in Banja Luka. The other one is that 10 years before the

27 I mostly was in private business and at one time even in Banja

28 Luka, and at that time I was tied militarily to my firm, to my

1 company and while I was in Croatia. That is why I was never

2 mobilized for the war in Croatia, in the first place. Also in

3 the former Yugoslavia people who were in private business were

4 almost never mobilized.

5 Q. At one stage you were issued with a certificate which excused

6 you from the military as a result of your position as Secretary

7 of the Local Commune which counted as your work obligation, is

8 that right?

9 A. Yes. That request by the procedure was produced by the

10 Executive Board of the Local Commune in Kozarac, but it had not

11 been acted on. It was not acted on until early 1993. Simply,

12 I was still from 19th November on, I was free of that, but there

13 was always a possibility to be involved in any police activity

14 in Kozarac. But because of this procedure until the end of, up

15 towards the end of 1992 I was already freed of these

16 obligations, so I worked as Secretary for the Local Commune.

17 Q. Can we look at Prosecution Exhibit 154. We see here a document

18 that is -- if the English can be put on the overhead

19 monitor -- the decision on the assignment of work obligations.

20 This document states that your post as Secretary of the Local

21 Commune in Kozarac is to be considered a combat assignment, and if

22 there is a call for mobilization you should report immediately

23 to the post you were assigned to. Were there in fact attempts

24 by the military to mobilize you and put you within the military

25 forces?

26 A. Yes.

27 Q. Although you had an exemption by reason of your work obligation,

28 were the military in fact accepting that as being something that

1 you were able to use to avoid being mobilized within the

2 military?

3 A. Beside this one, on 25th December 1992 I was permanently removed

4 from the list of the reserve police force, and that was always a

5 problem. The cessation of duties towards a unit of any kind was

6 always when you got the final seal in the military booklet. So

7 my first entry, the first seal is on 16th June, and the last day

8 I think is 25th December 1992. My obligation ceased both

9 regarding the military and the police. At that time I was

10 officially fully employed as Secretary for the Local Commune.

11 The procedure that the Assembly made in order for me not to be

12 recalled to the military or the police, was completed with this

13 decision when I was put in the position of Secretary of the

14 Local Commune. Here it says, "conscript". Any person,

15 regardless of whether they were police or the military, had a

16 military obligation. So that where it later says that one

17 should report to a post, according to this decision it says, it

18 is a post to where I should report in the future and that meant

19 from this date on. It meant the position of the Secretary of

20 the Local Commune. So this is my post. That was also my

21 workplace as of that date.

22 Q. Were there attempts by the military to forcibly enlist you for

23 military service?

24 A. Yes.

25 Q. When did those attempts by the military take place?

26 A. Those activities started first in March 1993 and up to August

27 1993. In other words, half a year I was exposed to the military

28 police in Prijedor. In the first period, from March till June

1 1992 I was arrested several times by the military police.

2 I would always show them this document. The patrol leaders at

3 that time told me that this is a document which obligated them

4 to release me. So they could not mobilize me without revoking

5 this decision, and this decision could only be revoked by the

6 men in charge of the National Defence.

7 JUDGE STEPHEN: The witness has said March till June 1992.

8 MR. KAY: Your Honour, yes. [To the witness]: Was that right, March

9 till June 1992 you were arrested several times by the police?

10 Is that the right year?

11 A. Yes.

12 Q. 1992?

13 A. 1993, I made a mistake.

14 Q. Thank you. Perhaps if we just slow things down a little bit,

15 Mr. Tadic, which is why I am searching for a document. It is

16 always a useful recourse. Can we have Exhibit D8.

17 A. If I can, I started reading this ----

18 Q. No. If you can just wait for the document.

19 A. If it was translated this is handwritten.

20 Q. Let us just go to a document here which will tie matters in. If

21 page 15 of the English can be put on the monitor and if you

22 could put this in front of the witness. I would like you to

23 look at section 10. Section 10 of the military book shows your

24 participation in war and it has your mobilization date of 16th

25 June 1992. That date you told us of, 25th December 1992. Did

26 that not release you then from any further obligation, taking

27 into account that decision that you had on the assignment of

28 your work obligations?

1 A. I think that the decision made on the work obligation was made

2 in early '93.

3 Q. Yes. Why then in 1993 were the military forces attempting to

4 mobilize you contrary to your exemption?

5 A. It was absolutely illegal, and it was illegal relative to the

6 laws of Republika Srspka. They could not have mobilized me. It

7 was illegal of them. As far as the stamps are concerned, the

8 first stamp is the security services centre, that is an old

9 stamp of Bosnia-Herzegovina, I know its shape, and the last

10 stamp is the stamp of Republika Srpska, also the police stamp.

11 Q. We also see as part of this section 10 the date of 10th June

12 1993. Was that a date that you were mobilized at the front by

13 the military?

14 THE PRESIDING JUDGE: You may have to move it. Is it on this

15 Exhibit, Mr. Kay?

16 MR. KAY: Sorry, yes. If you can move it up the screen a bit. I am

17 sorry, your Honour. Thank you. Section two as translated. Is

18 that the date that you were mobilized at the front?

19 A. Yes, and that was the stamp of the military. As I said, it was

20 illegal because on 10th June I had a work obligation as a

21 Secretary of the Local Commune. The real procedure was to

22 revoke that decision by the Ministry of Defence office in

23 Prijedor, and only then could they make decisions about my

24 assignment to the police or the military. So they had no right

25 to do that. I remember that I visited Slavko Budimir on this

26 matter and he said that he could not revoke this decision

27 because I was fully employed as a Secretary of the Local

28 Commune. I was being paid, given a salary, and the Assembly of

1 both Kozarac and Prijedor had to be involved in the process. So

2 he had no answer why they were doing it.

3 Q. Stop there. How many attempts had been made to arrest you

4 before you were mobilized on 10th June 1993? Do not give me the

5 details, just the numbers.

6 A. From March until this date, five or six attempts. Sometimes

7 I jumped out of the window. Sometimes I would take cover from

8 where I was sitting, but there were several attempts in Kozarac

9 to arrest me. Several times the military police came. I would

10 show them the documents. They would not arrest me, but they had

11 an arrest warrant for me. They said, "It is all fine, we have

12 other people, but for some reason they want to arrest you."

13 Q. On 10th June 1993 where were you mobilized to?

14 A. On that date I was arrested in Kozarac at the gas station, and a

15 patrol chief, his name was Desimir, and his colleague,

16 I think his name was Lajic, they took me to Prijedor in a van

17 with another group of people. On the same day transferred me to

18 the war zone near Gradacac. They told me in Kozarac they were

19 taking me in for an information conversation, and I told them

20 that I had a uniform and should I bring it. They said, "No.

21 No, we are just taking you in for an interview" -- Vujicic was

22 his name -- "and you will be released immediately." Their

23 headquarters were in the fire station. I was surprised when

24 I was just given travel documents. They said: "Take him to

25 Gradacac." I said: "What interview in Gradacac?" They said:

26 "Everything is fine. You are going to an interview with the

27 Chief of the Military Security who is near Gradacac and you have

28 to talk to him. He is there so you have to go there." They did

1 not tell me that I would be put in a unit. They just told me

2 there would be an interview, a conversation.

3 Q. Were you taken then to the front at Gradacac?

4 A. Yes.

5 Q. How long did you stay at the front at Gradacac?

6 A. They first took me to the command in Srednja Slatina. I waited

7 for an hour and then that Desimir came out and said: "The Chief

8 of Police is not going to talk to you. We have orders to put

9 you in on the first line of fire." So they took me to that

10 zone, into that zone, and that is where I spent the first

11 night. Nobody gave me a weapon or told me anything, to sign up

12 for anything. So they just brought me there and they left me

13 there.

14 Q. Did you remain serving at Gradacac or did you terminate your

15 duty early?

16 A. The next day I escaped from there. I remember I saw Jozo

17 Popovic there who was also mobilized as a civilian. So I was

18 not the only one, but I did not want to leave it at that. So

19 I met a truck driver who was bringing in food supplies and I

20 asked him if he would help me get out of that there, and he said

21 that he would. So I took a ride with him. I hid in the truck

22 when it was returning. I did not know that area, otherwise

23 I would have left on foot. That was not a problem.

24 Q. Did you desert?

25 A. I did not consider myself a deserter. I left because it was

26 illegal. They considered it desertion.

27 MR. KAY: Your Honour, that is an appropriate moment.

28 THE PRESIDING JUDGE: We will adjourn until tomorrow at 10.00 a.m.

1 (5.30 p.m.)

2 (The court adjourned until the following day).

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