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(Compilation Date 24/01/2003 by Desaster Area)

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• Page 3015 - WITNESS Q


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• Page 2940 • {1/115}

(1)Friday, 14th April 2000
[Open session]
[The witness entered court]

--- Upon commencing at 9.33 a.m.
(5) [The accused entered court]

JUDGE RODRIGUES: [Int.] Good morning, ladies and gentlemen; good morning to the interpreters. I can hear you too. Thank you. The technical booth, the legal assistants, the Prosecution, (10)the Defence, the court reporters, General Krstic. Good morning to you all. I also wish the public good morning. We already have a witness in the courtroom. I think it is Witness P. You're now going to read the (15)solemn declaration that the usher is going to give you. Please go ahead.

THE WITNESS: [Int.] I solemnly declare that I will speak the truth, the whole truth, and nothing but the truth.

(20) THE WITNESS: WITNESS P
[Witness answered through interpreter]

JUDGE RODRIGUES: [Int.] Please be seated. Are you comfortable, Witness P?

THE WITNESS: I'm fine, thank you.

(25) JUDGE RODRIGUES: [Int.] Have you

• Page 2941 • {2/115}

(1)had a good rest?

THE WITNESS: Yes.

JUDGE RODRIGUES: [Int.] So please be at ease. I think it is Mr. Harmon who is going to (5)put questions to you, so for the moment you will be answering questions put to you by the Prosecutor. Mr. Harmon, you have the floor. Excuse me. Yes, there is a minor matter that we have to attend to. Witness P, the registrar is (10)going to show you a piece of paper with your name written on it. Look at it, please, and tell us, simply by saying yes or no, whether that is indeed your name.

THE WITNESS: Yes.

JUDGE RODRIGUES: [Int.] So it is (15)your name indeed.

THE WITNESS: Yes.

JUDGE RODRIGUES: [Int.] Fine. So, Mr. Harmon, you have the floor now.

MR. HARMON: Good morning, Mr. President, (20)Your Honours; good morning, counsel; good morning, Witness P. Mr. President, before I begin my examination of Witness P, I just want to inform Your Honours that after Witness P we have one additional witness to call (25)for today, and at the end of the testimony of the

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(1)second witness we would like to introduce some documents. The introduction of those documents will not take more than 15 minutes. So we can schedule the day accordingly. I bring that to Your Honours' (5)attention and I will now commence my examination of Witness P.

JUDGE RODRIGUES: [Int.] Yes. Allow me to say to you that all the witnesses are very special.

(10) MR. HARMON: Thank you.

• EXAMINED by Mr. Harmon:

• Q.: Witness P, could you tell us how old you are?

• A.: I'm 40.

• Q.: And are you a Muslim by faith?

(15) • A.: Yes.

• Q.: Before the creation of the UN safe area of Srebrenica, were you a member of the Territorial Defence?

• A.: Yes.

(20) • Q.: Were you wounded?

• A.: I was wounded on the 16th of June, 1992, by orders of the army command, or rather the Territorial Defence. I was appointed to working on the collection of humanitarian aid in the local community.

(25) • Q.: So following your injury you were released

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(1)from the Territorial Defence?

• A.: Yes.

• Q.: At the time of the fall of the enclave in July of 1995, were you a member of the Bosnian Muslim (5)army?

• A.: I was not.

• Q.: Now, I'd like to focus your attention on the fall of the enclave in July of 1995, specifically on the 11th of July, 1995. At that point in time were you (10)married and did you have children?

• A.: Yes. I was married and had four children.

• Q.: And could you tell the Judges what happened on the 11th of July that caused you and your family to go in different directions?

(15) • A.: We simply received orders from the civilian structures that we had -- all of us had to go to the enclave of Srebrenica. Our assignment was that all of us should go towards Susnjari, especially the men, whereas the men [sic] and women went to UNPROFOR, to (20)Potocari. We got to a hill called Lehovici, where we split up. So all the women and children went to the battalion compound in Potocari and the men towards Susnjari.

• Q.: Why was there a distinction between where the (25)women went and where the men went?

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(1) • A.: Simply we didn't dare. We didn't dare go to Potocari. We couldn't trust them. So only the women and children dared go to Potocari.

• Q.: When you say "we couldn't trust them," who (5)are you referring to as "them"?

• A.: The Serbs, because when they captured the enclave, they controlled the UN. They took their vehicles. They occupied the enclave. So we didn't dare go to Potocari.

(10) • Q.: Now, Susnjari, how many men gathered -- men and boys gathered at that location, approximately?

• A.: The figure ranged between thirteen and fifteen thousand, according to the municipal authorities. The figure could not be established, but (15)I think it was between thirteen and fifteen thousand.

• Q.: Do you know the range of ages of those males who had gathered at Susnjari?

• A.: From 16 to 50 or 60 maybe. Though there were some women, or rather girls, who followed their (20)boyfriends there, men. A smaller number of women, maybe some 200 or 300.

• Q.: Are you able to estimate the number of men amongst that group who were armed?

• A.: Well, about one third had weapons in that (25)group.

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(1) • Q.: Witness P, did you have a weapon?

• A.: No, I did not.

• Q.: Now, I understand that the people in that group of approximately 15.000 people left the enclave (5)in a column; is that correct?

• A.: Yes. The column was formed. The order was that we had to pass through Serb lines. So it was about 7.200 kilometers to free territory, to Tuzla, so we had to break through the lines. And the column was (10)formed at the very entrance to the place Buljim, so this column was some ten kilometers long.

• Q.: And in which direction did the column advance?

• A.: It advanced towards Konjevic Polje. We (15)passed Nova Kasaba and then on towards Tuzla.

• Q.: Now, Witness P, I'm not going to ask you questions about your experiences in the woods -- perhaps the Judges would like to inquire about that, perhaps counsel will inquire about that -- but I want (20)to fast-forward the experiences that you had to the 13th of July, when there was a decision taken by you and by others to surrender to the Bosnian Serb army. Can you tell the Judges, did you surrender, and can you tell the Judges why you did?

(25) • A.: Yes. My group -- a relative of mine was

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(1)seriously wounded, my cousin, and there was a small group left of some 30 men. The night between the 12th and the 13th we were cut off from the big column. We were in a stream. It was foggy. We didn't know where (5)we were. In the morning there was heavy shelling. Shells were falling around us. There was an ultimatum. They were calling us out on the loudspeaker that we had to surrender, that we should carry the (10)wounded, that we should be exchanged, according to the Geneva Conventions, that no one would be heard. There was a lot of hesitation amongst us whether we should try to pull out or to surrender to the Serb soldiers at Kravica. And after a time they said they would begin (15)the countdown, and the order was to collect the wounded. A number of people were killing themselves, committing suicide. They didn't want to surrender. When we carried down the wounded to Kravica, a column was formed towards Konjevic Polje.

(20) • Q.: Now, you said a number of people committed suicide. Did you see people commit suicide, and do you know why they did commit suicide?

• A.: Yes. Yes, I did see it. I don't know. There were poisons that were being thrown, poisonous (25)gases, and people lost control. They knew more or less

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(1)what lay in store for them, that they would be killed or put into camps. And I saw two brothers. I don't know their names. First they embraced each other. They had an automatic rifle. There was a scream. They (5)opened a burst of fire to one another. Then there was another group of people that threw a bomb into the group, and then four or five of them were wounded.

• Q.: Now, Witness P, I'm going to ask you to talk just a little bit slower, because the interpreters need (10)to follow your testimony.

• A.: Yes, I'll do that.

JUDGE RIAD: Excuse me now the group of people who threw the bomb they were from the group of Muslims or the group of Serbs?

(15) MR. HARMON:

• Q.: Did the people that threw the bomb that you just testified about, were they Muslims committing suicide or were they Serbs killing Muslims?

• A.: I think it was Muslims who were killing (20)themselves. I heard that they may have been Serbs too. At that moment, I couldn't distinguish one from the other. They were all mixed together.

JUDGE RIAD: And the poisonous gases, they were thrown by the Muslims to commit suicide?

(25) • A.: No, it was the shells with poisonous gases.

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(1)I could feel it myself, my eyes were stinging and one was very thirsty and one could feel it on one's own skin.

MR. HARMON:

(5) • Q.: Now, Witness P, how many people along with you went down to surrender on the 13th of July?

• A.: I said that there may have been some 30 men in my group; I didn't count them. We had four or five wounded. And on the asphalt road, we came across a (10)large group that had surrendered at Konjevic Polje, there were 300 or so people and they had some 20 wounded.

THE INTERPRETER: Could we ask the witness to move away from the microphone, please.

(15) MR. HARMON:

• Q.: I've been asked by the interpreters if you can move a little bit away from the microphone. Now, Witness P, when you surrendered to the Bosnian Serb soldiers. Can you describe their (20)appearance, how they were dressed?

• A.: They were wearing camouflage uniforms in dark blue, dark blue camouflage uniforms.

• Q.: Did you see any people in dark green camouflage uniforms?

(25) • A.: Let me see. At that moment, I didn't really

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(1)distinguish. We were all frightened. I know that they all had camouflage uniforms. Whether they were lighter in colour or darker in colour, I really couldn't tell.

• Q.: Now, do you know the difference between (5)police camouflage uniforms and army camouflage uniforms?

• A.: At the time, I didn't, but later I saw on television that there was a difference, but at that moment, I really can't remember whether there was any (10)difference.

• Q.: All right. Tell the Judges what happened after you surrendered; where did you go?

• A.: When we carried down the group of wounded to Konjevic Polje, this group of mine, between 250 and 300 (15)men. The order was to lay down the wounded at the cross roads at Konjevic Polje. One of the Serbs told us that they would take over the care of the wounded. They put us up in a hangar which used to be a kind of (20)shopping area and some people started bringing water, but it wasn't enough. There were only two or three bucket fulls of water. We stayed there for some 20 minutes and then the order came to get on to trucks. I ran out and I (25)saw three or four trucks. I don't remember exactly

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(1)whether there were three or four. They were parked at the very crossroads at Konjevic Polje. The trucks were facing Milici and Nova Kasaba. The trucks were covered with canvas. I (5)couldn't see, and I don't remember the licence plates nor whom they belonged to but I think they were civilian trucks. They had canvas covers, and I think they belonged to the Boksit company, I think. I'm not sure. And we had to climb on to the trucks and the (10)truck I was in started towards Nova Kasaba. Then we passed a sports field that used to be used before the war, and the order was to get off the bus, the truck, I'm sorry. When we started getting off to our right-hand side, I saw a group of Serb soldiers (15)who were waiting for us there. The order was that all the equipment that we had on us, except for money and gold, which they had taken from us at the very beginning in Kravica, that we had to throw those things on to a big pile. And there (20)was a big pile of bags and backpacks and there were some poplar trees there, and we got off the truck in a line and entered this stadium. The stadium was full of men. According to my estimate, there were between 2.500 to 3.000 men and (25)they were all sitting there in a -- within the

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(1)compound. And my group that got off the trucks, we formed a new row there in the playground, sports field.

MR. HARMON: Now, let me have Prosecutor's Exhibit 12/4 and place this on the ELMO.

(5) • Q.: Witness P, I'm going to ask you if you can identify this location that's depicted in this image. Do you recognise that?

• A.: Yes.

• Q.: What is that?

(10) • A.: This is the stadium at Nova Kasaba. This is the goal [indicates] And we stopped here somewhere next to the trees. This is the road to Konjevic Polje to Nova Kasaba, and this is where I entered the stadium
[indicates], the sports field.

(15) MR. HARMON: Indicating for the record that the entry into the stadium was midway along the line of trees that boarders the road that goes from the top of the image to the bottom of the image.

• Q.: Now, this stadium, this football field, is (20)the location where you said there were thousands of men on it; is that correct?

• A.: Yes, yes, yes.

MR. HARMON: I'm finished with that image. Thank you very much.

(25) • Q.: Can you tell the Judges, was the football

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(1)pitch -- how many men were on the pitch and how much of the area of the football field was covered by those men?

• A.: I didn't quite understand your question. You (5)mean the Bosniaks?

• Q.: Let me ask it again. Did the Bosnian Muslim men cover the entire football pitch, half of the pitch, a quarter of the pitch?

• A.: I think that the whole pitch was covered.

(10) • Q.: Now, did you see Bosnian Serb soldiers in and around the Muslim men who were detained at the football pitch?

• A.: Bosnian Serb soldiers, about 15 to 20 of them were waiting for us at the very entrance gates armed (15)with rifles and they gave us orders. They swore at us and ordered us to enter the pitch. Within the pitch itself, around us who were sitting there, there were Serb soldiers with their guns pointed at us. They were swearing and giving us orders.

(20) • Q.: Can you estimate the number of soldiers that you saw around you and the other men at the football pitch?

• A.: I can't give you an exact estimate because, after all, it was a long time ago, but there were 15 to (25)20 at the very entrance. As for the total, in any

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(1)case, there were many in the field, at least 100 or so. But that may not be the correct figure.

• Q.: Do you remember how they were dressed?

• A.: Also they had camouflage uniforms on. On one (5)soldier, I couldn't notice any rank. He may have had insignia, but they all had camouflage uniforms.

• Q.: Now, continue with your -- describing your experiences at the football field, please.

• A.: So when my group entered and when we sat (10)down, after some 15 or 20 minutes behind my back I saw an APC of olive-green colour arriving, and I saw several soldiers around the personnel carrier. And then a big man came out of the APC, some 30 to 40 metres away from me. And when he passed by me, he (15)turned around and asked whether we recognised him. I knew him from the media and he introduced himself. He said that he was the commander of the Serb army, that he was General Ratko Mladic. He was a heavy man with a short cut, (20)well-shaved with some receding hairlines in a short-sleeved shirt. And when he stood in front of us, I don't remember whether it was a podium or a couple of steps, I don't know. He started insulting and cursing us. "Where (25)is your state? What are you dying for? Where is your

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(1)Alija? Where is Haris Silajdzic? Where are your leading commanders? Naser Oric and Zulfo Tursunovic. You are laying down your lives and you've left your women and children for us to care for them." (5)And there were other such insulting words and then the -- at the end he said, "Your authorities in Tuzla don't want you. So we will put you up. Our troops will give you water and food, and then we'll see whether we'll send you to Krajina, to Fikret Abdic or (10)to the Bijeljina camp to the Batkovici camp in Bijeljina." Then orders came for us to get up, to get on to the trucks. I was towards the end of the field, and we headed towards the trucks. I also saw the trucks (15)waiting on the road, three or four trucks, and I think there was a bus belonging to Boksit Trans from Milici. They were waiting on the road in front of the exit from the playing field. My group of men who -- the group that was (20)moving with me, when we were going through the gates, someone said that we should pick up the bags. And Serb soldiers were guarding the gates and the bags. One of the group of Serb soldiers said to us, "You won't need that any longer." Probably they were thinking of what (25)they were going to do. And so we got on to the trucks

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(1)again.

• Q.: Let me stop you right there for a moment, Witness P, and ask you two questions. Do you remember approximately what time of (5)the day it was when you and others started to board the trucks?

• A.: I think it was about 1700 hours or 5.00 in the afternoon. Somewhere around 5.00, between 5.00 and 6.00 in the afternoon.

(10) • Q.: Was the statement made by the Bosnian Serb soldier that you wouldn't need your bags anymore made at about that same time?

• A.: Yes. As we were leaving the football pitch and about to climb on to the trucks, I heard one of the (15)Serb soldiers saying when one of our men wanted to pick up his bag. I heard him telling him, "You won't need that bag anymore."

• Q.: My last question about this part of your experience: Did you receive any food and any water (20)while you were at the football pitch?

• A.: Never. Far from it. I don't know whether anyone asked for any water, but none was distributed anyway.

• Q.: I interrupted you, Witness P, when you were (25)recounting your story about getting on to the truck.

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(1)Would you please carry on from that point in time.

• A.: Yes. So we climbed on to the truck. I don't know how many trucks there were that became full at that point. My truck started out right away. There (5)was an order for the trucks to move. So we went in the direction of Konjevic Polje, that is along the same road we had used to come there, to get there. When we reached the junction with Konjevic Polje, the truck turned right again in the direction of (10)Bratunac. And then we arrived in Kravica. I knew Kravica very well because I had passed through Kravica on a number of occasions before the war. And we stopped near a supermarket. My truck -- well in my truck, we happened to (15)count ourselves, and there were 119 people on my truck. We were sitting on each other's laps on the floor, on the bed of the truck with our legs crossed. I was towards the rear part of the truck which was covered by canvas. Those were very large canvases, and (20)at the back of the truck, you could see through because there was a half a metre opening at that point. So I told you I was sitting in the back of the truck. And as the truck was turning right, I saw that there were two trucks behind us. All of them were (25)facing the direction of Bratunac.

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(1)It was getting dark at that point, and people were getting nervous. The Serb soldiers who were guarding the trucks, who were standing guard around the trucks started mistreating people, hitting them with (5)rifle butts through the canvas of the trucks. They would hit people who sat next to the side of the truck and they went on torturing them. Then they asked about people from specific villages from around the area of Srebrenica, the (10)villages of Glogova, Osmac and other villages. I don't know why they asked for people from those villages. If anyone stood up, they would take him out. We spent the whole night on the trucks and we could hear screams, moaning, cries for help. Screams again. (15)People shouting, "Please, don't beat me. Don't kill me. Don't butcher me." It was so terrible, it was so -- we couldn't take it anymore. I know that five people were taken off my truck during that night. I didn't see them being killed there on the spot, but (20)they didn't come back to the truck. I don't know their names. And bursts of gunfire could be heard throughout the night, coming from around the trucks, and the screams of people, and this lasted all night long.

• Q.: Witness P, were there two other trucks (25)parked --

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(1) THE REGISTRAR: [Int.] Sorry to interrupt you, Mr. Harmon, but I think there is a problem with the transcript.
[Technical difficulty]

(5) --- Break taken at 10.08 a.m.

--- On resuming at 10.21 a.m.

JUDGE RODRIGUES: [Int.] We shall resume, Mr. Harmon. You may continue, please.

MR. HARMON:

(10) • Q.: Witness P, the technical problem has been resolved and we'll continue with your testimony. Now --

• A.: Thank you.

• Q.: I have placed on the ELMO, to your right, a (15)map, and I'd like you to take a look at that map. And if you could use the pointer, first of all, could you point to the location where you were detained at the football field.

• A.: At the football field, this was here, between (20)Nova Kasaba and Konjevic Polje [indicates]

• Q.: And you were taken in a truck to a different location, where you spent the night, and you've just been describing your experiences at that location. Could you point to that location for the Judges, (25)please.

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(1) • A.: So we went back towards Konjevic Polje, and then towards Sandici and Kravica [indicates] And this was all along the road towards Bratunac. And this is where we spent the night, on the trucks.

(5) MR. HARMON: Indicating, for the record, the pointer is on the village of Kravica. Thank you, Witness P. Thank you, Mr. Usher. I'm finished with that exhibit.

(10) • Q.: Now Witness P, focusing your attention on the night of the 13th and the early morning hours of the 14th, while you were in the truck, did you receive any water? Did you receive any food?

• A.: While we were in the truck, during the (15)morning we got only one bucket of water. I don't know who it was who brought the water, but it was hardly a drop for all of us. You can image. It was only one jerrycan of water, and we were 119. We didn't get any food either.

(20) • Q.: Now, do I understand your testimony correctly that in addition to your truck that was at that location in Kravica, there were two other trucks nearby?

• A.: I could see behind my truck two additional (25)trucks. Whether there were any other trucks, I don't

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(1)know. I couldn't guarantee. I know that there were two more trucks, so in total there would have been three trucks, including mine. I don't know whether there were any trucks ahead of us. That I couldn't see (5)because of the canvases.

• Q.: Can you describe the type of uniform being worn by the Bosnian Serb soldiers who were in and around your truck on the night of the 13th and the early morning hours of the 14th?

(10) • A.: I said that they all had a camouflage uniform. To be perfectly honest, I couldn't tell the difference. I wasn't familiar with that. And then we were in great fear. We had been beaten and we didn't dare look outside. People were cursing at us all the (15)time. They were mistreating us. And I know that there was one young man who did not cross over. A Serb soldier put a gun, the barrel of his gun, in his mouth. And the situation was terrible. It was so hot. It was stuffy. People didn't have any water, any (20)food. And somebody tried and asked for water. It was total chaos. And at one point we could hear screams. It was complete madness. We could hear curses, and this soldier cursed his balija mother and he put a barrel of (25)his gun into his mouth. I don't know this man. And he

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(1)did not reach the free territory. But the soldier told me, "I will kill you and ten other people if I hear another word being uttered in the truck." And then everything went silent, and then (5)perhaps after 20 minutes or half an hour, people started screaming again, asking for water, for help, and I could see people drinking their own urine, trying to moisten their lips with their own urine. So you can image how it was, and it was all in terrible heat under (10)the canvas.

• Q.: Can you estimate how hot it was?

• A.: The outside temperature must have been around 28 or 30 degrees, so I don't know how hot it would have been under a canvas. I don't know what the temperature (15)would be.

• Q.: How long did you remain at that location in Kravica before you were transported to a different location?

• A.: At Kravica, on the 14th of July, when it (20)dawned, mistreatment started again, and we spent the whole day in the truck again. And sometime in the afternoon -- nobody had a watch. It had all been taken away from us on the first day when we surrendered. Nobody had any watch, therefore. But I know that it (25)must have been in the afternoon, between 2.00 and 3.00

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(1)in the afternoon.

• Q.: Where did you go?

• A.: At that point I heard somebody say that we were going to Batkovic, that the trucks were leaving (5)for the Batkovic camp. And the trucks that had been facing Bratunac turned around and started back towards Konjevic Polje.

• Q.: And after the trucks reached Konjevic Polje, in which direction did they travel?

(10) • A.: So my truck continued right, in the direction of Zvornik, and I could see, driving right behind us, maybe some 10 meters away from us, started moving as well. This truck was escorted by two Serb soldiers with rifles, who -- one of them was sitting next to the (15)driver and the other one was also in the cabin of the truck and he was holding his rifle out through the window. It was pointing out. And we had been told earlier on in Kravica that should anyone try to jump out of the truck, that they would kill ten people. So (20)I know that my truck was moving in the direction of Zvornik. We reached Zvornik. I knew the place very well. But we passed through and continued after Zvornik, and this is where women and children started (25)throwing rocks and stones on the buses.

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(1)We continued then towards Karakaj, towards the aluminum factory in Karakaj. That area was no longer familiar to me, but we didn't travel for very long, and at one point the truck turned left. It was (5)already evening. We didn't travel for very long, maybe only for about 15 minutes after Karakaj, after the factory. The truck therefore turned right, and we could see the trucks stopping, coming to a halt. I (10)could see that there was a schoolyard in the area, like a small playground.

• Q.: Witness P, let me stop you there for a minute?

MR. HARMON: And if we could have 1/E/1 again (15)placed on the ELMO, the small map.

• Q.: And I'd just like you to indicate on this small map the direction of travel that you took from Kravica up to the area past Zvornik. And I think the map will have to be opened up. And just use the (20)pointer, please.

• A.: Kravica [indicates], Konjevic Polje
[indicates], then we go down the river to the right of Konjevic Polje, we come to Zvornik, Karakaj, and somewhere there, to the left from Karakaj, we came to (25)the school. Between the Dam and Karakaj, that is where

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(1)the school was.

• Q.: Thank you very much.

MR. HARMON: And for the record, I think it's fairly clear from his description the route he took (5)between Konjevic Polje and the Drina River. He crossed the Drinjaca River. The rest I think is very clear. He progressed up along the Drina River, past Zvornik, to Karakaj, and left to an area near Petkovci.

• Q.: Thank you very much, Witness P.

(10) MR. HARMON: And I'm finished with the exhibit, Mr. Usher.

• Q.: Now, how long did it take you to travel from Kravica to the school that you've just described?

• A.: Well, let me see. When we travelled by (15)public transport, it took about an hour, an hour and a half to reach Zvornik. So this was a little bit further, so about an hour and a half.

• Q.: Will you tell the Judges what happened to you and to the other men once you arrived at the playground (20)at the school?

• A.: When we arrived at the playground of the school, I heard sporadic shooting. Then there was noise, cursing, yelling. And suddenly my truck stopped, and when it stopped I saw two other trucks in (25)addition to mine, facing forward at the school

• Page 2965 • {26/115}

(1)playground. The order was that we jump off the trucks, one by one, and as we jumped off, the order was to put our hands up behind our heads and to chant aloud, "Long (5)live the Serb Republic" and "Srebrenica is Serb," and maybe a few other words that I haven't remembered. And as we were jumping out of the trucks and running, Serb soldiers, in my estimate, some 20 or so, between the truck and the school, formed two lines. And as we ran (10)between them, I said that we had to run and chant those words. And usually everyone got hit, some with a rifle butt on the back. Some were kicked, some were slapped. And then we ran towards the school. Towards the school there were some steps, (15)five or six steps going down, so that the first level was lower than the yard itself. There was a double door, and we ran into the school, into a corridor. There was a short hall. And again there were soldiers there who were hitting us and beating us, and they (20)directed us to the right, up some steps leading upstairs. There were several steps and then there's a kind of landing and then the steps turned left to the second floor. When I reached the second floor, as I was running I could see that there was an iron railing (25)in the corridor, and the classrooms were lined one next

• Page 2966 • {27/115}

(1)to another. I know that I entered classroom number 3. 1, 2, 3. Whether there was another classroom further on, I'm not sure, but I think there was some other rooms (5)further down. When we entered the classroom, I saw that it was a school, and on the left-hand side of this classroom there was a blackboard, and on the floor were some vinyl tiles, those that are glued on. There were no school desks. All the windows were closed. And it (10)was stuffy, because we had travelled under the canvas in the trucks. And as soon as I entered I saw two men who had been badly beaten up and covered in blood. At first glance I thought they were dead. I knew one of them in person. He's Munib Admovic, who was very badly (15)beaten. I could describe him. He had a cap and a jacket. I thought he was dead. So we all sat down in rows. We had to form those rows from the windows forward. The windows could not be opened. There were two soldiers standing at the (20)doorway all the time, and they told us that we musn't open the windows, that we must sit there, that we would be given food and water. And so it went on until the classroom was full. As soon as it was filled up, other soldiers (25)started barging in, demanding money. They gave us 15

• Page 2967 • {28/115}

(1)or 20 minutes, otherwise 20 would be killed, if we didn't collect a certain sum of money. I don't know how much they said. They would close the door and go out, and say, "Not a word." The men were tired as a (5)result of high temperatures. They didn't have any water, and they started yelling again, and again they would come through the door, take people out, and one could hear bursts of fire and shooting around the school. No one dared look through the window to see (10)what was happening outside. Suddenly a young man tried to look out, and someone shot him, and he was wounded in that classroom. They said, "If anyone had money left in Srebrenica, that they had hidden, let him tell us and (15)we would take a car and go to Srebrenica, and that man would be saved and transported to Tuzla." However, nobody said they had any money, because this was the third time they were searching us thoroughly and taking everything away. (20)Suddenly, a relative, a neighbour of mine, asked for water. However, he was turned back. A second time when he went to look for water, he walked out the door and he never came back. We could hear fire all the time. Darkness was beginning to fall. I (25)personally didn't feel well. I was having problems. I

• Page 2968 • {29/115}

(1)was feeling dizzy. I somehow got close to the window to get some air, and in my estimate, there were about 200 men in that classroom. And what happened, I don't really know (5)myself. Suddenly when I came to a little, I could see that there were only a few men left in the classroom, 15 to 20, and I could see on those tiles blood and water, or rather urine, and then I saw Munib Admovic, who was trying to get up, and I asked him, "What has (10)happened?" And he couldn't give me an answer. Shortly after that two came in from the outside, two soldiers, and gave orders, "The next four now." And I saw that I had to get up. I and Kadrija Becirevic, who was with me, and two other men, I don't (15)know. We went out together. When we reached the corridor in front of that classroom, next to the iron railing, there were four to five Serb soldiers in uniforms as well, and they ordered us to take off everything, to strip. And I saw a whole pile of (20)clothing and footwear and documents, ID cards, medical ID cards, driving licences and that sort of thing. I took off my shoes, my socks. I only had my vest on, and they let me keep that on. We had to turn out the pockets of our trousers, every little piece of paper, (25)so make sure there was nothing left. What was the

• Page 2969 • {30/115}

(1)reason for this, I don't know. And so we had to stand against this iron railing and the order was to put our hands behind our backs which is what I did. And I saw next to those (5)soldiers a ball of string or rather rope. And I saw him cutting pieces of that rope and tying my hands twice around. There may be pictures somewhere how they tied me up. And he was a big man. He was fair. I don't know him. He just asked me where I was from. (10)When I told him where I came from, he slapped me, he cursed my balija mother, and he pushed me opposite classroom number two. Classroom number two was open, the door was open then, and there was no light on. When I fell, I (15)fell on a friend of mine. He hasn't come either. They were all tied up in that classroom. I couldn't say much, I just asked him, "What is happening?" He couldn't give me an answer. I knew then that the end was approaching. (20)Some 15 or 20 minutes later until all these men had come out and were tied up, I heard the order, somebody yelling, "Send me ten." And the man at the door said, "Get out, ten of you." And I was near the door, and as a group we (25)ran out with our hands tied down the steps. And when I

• Page 2970 • {31/115}

(1)started down the steps, I saw in that corridor or I could feel under my bare feet that there was blood. And in the hallway at the bottom of the steps, three to four men lying dead in the hallway of the school. (5)In front of the school there was a truck. It was already night-time, I don't know what time it was, but I think it was after midnight. And the truck was standing there, the back part facing the entrance to the school. The back side was down. (10)And so with our hands tied, barefooted, naked to the waist had to climb into the truck which was covered with a canvas. What type of truck it was, I don't know, whether it was a military or a civilian vehicle because it was dark. (15)The truck was filled quickly, they would say, "Ten of you," then, "Twenty of you." Then this one down there would call to the one upstairs. And when we climbed into the truck, it was packed full. The order was that we should sit down. We couldn't sit down when (20)it was packed. Again, they cursed us, our balija mothers. They said, "Haris Siladzic and Alija would receive you dead and wounded." They were probably implying some sort of exchange. (25)And again, a burst of fire at our feet and

• Page 2971 • {32/115}

(1)then this relative, Kadrija Becirovic, said to me, "I've been hit." And I only know that he dropped down amongst us. I know nothing more about him. And then the truck started. It was dark.

(5) • Q.: Let me interrupt you before we go on to the next part of your testimony.

MR. HARMON: If I could show the witness five exhibits; 21/1, 21/3, 21/4, 21/5 and 21/7.

• Q.: I'm going to show you a series of pictures (10)that you've seen before in my office. Let me ask you this, Witness P, did you return to the location of that school with investigators from the Office of the Prosecutor?

• A.: Yes.

(15) • Q.: And you identified that school as being the location where you were detained; is that correct?

• A.: Yes.

• Q.: I'm going to show you some pictures, a series of pictures starting with 21/1. I'm going to ask you (20)if you can identify the buildings that are in that particular exhibit. Can you identify the buildings in that exhibit? First of all, do you see a large parking lot on the left side of the image? Now, your pointer is on (25)a building. Can you identify that particular

• Page 2972 • {33/115}

(1)building? If not we'll go to the next exhibit.

MR. HARMON: Let's go to Prosecutor's Exhibit 21/3, please.

• A.: I really can't find my way, somehow.

(5) • Q.: All right. We'll go to the next exhibit.

MR. HARMON: Can we go to 21/3, please.

• Q.: Now, does this clarify the location for you?

• A.: This is the playground. Yes. The school, the entrance to the school. And this is the route we (10)took.

MR. HARMON: Indicating, for the record, there is a flat area where the witness now has his pointer which is the playground.

• A.: That is where the trucks were [indicates]

(15) MR. HARMON: The building in front of a playground is the school where he was detained.

• A.: This is the entrance [indicates]

MR. HARMON: Can we now turn to Prosecutor's Exhibit 21/4.

(20) • Q.: Do you recognise this picture?

• A.: Yes.

• Q.: What is it?

• A.: The steps that I mentioned going down the five or six that lead to the entrance to the school.

(25) • Q.: All right.

• Page 2973 • {34/115}

(1) • A.: The double door that I mentioned a moment ago.

MR. HARMON: The witness pointed to the double doors to the right side of the building. Thank (5)you. Could we turn to 21/5, please.

• Q.: Do you recognise this picture, Witness P?

• A.: Yes. The steps, as I said, the landing and then the -- go upstairs and the iron rails. This is where we were; one, two, three.

(10) • Q.: Let me turn to the last picture in Prosecutor's Exhibit 21/7 and ask you if you can identify this location?

• A.: Yes. As I said, the vinyl tiles that I mentioned that are glued on, and to the left, a (15)blackboard. This is the classroom, the entrance
[indicates], and in the door, the chimney stack for a stove with a hole in it.

• Q.: This is the location where you were detained prior to being taken out and put back on the truck?

(20) • A.: Yes, yes. I was here somewhere near the blackboard [indicates] Later, I moved closer to the window. You can't see the window in this picture. So I was here somewhere [indicates]

MR. HARMON: When the witness indicates (25)"here", he's referring to a place directly under the

• Page 2974 • {35/115}

(1)blackboard. Thank you very much, Mr. Usher.

• Q.: Now, we'll continue with your testimony, Witness P. You said you and other men had boarded a truck. Can you recall approximately how many men were (5)in your truck? You said it was packed?

• A.: After all, it was night-time, nor could anyone count, so I don't know the figure. But imagine, 100 or so men at least. It was a big truck I think.

• Q.: Would you continue, please, with your (10)testimony, describing the events once the truck started on its next leg of the journey.

• A.: We had climbed onto the truck after the shooting, and the truck's engine started. As soon as it started moving from the school, I saw immediately (15)that it was a bumpy road, and we were swaying left and right and hitting each other because our hands were tied. We were standing up. The truck didn't travel for long, maybe 10 or 15 minutes. I don't know what time it was. I know it (20)was after midnight. And then suddenly the truck stopped somewhere. At first glance, I could just see that there was a little light, that there was some sort of light reaching us. And so as soon as we stopped there, we heard (25)heavy bursts of fire, noise, yells. I just heard

• Page 2975 • {36/115}

(1)someone say, "Come down ten. Come on five." And we had to run off the truck. How I got off, I don't know myself. Whether there was any assistance, some way to get off, but we were jumping off and we were all (5)terrified. And when we got there and it was lighted, I saw a very big field of men lying dead who had previously been killed. They were all facing -- their faces were on the ground and they were all tied up. So (10)I and this group of mine were told to form a new row, somebody was giving us the command, the orders. And so we went to the area where we were shot at with our hands tied and barefooted. I saw that the path was rocky. I was barefooted, I didn't really know (15)where we were. I didn't know the location. So we formed a new row. We went to the end. And as we were passing at great speed, of course, I saw a group to my right of Serb soldiers in uniform, they were. And on their heads, they had something black, (20)whether it was socks or something so you couldn't see their faces. They were pointing their guns at us and I just heard one say, "Fall to the ground." That was the order. After that, I really don't know what (25)happened. Behind my backs, I just heard strong bursts

• Page 2976 • {37/115}

(1)of fire. They were shooting at our backs, at our heads. From a distance of seven to ten metres, there was this group of soldiers shooting. I fell over bodies of those who had been (5)executed before me. As I fell, I had some kind of a premonition that I might be saved. I tried to tuck my head between the legs of those who had been killed before me. I don't know, myself, how I managed to do that. I could hear fragments and shrapnel and stones (10)hitting me at my arms and legs, but I realised I hadn't been wounded yet. But then suddenly, something hot seemed to have been poured on my face. And as my hands were tied behind my back, I couldn't do anything. I kept digging (15)my head down among the dead. How long this lasted, I can't remember. The shooting, the bursts of fire, I was probably unconscious again. And suddenly, I heard some voices, individual shots being fired and they were calling each other by (20)name. One said, "Simo and Dragan, come here." And open brief bursts of fire into their heads. There must have been some men alive and indeed there were. And so they opened fire at them. He came close to me. I heard them searching (25)the rows. And then, again, they cursed balija mothers

• Page 2977 • {38/115}

(1)and one said, "You should see what he looks like. He's like a skeleton." He was probably implying the chest of this man. And he said, "If I had seen him in broad daylight I would have been afraid of him." (5)And I heard these Serb soldiers exchanging these words amongst themselves. I was lying down among the dead with my hands tied behind my back. I heard the steps. He kicked me here with his boot, with his leg and he said, "He's dead." (10)After that, what happened with me, these were moments after which I suddenly came to. I really didn't know what had happened. I felt I was suffocating. I was lying with my face down, with my hands behind my back. And as those men were falling, (15)someone had fallen on my neck. And I didn't have any air to breathe. I tried to pull myself out, pull my head out from among the bodies. I could hear moans and movements, so someone was still alive. And somehow -- as I said, my hands were tied. I couldn't pull free (20)with my fingers. I heard a voice, a man saying the following words, he was whispering, "My friends, let's move down. They'll kill us. I am alive too." I plucked up some courage, and I said to him, "If you can, come on, (25)let's try and escape."

• Page 2978 • {39/115}

(1)And then he somehow managed to get some five or six metres behind me in another row. He tried to reach me. He said, "You have double ropes around your hands and I can't untie you." I was whispering to him, (5)"Can I untie you?" So he crawled up to me and I managed to pull his hands free. And he said, "Let's run." You could hear a machine approaching. We could see the lights of the machine and the sound of this vehicle moving and he (10)said, "They'll kill us all here." And I was still tied up, he helped me get up and barefooted, covered in blood, stripped to the waist. I still didn't know where he had been wounded. We are treading over those dead bodies. (15)And down there we saw a kind of thicket, some woods, and we thought we could reach it though the grass was high and they would be able to see us moving. But we had no choice. And only did we manage the reach the wood when we caught sight of a big (20)concrete ditch that was leading somewhere. We didn't know the area. At the bottom of the ditch we saw a bit of water. This was water with a muddy sediment. We tried to reach that water to freshen up and for him to try (25)and untie me.

• Page 2979 • {40/115}

(1)And as we were going towards this ditch to our right, or rather to our left, a vehicle was approaching. We didn't know what kind of vehicle. I just concluded that it was a tractor with a trailer. (5)We heard it bumping over the macadam and as we reached the ditch, I said to this person, take two stones. And he found two rocks to try and cut the rope. So I leaned my hands against the rock and with those two rocks, he cut through the ropes. When (10)he did that, my hands were freed. I saw that I had been scratched on the head. I was bloody. This other person was wounded more seriously than me. I had this vest on me. I took it off and bandaged his wound. We found a bit of water so we washed up a (15)little. And we decided we would stay there until dawn came. This must have been just before dawn, the moments before night and day. And behind us, on the field where we had been shot at, we could hear strong fire again, noise and the (20)noise made by the machine. We heard the thuds as they were unloading. We couldn't see from the ditch what was actually happening. As soon as daylight came, we decided to leave the area, though we didn't know where we were. We (25)passed through a small wood. We found some mushrooms,

• Page 2980 • {41/115}

(1)some leaves, something to eat. And we saw a guard house, a small hut above us. And in that hut, a machine was parked. It was a bulldozer, a large bulldozer, that pushes the material (5)in front of it with a shovel and there was a man with a rifle near that hut. Whether he had a uniform, I don't know, but he was probably a guard working for that company left over from before. So we didn't dare go ahead in that direction, (10)so we retraced our steps, went back to the same ditch where we had been in the morning. We continued to hear explosions, the work of the machine, but we didn't know what was happening, so we were back in the ditch, and to the left of that ditch we saw a Bosniak village that (15)had been burned down. We saw the walls still remaining, the chimneys that had been toppled and we decided we would go to that village to try and find some fruit and water to freshen up. We were barefooted and wounded. (20)So after we had crossed the ditch, we came up on a macadam road which was passing along the Dam. So we crossed that macadam road. I was the first one to cross it, and then I motioned to him to cross it as well, because there were no vehicles. And this is (25)where we refreshed ourselves a little bit. We found

• Page 2981 • {42/115}

(1)some water and we found some fruit. We must have been some 150 or 200 meters from the area where they were loading machines. So we stood there watching. We didn't dare move. We were simply (5)lying in some brambles. We didn't know what to do. The loader arrived that morning, the one with a bucket, and it was loading dead bodies onto a tractor. I know that it was a tractor. It was a large type of tractor with very big wheels on the back and (10)smaller wheels on the front, and it had a trailer as well. So we could see it scoop up between 10 and 15 bodies with its bucket, and then it threw the bodies onto the tractor. The tractor that was transporting the bodies (15)would leave in a direction, but we couldn't follow it for very long, because at one point it turned off. All we could observe was that it was coming back very soon. The journey would probably last about 20 minutes, and after 20 minutes it would come back. So (20)meanwhile the loader with the bucket, with the shovel, would be waiting for the truck to come back. We could hear shots during that time. We didn't know whether they were still killing people, finishing them off, but shots could be heard, at any (25)rate. And we could hear them yell at each other, shout

• Page 2982 • {43/115}

(1)at each other. And this is where we stayed throughout the day. It was the 15th of July. It was getting dark and we knew that we could no longer stay there, so we -- from where we were (5)standing, we could see some water. We didn't know where we were. But once we were in this village, we could see a very large lake. At first I thought it was the Drina River, but later on I found out that it was an artificial lake that belonged to the aluminum (10)factory, would discharge waters. So there was a ditch leading to the Dam where we had been. I'm not sure that they threw bodies into the lake, but I think that they threw them somewhere in the vicinity of the Dam. We couldn't see the tractor. (15)It would turn off behind the Dam and disappear from sight. But it would come back very soon. So we spent the whole day there, waiting, and at one point we saw the TV relay at Majevica, which was in the direction of Tuzla. So I told this young man (20)that we should leave, that we should go in that direction, and we actually started out in the direction of the industrial area of Karakaj. The area was inhabited, so we didn't dare come out. We didn't dare cross the area. We were just trying to follow the (25)relay, the TV transmitter.

• Page 2983 • {44/115}

(1) • Q.: Let me interrupt you there for just a moment and let me ask you just a couple of questions to clarify your testimony. When you looked back from your position away from the killing field, can you estimate (5)how many bodies were laying on that field?

• A.: Well, I didn't make any estimates at the time, but judging by the features of the terrain and the number of people in the school, it must have been between 1.500 and 2.000 people.

(10) • Q.: Now, you also said that you observed some heavy construction-type equipment. One was a bulldozer with a scoop.

• A.: Yes.

• Q.: Are you familiar with construction equipment?

(15) • A.: Yes, very much so. I knew these types of construction machines. I had worked with them. There was a bulldozer with "Caterpillar" which had a kind of blade at the front. It was not moving, that machine, the bulldozer, whereas a loader that was standing next (20)to the bodies was. And there was a third machine, a tractor which had a trailer and which transported the bodies.

• Q.: Can you identify more specifically the bulldozer with the scoop, the type of vehicle that was?

(25) • A.: Well, there are several types: number 8, 9,

• Page 2984 • {45/115}

(1)7. I believe it was the type number 7, with Caterpillar, with tracks. As regards the loader, this type of machine, I believe it was the ULT machine. I used to work with the same type of machines. And they (5)were produced -- they were manufactured in Kragujevac before the war. Now they're importing them. They are of various types: 160 and 200. I believe that that one was ULT 160. It was orange in colour and it had a scoop in front of it.

(10) • Q.: Now, you also were taken to the location of the killing field with investigators from the Office of the Prosecutor and confirmed that being the location where you and others had been taken for the execution; is that correct?

(15) • A.: Yes.

• Q.: Let me show you four exhibits and ask you if you can confirm that the images depict the location --

• A.: I'm sorry. There's one thing that I forgot to mention. When we got out, when we reached the (20)village, from my vantage point I could see the Dam and I could see two very high pillars with floodlights which were on during the night. They were throwing light onto the area, onto the plateau where we had been shot at.

(25) • Q.: Thank you for that addition. I'm going to

• Page 2985 • {46/115}

(1)show you four exhibits, and what I'd like you to do is merely confirm whether this is the location where the executions took place.

MR. HARMON: If I could start first of all, (5)Mr. Usher, with a panorama, which is Prosecutor's Exhibit 22/3, and if that could be shown to the witness first and then placed on the ELMO.

• A.: This is easier for me, this one. This is the road.

(10) • Q.: You need to place that on the ELMO so -- now, using the pointer, could you just -- first of all, is this the location where the killings took place, Witness P?

• A.: Yes. Yes, it is. So this is the road
(15) [indicates] and this is where the ditch was, the Dam
[indicates] This is a kind of protection wall
[indicates] And this is the location.

• Q.: Would you point to the actual location where the killings took place in this particular exhibit, (20)which is 22/3.

• A.: [Indicates]

MR. HARMON: Indicating, for the record, an area that is below the number 100 and to the right of the area 50, and further to the right, beyond the (25)actual rectangle.

• Page 2986 • {47/115}

(1) • A.: I know this pile of rocks in the shape of a pyramid. This is where I was that night. And later on, when we came with the investigators, I saw it again. This is the pile of rocks [indicates] And (5)this is the area where we were [indicates] And it was from there that we went down into the ditch.

MR. HARMON: There is a pile of rocks indicated -- or shown on the diagram --

• A.: Yes.

(10) MR. HARMON: -- to the right of the large red rectangle --

• Q.: Mr. Witness --

• A.: And this is the wall [indicates]

• Q.: I need to describe where you're pointing, so (15)if you would just remain silent while I have an opportunity to describe the area. Then if you have additional comments, I'll permit you to make them.

MR. HARMON: The witness pointed to a pile of rocks which is located to the right of the red (20)rectangle, and it's evident in the upper part of the flat surface area.

• Q.: Do you have anything else to inform the Judges about this particular exhibit, Witness P?

• A.: I recognise this wall. I remember it very (25)well. It is a kind of support wall made of rocks. It

• Page 2987 • {48/115}

(1)is designed to support the Dam, the embankment.

MR. HARMON: Indicating the pile of rocks that's in the lower right-hand corner of that Prosecutor's Exhibit. (5)Now we'll turn to the next Exhibit, Mr. Usher, which is 22/4.

• Q.: And I'm going to ask you, very quickly, is this the cement culvert that you described in your testimony?

(10) • A.: Yes. This is the concrete ditch. This is where we climbed down and this is where we took shelter, hid ourselves.

• Q.: What is the building in the upper right-hand corner of Prosecutor's Exhibit 22/4?

(15) • A.: This is the guardhouse which we saw, and another structure next to it. The bulldozer was here, and these are the pillars where the floodlights were.

MR. HARMON: Indicating the bulldozer was between the house and the floodlights, which are (20)indicated with a circle on the upper right-hand corner of the exhibit.

• Q.: Now we will turn to the next exhibit very quickly, 22/6. Is this also a picture of the cement culvert through which you and your companion found (25)shelter?

• Page 2988 • {49/115}

(1) • A.: Yes.

• Q.: All right. Now if we could turn to Prosecutor's Exhibit 22/7. Do you recognise what's depicted in Prosecutor's Exhibit 22/7?

(5) • A.: Yes, I do. This is the road, the path leading to the Dam, and this is where we had been shot at [indicates]

MR. HARMON: Indicating the red oval on the right-hand side of the image.

(10) • Q.: Now, you said at some point in time, Witness P, that you left the killing field and you took shelter in an area near some buildings that were nearby.

• A.: Yes. This would have been here, in this area
[indicates] There was a village there.

(15) MR. HARMON: Indicating to the left-hand side of the road, the perpendicular road that comes from the top of the image down toward the Dam, to the left of that.

• Q.: Now, let me --

(20) MR. HARMON: I'm finished with those exhibits now, Mr. Usher.

• Q.: And Witness P, thank you very much for identifying them. Lastly, my last question --

(25) • A.: Thank you too.

• Page 2989 • {50/115}

(1) • Q.: -- did you and did your companion ultimately arrive on the Bosnian-held territory, Bosnian-Muslim-held territory, on the 18th of July?

• A.: Yes, in the afternoon of the 18th of July.

(5) • Q.: Witness P, I've concluded my examination. Thank you very much.

• A.: Thank you.

MR. HARMON: Mr. President, I've concluded.

JUDGE RODRIGUES: [Int.] Thank you (10)very much, Mr. Harmon. I think that it would be a good idea to have a short break, perhaps a 10-minute break, and later there would be a longer break, around half past 12.00. At this point we will have a only a 10-minute break. I should like to ask the Defence to (15)try and ask very direct and precise questions for the cross-examination. A 10-minute break.

--- Break taken at 11.23 a.m.

--- On resuming at 11.34 a.m.

JUDGE RODRIGUES: [Int.] Witness P, (20)you're now going to answer questions that will be put to you by Mr. Petrusic who is representing the Defence here. Mr. Petrusic, you have the floor.

MR. PETRUSIC: [Int.] Good morning (25)Your Honours, good morning counsel.

• Page 2990 • {51/115}

(1) • CROSS-EXAMINED by Mr.Petrusic:

• Q.: Good morning Witness P.

MR. PETRUSIC: [Int.] In accordance with your suggestion, Mr. President, I will try and ask (5)my questions in a specific manner.

• Q.: Witness P, on the 11th of July, when you went to Susnjari, did you know that the members of the VRS had confiscated personnel carriers from the United Nations?

(10) • A.: Yes, I did. I did know.

• Q.: I believe the witness has answered. We do not need any further clarification in respect of this. So when you started out from Susnjari towards Konjevic Polje towards the territory of Tuzla, you said (15)that at one point the Serb soldiers mixed with you.

• A.: Yes.

• Q.: The Serb soldiers threw hand grenades which, as far as I understand, contained some poisonous gases.

(20) • A.: Yes.

• Q.: Could you tell us, briefly, what kind of consequences did those poisonous gases have?

• A.: Well, we became very thirsty and my eyes were smarting and there were tears in our eyes.

(25) • Q.: The fact that the Serb soldiers mixed with

• Page 2991 • {52/115}

(1)you and that those grenades were thrown, can we therefore conclude that the Serb soldiers were at the same territory the same night?

• A.: No, when they threw grenades it was on the (5)first night it was only on the following day that the Serb soldiers mixed with the Bosnian soldiers and civilians who remained in the forest.

• Q.: It was on the 12th of July then?

• A.: No, it was on the 13th. The ambush was on (10)the 12th of July in the evening and --

• Q.: I apologise. Were there any opposing views amongst the representatives of the Muslim population as regards the situation in which you had found yourselves, whether you should surrender or continue (15)with the break-through?

• A.: Could you please repeat your question? I don't quite understand what you mean by "opposing views".

• Q.: Well, were there any different views as to (20)what should be done?

• A.: You mean amongst the Bosnian population?

• Q.: Yes.

• A.: Well, yes, people were trying to reach the right decision. Some people wanted to surrender, some (25)were in favour of continuing.

• Page 2992 • {53/115}

(1) • Q.: In view of that, were there any conflicts?

• A.: Well, most probably there were conflicts somewhere.

• Q.: At Kasaba at the football field, General (5)Mladic spoke to you?

• A.: Yes.

• Q.: Did General Mladic mention at that point that the units with dogs were at that location?

• A.: Yes, he did. He said that there were some (10)special units there with dogs and dog handlers, and that every inch of the forest would be covered by them and nobody would be able to cross the asphalt road.

• Q.: After that, you left for Kravica by trucks?

• A.: Yes.

(15) • Q.: The Serb soldiers called out people from Glogova, Kravica?

• A.: Not from Kravica.

• Q.: No, from Kamenica, I'm sorry, Osmac?

• A.: Yes.

(20) • Q.: And Zedansko?

• A.: Yes.

• Q.: And those people would actually come out?

• A.: Well, yes, if they were from those villages. But people didn't dare speak up. But those who did (25)were taken out.

• Page 2993 • {54/115}

(1) • Q.: Do you know what was the reason for that, why did they call people from those specific villages?

• A.: I don't know. Maybe they were their neighbours, they were perhaps looking for their (5)neighbours, people from their area. I don't know.

• Q.: Did they mention Kravica, did they look for people from Kravica?

• A.: No, not from Kravica. It wouldn't have been possible. I don't understand what you mean.

(10) • Q.: While they were calling people out, while they were looking for specific people, people from specific villages, did they also mention Kravica? And my question to you is: Did they ask who had participated in the take-over in Kravica?

(15) • A.: I didn't hear that.

MR. PETRUSIC: [Int.] Mr. President, I should like to show the witness, very briefly again, the statement that he gave to the investigators of the Tribunal on the 14th, the 15th, (20)the 16th of August of 1995. THE REGISTRAR [Int.] Exhibit D-18.

MR. PETRUSIC: [Int.]

• Q.: On page five of the statement given on the (25)14th of August, 1995, second passage, the second

• Page 2994 • {55/115}

(1)passage from the bottom, there is a portion of highlighted text. The last sentence of the passage reads as follows, "The Serbs asked who had participated in the take over of Kravica when it fell under BH (5)control."

• A.: I don't remember. I don't know how this was translated.

• Q.: You signed this statement. Did you sign this statement?

(10) MR. HARMON: Mr. President, may I interrupt? D-18 is a redacted statement so the signature of this witness has been removed. We're prepared to stipulate that the witness did, in fact, sign this statement.

JUDGE RODRIGUES: [Int.] Thank you (15)very much for your remark, Mr. Harmon. I, myself, have realised that the witness is having some difficulties as to his signature. Mr. Petrusic, could you ask your question in a different way? Could you ask him whether he signed (20)the statement, not whether he can see the signature on the statement.

MR. PETRUSIC: [Int.]

• Q.: Witness P, your signature has been redacted from the statement so we cannot see it. So my question (25)to you is whether this is, indeed, your statement, the

• Page 2995 • {56/115}

(1)one that you gave to the Tribunal's investigator on the 14th, the 15th and the 16th of August, 1995?

• A.: I believe it is. I cannot tell you the exact date the statement was given but I think this is my (5)statement.

• Q.: When you arrived in the school, the school was a two-storey building, was it not?

• A.: Yes.

• Q.: Was only the first floor filled with people?

(10) • A.: I believe that it was the first floor and the ground floor. This is what I could tell judging from the voices of the people, I believe it was full.

• Q.: How many trucks arrived in your group?

• A.: I said that there had been three trucks. Two (15)that were at the football field plus my truck. I don't know if there were any trucks later on or before.

• Q.: Let us go back to Kravica and then I will finish with my cross-examination. Was there any reason why the Bosnian Serb soldiers would be interested for (20)that place, in particular?

• A.: I don't know.

MR. PETRUSIC: [Int.] Mr. President, I have no other questions to ask of this witness.

(25) • Q.: Witness P, thank you very much.

• Page 2996 • {57/115}

(1) JUDGE RODRIGUES: [Int.] Mr. Petrusic, thank you very much. Mr. Harmon, do you have any additional questions?

(5) MR. HARMON: I do not, Mr. President. Thank you.

JUDGE RODRIGUES: [Int.] Thank you, Mr. Harmon. Judge Riad.

(10) JUDGE RIAD: Thank you, Mr. President. I have a few questions. Good morning, Witness P.

• A.: Good morning.

JUDGE RIAD: Let me just try to clarify some (15)points you mentioned from the beginning. You spoke of the column of almost ten kilometres when you were fleeing away and before you surrendered. And you said that one-third had weapons; is that right? One-third of you in the column had weapons. (20)Did you use these weapons, these weapons? Had they been used against the Serbs while you were fleeing? Was there exchange of fire, some kind of fighting or were you just running away?

• A.: There were no combats until the ambush. The (25)people who had weapons were at the front of the column

• Page 2997 • {58/115}

(1)and I was somewhere in the middle of the column. And I know that there had been no fighting before the ambush, but then after I had been captured, I don't know what happened.

(5) JUDGE RIAD: And when you were captured, you were captured because they announced, as you said, they asked you to surrender and that you will be exchanged; is that right, that you will be safe? But in spite of that, in spite of their (10)reassurance, some committed suicide. What promoted this reaction if they knew that they would be exchanged? Did the Serbs give them this assurance?

• A.: Well, I think that they simply didn't believe. They didn't dare to believe in their (15)guarantees, that is, that they would be exchanged, because they were killing people. They didn't pay any attention to the age, regardless of whether it was an old man or a child.

JUDGE RIAD: So there was killing before that (20)and you could not trust them. That was the feeling you had, that already there was no reason -- there was their precedents of killing?

• A.: Yes.

JUDGE RIAD: And when was that, with your (25)group?

• Page 2998 • {59/115}

(1) • A.: Yes.

JUDGE RIAD: But your group had started. There was no killing before that. What gave them this conviction that they would not -- that they be killed, (5)beforehand?

• A.: I said that there had been an ambush, and a lot of dead bodies were scattered around the forest and people simply couldn't believe that. They were afraid of ending up in their hands. Thousands of people must (10)have remained in the forest, so they couldn't trust them anymore when it comes to the surrender.

JUDGE RIAD: It was the ambush. Before that, was there any media announcing or threatening, in the media anything which gave them this conviction?

(15) • A.: Yes. Throughout the war people were getting killed, and there was an order, a command, that we should go through the woods. Somebody had issued an order to that effect. People didn't dare. I don't know. They just didn't trust them. They went to the (20)woods. A lot of people got killed in the woods and a lot of people killed themselves in the woods, because they were afraid of ending up in their hands.

JUDGE RIAD: You were living in Srebrenica before the 11th of July?

(25) • A.: Yes.

• Page 2999 • {60/115}

(1) JUDGE RIAD: And could you listen, could you hear Serb radio and Serb television?

• A.: No. No. We didn't have electricity at all.

JUDGE RIAD: Now, at a certain stage, and I (5)follow the question the Defence counsel asked you, certain people were called because they belonged to certain places. You had people coming from Osmac, they were asked to come out and so on. And as you said, after that you heard screams and gunfire. At a later (10)stage, the order came by numbers. They would say, "Bring four people now," "Bring ten people now." Also at this second stage were these ten people or four people, were they more or less coming from a certain place or they would be without discrimination?

(15) • A.: You haven't understood me, Your Honour. I said that they were taken out individually, one by one. During the night, while I was in that truck, five people were taken off my truck. I don't know where the Serbs had come from. The trucks had canvases and they (20)stood guard around the trucks all the time. They were working in shifts. So there would always be between 10 or 15 Serb soldiers near the trucks, and they were taking people out. And during that night, five people were taken off my truck.

(25) JUDGE RIAD: All right. I then, I repeat my

• Page 3000 • {61/115}

(1)question more precisely. When you were in classroom 1 and classroom 2, you would hear an order, somebody saying, "Send me ten." Would he say: Send me ten from this village or that village? Or he would say: Send (5)me ten just from the whole group, without discrimination?

• A.: No. I was in classroom number 3. And after my hands had been tied up, I was transferred to classroom number 2, that is, the next-door classroom. (10)And they were not saying anything to that effect, anything involving a village. I could only hear a voice coming from outside the school, or from the entrance I would hear words, "Send me ten of them" or "Send me 20 of them." This is while I was already on (15)the truck.

JUDGE RIAD: Ten of them, without saying ten of which village, or anyplace; just ten?

• A.: Yes. Yes.

JUDGE RIAD: Now, when you were asked how (20)many people had been lying in the killing field, you said there would be between 1.500 and 2.000. Was there enough light for you at your escape to see the extent of the lying bodies, or was it too dark? I mean, on what did you base your estimation?

(25) • A.: I could make an estimate on the basis of the

• Page 3001 • {62/115}

(1)number of people who had been in the school. There were three classrooms on that floor, so there must have been up to 600 people there. So I believe the same number of people would have been on the ground floor. (5)And I believe that there were other classrooms as well. As to the area itself, I was able to observe it on the next morning, when we came out of the ditch, and also when we reached the village, because we were (10)about 150 or 200 meters away from the spot. So I could see the whole area, and the whole area, the whole location was filled with dead bodies.

JUDGE RIAD: Thank you very much.

• A.: Thank you too, Your Honour.

(15) JUDGE RODRIGUES: [Int.] Thank you, Judge Riad. Judge Wald.

JUDGE WALD: Witness P, you told us in the beginning of your testimony that the reason that the (20)men decided to go or were given orders to go in the woods toward Tuzla rather than to Potocari was because they didn't trust the Serbs not to kill them. They thought they wouldn't get any protection from the UN. When your group surrendered to the Serbs, what changed (25)their mind? Why did they feel they would be able to

• Page 3002 • {63/115}

(1)survive if they surrendered to the Serbs, when earlier they thought they wouldn't survive if they went to Potocari?

• A.: It was very simple. The groups had been cut (5)off from the rest of the column, and they had a large number of wounded. And the order was that the wounded should be brought down and that we should all come down to the road. All the while there was a white personnel carrier travelling along the asphalt road, coming from (10)the direction of Konjevic Polje -- this is what I forgot to mention -- moving towards Kravica. And it passed our group and they threw out two bottles of water. And I think that half of the people surrendered and came out onto the asphalt road because they (15)believed it was a UN personnel carrier. And I think that it actually carried Serb soldiers, because they didn't say anything to us; they simply threw out two bottles of water when they passed by us. And again they went back in the direction of Konjevic Polje.

(20) JUDGE WALD: You said you had a large group of wounded that you carried down at the time of surrender. Had most of those wounded been wounded in crossfire of an ambush, or had they been wounded just by the shelling from the Serbs? I mean, had they been (25)wounded in an actual crossfire between the armed people

• Page 3003 • {64/115}

(1)in the column and the Serbs, or just as they were trying to walk along and just got shelled?

• A.: Part of the group was exposed to a shelling and part of the group -- people from the group were (5)wounded in the ambush that took place on that night.

JUDGE WALD: During the ambush there was crossfire, right, between the Muslims who were armed in the column and the Serbian soldiers. Okay. Now, you mentioned about this incident with (10)the poisonous gas that made the throat get thirsty and the eyes sting. Are you familiar with what's known as tear gas? I mean, sometimes police use it to break up crowds in demonstrations. It brings tears to your eyes, but it doesn't have -- so far as we know, it (15)doesn't immediately blind anybody or anything like that. Was this something like tear gas, or was it anything you were familiar with before?

• A.: I couldn't tell you, Your Honour. I don't know. I just heard someone saying at one point that (20)poisonous gases had been thrown at us. I wasn't very familiar with it. And I tried protect myself, to protect my face, and I was looking for a shelter.

JUDGE WALD: Did this happen only once? Was this just one incident of poisonous gas or did it (25)happen other times, or did you hear other people say

• Page 3004 • {65/115}

(1)that it happened to them, even if you weren't there?

• A.: I heard it from a number of people who were there, who were ambushed. I don't know what happened elsewhere or later on. I'm referring to the ambush (5)that took place on the night between the 12th and the 13th of July. The ambush was at the location called Kamenicko, called Brdo.

JUDGE WALD: Okay. My last question is: You said that from the burnt-out Bosniak village you were (10)able to see this artificial lake near the killing fields, the one where the aluminum company dumped its refuse. Could you estimate the time it would take to drive from the killing fields to that lake? What would you guess or think it would take? How long to make the (15)drive from the killing fields to that lake?

JUDGE RODRIGUES: [Int.] Witness P, just a second. I'm sorry to interrupt. Mr. Visnjic, you were about to say something, probably in relation to "Tihomir Blaskic." I myself (20)didn't get that as a translation or interpretation. Were you going to point to that?

MR. VISNJIC: [Int.] Yes, Mr. President, you're right.

JUDGE RODRIGUES: [Int.] Well, I (25)didn't hear it in the French interpretation, but on the

• Page 3005 • {66/115}

(1)transcript I can see that there is a kind of poisonous gas that is called Tihomir Blaskic, apparently. Judge Wald, maybe you will have to repeat your question so that we can hear the answer. (5)Thank you, Mr. Visnjic.

JUDGE WALD: I'm sorry. I don't know what -- on my transcript, I don't see what question --

JUDGE RODRIGUES: [Int.] I'm afraid it has already disappeared from the screen. I don't (10)know whether it has something to do with the method used by the court reporters. Maybe we should pay attention to this aspect, we should be mindful of this particular feature of the transcript. It had something to do with a question that you asked of the witness (15)regarding tear gas which the police sometimes uses and the poisonous gas that the witness was trying to describe. Mr. Harmon, you might help us, perhaps.

MR. HARMON: I saw the name "Tihomir Blaskic" (20)and thought it was the wrong case, but it was at a point in the transcript at 20.02.12 and it was in response -- this witness gave an answer, and what I wrote down was: "I just heard at one point that poisonous gases Tihomir Blaskic ..." and it went on. (25)So that's the point that Mr. Visnjic stood up.

• Page 3006 • {67/115}

(1) JUDGE WALD: Shall we ask the witness -- let me ask the question to the witness again, and the question was that whether the witness had any idea whether this poisonous gas was like the tear gas.

(5) • A.: I think it was something like that, because the rumour spread among the people that something had been thrown.

JUDGE WALD: All right. We'll take that as your answer to the question. Now, I think we're still (10)in the middle of the last -- well, okay.

JUDGE RODRIGUES: [Int.] Mr. Visnjic.

MR. VISNJIC: [Int.] Mr. President, I think it would be sufficient to hear the transcript. (15)The witness didn't mention Tihomir Blaskic. He used a word in Serbo-Croatian that sounded like this.

JUDGE WALD: Okay. That's helpful to know that. But we have his answer later on to the straight question anyway. (20)So just to answer my last question which I had asked you about, how long you would have estimated it took to drive from the killing field to the Dam, the artificial lake?

• A.: We could only see from the village where our (25)men were. We could see that lake and the field where

• Page 3007 • {68/115}

(1)we were executed. We couldn't get close. It is behind the hill, around a bend. You have an access road to the Dam so we couldn't really see the access to that lake. In my estimate, it would take 15 or 20 minutes (5)to get there and back.

JUDGE WALD: Okay.

JUDGE RODRIGUES: [Int.] Thank you, Judge Wald. I think the question of transcript will be resolved as usual. The court reporters have heard the (10)answer and will make the necessary corrections so there is no point in wasting too much time. But it has been registered in the transcript that there was a problem. Witness P, I also have some questions for you. The 13th of July, the call for surrender by Serb (15)soldiers. In that call, they mentioned Geneva Conventions [Realtime transcript read in error "general Eva"] could you remind us in what context they mentioned the Geneva Conventions?

• A.: I think that they were guaranteeing the (20)safety of our lives and an exchange. That was at least my opinion because I had a wounded relative, and when they mentioned the Geneva Conventions that nobody could be hurt, that we would all be exchanged. So my opinion was that they would guarantee our safety, our transfer (25)to free territory either by exchange with their

• Page 3008 • {69/115}

(1)vehicles or with the help of UNPROFOR.

JUDGE RODRIGUES: [Int.] So we have another type of convention. The Geneva Conventions, I think all these things have to be reviewed. We are (5)talking about the Geneva Conventions and not the "general Eva conventions". Another question, did they expressly use the words Geneva Conventions?

• A.: Yes, I personally heard them over the loud (10)speakers saying that we would all be exchanged in accordance with the Geneva Conventions.

JUDGE RODRIGUES: [Int.] My second question. Nova Kasaba, the football pitch, the whole pitch was covered. My question, were the people (15)sitting or standing or both?

• A.: When I arrived, everybody was sitting down. My group and those who came after me, we all sat down on the grass field of the pitch.

JUDGE RODRIGUES: [Int.] General (20)Mladic arrived. Did he come alone or in the company of others?

• A.: I just saw the APC coming and I saw certain soldiers who were standing right next to the APC. At that moment, I didn't see whether anyone else came out (25)with him, I don't remember. Of course there were the

• Page 3009 • {70/115}

(1)soldiers next to him, but I do know that he, himself, and alone spoke to the people there.

JUDGE RODRIGUES: [Int.] When you left the football pitch, you were boarded on trucks. (5)Those trucks, were they already there when you arrived or did they come after you?

• A.: I didn't see them having come there before us because trucks were passing by all the time. They were driving women and children from Potocari so trucks and (10)buses were passing by. Some were going towards Konjevic Polje, and the others were passing towards Kasaba. So I don't know whether those trucks had come there from Kasaba and were waiting for us or did they come from some other place specially. I just know that (15)they were empty when we came off the field and started boarding them.

JUDGE RODRIGUES: [Int.] While you were at the football pitch, did you see buses passing in the direction of Bratunac-Konjevic Polje with the (20)women and other people?

• A.: Yes, yes, we did see trucks and buses passing from Konjevic Polje towards Kasaba. And in the opposite direction, there were empty buses going towards Konjevic Polje probably to Potocari again to (25)fetch some more women and children.

• Page 3010 • {71/115}

(1) JUDGE RODRIGUES: [Int.] Witness P, I have no further questions. You have answered a large number of questions put to you. Is there something that you would like to say (5)and that you didn't have an opportunity to say?

• A.: First of all, I should like to thank the International Community and this Tribunal that the truth, at least about Srebrenica, should be proven and that some kind of justice is served although that is (10)difficult to do and that everybody should be punished for this preconceived genocide in Srebrenica. Let us take into account merely the fact that each family in Srebrenica has lost two or more family members. I lost 20 family members. My brother, their (15)wives, aunts, cousins and so on. So I wish once again to thank the International Community and, if it can, to resolve this problem of genocide and for all the perpetrators to be punished.

(20) JUDGE RODRIGUES: [Int.] Thank you very much, Witness P, for coming. You have many years before you to live. I think you have a very good reason to live, and that is through your actions and words, you should contribute (25)to a world avoiding a catastrophe of this kind, and I

• Page 3011 • {72/115}

(1)say that regardless of who is responsible. Whoever committed these acts regardless of the ethnic group they may belong to is horrific for all human beings and the human race. (5)Witness, don't move for the moment. I think that we have some exhibits to deal with. We have Defence exhibit D-18. Mr. Harmon, I think you don't have any exhibits to tender now.

(10) MR. HARMON: I don't have any exhibits.

JUDGE RODRIGUES: [Int.] Mr. Petrusic, then.

MR. PETRUSIC: [Int.] Mr. President, the Defence would like to tender into (15)evidence Exhibit D-18, but it seems to me that the -- some redactions need to be made in the Serbian version which the witness has, but the English version has already been redacted to remove all names that might reveal the identity of the witness or other protected (20)persons.

JUDGE RODRIGUES: [Int.] Thank you, Mr. Petrusic. Mr. Harmon.

MR. HARMON: I only have a couple comments (25)about this exhibit, but I need to go into private

• Page 3012 • {73/115}

(1)session to do so. It will only take a couple of minutes.

JUDGE RODRIGUES: [Int.] Mr. Dubuisson, shall we go into private session now, (5)please. Please be seated, Mr. Petrusic.
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(5) JUDGE RODRIGUES: [Int.] I see we are in open session now. I think, Mr. Harmon, that it would be better to have the break, which we had planned before, to have it now, give the opportunity to Witness P to leave, and (10)when the Chamber comes back, the other witness will be in the courtroom. Will he have the same protective measures as this one, Mr. Harmon?

MR. HARMON: He will.

(15) JUDGE RODRIGUES: [Int.] Very well. Witness P, good-bye. We wish you a safe journey home. We're going to have a half hour break now and we will resume work by hearing the next witness.

• A.: Thank you too, Your Honours.
(20) [The witness withdrew]

--- Recess taken at 12.20 p.m.

--- On resuming at 12.56 p.m.
[The witness entered court]

JUDGE RODRIGUES: [Int.] Good (25)afternoon, Witness. Can you hear me? Can you hear

• Page 3015 • {76/115}

(1)me?

THE WITNESS: Yes.

JUDGE RODRIGUES: [Int.] You're going to read the solemn declaration that the usher is (5)going to give to you, please.

THE WITNESS: [Int.] I solemnly declare that I will speak the truth, the whole truth, and nothing but the truth.

WITNESS: WITNESS Q
(10) [Witness answered through interpreter]

JUDGE RODRIGUES: [Int.] You may be seated, Witness. The registrar is going to show you a piece of paper with your name written on it. You're going to look and tell us, yes or no, if that is your (15)name.

THE WITNESS: Yes.

JUDGE RODRIGUES: [Int.] So that is indeed your name. Are you comfortable? Are you at ease?

(20) THE WITNESS: Yes.

JUDGE RODRIGUES: [Int.] You are now going to answer questions which the Prosecutor, in this case, Mr. McCloskey, is going to put to you. Mr. McCloskey, you have the floor.

(25) MR. McCLOSKEY: Thank you, Mr. President.

• Page 3016 • {77/115}

(1) • EXAMINED by Mr. McCloskey:

• Q.: Witness, you know I'll be asking you some questions, and please just do your best to answer them. And if you don't know an answer, that's fine, or (5)if you can give us estimates or rough estimates about certain things, just do your best. Do you understand that?

• A.: I'll do that.

• Q.: Okay. And how old are you?

(10) • A.: I'm 28.

• Q.: And are you a Muslim by faith?

• A.: Yes.

• Q.: And I want to take you back to July 11th, 1995. Where were you living then?

(15) • A.: Srebrenica, the village of Suceska.

• Q.: And who were you living with?

• A.: I was living with my parents and my wife.

• Q.: And what did you decide to do on July 11th?

• A.: I decided to go to Jaglic and the family to (20)Potocari.

• Q.: Why did you decide to go to Jaglic?

• A.: I didn't dare to go to Potocari.

• Q.: Why not?

• A.: Well, I was afraid they would kill me.

(25) • Q.: The Serb soldiers that took over the town of

• Page 3017 • {78/115}

(1)Srebrenica, you mean?

• A.: Yes.

• Q.: And about what time on July 11th did you get to Jaglic?

(5) • A.: It must have been dark already.

• Q.: Can you give us a rough estimate of how many people were assembled there at that time?

• A.: Ten to fifteen thousand. A large crowd.

• Q.: And what did the crowd decide to do?

(10) • A.: They decided to head for Tuzla.

• Q.: How did you get the word that that was the decision?

• A.: I heard the other men talking.

• Q.: And when did you decide -- or when did you (15)actually head out with the group and go towards Tuzla?

• A.: On the 12th, in the afternoon.

• Q.: So you were near the -- farther back of the column, I guess.

• A.: [No interpretation]

(20) • Q.: So did you spend one night in the woods, and then, when you got near the Nova Kasaba area, get captured, on the 13th, in the morning?

• A.: Yes.

• Q.: Can you tell us about your capture, how that (25)happened? Can you just try to explain a little bit who

• Page 3018 • {79/115}

(1)you were with and who captured you and where it happened, that kind of thing?

• A.: Yes. I was with ten other men. We were going to cross the asphalt road. However, Serb (5)soldiers captured us. We didn't manage to cross.

• Q.: And did anybody in the group of your ten have any weapons?

• A.: Yes. One had a pistol only.

• Q.: And what happened to the pistol?

(10) • A.: They seized it, the Serb soldiers.

• Q.: Did you get in any firefight or any exchange of fire with this group of Serb soldiers, or did they just surround you and capture you?

• A.: They just surrounded us and captured us.

(15) • Q.: And what happened after that? What did the Serb soldiers do with you, your belongings, and where did they take you?

• A.: They took away our bags with food in them, then they ordered us to put our hands behind our heads (20)and to proceed towards Nova Kasaba.

• Q.: And about what time did this happen on the 13th?

• A.: About seven o'clock in the morning.

• Q.: And where did they take you?

(25) • A.: To the elementary school in Kasaba. I think

• Page 3019 • {80/115}

(1)that was where the troops were, a kind of barracks, and we were imprisoned there.

• Q.: Serb troops were in the barracks?

• A.: Yes.

(5) • Q.: Can you tell how many Serbs were in the barracks at that point when you were put there?

• A.: A group of some 10 to 20 people.

• Q.: And where were you put?

• A.: In a small room, like a kind of prison.

(10) • Q.: Did you see any Dutch soldiers around these barracks anywhere?

• A.: No.

• Q.: And had the VRS soldiers provided you with any water or food yet at this time, when you were first (15)put into the barracks?

• A.: Yes.

• Q.: When did they give you any water? When did they first give you water?

• A.: Maybe after some 20 minutes.

(20) • Q.: Were there wounded among you when you came out of the woods and were captured?

• A.: No.

• Q.: And what happened when you were in the barracks, if anything?

(25) • A.: I heard the voice of a woman crying out near

• Page 3020 • {81/115}

(1)Jadar. The soldiers went down there and they brought over another man.

• Q.: The Serb soldiers went outside the barracks somewhere where you heard these noises coming from, and (5)brought a man back?

• A.: Yes.

• Q.: And this was a Muslim man?

• A.: Yes.

• Q.: And eventually were you taken somewhere else (10)that day outside of those barracks?

• A.: Yes.

• Q.: About what time were you taken outside of the barracks, and where were you taken?

• A.: At 2.00, they ordered us to put our hands (15)behind our backs, to go in line one by one towards the stadium.

• Q.: And were you and your group then marched down the road to the stadium?

• A.: Yes.

(20) • Q.: When you say the stadium, what kind of a place was this?

• A.: It was a football pitch.

• Q.: And were you still in Nova Kasaba?

• A.: No, a little bit further from Nova Kasaba.

(25) • Q.: Just right outside Nova Kasaba?

• Page 3021 • {82/115}

(1) • A.: Yes.

• Q.: And do you know roughly how many soldiers that were guarding your group as you were walking towards the football pitch?

(5) • A.: Two to three soldiers.

• Q.: And what were they wearing?

• A.: Camouflage uniform.

• Q.: Was that the same kind of uniform the soldiers that captured you were wearing?

(10) MR. McCLOSKEY: I think I heard him say "yes", but I didn't hear a translation.

THE INTERPRETER: Could the microphone be placed closer to the witness, please.

MR. McCLOSKEY:

(15) • Q.: Were the soldiers that captured you different from the soldiers that were guarding you around the barracks?

• A.: They had the same uniforms, but they weren't the same ones.

(20) • Q.: How about the soldiers that took you to the football pitch? Were those the same soldiers that were guarding you at the barracks or were those different soldiers?

• A.: Could you repeat the question, please?

(25) • Q.: The soldiers that took you to the football

• Page 3022 • {83/115}

(1)pitch, I think you said around three that walked you down to the football pitch, had those soldiers been guarding you at the barracks or were they new guys?

• A.: They were different soldiers.

(5) • Q.: Do you know roughly how many soldiers were guarding you at the barracks?

• A.: A group was in the barracks. There was some outside as well. Ten to twenty soldiers in all.

• Q.: And when you got to the football pitch, can (10)you describe the scene there; how many people, who were they, what was happening?

• A.: There were about 1.500 to 2.000 men who were sitting on the field in rows surrounded by Serb soldiers.

(15) • Q.: So 1.500 to 2.000 Muslim men; is that right?

• A.: Yes.

• Q.: Can you give me an estimate of how many Serb soldiers you saw around them?

• A.: There were quite a number of them. I really (20)don't know the number. There was an APC behind our backs. The soldiers were all around surrounding the playing field. There was no more than a metre between each one of them and the next one.

• Q.: Did you see any other equipment besides this (25)APC?

• Page 3023 • {84/115}

(1) • A.: Yes.

• Q.: What else did you see?

• A.: I saw two more APCs on the asphalt road, and a UN APC from which no one came out. It was just (5)standing there.

• Q.: And were all these soldiers that were around the Muslim men, were they armed?

• A.: Yes.

• Q.: And this football pitch, how much of the (10)football pitch was taken up by these Muslim men?

• A.: More than half.

• Q.: And did you see any Muslim men continue to arrive while you were there at the football pitch?

• A.: Yes, I did see it.

(15) • Q.: And in what direction were they arriving from?

• A.: They were coming from Konjevic Polje along the asphalt road, and they brought some from the woods. There was some who were wounded too. They (20)bandaged the wounded and put them to the other side.

• Q.: Who bandaged the wounded Muslims?

• A.: The Serb soldiers.

• Q.: About how many wounded Muslims did you see get bandaged by the Serb soldiers?

(25) • A.: Ten or so.

• Page 3024 • {85/115}

(1) • Q.: And the arrival of the Muslim men to the soccer field, were they arriving by foot or by vehicle of some sort?

• A.: On foot.

(5) • Q.: And can you tell us what you remember happening while you were there at that football pitch?

• A.: The soldiers told us that General Mladic would come. And a short while later he came escorted by two cars and he held a speech. He told us that we (10)would all be exchanged and that they were not criminals. He said that we should have all surrendered because not a bird could pass through their lines as there were hundreds of their lines. And he said that we would go to Bratunac for lunch. And that he would (15)organise groups to collect the wounded in the woods, and for the dead to be buried where their families want them to be buried. Then he ordered the soldiers to make a list of the names of all those captured. At that moment, a (20)prisoner got up and the Serb soldiers approached. They kicked him and hit him with their rifle butts. And then one soldier took out his pistol and killed him. And he was thrown into the other. Mladic was present. He didn't respond in any way. (25)A camera was shooting the prisoners and

• Page 3025 • {86/115}

(1)Mladic as he was delivering his speech. When the lists were made, Mladic left towards Konjevic Polje.

• Q.: Did you put your name on this list?

• A.: Yes.

(5) • Q.: And did you see others put their name on this list?

• A.: Yes.

• Q.: Could you tell if you were being filmed when you had to put your name on the list?

(10) • A.: No.

• Q.: When you eventually left that football pitch, about what time was it?

• A.: It was close to dark, maybe an hour before night fell.

(15) • Q.: And how were you transported away from this football pitch?

• A.: Buses came. They stopped. They ordered us to get into the buses. When the buses were full, we started towards Konjevic Polje. We passed through (20)Konjevic Polje towards Sandici. To the left, I saw a group of men who were sitting down in a circle surrounded by Serb soldiers.

• Q.: Was this near Sandici that you saw these men sitting in a field surrounded by Serb soldiers?

(25) • A.: Yes.

• Page 3026 • {87/115}

(1) • Q.: What else did you see on your journey?

• A.: I saw near Kravica on the right a kind of hangar and dead people at the entrance.

MR. McCLOSKEY: Can we show the witness (5)Exhibit 8/4. And can we first let him take a look at that far right-hand side of the picture and then if we could put that on the ELMO.

• Q.: And Witness, if you could pick up the pointer and point out on the picture itself that sits on that (10)funny machine next to you where you saw the bodies.

• A.: Here [indicates]

MR. McCLOSKEY: And the record should indicate that the witness has pointed to the centre of the large opening in the centre of the photograph.

(15) • Q.: As you were driving by, were you able to tell how many bodies were there?

• A.: Four or five bodies.

• Q.: Could you look all the way in the warehouse, or were these just the ones that were near the opening?

(20) • A.: Those were bodies that were close to the opening.

• Q.: Did you notice any damage to the building that the bodies were in as you drove by it?

• A.: Yes. The traces of bullets could be seen on (25)the building.

• Page 3027 • {88/115}

(1) • Q.: Did you hear anything going on around Kravica while you were driving by it?

• A.: I heard shooting behind the hangar.

• Q.: Thank you. That's fine. And shortly after (5)driving by Kravica, did you arrive to Bratunac?

• A.: Yes.

• Q.: And did you stop in Bratunac?

• A.: Yes.

• Q.: And did you spend the night on the bus in (10)Bratunac?

• A.: Yes.

• Q.: Do you remember what was written on the side of the bus that you were in?

• A.: "Boksit Trans-Milici" was written on the bus.

(15) • Q.: What kind of bus was it? Big bus, small bus?

• A.: A big, double bus.

• Q.: And how full of Muslim men was it?

• A.: It was very crowded.

(20) • Q.: On your trip from Nova Kasaba to Bratunac, were there any Serb soldiers on that bus with you?

• A.: Yes.

• Q.: How many?

• A.: Two.

(25) • Q.: Were they armed?

• Page 3028 • {89/115}

(1) • A.: Yes.

• Q.: And wearing camouflage uniforms?

• A.: Yes.

• Q.: And when you got to Bratunac and stopped, (5)could you tell where you were?

• A.: I knew that that is -- they said that we were going to Bratunac. I saw the town, so I assumed it was Bratunac.

• Q.: Do you know where you stopped, what kind of (10)buildings were around you where you stopped and spent the night on that bus?

• A.: I think there was a school nearby.

• Q.: And were there other vehicles that also stopped in Bratunac around the same location you were?

(15) • A.: There were smaller cars.

• Q.: Any buses or trucks full of Muslim men at the location where you were besides your bus?

• A.: There were more buses behind me.

• Q.: Could you tell how many might have been there (20)that night?

• A.: Four or five buses.

• Q.: And could you tell if they were filled with Muslim men?

• A.: I couldn't see, but I think that Muslims were (25)inside.

• Page 3029 • {90/115}

(1) • Q.: And what happened that night that you stayed in this bus in Bratunac?

• A.: We heard shooting throughout the night, and they would take people out of the bus who never came (5)back to the bus.

• Q.: How many people, if you know, were taken out of your bus that didn't come back?

• A.: Four or five.

• Q.: And that was Serb soldiers that took them out (10)of the bus?

• A.: I think they were, because we didn't dare look. Our heads were bowed down.

• Q.: Did a Serb soldier stay on your bus all night guarding you?

(15) • A.: No. They were outside.

• Q.: How many Serb soldiers were you able to see outside your bus and around that area that night?

• A.: I don't know exactly, but a lot of them were passing by the buses.

(20) • Q.: More than 20, less than 20?

• A.: Fifteen to twenty.

• Q.: Okay. And the next morning, what happened? That would be the morning of July 14th.

• A.: Yes. The driver got out. He had started the (25)engine and he had turned on the heating and then got

• Page 3030 • {91/115}

(1)out. We remained in the bus. And then it was in the afternoon and people were fainting because of the heat. Later on a soldier arrived and told us that we were going to be exchanged.

(5) • Q.: How long were you in that bus with the heat going?

• A.: Two to three hours.

• Q.: Did they give you any water while the heat was going on that bus on that day? Sorry, you have to (10)answer a little bit out loud. I know this is not easy, but the microphone didn't pick up your answer. Were you given water while the heat was going on the bus?

• A.: No.

• Q.: So finally when this soldier showed up and (15)says you're going to be exchanged, shortly after that did the bus -- did your bus start to leave?

• A.: It started to leave, perhaps not right away, but maybe half an hour later.

• Q.: And did your bus drive northward up towards (20)and through Zvornik and up to the area of Pilica?

• A.: Yes. First it was driving along a macadam road which at one point became asphalt road. We were not allowed to watch, but I noticed that it was going towards Zvornik.

(25) • Q.: And where, when you got to the Pilica area,

• Page 3031 • {92/115}

(1)where did the bus stop, and what happened?

• A.: The bus stopped above the school, and the soldiers ordered us out and told us to run up towards the school, and they put us in a hall which was (5)completely crowded.

• Q.: Okay. How many soldiers were on your bus trip from Bratunac to Pilica school?

• A.: You mean on the buses, in the buses, how many soldiers there were?

(10) • Q.: Yes. How many soldiers were in your bus when it drove from Bratunac to the Pilica school?

• A.: Two soldiers.

• Q.: Were those soldiers you recognised from your time in Bratunac, or were these two new people?

(15) • A.: I think they were different, two new people.

• Q.: And they were armed?

• A.: Yes.

• Q.: And when you arrived at the school, how many soldiers did you see outside the school and around the (20)bus that you got off of?

• A.: There were 15 to 20 soldiers.

• Q.: And how were they dressed?

• A.: In camouflage uniform. They were armed.

• Q.: And this place they took you, can you (25)describe what kind of a hall it was?

• Page 3032 • {93/115}

(1) • A.: It was a kind of gymnasium that belonged to the school. It had baskets for basketball.

• Q.: And when you first arrived in this gymnasium, how many Muslim men were in the gymnasium before you?

(5) • A.: Less than half. Later on the hall filled up.

• Q.: Could you tell how many buses were -- or trucks were travelling along with you on your trip to Pilica?

• A.: I think four to five buses.

(10) • Q.: And could you tell if there were any Muslim men in any other part of the school besides the gymnasium where you were?

• A.: Yes, I noticed some people on the steps. There was a very wide stairway leading to the upper (15)floor. Some were standing and some were sitting, and we passed by on our way to the gymnasium.

• Q.: Okay. After you were put in the gymnasium that first day at the Pilica school and it filled up with people, did you volunteer to go get water?

(20) • A.: Yes, I volunteered together with four other men. We took some buckets and we went down the wide stairway which was on the other side past the football field. And further down, there was a tower and a water point with two fountains. (25)When we got there, it was already dark and we

• Page 3033 • {94/115}

(1)started filling up the buckets with water. At that point, we heard a bus approaching the school building. Later on, we heard some noise and shooting and the guard ordered us back to the gymnasium as (5)quickly as possible so we went back.

• Q.: What kind of noise did you hear before you heard the shooting?

• A.: I could hear people crying for help.

• Q.: And could you tell what area around the (10)school these cries of help were coming from?

• A.: Could you please repeat your question?

• Q.: Could you tell what direction or what area these cries of help were coming from?

• A.: Yes, from behind the school.

(15) • Q.: And you'd heard a vehicle arrive before hearing the cries of help; is that right?

• A.: Yes. I think I could hear a bus.

• Q.: Was the sounds of that bus and the cries of help from the people coming from the same general area?

(20) • A.: Yes.

MR. McCLOSKEY: If we could show the witness Exhibit 23/1. Could we use one that doesn't have markings on it. I've got my copy of 23/1. I hope that doesn't confuse things too much but, I'm sorry, I (25)didn't realise that had all those markings.

• Page 3034 • {95/115}

(1)And should we give it another number for the record? THE REGISTRAR [Int.] Yes, it will be Exhibit 24/5.1.

(5) MR. McCLOSKEY: All right. Well we'll take care of that after the witness, I think, if that's all right.

• Q.: Now, Witness, if you take a look at this photograph which has been placed on the ELMO. And (10)first of all, could you point with your pointer the area where the bus pulled up that you were in the day you arrived at the school?

• A.: The bus stopped here [indicates]

MR. McCLOSKEY: Indicating for the record the (15)asphalt road or the -- well, the road right in front of the school.

• Q.: And where did you enter the school? Can you point us out the entrance that you went in with that pointer?

(20) • A.: Yes. This way [indicates] and then here
[indicates]

MR. McCLOSKEY: And for the record, the witness went around to the left of the school building and then into a side entrance near the building that is (25)perpendicular to what looks like the main building in

• Page 3035 • {96/115}

(1)the school.

• Q.: And is that building that you've got your pointer on the gym?

• A.: Here [indicates]

(5) • Q.: Yes. Is that the gym, that's where you went to?

• A.: Yes.

• Q.: And can you now show us the route you took to get the -- to go down and get the water where you heard (10)these screams and the shooting?

• A.: I got out here [indicates] There are some steps here. We went across the football pitch, past the tower and reached this area here [indicates]

MR. McCLOSKEY: Okay. And for the record, (15)the witness went out the back of what appears to be the back of the gym by what looks like a big concrete playground, past the playground, in front of the tower and down into some trees.

• Q.: Was it down by the water that you heard the (20)bus arrive and the people call for help?

• A.: Yes.

• Q.: And shortly after that is when you heard shooting?

• A.: Yes.

(25) • Q.: How long did that shooting go on for?

• Page 3036 • {97/115}

(1) • A.: Not for very long. Five to ten minutes because we were taken back immediately to the gymnasium.

• Q.: Could you still hear the shooting when you (5)were in the gymnasium?

• A.: No.

• Q.: Do you know about what time of day it was when this shooting started?

• A.: It was already dark.

(10) • Q.: And that was the night of the 14th?

• A.: Yes.

• Q.: Can you describe what occurred in the gymnasium that night, the night of the 14th, when you and all the men were crowded inside that gymnasium?

(15) • A.: Yes. It was stuffy. Two or three men died there from lack of air.

• Q.: What happened to their bodies?

• A.: I think that they were taken out by our people.

(20) • Q.: Was anyone given any medical treatment in that gym that night?

• A.: No.

• Q.: Was the water that was brought back by you and your group enough to provide everyone with enough (25)water?

• Page 3037 • {98/115}

(1) • A.: No.

• Q.: Did these soldiers provide anyone in that gym with any food that night?

• A.: Yes. I went out. I went to the toilet, and (5)I know that when I got in, I fainted. And when I recovered, when I came to, I was in the corridor. A soldier gave me some pate and a piece of bread and took me back to the gym.

• Q.: Did you see anybody besides yourself get any (10)food that night?

• A.: No.

• Q.: And did you spend all the next day inside the gym?

• A.: Yes.

(15) • Q.: That was July 15th. What happened in the gym, if anything, on that day, on July 15th, with all the people crowded in there?

• A.: They were taking men out. I'm sorry, I made a mistake. Could I start again?

(20) • Q.: Sure.

• A.: On that day, Serb soldiers arrived and they took jewellery, watches, money from those who had them. Then they came later on again. They were asking for German marks, and they told us if we don't manage (25)to collect the money, that we would all be killed.

• Page 3038 • {99/115}

(1)They came two more times, but nobody had that money.

MR. McCLOSKEY: We're done with the exhibit. Thank you very much. I'm sorry.

THE INTERPRETER: The witness mentioned the (5)amount of money, but we couldn't hear him.

MR. McCLOSKEY:

• Q.: Witness, I'm informed that you need to speak up a little bit more, and could you tell us the amount of money again?

(10) • A.: 10.000 German marks.

• Q.: Did anything come of any of that?

• A.: No. No, because nobody had that money. Whatever people had had already been taken away by the Serb soldiers.

(15) • Q.: Okay. And then what happened after they tried to take all the people's money and their valuables?

• A.: After that, the next night, the men were being taken out from the gym. Some would come back, (20)some didn't. The next day, I noticed that there were fewer of us in the gym.

• Q.: So that night, you're talking about the night of July 15th and the morning of July 16th, you noticed there weren't as many people in the gym; is that right?

(25) • A.: Yes.

• Page 3039 • {100/115}

(1) • Q.: When men were taken out of the gym, did you hear any sounds?

• A.: No.

• Q.: And were there any soldiers inside the gym (5)guarding you during your stay there or did they stay outside the gym itself?

• A.: Yes, they were at the entrance to the gym.

• Q.: Could you tell how many Serb soldiers were outside the entrance of the gym and were around the (10)school area during your stay at the school?

• A.: There were two to three soldiers at the entrance. There was a group of them in the corridor, perhaps five to ten people. There may have been 20 of them in total over there.

(15) • Q.: Now, you spent two nights at this school, the 14th and the 15th. Do you know if the Serb soldiers changed shifts, or was it the same group the whole time you were there?

• A.: I think that they changed shifts, but I'm not (20)sure.

• Q.: Okay. On the morning of July 16th, what happened?

• A.: Serb soldiers came, and one of them said that some people thought that they had killed a number of (25)young men, and he said, "Let all the young men leave

• Page 3040 • {101/115}

(1)the gym, one by one, because they will be exchanged." I was next to the entrance, so I stood up and got out of the gym. And as we were leaving the school building, they told us to line up against a wall, put (5)our hands against our backs, and this is where our hands were tied up. Three buses were parked there, and we climbed onto the second bus. There were three of us sitting in one row of seats. And once the buses were filled up, (10)they left. They started along the same road we had taken when we came to the school. At one point we turned right and reached a meadow. On that meadow I saw a large number of dead bodies. The buses stopped on a (15)road near the meadow, and I could see a hangar there and people lying about, killed.

• Q.: Why don't you tell us, continue to tell us this story of what happened.

• A.: When the buses stopped, soldiers started (20)taking out groups of people who were tied up. They were taking them in one column. They had to put their hands behind their backs. Those were groups of ten people which were taken to the area where the dead bodies were, on the meadow, and this is where they were (25)killed. And then they would shoot at each one of them

• Page 3041 • {102/115}

(1)individually, and this is what I could observe from the bus. After the first bus had emptied, it was our turn. They took out two groups of people from my bus, (5)and I was in the third group of people. As we were getting out of the bus, they asked if anyone had any relatives abroad so that they could send the money for the exchange, and some people spoke up and they were then singled out. And I was taken to the meadow where (10)the bodies were. They ordered us to stop, and we stopped. There was a group of Serb soldiers there. They were in a line and they were shooting at us from their automatic rifles and from machine-guns. When they (15)opened fire, I threw myself on the ground. My hands were still tied behind my back and I fell on my stomach, face down. And one man fell on my head. I think that he was killed on the spot. And I could feel the hot blood pouring over me. (20)The shooting continued and then they ordered soldiers to shoot people individually. And I could hear a voice saying that they shouldn't shoot people in their heads, so that their brains wouldn't spill out, but rather to shoot them in their backs. (25)They shot me at my back. My hands were tied

• Page 3042 • {103/115}

(1)on my back, but a bullet passed under my left armpit, through my shirt, and it only scratched me. And I remained there, lying. I could hear them ask if anybody was wounded. They said that they would be (5)bandaged. And some people spoke up and then they were finished off. I could hear one man crying for help. He was begging them to kill him. And they simply said that "Let him suffer. We'll kill him later." They kept (10)bringing in groups of people on that day, also in the afternoon, maybe for about four hours.

MR. McCLOSKEY: Could we show the witness Exhibit 24/5. Excuse me. It's now 24/5/1. My mistake.

(15) THE REGISTRAR: [Int.] At the end of the transcript I will correct what was said a moment ago. The previous exhibit was 23/1/1.

MR. McCLOSKEY: Could you move that over a little bit so that black dot -- there we go.

(20) • Q.: Now, last night in my office you had a chance to look at this photograph, and could you first take the pointer and point to where your bus stopped.

• A.: Here [indicates]

MR. McCLOSKEY: Okay. And for the record, (25)he's pointing at the road that has vehicles on it that

• Page 3043 • {104/115}

(1)goes sort of in a -- well, it would be a north/south position, perpendicular to the road that goes across left and right.

• Q.: Can you show us the direction that Muslim men (5)were marched to the killing fields?

MR. McCLOSKEY: Okay. And for the record, the witness has just shown us that they walked across a big open field, over to the area of a black spot.

• Q.: Now, did you have a chance to write in that (10)black spot, or I helped you write in that black spot last night?

• A.: I knew where it was. This is where the execution took place. And there is more over there.

• Q.: And is that black spot roughly where you were (15)when they tried to execute you?

• A.: Yes.

• Q.: And how many soldiers did you see taking part in the execution?

MR. McCLOSKEY: I think we're done with that (20)exhibit. Thank you.

• A.: Ten soldiers.

• Q.: And how many were taking part in the escorting of the victims over to the killing fields?

• A.: Three or four soldiers.

(25) • Q.: And you said you saw a machine-gun and

• Page 3044 • {105/115}

(1)automatic weapons. You were a soldier for some time, were you not?

• A.: Yes.

• Q.: What kind of machine-gun was that that you (5)saw in the hands of the executioner?

• A.: M-84. M-84.

• Q.: And while you were lying there, did you hear a vehicle arrive and unload something?

• A.: I did. That was in the evening. We heard a (10)vehicle. It came close to me. It unloaded something and went away again. Later, during the night, I saw that they were the bodies of killed men that were brought there.

• Q.: All right. Now, I'm going to -- we're going (15)to go a little quicker now. I'll ask you a few questions which you can answer yes or no, and if you feel like you need to explain them, that's okay too. But did you spend the night on the killing field there?

• A.: Yes.

(20) • Q.: And the next day you spent some time hiding under a bridge?

• A.: Yes.

• Q.: And were you able to hear anything coming from the direction of the killing fields while you were (25)hiding under that bridge?

• Page 3045 • {106/115}

(1) • A.: Yes.

• Q.: What?

• A.: I heard the sounds of machines. I couldn't see it, but I could hear it. I could hear vehicles (5)moving, nonstop, towards that place, and going back again. This went on all day.

• Q.: And a short time later did you come across an older man, whose name you know? But don't say who it is.

(10) • A.: Yes.

• Q.: And did you and he travel together for a few days and then meet another man?

• A.: Yes.

• Q.: And did that second man eventually get lost (15)from you and the older man?

• A.: Yes.

• Q.: And then did you and the older man finally decide to turn yourselves in?

• A.: Yes.

(20) • Q.: And why did you decide to do that?

• A.: We couldn't walk any further. We were exhausted. We hadn't had anything to eat since our capture.

• Q.: And after you turned yourself in, did you go (25)to a cafe where a Serb man looked after you?

• Page 3046 • {107/115}

(1) • A.: Yes.

• Q.: Can you describe that?

• A.: Yes. When they captured us or rather when we surrendered, a small bus, a mini bus, there were two (5)military policemen in it. They took us in and they drove us to a shop. They got off, sat at a table to have a drink, we stayed in the bus. Then a man came up to us, gave us each a packet of cigarettes and a pint of fruit juice, a litre (10)and he introduced himself but I've forgotten his name. He asked us whether we were hungry. We said we were. He took us to give us food to eat and he made us coffee. Then they put us back on the bus and took us back to Karakaj. (15)In Karakaj, there was a military truck with some 20 men on it who had also been captured. I got on to the truck, I got on to the truck. They put hand cuffs on my hands. And we were driven to Batkovici, to the camp there.

(20) • Q.: What day, if you recall, were you finally released and made free?

• A.: From the camp?

• Q.: Yes, from the camp.

• A.: On the 26th of the December, 1995.

(25) MR. McCLOSKEY: I have no further questions,

• Page 3047 • {108/115}

(1)Mr. President.

JUDGE RODRIGUES: [Int.] I think that we need a break now. Perhaps a short break, 15 minutes. And then the Defence will ask its questions.

(5) --- Recess taken at 2.05 p.m.

--- On resuming at 2.21 p.m.

JUDGE RODRIGUES: [Int.] Witness Q, you are now going to answer questions which Mr. Petrusic, the Defence attorney, will ask you, (10)please. Mr. Petrusic, you have the floor.

MR. PETRUSIC: [Int.] Thank you, Your Honours.

• CROSS-EXAMINED by Mr. Petrusic:

(15) • Q.: Good afternoon sir?

• A.: Good afternoon.

• Q.: You lived in Suceska from 1992 until Srebrenica fell?

• A.: Yes.

(20) • Q.: Do you know that in that location, Mr. Zulfo Tursunovic lived there and was militarily active there?

• A.: Yes.

• Q.: He was one of the commanders in the military establishment?

(25) • A.: Yes.

• Page 3048 • {109/115}

(1) • Q.: Did he or somebody from his staff issue the order for the able-bodied men to take the route you took?

• A.: No.

(5) • Q.: The rallying of the population of that age group in Susnjari, did that take place spontaneously?

• A.: What do you mean? Could you explain that to me?

• Q.: When I say "spontaneously", I mean that there (10)was no order issued by anyone, any individual or body belonging to the military or the political leadership of the area?

• A.: I don't know. I know I heard from others that we were going to Jaglici, to Susnjari. I never (15)saw Zulfo, I think he must have left before then.

• Q.: Do you have any knowledge about the fact that units under his command in the summer and autumn of 1992 and the winter of 1993 until the area was proclaimed a protected zone had carried out combat (20)operations against both military forces of Republika Srpska as well as the civilian population around Srebrenica?

• A.: I don't remember.

• Q.: On the 13th of July, you were at the soccer (25)pitch in Kasaba?

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(1) • A.: Yes.

• Q.: You said that a list was made of those of you present there at the playing ground?

• A.: Yes.

(5) • Q.: Do you know, did you see who took that list?

• A.: I think it was Mladic.

• Q.: After that, you remained in the football pitch?

• A.: Yes.

(10) • Q.: Can you tell us when you left the field to go towards Bratunac?

• A.: It was in the afternoon an hour before nightfall, perhaps.

• Q.: And when did you pass through Kravica, was it (15)dark?

• A.: Not yet. It was dusk. Night had started to fall.

• Q.: On what side of the bus were you seated?

• A.: I was standing in the bus.

(20) • Q.: And this warehouse, how far is it from the road?

• A.: Not very far.

• Q.: Can you be more precise?

• A.: I don't know exactly. I couldn't really tell (25)you how far it was.

• Page 3050 • {111/115}

(1) • Q.: When from the school at Pilica, you went to fetch water, you heard shots or rather shooting that lasted. From that spot, could you see what was happening?

(5) • A.: No.

• Q.: What was happening in the schoolyard?

• A.: No, I only heard screams and shooting because it was dark.

MR. PETRUSIC: [Int.] (10)Mr. President, the Defence has no further questions.

• Q.: Thank you, Witness.

JUDGE RODRIGUES: [Int.] Very well, Mr. Petrusic. Mr. McCloskey, have you any additional (15)questions.

MR. McCLOSKEY: No, Mr. President.

JUDGE RODRIGUES: [Int.] No, Judge Riad.

JUDGE RIAD: No, thank you, Mr. President.

(20) JUDGE RODRIGUES: [Int.] Madam Wald, no.

JUDGE WALD: I have no questions either.

JUDGE RODRIGUES: [Int.] In that case, Witness Q, you have finished your testimony here (25)at the International Criminal Tribunal.

• Page 3051 • {112/115}

(1)We're very glad that you managed to survive those terrible events that you were able to testify to. We wish you a safe journey home and we hope (5)that you will have a life that will give you reason to smile again. Don't move for the moment. Mr. McCloskey, I think we have several matters to deal with this question of Exhibit 24/5.1. The exhibit submitted under that number was, in fact, (10)23/1.1, so we need to correct that.

MR. McCLOSKEY: Thank you, Mr. President. I'm, at this point, just slightly confused about all things exhibit-wise.

JUDGE RODRIGUES: [Int.] No (15)problem. Mr. Mark Dubuisson knows everything by exhibits and is going to explain it to us.

THE REGISTRAR: [Int.] Exhibit 23/1.1 is the document shown by the Prosecutor directly to the witness and it was a photograph which (20)was not annotated by Jean Ruez. It was a photograph of the school. And finally there is an exhibit, that is the first one that needs to be corrected. The second one is 24.5.1 an aerial photograph. Again, one that was (25)not numbered because 24/5 was annotated by the first

• Page 3052 • {113/115}

(1)witness. So 24/5.1 is an aerial photograph of the execution site.

JUDGE RODRIGUES: [Int.] I also know (5)a little bit about exhibits, don't I, Mr. Dubuisson? THE REGISTRAR [Int.] Yes, of course, Mr. President.

JUDGE RODRIGUES: [Int.] Mr. Petrusic, have you any objections regarding the (10)admission of these exhibits?

MR. PETRUSIC: [Int.] No, Mr. President.

JUDGE RODRIGUES: [Int.] Thank you very much, Mr. Petrusic. (15)So these exhibits will be admitted into evidence as explained by Mr. Dubuisson and which I also have confirmed. I think we have to make a very short break before we begin our Status Conference. So we will only (20)have a five-minute break. As I was saying, we need a five-minute break and we will have our Status Conference in closed session. Mr. Harmon, you have something to say.

(25) MR. HARMON: Yes, Mr. President. This

• Page 3053 • {114/115}

(1)morning I announced that we would have two witnesses and at the conclusion of the second witnesses, we would like to tender some exhibits, some additional documents. And if we could be permitted to do that (5)before we have the Status Conference then we can conclude the presentation of our evidence in this particular trial block.

JUDGE RODRIGUES: [Int.] Perhaps it will be better to do that afterwards. I think it is (10)more urgent to have the Status Conference than to have those documents. Perhaps during the Status Conference I can suggest a solution to deal with that matter. I think it is more urgent to have the Status Conference than to (15)deal with those exhibits now. So we're going to have only a five-minute break. We will come back into the courtroom without a witness. Please, Witness, don't move because of your (20)protective measures. Good-bye, witness, therefore.

--- Whereupon the hearing adjourned at 2.33, to be followed by a Status Conference

• Page 3054 • {115/115}