⁶²⁵ Tuesday, 14th July 1998

(Open session)

(The accused entered court)

(The witness entered court)

--- Upon commencing at 9.56 a.m.

THE REGISTRAR: Case number IT-97-24-T, the Prosecutor versus Kovacevic.

JUDGE MAY: Yes, Mr. Vucicevic?

MR. VUCICEVIC: Good morning, Your Honours. Good morning, Mr. Semenovic.

WITNESS: MEVLUDIN SEMENOVIC (Resumed) Cross-examined by Mr. Vucicevic:

Q. Good morning, Mr. Semenovic. Mr. Semenovic, you testified in the Tadic case and also you gave a statement in this case about the date when you met with SDS officers and the military commanders of Prijedor. In the Tadic case you said it was 16th, and then in Tadic case you said it was eight days before, another answer was eight days before the attack began, and then you said in this case, it was 15th to 18th. Could you please reconcile those dates for the Court?

A. When answering that question, I clarified that I could not give the exact date because I had not remembered the exact dates, but I gave it a time frame, ⁶²⁶ when this meeting took place, and I said that it was after the 16th or eight days before the attack, so that refers to the same period because the attack on Kozarac was on the 24th, but at any rate, the meeting took place within that time period.

Q. Directing your attention to the meeting itself that was held in the offices of SDS in Prijedor, you testified that Mr. Kurnoga was there, Mr. Kuruzovic was there, and the meeting couldn't get started before the military commanders came over; isn't that correct?

A. Yes, Mr. Miskovic said that the meeting could only start after Mr. Zeljaja and Mr. Arsic arrived.

Q. What was Mr. Miskovic's position in the SDS at that time?

A. He was the president of the Serbian Democratic Party.

Q. You testified in the Tadic trial that about half an hour later, Mr. Zeljaja, Lieutenant-Colonel Arsic, and another soldier or a military officer whom you did not know arrived; isn't that correct?

A. Yes.

Q. Did anybody else arrive with them?

A. I do not remember whether anybody else arrived with them. There were some persons present there previously, and I had mentioned them. ⁶²⁷

Q. ... that were present in the room, before the meeting commenced?

A. I already stated that Kuruzovic was present as well as Miskovic, Dusan Kurnoga was present, and there were another one or two persons whom I did not know, they were in civilian clothes. I assumed they were not members from the SDS leadership, but I do not know these persons so I could not tell you who they were.

Q. Is it fair to say you knew all the leadership of the Prijedor SDS by that time, having been in a coalition government with them?

A. I could not know all the SDS leadership because the leadership of every party consisted of a number of people who had at least eleven members. The SDS changes leadership at least two or three times. It was impossible to remember all these names. I only knew the persons with whom I had some direct type of contact.

Q. Could you please -- you have testified in the Tadic trial that Major Zeljaja told delegation from Kozarac to return 7.000 rifles. Then when you testified on Wednesday, you testified that Colonel Arsic told the delegation to return 5.000 rifles. Could you reconcile who said that and how many rifles indeed were demanded for return? ⁶²⁸

A. As far as I recall, Zeljaja said 5.000 rifles, and when Mr. Arsic referred to his intelligence officer who was sitting right next to him, the figure was put at 7.000, and for the entire Prijedor, I think the total number was 11.000. I do not know the exact number, but I know that it was over 10.000.

Q. Who made a demand or made an estimate that there was over 10.000 rifles in Kozarac on or about May 16, 1992, at the meeting in the SDS offices?

A. Nobody estimated that the number referred to Kozarac, but in the area of the Prijedor municipality. This is what Colonel Arsic was referring to.

Q. You referred to a statement made by Lieutenant-Colonel Arsic, wasn't it?

A. At that time, all their statements were important to us, not only at that time but even before, because we had been accused of something for which there was no evidence, and since these were accusations against us, we deemed them very important.

Q. ... you testified to that statement in Tadic's trial, didn't you, that there was ten to eleven thousand rifles according to Lieutenant-Colonel Arsic?

A. No, I do not remember whether I said that or not. That meeting took place -- it was a long one, and what I was saying at that time was answers to questions ⁶²⁹ that were asked and I was not in a position to say -- to state the entire event, and this is one of a large number of meetings which I attended before, during, and after the election process, so in that short period of time, it would have been impossible to interpret all of this, and even when you're asked questions, you cannot recall all the details. This is why you need a discussion.

Q. It seems it would be very important to distinguish political dialogue in the meetings and testifying in the court, isn't it?

JUDGE MAY: Well, I think that's a matter of comment, Mr. Vucicevic.

MR. VUCICEVIC: I will withdraw that one.

Q. In Tadic's trial, you testified that Mr. Medunjanin made a comment about the number of the rifles. What was the number of rifles that Mr. Medunjanin mentioned. Your Honours, I will direct you to the Tadic transcript, page 924.

A. At this moment, I cannot remember the number mentioned by Mr. Medunjanin. I spoke about that two years ago, so it has been two years since that time. I only know that he spoke about a much, much smaller number of weapons than the number for which we had been originally accused. ⁶³⁰

Q. So today you don't remember what you said two years ago; isn't that correct? And today you don't remember what Mr. Medunjanin said seven years ago -- six years ago?

JUDGE MAY: Mr. Keegan?

MR. KEEGAN: Yes, Your Honour, first I would object. Counsel is misstating the record. If he is going to refer to the record, I assume he is asking that this be admitted as evidence for consideration by the Trial Chamber, and in which case he is misquoting the evidence given by the witness, because at the time -- it's actually 923 on the transcript I have, the conversation which I believe he's referring to, and in which case Mr. Medunjanin was simply responding to --

MR. VUCICEVIC: Your Honour, I'm objecting to this --

JUDGE MAY: Let Mr. Keegan -- let Mr. Keegan finish.

MR. VUCICEVIC: Yes.

MR. KEEGAN: Of course, the testing of memory is a legitimate avenue but not when you're misquoting the witness which then misleads the witness, and can put the witness into conflict.

JUDGE MAY: What is the quotation?

MR. KEEGAN: There's nothing on 924, I ⁶³¹ believe it's on 923, the conversation, and Mr. Medunjanin didn't refer to them having a specific number of weapons, he was simply responding and said, "How can we give you 7.000 when there's not even a thousand?" So Mr. Medunjanin did not refer to a particular number of weapons, which is exactly what the witness is saying, and yet counsel is asserting that there is somehow a difference in the witness's testimony when there, in fact, isn't.

JUDGE MAY: I'm not, at the moment, going to ask the Trial Chamber to consider any question of admitting some previous statement as evidence. No doubt we can consider such an application in due course.

But clearly counsel is entitled to cross-examine about earlier evidence. I do wonder, Mr. Vucicevic, about how helpful it is for a witness to be cross-examined as to precisely what he said two years ago and whether he remembers what he said two years ago. It would be surprising if he did. Put any inconsistencies, by all means, to the witness, but I don't think we're going to be helped by a detailed recital of what the witness said or didn't say in Tadic.

Can we move on now -- ⁶³²

MR. VUCICEVIC: Your Honour, if I may comment?

JUDGE MAY: No, I'm not asking you to comment, Mr. Vucicevic, I'm asking you to move on, please.

MR. VUCICEVIC:

Q. Mr. Semenovic, I am directing your attention to your testimony in Tadic's trial, page 923, line 14, and I will read this for you, sir, verbatim. The question was: Did Commander Zeljaja indicate what he would do if 7.000 weapons were not turned over to SDS? Your answer was: Yes, he did. After these words of his, Mr. Medunjanin asked to speak and then Mr. Tadic. They said it was impossible to surrender 7.000 rifles when there was not even a thousand of them. Do you remember speaking these words?

JUDGE MAY: Well, now whether the witness remembers or not, that is what the transcript says in the Tadic trial.

Now, Mr. Semenovic, is that the position or not? Did Mr. Medunjanin say something along those lines?

A. Something along those lines, but the number of pieces of weapons, he did not specify. He did not say a precise number. He wanted to say that there was ⁶³³ not even an approximate number of the ones we were accused of. Now you have just reminded me. He said something to that effect. He did not say that Kozarac had about 1.000, he said, in fact, Kozarac did not have even 1.000. Those were his words. Of course, I testified two years ago, and I did not have an opportunity to read or review this testimony of mine, so that when I'm asked a question, I need to refresh my memory, I need to recall these events and what the gentleman is asking me about.

MR. VUCICEVIC:

Q. Mr. Semenovic, when you testified yesterday, you quoted Mr. Medunjanin that there was no more than 5.000 rifles?

JUDGE MAY: Mr. Vucicevic, I'm going to instruct you to move on. You've dealt with this point, you've drawn our attention to what it said in Tadic. I don't think we're going to get much further.

MR. VUCICEVIC: I was just, you know, pointing inconsistencies, you know, two years versus yesterday.

JUDGE MAY: You can make all those points in due course. Can we move on now to something else, please?

MR. VUCICEVIC: Yes, Your Honour. ⁶³⁴

Q. Mr. Semenovic, in the Tadic trial, right at the beginning, when you began discussing your political career, page 892, line 1. In answer to the question "Did you become involved in the political process at this time?" You said, "Yes, I became politically active as of the second half of 1989."

In your testimony yesterday, you said you began your political career, you became politically active as of the middle of 1990. Could you reconcile those two answers?

JUDGE MAY: I think you asked him yesterday about this. That's my recollection.

MR. VUCICEVIC: Your Honour, I intentionally, after hearing his answer, I intentionally omitted his reference to Tadic's trial. I think the record -- my recollection is clear, the record would reflect it. That's why I'm asking him today.

JUDGE MAY: Well, I don't think we ought to go back to all that again. You cross-examined about it very fully yesterday.

Can we go on, please?

MR. VUCICEVIC:

Q. Mr. Semenovic, when you testified yesterday, when the SDA was formed, you also indicated that the presiding officer, the chairman of SDA, on the State ⁶³⁵ level, was Mr. Alija Izetbegovic; is that right?

A. Yes.

Q. And you also testified a few days ago that SDA had a programme, didn't you?

A. Yes. Every party had its own programme.

Q. When did Mr. Alija Izetbegovic become the president of the SDA or the chairman, whatever the proper translation might be?

A. As far as I recall, I gave that answer yesterday. When the SDA was officially established, that was sometime in June in 1992 -- in the '90s. That is when it was registered and that's when its founding conference was held.

Q. ... founding declaration written by Mr. Izetbegovic?

A. Yes, I did. A lot was said about that. It was covered in the media, and Mr. Izetbegovic was very much in focus. No.

Q. Has Mr. Izetbegovic written any other books, to the best of your knowledge?

A. I believe that he wrote very few books, but I did not read them.

MR. VUCICEVIC: Your Honour, we would like to tender the next Defence Exhibit. Just different national practice. ⁶³⁶ Your Honours, I didn't get a chance because I got this book a couple days ago. I didn't get a chance to translate it. But I will read -- I will ask the witness to read a pertinent paragraph, and you will get a translation. In a couple of days, I will translate and tender to you the full translation of the exhibit.

JUDGE MAY: We will allow you to do it, but normally, you must understand, the Rules are these documents have to appear translated. As an exception, we will let you do it on this occasion, but in future, could you make sure it is translated, Mr. Vucicevic.

MR. VUCICEVIC: Your Honour.

Q. Mr. Semenovic, I'm directing your attention to the page 22, the last paragraph, starting with "First and most important of these conclusions," first two sentences.

A. I did read it.

Q. Would you read it out loud so that the Court -- the interpreters would interpret that for the Judges to hear what is being written there?

A. You mean to quote the text?

Q. Yes.

A. Here it states, and I quote: "First and most important of these conclusions and I did not read what these conclusions were, so the first and most important ⁶³⁷ of these conclusions is the irreconcilability of Islam and non-Islamic religions, there is no peace between and coexistence between the Islamic and non-Islamic social and political institutions."

JUDGE MAY: Do you want the witness to read on, Mr. Vucicevic?

MR. VUCICEVIC: Pardon me?

JUDGE MAY: Do you want the witness to read on?

MR. VUCICEVIC: No, Your Honours.

JUDGE MAY: Just that passage.

MR. VUCICEVIC: Just this.

Q. Do you agree with this statement, Mr. Semenovic?

A. No. I do not understand the context of it because I read a quote from a book which I have not read, so I don't know what preceded this quote and what came after it.

Q. I am asking you simply whether you agree or disagree with the statement that you just read, and I'll repeat it: "There is no peace or coexistence between Islamic faith and non-Islamic social and political institutions."

A. No, I absolutely do not agree with it.

Q. Where was the first annual convention, ⁶³⁸ anniversary of the SDA -- of the SDA of

Bosnia-Herzegovina held? I'm directing your attention to a year 1991.

A. You mean the first anniversary?

Q. Yes.

A. I don't understand.

Q. Where was the first annual assembly of the SDA for Bosnia and Herzegovina held, in 1991 being that the establishment was in 1990?

A. You mean the first convention or you mean the founding conference?

Q. Was there a meeting held in Foca in 1991?

A. There was a meeting in Foca, but it was neither a convention nor the founding conference, it was just a meeting. I heard that on television and I heard from within the party that they supported that meeting.

Q. ... Mr. Izetbegovic's presentation at that political gathering?

A. I do not remember following it.

MR. KEEGAN: Your Honour, I'm sorry. If I might? This is now approximately about the fifth question or answer that the reporter has not been able to get, the same problem as yesterday, that he is talking over the witness. You will notice in the ⁶³⁹ transcript we are missing the first part of questions. We have also missed answers.

JUDGE MAY: Mr. Vucicevic, did you hear that point made by Mr. Keegan.

MR. VUCICEVIC: Yes. I'm cognisant of that fact, Your Honour.

JUDGE MAY: Can you bear that in mind all the time, please?

MR. VUCICEVIC: Certainly, Your Honour.

Q. Mr. Semenovic, having testified that you disagreed with this statement of the party leader, isn't it fair to conclude that the Prijedor SDA disagreed with the policies of the leadership in Sarajevo?

MR. KEEGAN: Your Honour -- may I object to that, please?

JUDGE MAY: I don't think so. No, you can't object. It's not objectionable. But let's deal with these matters as quickly as we can, Mr. Vucicevic.

MR. VUCICEVIC: Yes, Your Honour.

JUDGE MAY: Mr. Semenovic, did the local SDA disagree with the policies of the Sarajevo leadership?

A. I just want to say that this is not a statement of the president of the party, this is a statement that this man gave 20 or 30 years ago in a ⁶⁴⁰ book, and this is the book. This book was written several decades before the period of which we are talking, and this is a quote from one book of this man.

Many years later he became the president of this party, and he did not give this statement, nor did he officially restate this as president of the party. He was talking -- he talked about this book on a number of occasions, but I was never much interested in that book, I never read it, and it was not part of the programme of the SDA. This is all I can state about it.

MR. VUCICEVIC:

Q. When you were referring to the arms that were available in Kozarac area, you said there were not enough arms even for one-third of the population.

A. I said that that was to illustrate the things that I was referring to before.

Q. ... you testified and you were shown the exhibits denoting the lists of the Territorial Defence mobilisation, call-up lists. You also testified in Tadic's trial that you participated personally in reinforcement of these lists. Could you tell the Court how many formation units of TO were there in Kozarac and surrounding areas? ⁶⁴¹

A. I don't know because I was not in charge of Territorial Defence nor was I in charge of the organisation of the Territorial Defence in this military sense based on the laws under which they were established, so I really don't know how many people were involved, how many pieces of weapons there were. It was not part of my duties, simply put. And I don't know these numbers.

Q. You testified that there was on April 8th, there was a letter or directive that came up from the Republic level indicating the call-up, mobilisation of the Territorial Defence. Do you know who issued that order?

A. I said that as far as I recall this was on the 8th, so it was probably on the 8th of April, but I'm not sure about it. However, what I am sure of is that it was an order of the Presidency of Bosnia and Herzegovina. The territorial staff of the defence of Bosnia and Herzegovina was established and this decision was read on the radio, anybody could have heard it. I think that also Croatian television carried it as well as some others.

Q. It was on April the 8th, State of Bosnia and Herzegovina called up all its armed forces which it had on its command; correct? ⁶⁴²

A. It issued an order on mobilisation of Territorial Defence, and I mentioned this order.

Q. In Prijedor, SDA committee implemented that order on the Muslim populated and dominated area, isn't that correct, by setting up the checkpoints?

A. No. There was a Territorial Defence command in Prijedor, and it was in charge of implementing this order. However, it had a mixed ethnic composition, and the relationship between the leaders of Serbian ethnic background -- I have already explained their position in view of this. So in this context and in view of these relationships, this order could not be implemented because part of the people did not accept this order. I said that this order from -- this order could not be implemented completely in Prijedor, which meant that in a part of Prijedor, a decision of the Presidency of the State cannot be implemented. Some people started implementing parts of this decision; however, it was not very successful because the central coordination was lacking.

Q. You were a politician from -- living in Trnopolje, a politician for the whole municipality. You were indeed very concerned when this order came down, weren't you?

A. Yes, I was concerned even before this order ⁶⁴³ because daily we watched events that I have already described in my testimony, there were explosions, shootings, and everybody was concerned at that time.

Q. Yesterday you testified that JNA tank was positioned on or about May 3rd at the intersection of the main road from Prijedor to Banja Luka, so-called Banja Luka Cesta, and the main side road that is going into Kozarac; isn't that correct?

A. Yes. As far as I remember, it was on May 3rd.

Q. And at that time was there a checkpoint by Kozarac or just on the other side of the road?

A. I think yes. After the tank appeared, people created this checkpoint and sort of protection -- sort of a shelter, I think it was made out of wood or sand.

Q. So basically JNA soldiers on one side of the road and SDA army, TO, from the other side, were staring at each other across the road, down the gun barrel?

A. Those were not the JNA soldiers, it was mainly the known persons -- well-known persons and people from Kozarac even talked to them. I have in mind soldiers that were around the tank and the crew of the tank. Those were people, older people from Kozarac and from the area who served their army service a long ⁶⁴⁴ time ago, and this happened after the take-over of the power by SDS in Prijedor, three days after that take-over, the tank appeared there, and the population was just basically taken by -- overcome by panic and they tried to create some kind of shelter for themselves, protection.

You said on one side there was TO and on the other side was the JNA. No, it was not the JNA. We could clearly recognise the soldiers of the JNA. At that point, part of the soldiers of JNA were in Benkovac in the military camp, and we know that because many of them wanted to escape and they would apply to people in Kozarac, and some of the people in Kozarac would help them and procure a civilian wardrobe so they could escape. There was an example, a baker, Jevid, provided clothes for several soldiers of the JNA so they could escape. Another example is Avdo Mujkanovic. He also assisted them.

MR. VUCICEVIC: ... from in a intersection that I just asked about.

JUDGE MAY: Yes. Your next question, please.

MR. VUCICEVIC:

Q. Isn't it fair to say that from April the 8th, there was a state of Cold War in Bosnia between SDA and SDS based on what you just testified? ⁶⁴⁵

A. I don't understand the term "Cold War," the state of Cold War. We were issued an ultimatum, and prior to that, the officials in their discussions and on the radio broadcast, after the take-over, they were issuing messages and saying -- stating that very clearly, they want disarmament of extremists, and after that the tanks appeared and things were obvious. If you wish to ask me if, on one side, there was a checkpoint of TO and on the other side was the tank, yes, that's clear. It's an obvious matter.

Q. So on or about May 16th, when you and the other officials from Kozarac were issued ultimatum by the JNA commanders, you go back to Kozarac and discuss that ultimatum with anybody?

A. Yes.

Q. Whom did you discuss it with, when and where, location? Who was present?

A. I don't recall the exact date. I think it was a day after this meeting in Prijedor. A meeting was called, a mass meeting was called, and there were representatives of the local communes there, police and Territorial Defence representatives, all of them came and the meeting was held in the building of the elementary school in Kozarac.

Q. Did you speak at that meeting? ⁶⁴⁶

A. Yes, I did.

Q. Did anybody else speak at that meeting?

A. Becir Medunjanin spoke as well. Many people spoke. It was a meeting that lasted for several hours, because after these threats, it was obvious people would be killed and we looked for a solution. Many people spoke and I really cannot remember the names of 20 or 30 people that did speak.

Q. Basically choice was either to surrender the arms or go to war, to shooting war. What did you recommend?

A. No, no. The choice was to surrender the weapons and to have the Serbian police enter Kozarac and raise the Serbian flag. That was what we were asked to allow.

Q. ... for the gathering at the elementary school?

A. I did not have a proposal. I interpreted what I had heard at that meeting that I've mentioned. People were called to the meeting to discuss this and to make a decision. I did not suggest anything at that time.

Q. Do you remember what Mr. Medunjanin said at that meeting?

A. I don't remember quite well those speeches, ⁶⁴⁷ but I know that Medunjanin didn't have a specific proposal either. The purpose of that meeting was to make some kind of a common -- issue some kind of a common decision; however, not to pass the decision by an official or an official of the TO or a politician. If we had wanted to do that, we wouldn't call upon the people to come to the meeting. The purpose of the meeting was to have a large number of people make a common decision that would be supported by everybody, and if I remember correctly, Becir Medunjanin did not say "We will do this and this" or "We should do this and that." He simply called the meeting in order to ask what was the will of the people present there.

Q. My question put --

JUDGE MAY: That was an example. The interpreter hadn't finished.

MR. VUCICEVIC: Sorry, Your Honour.

JUDGE MAY: I may have to insist in due course that you put the ear phones on so you can hear, Mr. Vucicevic.

MR. VUCICEVIC: Yes, Your Honour. It will be helpful.

JUDGE MAY: It may be helpful.

MR. VUCICEVIC:

Q. Mr. Semenovic, was there a question put to ⁶⁴⁸ the assembly on the issue whether to surrender the arms and accept the Serbian authority in Kozarac or not? Was there a vote taken on that issue by the assembly of people?

A. I don't remember exactly, but I do think that there was some kind of expression of opinion.

MR. VUCICEVIC: Your Honours, this was indeed a very important meeting and this seemed to be a democratic process taking place. If I may follow up with the same line of questioning?

Q. Mr. Semenovic, there was indeed an important issue debated. One of the most important issues in the life of all politicians from that area. And SDS and SDA advised and supported democratic processes. How was a decision reached at that meeting and what was the decision?

A. The decision at the meeting was for us to abide by the laws of Bosnia and Herzegovina because we did not recognise the State that was created by the Serbs. They had already by that time created Serbia and Bosnia and Herzegovina, and they wanted this part to become a part of the Serbian Bosnia and Herzegovina, and at the end, the decision was made to follow the instructions of the presidency of Bosnia and Herzegovina and of our authorities. ⁶⁴⁹

Q. So what was the direction by your authorities which you followed on the point of ultimatum that was before you?

A. We did not have any contact with our authorities in the Republic, we had no telephone communication or any other means of communication. The only thing we had were the laws of Bosnia and Herzegovina, we had a Territorial Defence as a structural organisation of Bosnia and Herzegovina, we had police in Kozarac as a structural organisation set up by the laws of Bosnia and Herzegovina. That's all that we had. And we also listened to radio broadcasts, we heard the statements by the officials and the views taken by the presidency.

We had two options, either to stop -- cease being Bosnia-Herzegovina and agree to enter the newly created Serbian Bosnia-Herzegovina or to remain Bosnia and Herzegovina, and people decided to remain in Bosnia and Herzegovina. That was the decision reached at that meeting.

Q. Mr. Semenovic, you were informed that Kozarac was encircled. Based on information received before, you knew the location and the strength of the military that was opposing you and their artillery, the numbers, and it seems the decision before you and the ⁶⁵⁰ people of Kozarac is not to defend independence of Bosnia and Herzegovina at that point, but to decide whether to fight or not or to surrender. Could you narrow your answer to that

question, please?

A. I can tell you the following concerning that issue: People had decided -- of course, everyone was afraid for their lives. We were aware that we were completely surrounded and we decided to continue to exist as Bosnia and Herzegovina because only as such we had a right to legal defence, lawful defence. Also at that time there was a decision issued by JNA to withdraw from Bosnia and Herzegovina. That was broadcast on the radio. The Security Council of the U.N. also made a resolution concerning the aggression in Bosnia and Herzegovina, and we expected that despite this huge military force that was around us, we believed that in view of this decision, resolution by the International Community, that the attack would be prevented and we thought it was just a matter of a few days when this decision on withdrawal would be upheld, and, of course, at that time we just wanted to make sure that we did not provoke any action. The decision at that meeting was to abide by the legislation of Bosnia and Herzegovina and to maybe ⁶⁵¹ protect ourselves legally should we be attacked. And the decision was, should we be attacked, to defend ourselves, and the only way people could defend themselves was through the Territorial Defence because that was the only remnant of our defence structure under the auspices of the President of the Republic. Everywhere around us was the new state of the Bosnian Serbs that they had created.

Q. Mr. Semenovic, I am bringing you back right to that meeting in Kozarac that you described earlier. Have you, in your address to the meeting, spoke these words that you spoke before the Court about international situation and imminent international developments while facing the ultimatum? Have you spoken about this same issue that you just informed the Court?

Your Honour, if I may instruct the witness to just answer "Yes" or "No" and I'll follow up very quickly.

A. I don't recall.

Q. So perhaps you could have spoken about this at that time, could you?

A. I really don't recall.

Q. You have testified that you had volunteered for the TO. What was your military assignment or ⁶⁵² fighting assignment in TO before the fighting started on Kozarac?

A. I didn't have any special duties. I was placed -- I was a member of TO at their service and I didn't have any particular duties.

Q. Who was the president of the local board of the SDA in Prijedor at that time, in Prijedor municipality?

A. Dr. Mirza Mujadzic.

Q. Had you consulted him after the ultimatum was given to you on the 16th of May?

A. No, it wasn't possible to establish any kind of connection anymore.

Q. Did you know perhaps where he was at that time?

A. No, I didn't. I knew where he lived and where his house was, but I didn't know where he was at that point. I didn't know if he was at home or some place else.

Q. You testified yesterday that Mr. Medunjanin guaranteed to military commanders that the Moslem side or Territorial Defence shall not open fire first.

A. Yes. He said in Kozarac it is definite that nobody would shoot at your army.

Q. But yet the fire was opened at Hambarine ⁶⁵³ checkpoint on the 22nd of May; isn't that true?

A. Yes, I had heard that on the radio. However, I wasn't present in that part of Prijedor, and I don't know what, in fact, did happen.

Q. Do you remember exactly what you heard on the radio at that time about the military confrontation at Hambarine checkpoint?

A. I do not remember exactly, but on the radio they said something that there was fire, some shooting, somebody was shooting at the Serbian army, and I think it was information of the Crisis Staff, I don't remember exactly because we were in Kozarac, we were surrounded, and we had no physical contact with that part.

Q. Did you hear any ultimatums given to the Hambarine TO over the radio shortly thereafter after the incident happened?

A. No. As far as I remember, some kind of ultimatum was mentioned in that news, but I cannot remember precisely.

Q. After the military activities on Kozarac on the 24th, have you managed at all to go to Kozarac in the next day or two or three?

A. I tried once, but then after that, no, there was no opportunity for that after that. ⁶⁵⁴

Q. Have you been in any contact with the political leadership of SDA after 22nd of May? And I'm directing your attention only for the three months of 1992, summer months.

A. No, I had no contact. I only met a gentleman, his name was Besim Alic who was in the Territorial Defence staff, and I met him mid-July. I already mentioned that I had remained completely alone in that area where I was hiding, and at that time I met this gentleman, Mr. Alic. We had a very brief conversation, two or three sentences, and he said that he's going over the mountain of Kozara and he left and I have never seen him after that.

MR. VUCICEVIC: Your Honours, this might be a good time to adjourn because we will have a tape for the continuation of the hearing or I can go for another --

JUDGE MAY: No, that's a convenient moment. Twenty minutes.

MR. VUCICEVIC: Thank you, Your Honour

--- Recess taken at 10.57 a.m.

--- On resuming at 11.26 a.m.

MR. VUCICEVIC: Your Honours, if I may point out to the exhibit that we introduced earlier titled "Islamska Deklaracija," "Islamic Declaration," that ⁶⁵⁵ publication was -- here is the book.

JUDGE MAY: Yes. What was the date?

MR. VUCICEVIC: And the book, the publication was by small Muslim library, that's the publishing house that's published in Sarajevo in 1990, for your inspection.

JUDGE MAY: We will admit the exhibit when it is translated. Yes, Mr. Vucicevic?

MR. VUCICEVIC: The second point, when the -- I pursued a line of questioning on the meeting that took place after the ultimatum was issued by the military commanders, and the meeting took place in Kozarac. I noted the witness used the word "consensus" and translation was made "a decision," and I'd just like to pose a question just to clarify that point, Your Honour. That was pointed out to me by co-counsel during the break.

Q. Mr. Semenovic, when you testified about the ending phase of the meeting that took place at the elementary school in Kozarac, was there a vote taken?

A. I said that there was some kind of expression of will, and I do not remember what exact kind of expression of will, but the point was for the people that came to the meeting, to express their opinion on a common view, common position, with respect to the ⁶⁵⁶ problems that surrounded them. I don't remember if they voted by raising their hands or it was some kind of a collective expression of will, I really don't remember. I stated that before.

Q. You just referred to collective expression of will. Could you explain, what do you mean? How is that being done?

A. There is voting where you make the ballots with the voting lists and then you put the questions on the list and then you put it in the ballot boxes and there is voting conducted in such a way that peoples names are called up and people get up and they say "Yes" or "No." There is also a type of voting where all the people gathered there are asked, "Do you agree with this proposed solution?" And then everybody who is for it raised their hands and those who are against it that don't raise their hands, and then you establish whether you have a majority, whether everybody voted, whether you had enough people for or against it, and this is all different type of voting.

I know that we didn't have ballots, this is not how we voted at that meeting. It was some kind of other means of expression of will.

Q. So today you clearly explained several modes by which the people could express their vote, informed ⁶⁵⁷ decision, but you also testified that you really don't remember which one of these means was used.

A. I don't remember if people's names were called out one by one or all of those who were present there were asked whether they agree and they had to raise their hands, I don't remember because in the years prior to that, I participated in a lot of types of voting and I really don't remember which kind of voting took place at what meeting. It would be impossible to remember that.

Q. Isn't it fair to state this was one of the most important meetings in your life? Wasn't it?

A. There were several most important meetings in my life.

Q. But this one you just do not remember, do you?

A. I don't remember, sir. We were under terrible pressure, we lived in fear, and we arranged that meeting fearing for our lives, so I think you can understand how we felt at that point. It was a question of whether we will survive or be killed, and we also had to decide how to avoid the mass murder that we saw on TV was taking place in other municipalities in Bosnia and Herzegovina.

Q. Thank you, Mr. Semenovic. I will move on, ⁶⁵⁸ Your Honours.

Mr. Semenovic, in Trnopolje, did you have any family members who lived in the same house with you?

A. My mother was there.

Q. Did you go in hiding immediately after the military action started in Kozarac?

A. I said that yesterday. On the second day after the mass exodus started from Trnopolje, I started hiding so that people would not suffer if the military who was approaching were with me, because in the eyes of these Serbian authorities, I was an extremist.

Q. What happened to your mother during that period of time? Could you tell the Court?

A. You mean in those days or later, during the entire period?

Q. Both, both.

A. Could you please specify? My mother also started hiding. First she was in the village of Sivci with a group of -- large group of people, then she had to leave that house, and she wandered about through the forests and across the fields, and she herself did not know where she was going, exactly, and somehow she managed to get to Prijedor through Garevci, which was a Serbian area. ⁶⁵⁹ This is an elderly woman who can barely read and write. She found a person in Prijedor who hid her there and then sent her to the village of Cejreci. From the village of Cejreci, together with some other women, she went to Hambarine. When the Serbian authorities gathered women and children and put them on buses in order to transport them, she was among them and they were transferred to Trnopolje in a convoy. There they spent one night, and the following morning, on these buses and trucks, they took them to Travnik, that is to the village of Turbe which was under the control of the Bosnian army.

In Prijedor, it was Muharema Trnjanin's wife who helped her hide, and I don't know about other names.

Q. Was your mother ever inquired about your whereabouts?

A. Yes.

Q. Could you tell the Court about that occasion?

A. Yes. I mentioned that my mother was in the village of Cejreci with a large group of people, and a couple of days later, the people started fearing her because she was the mother of a Muslim extremist, as the Serbian authorities called me, and so they asked her to leave this house, which is the house of Osman ⁶⁶⁰ Sivac. So she left the house. She wandered in the fields, she was hiding there.

Then she went back to the house to pick up some things because she realised she had to flee, and she did not have personal effects that she needed to take along. And so she went to the house -- this was our house now -- and they -- according to what she said, four Serbian soldiers came, they came in a car, they surrounded the house, two of them stayed outside and two of them entered. They mistreated her there, they threatened her, they put the barrel of their rifle in her mouth, and after that, they took her to the car. Leading her to the car, they opened the back door, and she is very short, she's only 150-plus centimetres, and the car was parked next to the vineyard and there was some bushes, and she ran and hid down in the creek. They went looking for her, they shot around, they searched through the garden, they searched through the little forest; however, she was in that creek which had a lot of undergrowth and she went upstream and fled.

So this was going on during that day. What she told me. And part of these events were witnessed by some other people who later related it to me. Later on, I received information that she had been killed ⁶⁶¹ because some people observed when she was led out of the house, and later on, they heard shots and they thought that she had been killed. However, later on, it turned out that she managed to flee.

Q. That was indeed a very difficult time that your mother survived. But nevertheless, later on, when she came to Trnopolje, she was transferred to the Bosnian Muslim territory; is that correct?

A. Yes, that is correct.

Q. And I hope that she is living and well today.

A. She's alive.

Q. You testified that you found refuge in a house of a Ukrainian lady and you stayed there for a month; isn't that correct?

A. No. In a house of a Muslim woman, but her house was among the homes of Ukrainians, her neighbours were Ukrainians. This is the wife of Dzemala Sivac, we called her Hada Sivac, she is also alive today.

Q. This is a rather new effect that has come up. Could you please explain to the Court the origin of the Ukrainians around the Prijedor area, they assimilated, their parties affiliations, their religion, so that we will know?

A. I mentioned that in Trnopolje, there were a lot of ethnic groups. I believe there were 17 of ⁶⁶² them. Among them there were a number of Ukrainians, there were two German families, there were Turks, Albanians, Romalis, Serbs, Croats, and as far as Ukrainians are concerned, I do not know much about their past, or about them. I had some friends at school who were Ukrainians and later on colleagues. I don't know when they had settled there. I know it was in some distant past, but I know that these people whom I knew were born there and they lived and worked on their properties regularly like everybody else.

Q. But isn't it fair to conclude that the Ukrainians' families that created majority in that hamlet were friendly to the SDS or at least you perceived them friendly to SDS?

A. No. No, that was not my perception. A certain number of Ukrainians managed to escape from the area before the events that we are talking about, and those who did not manage to do so remained there, and out of those some, probably out of fear, agreed to be mobilised.

After these events, there were no more Ukrainians left in the village, and I believe that today there are none there.

Q. But at least it will be -- could we state they were neutral as far as the relationship between ⁶⁶³ SDS and SDA because you sought refuge in that village because there was predominance of the Ukrainians, and Ukrainian who was in the military uniform at that time had given you some information.

A. No, not to me. They were neighbours of Ms. Hada who had offered to hide me. I did not make any contact with the Ukrainians, they did not know that I was there. In fact, she was asked at one point, because I guess they had suspected that she was hiding someone and she denied it.

Also, I can confirm that there were not many Ukrainians who agreed to be mobilised. It was a small number. And perhaps they did so because they felt that they had to, because they feared for their own lives.

Q. Do you know whether the Ukrainians in that village where you sought refuge were Orthodox or Catholic or any other religion?

A. They are members of some type, I believe, of a Catholic religion. I think that they call themselves Greek Catholic, I think that's how they define it. I had a colleague in school who was that. But I don't know enough about the distinctions between the Roman Catholic and the Greek Catholic. Whether there were any Orthodox there, that I also do not know.

MR. VUCICEVIC: Your Honours, I'd like to ⁶⁶⁴ move on, and if we could view the tape that the Prosecutor introduced yesterday? Of course, I will not suggest that we view it all, just a few scenes.

(Videotape played)

Q. Mr. Semenovic, do you recognise the intersection in the background of the picture?

A. The image that I have on the screen is pretty bad, so I'm not sure that I can see very well what area this is.

Q. I will direct your attention that this was footage that was taken in and around Trnopolje detention centre. Does that refresh your memory?

A. Yes, yes. I believe this is where the substation, the power substation is, if I see it correctly because, as I said, the image is very bad, and the road could be the Trnopolje-Prijedor road, as far as I could see.

Q. So the Trnopolje-Prijedor road is the stretch of road going from the left edge of the screen to the electrical station here; right?

A. Yes, yes.

Q. And that road runs basically east-west?

A. Yes.

Q. And the other road is intersecting the Trnopolje-Prijedor road at 90 degrees, doesn't it? ⁶⁶⁵

A. Yes, and it's going in the direction of Kozarac. And the road which we have just described is going towards Omarska.

Q. So it wouldn't be fair -- strike it. What does this corner represent then that you see in the picture?

A. This is part of the area which was part of the business premises of the agricultural commune, so it was the substation and then, to the right, there were warehouses of this commune and their buildings.

Q. So is this electric station, trafo-stanica you called it, that's in the very corner of the property as you described; is that correct?

A. Yes.

Q. Take a look at this photo. If you can maybe move it a little bit back and forth so we would get a clearer image?

I'm directing your attention, Mr. Semenovic, as the tape is being played, to observe if there is any fence? Could you play it forward now?

(Videotape played)

Q. Is there any fence at this corner?

A. No. Here, on this tape, I cannot see a fence.

Q. That's enough, please. In relation to this ⁶⁶⁶ corner that we have on tape, could you describe where did you get in and out on few occasions into this camp, because this would be a south-west corner of that detention centre?

A. It would be the opposite end, over to the right, behind the old cinema building and school building, and on the tape, that would be even farther. The other side that is completely opposite to this side.

Q. Were you inside Trnopolje detention complex, had you ever come close to this corner that you see now in front of you?

A. No, no. But I know this area because my house -- it can almost be seen from this vantage point at the end of this road which you have shown, Prijedor Trnopolje, at the end of that road on the right is my house. You can see a pine tree which is in front of my house, behind this pine tree to the right, at the very pine tree is the entrance to my house, and then behind it is my house, and you cannot see it because there is a lot of greenery covering it. So I knew this area or this terrain quite well.

Q. Indeed. That is indeed very helpful. Based on your recollection prior to -- just immediately prior to the armed conflict around Kozarac in this area, what ⁶⁶⁷ kind of fence was on this corner, if you recall?

A. In this part, in this area, when I arrived there, which officially was the camp, in certain parts had a fence, but the fence did not fully surround the compound. This area towards the road did not have a fence, neither before nor during that time when there was a camp there. However, there were machine gun nests there, near my house, and then in this open clear area, on the balcony of Hamdo's house, and then over on the other side on the side where I would enter, behind the road, there was a row of houses between the school building and the house across, there was a barn. This barn was open on both ends. And in this barn, there was also a machine gun nest.

The portion that you just showed me, near the place where the camera is standing there was some kind of a bunker and maybe another 50 or 80 metres away from that, there was another military sentry post there, and another further metres along the road there was another sentry post, so this fence was not there along the road, it was on this front side. I don't know how long. Then there was the school fence and the warehouse fence and then there was also a section of the fence where I was entering, from the school and onward, and again there was a clear open space to the ⁶⁶⁸ house of Hamdo who I have just mentioned. These open spaces were under guard, and

these sentry points where these machine gun nests were always manned and somebody was always observing.

Q. Mr. Semenovic, you just testified about the position of the machine gun nests?

A. Yes.

Q. In this very location here, but indeed, just a few moments ago, you testified that while you were in the camp, you never came to this corner. Could you please tell us when did you ascertain a position on those machine guns?

A. When I entered the camp, when I crawled through the canal which I described, I saw the machine gun nests in the barn which I have mentioned. I also saw machine gun nests on the balcony of Hamdo's house, I saw the machine gun nest -- here we go again. Here's the tape.

(Videotape played)

A. Here to the left of this image, the machine gun nest that I described on the road, I did not personally see, but I contacted about 15 people in the camp and I asked them what the deployment was when the convoys were going and all that stuff. So the majority of people who were there knew about this. I personally ⁶⁶⁹ did not see it, but other people did. So all this was in one and the same area. But I did mention the ones that I saw personally.

Q. Place, the exact place, where you entered Trnopolje centre was along this road that we see here but way down west -- I mean -- strike it -- east?

A. Across from this road. It was behind the substation and the school. It was a lawn. It used to be a soccer field. Parallel to that road, the other end of this soccer field is where I came in; in other words, not this road but the opposite end, the opposite side.

Q. Just to make sure that we are talking about the same location, the place where you entered the centre, was it diagonal corner from this corner or the corner which is way to the left as we are looking now on the picture?

A. To the right, not to the left, all the way to the right of the image, and you cannot see that part.

Q. Okay. Now we are seeing a man with a wheelbarrow pushing something in a wheelbarrow. Could you tell us what was held in these containers, if you do know?

A. You mean in the wheelbarrow?

Q. Yes. ⁶⁷⁰

A. This is probably one of the people who had received permission to go home and bring back a sack of flour or something else which he had, because every few days, the police would give permission to a few people to go to their homes and bring wood to build a fire for big caldrons or to bring potatoes if they had any in their back yards, and these permits were issued every several days. However, I do know that they had to receive permission, they had to talk to the guards, and some of them were allowed to go there and some of them were not. However, they all had to come back within a defined period of time.

Q. The persons under special permission were not escorted by the armed guards to their houses, were they?

A. No. I mentioned the road Trnopolje-Kozarac. On that checkpoint, the permits were issued and also the deadline -- the specified time within which they had to come back, and also I heard that close to my house there was a checkpoint as well, and that you could also get permission to leave there and you would go and let them know when you're leaving and they would record the time of departure.

Q. But just to be clear, the picture depicting this man is taken inside the camp, not the outside of ⁶⁷¹ the camp; isn't that correct?

A. Yes, yes. I think that a person brought back flour, maybe water from somewhere. I can't see very well on this picture what it is. If it's flour, then based on the permit, he probably went and got it, and if it's water, if it's a water gallon, then the water was probably brought from the pump which was about a hundred metres away, by the school, because this part didn't have really running water and I guess people needed drinking water, so I can't really see what is in the wheelbarrow so I can't tell you precisely.

Q. So this could be a container in which the water was held for the people in the detention centre; is that correct? Because there was no water in this part of the centre.

A. No, there was just the electrical station here, there was no water.

MR. VUCICEVIC: Will you please move on to the next section of the tape?

(Videotape played)

MR. VUCICEVIC: Further back. You just passed the point that I had some interest in. Could you rewind it, please? Could you rewind it some more? Some more? Right here. Move up a little bit to the point that I indicated to you on the break. Okay. ⁶⁷² Right here.

Q. Mr. Semenovic, I am directing your attention to two fences. There is an inner fence and it seems there is an outer fence; isn't that correct?

A. I don't know that there is an inner and outer fence.

Q. Could you describe what is the building in the right-hand corner of the picture now as you see it on the screen?

A. This is the building of the old cinema, and it belongs to the complex -- to the compound of the local commune building.

Q. And where is that trafo-stanica corner that we just looked earlier in relation to this building?

A. To the left.

Q. And where is that storage material building that you indicated earlier in relation to this building?

A. To the left.

Q. Having lived several years just perhaps 200 yards away, if not less, do you recall what was this fence that is now on the screen?

A. It was the fence that existed prior to this, before it existed before the one that we can see on the screen. ⁶⁷³

Q. And this was also a fence that was a perimeter of the detention centre, isn't that correct, when you were there?

A. Yes.

MR. VUCICEVIC: Could you move to the next section of the tape, please? You can fast-forward. Okay. Stop here.

Q. You see these wheelbarrows here, don't you, Mr. Semenovic?

A. The image is not really good, but I do suppose that these are wheelbarrows.

MR. VUCICEVIC: Could you just run the tape back and forth, please, so that we can get a clearer image?

(Videotape played)

Q. Okay. Do you see a little bit better now, Mr. Semenovic?

A. Unfortunately, the image is really poor, but I do suppose that these are wheelbarrows. They certainly look like wheelbarrows. It's quite possible that they are.

Q. These wheelbarrows belonged to the building material company, didn't they?

A. That's possible, but I'm not sure.

JUDGE MAY: Mr. Vucicevic, we should be sure ⁶⁷⁴ about this. This is Omarska, isn't it, or are you back at Trnopolje.

MR. VUCICEVIC: This is at Trnopolje, Your Honour.

JUDGE MAY: You're still at Trnopolje.

MR. VUCICEVIC: Yes.

JUDGE MAY: Very well.

A. I'm not sure. It's possible that they belonged to the company and also possible that they belonged to the people who were allowed to go out and fetch the flour, and this is why they, after they completed the task, left their wheelbarrows here, but I'm really not sure.

MR. VUCICEVIC:

Q. Do you see the house which is right in the middle of the screen there? Perhaps you lived in that area and you might know whose house that is, the house way in the back.

A. I can't see, really.

Q. There is a house, as the image is moving, between two blond men in civilian uniforms. It seems they are reporters. Way in the back. Do you recognise that house?

A. I see the edges, but I guess it's a house of ... I can't see well. ⁶⁷⁵

Q. Play it a little further. Slow.

(Videotape played)

MR. VUCICEVIC: Could you stop it here?

Q. Do you recognise the tree line in the back here?

A. I don't understand. I do see that these are the trees --

Q. Do you recognise this particular cluster of trees, having lived there for so long and having been at the camp, detention centre for a little bit?

A. I think that these trees are those that are located on the road in the direction of Prijedor. I think that it's in the vicinity of the house of -- Hamdo's house that I've mentioned.

MR. VUCICEVIC: Could you move it to the next -- quickly to the next piece, section of the tape?

(Videotape played)

MR. VUCICEVIC: Could you slowly now play that part of the tape from here?

(Videotape played)

MR. VUCICEVIC: You can play it normal speed, I didn't mean slow, just play it normal speed.

Q. Mr. Semenovic, I'm directing your attention to the people that are next to the fence and the people ⁶⁷⁶ that are getting out.

That's enough. Thank you. Mr. Semenovic, did you recognise that part of the fence there in the picture now?

A. I think that this is the fence by the road, Trnopolje-Kozarac. I think that's what it is. And across from this fence are the houses, mostly Ukrainian houses, in which at that point still some Ukrainians resided.

Q. You would agree with me at this point at least, in the detention centre, the people are walking in and out freely, were they?

A. No, no. I think -- I suppose that these people on the road are the people that actually live in the houses that I have mentioned, in the houses across from the camp. There was a family of Pavle, the Ukrainian who was there, and also some other families who lived there for a while before they departed as well.

Q. But we've seen two civilians, two young girls, walking out?

A. Yes. I'm talking about the people, about the families that actually lived there. I suppose that these are those families.

Q. Could you please play the tape back again? ⁶⁷⁷ Only with the civilians getting out of the -- the section of the fence where the civilians are getting out.

(Videotape played)

MR. VUCICEVIC: A little more. Could you back it up just a bit more? You can play it at a normal speed from here.

(Videotape played)

Q. Could you direct your attention, Mr. Semenovic, to the man walking now in the picture? The girl coming out, the second girl coming out. Thank you. You can stop playing this

footage. Mr. Semenovic, do you recognise the man, elderly man, who walked in on that part of the film?

A. No, I don't recognise. I don't know who it is.

Q. You testified about Ukrainian men having a house just across the street. Are these girls that walked out part of the household?

A. I don't know. I didn't recognise the exact persons. I have just said that in these houses across from the camp at that point there was still some people residing there, and also the people from the Serbian Red Cross from Prijedor visited the camp as well and ⁶⁷⁸ there were civilians. Also the treatment was different for men and women in Trnopolje. The men were treated much, much more strictly. And they were not allowed to leave the camp without permission.

Q. But the elderly gentleman who we saw in this footage seemed like he was bringing something in a container to the centre, didn't he?

A. No, I don't know.

MR. VUCICEVIC: Could you play that part of the tape back, please?

(Videotape played)

MR. VUCICEVIC: You can play it from here.

Q. There are two uniformed men right on the road now, as you see, and there's a man with a white T-shirt coming out carrying a container in his right hand.

A. I think he was going to fetch the water into one of those Ukrainian houses.

Q. So would it be fair to conclude that was one of the detainees or the refugees at this centre going to get water at this time?

A. It is possible, but I'm not sure because I don't know this particular person and he must have had permission because otherwise he wouldn't have been able to go there. I know that for a fact.

MR. VUCICEVIC: Go to the next segment of the ⁶⁷⁹ tape.

Q. You testified yesterday that this man is Mr. Kupresanin; is that correct?

A. Yes.

Q. What was his position in the assembly of Bosnia and Herzegovina at the time when the coalition government was formed in the beginning of 1991?

A. He was a member of the parliament of Bosnia-Herzegovina, just like me.

Q. Was he in the leadership of the SDS, on the State level?

A. I don't know about that.

Q. Have you had any communications with him, any conferences, either professional or social in terms of determining the policy, or trying to do a better job as a legislator or any conversations with him in the beginning of 1991?

A. I have seen him in the parliament and I have listened to him talk just like other legislators from other parties. We didn't have any particular contact, nor did we carry on any particular conversations. He was just a member of the parliament just like me, and since I was a legislator as well, I've seen a lot of these people, sometimes I would listen to their speeches, sometimes I would listen to the conversations ⁶⁸⁰ they had with other people, just like they listened to mine, and that's all.

Q. But yet this man, Mr. Kupresanin, later became the president of the autonomous region of Serb Krajina; isn't that correct?

A. Yes.

Q. And while you were confined in Omarska, he came in to see you, didn't he?

A. No, he didn't come to see me. From what I understood, he came to look for the officials, highly placed officials that were still alive, and he wanted to gather them at one point in Banja Luka, and he coordinated that with the higher leaders, he had some consultations with Karadzic on that issue, and the purpose was to use those surviving highly-placed officials for their own purposes.

Q. So just from their actions it would be fair to say that Mr. Karadzic and Mr. Kupresanin thought that the SDA leaders in Omarska are not at great peril because he came to contact them, as one of the conclusions?

A. Two days later, I found out exactly what their intentions were. One Serbian soldier who escorted me from the municipal building where I was taken by the police, when he escorted me back to ⁶⁸¹ Vrbanja in the car, at one point the soldier told me, "Your decision to become a member of the Serbian parliament was a good one. I appreciate that. However, you have to be aware the Muslim extremists can kill you." And it was completely clear what was actually taking place in this case.

Q. In Tadic's trial, you testified on page 961 that, starting on line 20 to 26. Did Mr. Kupresanin ever ask you to assist in negotiations? You answered: Yes, yes. One of the first things that they wanted to do was they wanted to create some kind of roundtable in Banja Luka. He said as follows --

JUDGE MAY: Don't go too quickly. It's got to be interpreted.

MR. VUCICEVIC: ... is going to be the part Serbian Bosnia-Herzegovina, that is of the Banja Luka region -- Your Honours, I lost the sound on my earphone.

Q. A Muslim will be the President of the government, the Prime Minister. We have got a very excellent man Fikret Abdic. We have already agreed with Fikret Abdic. He will be the Prime Minister and the Serb will be the President, and the Muslims will be satisfied and all those that remain in Banja Luka as well. ⁶⁸²

A. Yes, that's correct, that's what he said.

Q. Would you explain -- you hear about this plan first from the soldier or from Mr. Kupresanin?

A. I think that if I remember correctly, I think that I first heard it from Kuprasanin and shortly thereafter from the soldier.

Q. Could you explain to the Judges who is Mr. Fikret Abdic?

A. Prior to the war, he was a member of the Presidency of Bosnia and Herzegovina. However, he left the Presidency and established paramilitary formations that cooperated with the military formations of the Serbs and Croats -- cooperate with Martic's police and later on with the Serb forces and they jointly attacked the army of Bosnia and Herzegovina.

MR. VUCICEVIC: Your Honour, that would be a convenient moment.

JUDGE MAY: Have you got very much more for this witness, Mr. Vucicevic?

MR. VUCICEVIC: Your Honour, I have to just tie this up, this encounter with Mr. Kupresanin and perhaps another few questions. Not very much at all.

JUDGE MAY: Very well. Five past two.

--- Luncheon recess taken at 12.28 p.m. ⁶⁸³

--- On resuming at 2.08 p.m.

MR. VUCICEVIC: Good afternoon, Your Honours.

Q. Mr. Semenovic, before we paused for the lunch break, you were testifying about Mr. Fikret Abdic. Who was Fikret Abdic?

A. I already said that he was a member of the Presidency of Bosnia and Herzegovina, elected after the first free multiparty elections. At first he was a member of the Party of Democratic Action, and later on, he left it.

Q. When he was a member of the Presidency, was he a member of the SDA?

A. Yes.

Q. Was he a member of the executive board of the SDA at any time?

A. It is possible that he was in the beginning, but I am not sure of it.

Q. Indeed, he was a candidate for President of the State in the election of 1990, wasn't he?

A. No, he was a candidate for the membership of the Presidency of the Republic.

Q. Therefore, his name was on the ballot, wasn't it?

A. Yes. ⁶⁸⁴

Q. The name of Mr. Izetbegovic was on the same ballot, wasn't it?

A. Yes.

Q. Isn't it true that on that election, Mr. Abdic won the most votes, the majority votes?

A. Yes, he received more votes than Izetbegovic.

Q. Isn't it fair to state that Mr. Fikret Abdic is a Muslim, Bosniak?

A. Yes.

Q. You also testified and stated that he, relating to Mr. Abdic, later attacked army of Bosnia and Herzegovina. Is that the --

A. Yes.

Q. -- army of Mr. Izetbegovic's Bosnia and Herzegovina?

A. After the pull-out of the Yugoslav People's Army from Bosnia and Herzegovina, the army of Bosnia and Herzegovina was established. On exactly what date it was established, I do not know that, but I know that the Territorial Defence was established in early April, and after that, it grew into the army of Bosnia and Herzegovina.

Q. So Mr. Abdic separated from the government which was headed by Mr. Izetbegovic and declared his own entity in north-western Bosnia; isn't that correct? ⁶⁸⁵

A. Yes. A part of the area in which he was present, he split off and he declared an autonomous province there.

Q. Could you name a few bigger towns in that region?

A. In that area, Bihac, Velika Kladusa, Cazin Buzin, Bosanska Krupa that is the area of the Bosnian Krajina, and in the area in which Fikret Abdic proclaimed autonomy was Velika Kladusa and a portion of the Cazin municipality.

Q. So when you testified that Mr. Abdic later attacked the army of Bosnia and Herzegovina, that means you basically stated there was an arms conflict between two Muslim armies?

A. There existed a defence formation of Bosnian army in Bosnian Krajina, at one point Fikret Abdic who at that time was in the territory of the Republic of Croatia issued directives and returned to Velika Kladusa and split off that area with the assistance -- with the weapons which he received from the Bosnian Serbs, he was able to corral that territory and I don't know more about that territory because I was not in that territory.

Q. What you know from the press reports at that time, could you inform the Court when was that, ⁶⁸⁶ approximately?

A. I don't know exactly when that was.

Q. You testified that Mr. Abdic and his followers, the autonomous region that he declared as separate from the central Muslim government in Bosnia, cooperated with the Serbian entity known as Autonomous Region of Krajina, didn't you?

A. Yes, I could read that in the media, and also see it on television and other mass media. At the time when he did this, he was no longer a member of the Presidency of Bosnia and Herzegovina. He stepped down from that position.

Q. And the followers and members of his insurgent troops were majority Muslims, were they?

A. Members were, for the most part, Muslims, but the officers for the most part were Serbs.

Q. So what you are testifying before this high court today is that Muslims from Bihac area, Sasinska Krajina so called as you testified earlier, had indeed very close cooperation and military alliance with Serbs from Autonomous Region of Krajina, including Prijedor, that you are from?

A. I have been talking about the impressions which are gained from reading reports in the press and watching things on television, so I was talking about ⁶⁸⁷ what I saw something regarding Velika Kladusa and not Buzim and Sasinska Krajina.

Q. Do you know whether there were any military actions between the army of Bosnia and Herzegovina, under central authority of Mr. Izetbegovic, and troops, formations loyal to Mr. Abdic?

A. The army units of the army of Bosnia and Herzegovina which were under the control of the Presidency of Bosnia and Herzegovina, not Alija Izetbegovic because he was only one member of this Presidency, were defending the country and the aggressor's forces were attacking it. Apart from the Serbian aggressors, there was also the militia of Fikret Abdic which was engaged in this aggression. This is what I knew from the general mass media, and I did not have any personal additional knowledge of it.

Q. Just one more question, Your Honours, along this line. Mr. Semenovic, do you know whether there were any prisoners of war taken between two Muslim armed groups, armies, armies of Mr. Izetbegovic and military formations of Fikret Abdic?

A. I don't know. I do not know that.

Q. In Tadic's trial, you testified that Mr. Kupresanin had informed you that the Serbian entity in Bosnia is about to form a coalition government with ⁶⁸⁸ Mr. Abdic whereas Mr. Abdic was supposed to be the President of the new political entity. Do you remember that testimony?

A. I remember it, but the interpretation is wrong. Kupresanin was talking that the President of this entity, of this Serbian state, was going to be a Serb, and Abdic was going to be the Prime Minister.

Q. And the position that you were considered for was a member of the parliament of such an entity. You testified to that effect, didn't you?

A. I was not told this by Kupresanin, I repeat, I was told this by a soldier who drove me from the municipality building back to Vrbanja, and I did not have a conversation with him. He just on his own commented that "It was good that you decided to become a member of the Serbian assembly." And several days later, Kupresanin came and said that they would probably take me to Knin and from Knin, we would probably go to Bihac, to the demarcation line with UNPROFOR because we were going to start negotiations there. However, he told me nothing about the nature of my presence there. I just know that I was terribly afraid of this possibility and I refused it even at the cost of my life.

Q. So at that time, you looked Mr. Kupresanin ⁶⁸⁹ straight in the eyes and said "I can't go to Knin, I can't go to Knin or these negotiations," didn't you?

A. No, I did not dare say it in that way. I told him, "Sir, Mr. Kupresanin," this is as far as I recall, "I don't know how much this will contribute to these negotiations, but I believe that it will not be of much use. However, you are a smart man. You know these things best. So you decide." In other words, I was trying to be conciliatory. I did not want to tell him openly that I wasn't going to go because I knew where I was, nor did I tell him that I did not want to go.

After this conversation he said, "We'll still come for you tomorrow and we'll take you there on a helicopter, maybe even a car, because I don't like flying in a helicopter." And in these following days, I expected to be taken -- to be picked up by the police and taken there.

Q. But, in fact, you never made that trip, did you? You were not forced to go.

A. No, they did not take me there.

Q. And while you were waiting for a possible trip to negotiate with the Muslim representatives of Mr. Abdic, you were recuperating at your sister's home in a suburb of Banja Luka, weren't you? ⁶⁹⁰

A. Yes. Those were the contents of the conversation of Kupresanin and the military officers who came and who talked to my sister. They said that I needed to put on some weight and recover, and in those days, they kept bringing food.

Q. As a matter of fact, do you recall whether any of the Serb authorities, soldiers, ever brought you any food as they promised?

A. Yes, once -- I don't know the exact date when this was -- but they came to Vrbanja, that is Kupresanin did and some officers, and they brought a lunch package. There was some cooking oil and beans and some other food items in it.

Q. One more point here in your contacts with Mr. Kupresanin. Mr. Kupresanin picked you up in his limousine and drove you to Banja Luka; isn't that true?

A. This was a car -- this was an official car of the Banja Luka municipality, of the municipal government.

Q. And in Tadic's trial you testified that you had casual conversation with Mr. Kupresanin upon entering the car, and then it seems there is an hour gap, and then you arrived at your sister's home. What, if anything, has Mr. Kupresanin told you during that limousine drive from Omarska to Vrbanja? ⁶⁹¹

A. I did not have a casual conversation, I was answering the questions which he was asking me, and I listened to what he had to say. During this trip, the driver stopped at one point and picked up two soldiers who were hitchhiking, and for the most part of the trip, they talked to the soldiers about the front-line in Gradacac, in Jajce.

Q. Could you mention to the Court -- what is Gradacac, where is it located, and why was Mr. Kupresanin interested in military situation in Gradacac?

A. During the trip from Omarska to Banja Luka, there was a bus stop about ten kilometres out of Omarska and two soldiers were standing there hitchhiking. Mr. Kupresanin told the driver to stop and pick them up, and he asked them where they were on the front. One said that he was at Gradacac and the other one as I recall said that he was on the front-line at Jajce. Then he asked them what the situation was like where they were, how many days of holiday they got and those were basically the contents of the conversation.

Q. I just asked you a simple question and if you can answer with a very short answers. Your Honour, I ask for some latitude here. Who was fighting whom at ⁶⁹² the positions in Gradacac?

A. The soldiers said that they were fighting Ustasha, those were the words that they used.

Q. And Gradacac is located east from Banja Luka; is that right?

A. No, Gradacac is on the border with Croatia.

Q. But how many kilometres approximately east of Banja Luka is Gradacac located?

A. I don't know that exactly.

Q. Would you care to state that the Gradacac's military activities were part of the battle for corridor?

A. I heard that on the radio, that there was fighting for the corridor, but we didn't know anything, we were under siege, so what I could -- the only information I could get was from the radio and maybe from the Croatian media, so I could only sort of guess what was going on. I did not know what was going on.

Q. You have testified that you and the citizens of Kozarac were blocked at some time at the beginning of May of 1992. Do you know for general information whether the whole region of Krajina was blocked from the eastern part of Bosnia because of the closure of the corridor along the river Sava by Muslim forces?

A. I did not know that at that time. ⁶⁹³

Q. When did you learn that fact, Mr. Semenovic?

A. I heard it on the radio, in the following days, that there was fighting for the corridor. There was fighting against the army of Bosnia and Herzegovina and on the other side, the other side was the army of the Serbian Bosnian army, that is of this new state which the Serbs had established and Bosnia and Herzegovina.

Q. Let me ask you: Do you recall when did electrical power was disconnected to Kozarac and Prijedor in April or May of 1992?

A. I don't know that there was -- that the electrical power was cut off in Prijedor. Maybe there were shortages, maybe there were interruptions, but I know that immediately before the attack on Kozarac, the power was cut off.

Q. But to the best of your recollection, Trnopolje had electrical power until the very day when you were forced to leave the city or the village, is that correct, or perhaps there is another explanation?

A. That is correct. All Serbian households in Trnopolje in the village had an uninterrupted supply of electrical power throughout the fighting period because we could see the lights on, whereas in the Muslim areas, including Trnopolje and Kozarac, there was no ⁶⁹⁴ electrical power at all.

In one area in the Krajina area -- in these Ukrainian households they also had supplies, but for the most part, all the way to the foothills of Mount Kozara, the electrical power was cut off from most households.

Q. You are a mining engineer. Perhaps just as having general engineering background you might know the answer to the following question: Where was the electricity supplied to Prijedor and Banja Luka? Where from? Only if you do know.

A. I don't know that exactly, not exactly. I suppose that part of the electricity came from the mid section of Bosnia and the other from somewhere else, I'm not sure from where, what quantities, and where they came from. It's really not -- doesn't have much to do with my profession.

Q. You testified in Tadic's trial that you overheard two conversations between Mr. Kupresanin and Dr. Radovan Karadzic; is that right?

A. Yes.

Q. You testified that you definitely recognised the voice of Mr. Karadzic having heard him speak on the floor of the parliament and also, I believe, in some personal contacts; isn't that correct? ⁶⁹⁵

A. I rarely had personal contact, maybe on two or three occasions when I had, on behalf of the club of SDA members of the parliament, take over to them some bills, and occasionally in that club, Mr. Karadzic would be present as well. Those were very rare contacts, maybe just on two or three occasions, and those were formal -- the contacts were of a formal nature. And, of course, his voice, I knew his voice very well, because Mr. Karadzic was a frequent speaker at the parliament when the members of SDS were present at the Bosnian parliament. I managed to recognise the voice, not on the first occasion when Mr. Kupresanin talked to him from Omarska but on the second occasion in Banja Luka in the municipality building, since I wasn't far away from the telephone and I could hear. Usually when you have old telephones, you can hear that -- I heard a voice similar to Karadzic's and the content of the conversation convinced me later on that indeed it was Dr. Karadzic on the other line.

Q. During the first conversation, besides Mr. Kupresanin and yourself, who else was present in those two rooms, as you testified?

A. In the room where I was, I was brought in by a policeman, and when Mr. Kupresanin came in, the policeman left and I remained alone with Mr. Kupresanin ⁶⁹⁶ and then we started a conversation, as I have indicated before. And then from a nearby office, they called him and they said that the president needs to speak to him on the phone, and he got up and went to answer the phone.

Q. Could you see any other persons being present in the other office?

A. I think there was a person or somebody, there were some official persons there, but this is what I could see from the hallway and through the other doors that were diagonally across. I couldn't even turn back. This is just what I could see without really moving my body, just using my eyes, because indeed I was in a camp where there were terrible conditions, and you had to be aware of every millimetre of your movement and your behaviour, and at one point, when he was talking, carrying a conversation there, Mr. Merkic entered the room and he wanted to start a conversation with me but I didn't dare really start a conversation, and after a while he left, and from the other office, the only thing that I heard was about the beds and the soaps and the sheets. I heard it twice. It was repeated twice. He said, "I found only one of them." I didn't understand the essence of it. It was only clear to me later on when he told me that I needed to ⁶⁹⁷ go with him.

Q. While you observed Mr. Kupresanin speaking with Dr. Karadzic, did you hear these words: "Blankets, beds, detergent" directly from the telephone in Dr. Karadzic's voice or perhaps you heard Mr. Kupresanin repeat them?

A. No, I didn't hear what was said on the other side, I heard what Kupresanin said. He repeated those words, that he needed soaps, detergents, 300 beds.

Q. If you heard Mr. Kupresanin convey those requests or orders to anybody at that time or at any time later on in Banja Luka?

A. No, I didn't hear him talking about those orders to somebody else, I heard him carry on a similar conversation on the phone in Banja Luka, but he wasn't issuing orders. He wasn't ordering somebody to bring that in, he was just mentioning the same things again, and he also mentioned clothes for me, a job, as far as I could remember he was saying, "All right, all right." He was confirming some of the statements.

Q. So you are testifying now that it was Mr. -- Dr. Karadzic who requested a suit and good treatment for you because you overheard him directly, in Banja Luka it wasn't Kupresanin repeating, it was Karadzic's voice that you could overhear from the old-fashioned ⁶⁹⁸ telephone on the desk?

A. Based on what I had heard, I repeated several times what I had heard, I concluded that it was ordered to Kupresanin to go to Omarska and search for the surviving members of the parliament and put them somewhere where they could get better and then use them for his political purposes. This is how I understood the whole matter.

Q. But what you have just testified that you understood, that is not what Dr. Karadzic said. What I asked you only, what did you hear in his own voice?

JUDGE MAY: I think the witness has dealt with that.

MR. VUCICEVIC: Thank you, Your Honour.

Q. One minor point. Mr. Semenovic, I will direct your attention to the very first day when you surrendered yourself to the authorities of the detention centre in Trnopolje. What was the name of the captain that you were turned into?

A. His name was Slavko and I heard that from Adem Trnjanin a friend of mine who later went on to this Slavko.

Q. Did Mr. Trnjanin make any comments who to turn into and not to turn into?

A. He asked me to surrender because he was ⁶⁹⁹ afraid that they would kill 15 persons, including himself, because they were given the ultimatum with a deadline of 48 hours, and he told me that Slavko would not beat me, he was solely interested in how I entered Trnopolje camp and how I exited the camp. This is what Slavko wanted to hear from me. This is what Adem told me, and he didn't say anything about the others, and he was beyond himself. He could barely speak about that situation.

Q. So it wouldn't be fair to conclude that the inmates, refugees, at Trnopolje centre, had favourable opinion about Captain Slavko?

A. Captain Slavko was interrogating some of the 15 persons that I have mentioned. Among others, he also interrogated Adem Trnjanin, and at the end of that interrogation and abuse, some of them were beaten. They issued the ultimatum. What else was said in the conversation, I do not know, but Adem said he will not beat you, he's only interested in how you entered the camp, because Slavko was the head of the guards at the camp, and he was only interested in how I was able to enter the camp.

Q. As a matter of fact, Captain Slavko was almost your neighbour before the war started, wasn't he? ⁷⁰⁰

A. No, no, I had not known him. It is possible that he was my neighbour but maybe further away from my house. I really didn't know him. I didn't recognise him when I saw him.

Q. You were then taken to the -- or the car that you were driven in stopped in front of Keraterm factory and you testified you observed the prisoners in that camp in very, very poor shape, and you observed a building across the street. Who was housed at that time in that building?

A. The car stopped across from the Keraterm camp, and on the road, going on the road from Trnopolje towards Prijedor, we, in front of Prijedor, came to the point where this road connects with the road Prijedor-Banja Luka, and at that spot, on the right-hand side is the factory, Keraterm, and the property that belongs to it, that's next to the road, and on the left side are some kind of buildings that belong to one of the companies from Prijedor, so the car stopped on the other side across from Keraterm in the back yard, right through the gate, and in that building was the military police.

Q. Did you observe any uniformed men in and around Keraterm factory?

A. Behind the car through the right window, so ⁷⁰¹ next to the soldier and in front, I saw the fence of the factory property, and I saw a large number of people, inmates, inside the camp, and I couldn't see the other part of the factory property. I could see a large number of uniformed persons leaving the building that I have mentioned, the building in front of which the car had stopped.

Q. Did you see any uniformed men on the other side of the road, on the Keraterm side?

A. No. I could see a smaller portion of the factory property, the fence, and also a large number of inmates along the fence, and then further inside, the portion that I could see, I couldn't see the whole Keraterm and the whole factory property and I couldn't see what was going on on the other side of the property.

Q. In comparing Trnopolje and the building in Trnopolje and comparing the building of Keraterm, just the physical structure, Keraterm building is indeed very, very close to the road, isn't it?

A. Yes, it's close to the road.

Q. Did you notice any machine gun nests at Keraterm?

A. I couldn't notice it from the car, the area to 30 to 40 metres around the car, I couldn't see any ⁷⁰² machine gun nests, there was just a very high fence, and along that fence, I saw those people, but I repeat to you that I could see only a portion of that area through the window of the car.

Q. And I apologise to the Court and also through the Court to the witness that I am asking for these details. I know it's very difficult for him. But I will just move on with this as quickly as possible, Your Honour, because I know that it's very painful for him to go through these things.

Mr. Semenovic, just one minor detail. Once you were put into the cell in the police building, in the police, basically, prison, cells, in Prijedor, you testified about the horrible situation of the cells, the condition of other people, but at one point you stated that the -- somebody knocked on the door and you were supposed to clean a dorm. Who were the people who knocked on the door and whose dorm were you supposed to clean up?

A. Special police. And the person that knocked with his foot on the door, that hit -- and who was verbally abusing me was Dragan Saponja who beat me the previous day in the SUP building just prior to the interrogation.

Q. That is indeed so reprehensive and I deeply ⁷⁰³ feel for your suffering. However, in your testimony you mentioned that you were woken up and you were supposed to clean up a dorm. Whose dorm were you supposed to clean up?

A. It was the dorm of the special police that slept there, the special police. When I was taken into the cell, when I was taken into the first door, I was beaten right in front of the cell door. Several of those soldiers beat me. And the next door of the next cell was open, and I saw the beds in there, and I saw that it was a dorm.

Q. I apologise to you, Mr. Semenovic, but I was under the impression, and I checked it in the transcript, I believe that you mentioned yesterday that was military police. That's why I was confused. I just wanted to find out was that police special units of the ordinary police of the police that we know belonged to --

A. No, it wasn't an ordinary police, it was special police.

Q. But based on the uniforms, was it special police in blue uniforms, as is the traditional colour of the police in Yugoslavia, or is that military police?

A. No. It wasn't a civilian police, it was a ⁷⁰⁴ special police. Yesterday, when giving the answers to some of the questions, I explained the difference between the uniforms that they had and the rest of the uniforms. I said that they had sort of a purplish uniform, it was also a camouflage uniform, and that's all that I saw. All of them wore those uniforms. And when I was beaten right in front of the cell, some of them asked that I be thrown into the dorm to scrub their floor, to clean their dorm; however, I wasn't taken into the dorm. I, as I was beaten, I fell down, and later on they stopped and they put me into the cell on the floor and they closed the door.

After that, I wasn't taken into the dorm to clean it.

Q. It seems one of the marks of the military police in the former Yugoslavia, in the units that followed, is a white belt. Did they have a white belt or they didn't have a white belt? And you can answer if you agree with the first proposition with me. If it's something else, then please state so?

A. As far as I can remember, they didn't have white belts. Dragan Saponja did not have a white belt, he had a dark belt. And as far as I can remember, others didn't -- that I could see -- and those who beat me in front of the cell, I don't recall that I saw them ⁷⁰⁵ wearing white belts. However, I listened to some of their conversations during the night because I couldn't sleep and they were on guard, so I listened to some of the conversations on the actions that they undertook, and based on that conversation, I concluded that they were the special unit.

MR. VUCICEVIC: Your Honours, may we play the tape that we played earlier, please?

JUDGE MAY: Yes.

MR. VUCICEVIC: Could you please roll the tape forward and identify the segment of the tape when Mr. Semenovic is being interviewed.

JUDGE MAY: That's the wrong way.

MR. VUCICEVIC: I apologise. This is a Prosecutor's Exhibit, so -- could you roll it back there, please.

JUDGE MAY: Mr. Keegan, can you help? Where are we going to find this.

MR. KEEGAN: If my recollection serves me, it's at about 8 minutes on the tape.

MR. VUCICEVIC: Thank you, Your Honour. Are we getting the tape rolled back or what is the status of the medium?

MR. KEEGAN: To be more precise, Your Honour, looking at my notes, it would be eight minutes 30 ⁷⁰⁶ seconds.

MR. VUCICEVIC:

Q. Could you please play the tape and the sound also?

JUDGE MAY: This is page 8 of the transcript; is that right?

MR. VUCICEVIC: Could you roll it back until the Court gets the proper reference.

MR. KEEGAN: Yes, Your Honour, down the page it starts, and the witness is referred to in the transcript as "Man" because his name is not repeated.

JUDGE MAY: Before we play it, I see the -- our own transcript refers to page 8. I said page 4. Presumably it's the passage beginning "Journalist on/off camera, we've heard that you're one of the rare inhabitants of this reception centre who came to Omarska on his own? Man: Yes, that's correct.

MR. KEEGAN: Yes, Your Honour, that is it.

JUDGE MAY: And the "Man" is Mr. Semenovic.

MR. KEEGAN: That's correct, Your Honour.

MR. VUCICEVIC: Could you play the tape, please?

(Videotape played)

THE INTERPRETER: We heard that you're one of the rare inhabitants of this reception centre that came ⁷⁰⁷ to Omarska on his own.

Yes, that's correct. Can you explain why you did that? Why did you come here?

I came here after waiting for a while and hiding here. I waited for all the prime actors in these horrendous events to be captured and for the truth to be established about the people who have done all this evil acts, so that my efforts and work as well as the statements I can give can be appreciated. Who do you have in mind? Who is responsible for all these horrors that took place here? First of all I have in mind the leader of the party for Bosnia and Krajina, Mirsad Mujadzic and Mirsad Mujadzic chairman of the party branch in Prijedor and also member of the party executive council for Bosnia and Herzegovina, also the persons who within the party organised all these military activities. Are your colleagues who are here with you, are they aware of your opinion? Are you able to state your opinion publicly why all this took place? I have spoken on two occasions about this, also in an interview for TV Krajina, I have made my statement, and I have sent a message to the people with respect to this situation that I am now personally witnessing in Bosnia, Krajina, and Prijedor, not ⁷⁰⁸ theoretically like those who are watching from the denizens and who are the master minds behind all these. I don't know if you are aware of the fact that there are some foreign reporters who came here, and the reason why they came here is because in the past few days, the international media have stated that in the Republic of Srpska, so in this territory here there are concentration camps for Muslims and Croats. Since you have stated that you have come here on your own free will, can you tell us whether this is a concentration camp or this is a reception centre? What can you tell them?

I would like to tell them that the military operations caused such consequences that it was necessary for the people to group up both for their own safety and for the survival, and this centre does not have the characteristics of the concentration camp in the sense that is stated by the political propaganda. And one last question: Before the war broke out here, were the Muslims in any way preparing themselves for the war? In the past few months --

MR. VUCICEVIC: We can stop the tape here, please.

Q. Mr. Semenovic, you have testified yesterday that you were given a statement to read before this ⁷⁰⁹ interview. I am just asking you: Did you have that statement in front of you when you made this interview?

A. Yes. When the journalist from Prijedor arrived, Mr. Ecim, he brought a statement which I was to read and he was going to tape it with a camera. And then later on, he wanted me to interpret this statement without a statement. He taped me twice. And following that, this interview took place when the Serbian SRNA television outlet taped this report.

Q. So you didn't have that statement in front of you when SRNA took this statement?

A. No, I did not.

Q. Did Mr. Ecim offer for you to speak to the foreign journalists?

A. No.

Q. Do you remember when the foreign journalists came in to visit the centre Omarska?

A. A day after the interview conducted by Zivko Ecim, it was I believe one day later that the four journalists arrived and then the police took me from the glass house and took me upstairs and up there there were the crews of the international TV media, and they refused to take me, and then they took me to a room on the first floor when this interview then took place.

Q. Just a couple of minor points, Your Honours. ⁷¹⁰ Mr. Semenovic, have you been a member of the Territorial Defence in Trnopolje after you finished your regular military service? To what duty were you assigned as a reservist?

A. I was not a member of the Territorial Defence. I put myself at this position on the eve of the war when the TO needed to be expanded because there were no other ways to legally organise defence, and before the war, after completing my regular military service, I was part of the reserve forces, reserve units, which every couple of years would be called up for military exercises, that was the only duty. Some were called every two or three years, some were called every seven or eight years. Within ten years, I was only called up once, and I believe that was sometime in 1984 or '85, I am not entirely sure. It was a long time ago.

Q. After signing up for the Territorial Defence, have you at any time received a weapon from anyone?

A. I did not, no, because there weren't weapons to be had, and those weapons that were around, it was supposed to be taken only by the persons who were on the front-lines. So if they were to be killed, the others would take over from them and keep defending Kozarac and their villages. ⁷¹¹ The majority of people who reported to these reserve -- these units did not have any weapons.

Q. You just testified that you were in the reserve composition of the Yugoslav Army after you finished your regular service. In the time of emergency, at a time of mobilisation, you had your place where to report. Where was that place supposed to be?

A. In law, that place was called gathering point. When we had that military exercise in 1984 or '85, we received calls, and those who received them had to report to this gathering point, and this gathering point where I was supposed to report was in the area of Orlovci, that is the Upper Orlovci, at the intersection off to the right, there is a local road, and down that road somewhere, a couple of kilometres down that road, that is where the gathering point or the meeting point was. When everybody reported there, from there, everybody would go to the location where the military exercise then took place.

Q. And Gornji Orlovci remained your Zborno Mesto for the rest of your reserve service; right?

A. No. This meeting point or gathering point, also called Zborno Mesto was a point where everybody who was to take part in this military exercise was ⁷¹² meeting or gathering. From there, from that point, we all travelled to the location where the actual military exercise was then to take place.

Q. I'm directing your attention now to the beginning of September of 1991. Have you received a summons as a military reservist and at that time still under the jurisdiction of JNA to report to active duty?

A. As far as I can recall, no, I did not.

Q. Who had the jurisdiction? What body had jurisdiction to issue the summons for mobilisation?

A. I believe that it was the secretariat for the People's Defence which issued this call, I believe it was this secretariat, but I'm not entirely sure.

Q. And isn't it fair to state that Mr. Becir Medunjanin from Kozarac was Nacelnik, meaning head of that body?

A. I believe that he was. I am not sure, but I believe that he was.

Q. And he was very close friend of yours or close political associate of yours, wasn't he?

A. Yes, a political associate. That, he was.

Q. And do you know whether men of your age at that time were called up for service, weren't they?

A. Yes, many were called up.

JUDGE MAY: I think we've been through this ⁷¹³ call-up.

MR. VUCICEVIC: Thank you, Your Honour. Indeed.

JUDGE MAY: Anything else for the witness?

MR. VUCICEVIC:

Q. In your testimony yesterday, you retracted the statement that you've given to SRNA television, of course. But when was the first time that you retracted that statement?

A. I do not understand the word "Retracted."

Q. I would say "disavowed" or ...

JUDGE MAY: "Contradicted."

MR. VUCICEVIC: Thank you, Your Honour.

JUDGE MAY: You said yesterday that what you reported as saying on television, you, in fact, didn't mean. You explained that. And what counsel is asking, if you can answer, is when, for the first time, did you take that statement back? Can you assist?

A. I said that for the first time when I managed to leave the area of Serbian Republic of Bosnia and Herzegovina and in conversation with the official bodies of Bosnia and Herzegovina, and that is what I stated to this Trial Chamber.

MR. VUCICEVIC:

Q. This is indeed a very important statement in ⁷¹⁴ the life of any man who has suffered as much as you did. I'm just trying to see whether you recall who was that official that you stated to and when?

A. During the conversation which I had about my stay in the camp, I believe that this conversation was conducted with one of the investigators of The Hague Tribunal, it was the first time then that I talked about these events and that is when I spoke about it, about this interview and about the taping.

Q. If you could remember, perhaps the month or a season and what year that you spoke to representatives of the Tribunal and that you took back this statement?

A. In 1995, I believe in late '95, but I'm not sure. It could have even been early '96.

Q. You left the territory of Krajina on January 15, 1993, didn't you?

A. On 15th or 19th, I am not sure, but within that time period.

Q. Did you have any approval of Mr. Kupresanin to leave the Serbian-held territory because that point is not completely clear to us? If you could just state what conversation have you had with Mr. Kupresanin directly or indirectly before you were permitted to leave?

A. Regarding my departure, I never talked to ⁷¹⁵ Kupresanin. A representative of the International Red Cross talked to Mr. Kupresanin and a gentleman called Nikola Granic, he was director of the Plon company in Banja Luka who had good personal relations with Kupresanin and a dentist called Emir. So they talked to him and he gave approval for me to leave this territory, and they were engaged in some activities there of which I did not know.

Later on, when this dentist named Emir came to me and asked me to sign a statement in which I'm expressing my gratitude to Mr. Kupresanin for having saved my life which was to stay in Banja Luka, in return, through auspices of the IRC, they were going to enable me to go to Norway. I do not know why Norway, but they said that they could do that and I would be able to leave for Norway.

Q. If you do know, what is the ethnic background on Mr. Nikola Granic?

A. I am not sure. I believe he is a Croat, but I'm not entirely certain.

Q. So isn't it fair to conclude that even in '93, that Mr. Kupresanin had a close relationship with a Muslim doctor and Croat in Banja Luka, and all three of them, a Serb, a Muslim, and a Croat assisted you to leave the area? ⁷¹⁶

A. And Mr. Bernard Schwitzer, or Schwartzer, a representative of the International Red Cross. But I know that the three gentlemen were all close friends, they were all wartime orphans from World War II, and all three of them grew up in a house, in a Muslim household. I believe it was the mother of this dentist, I believe that she raised them, and so they continued this friendship, continued into 1993. Following that, Mr. Granic had to leave Banja Luka. I believe that he went through to Slovenia. That is as far as I heard, and I do not know what happened to Mr. Emir.

Q. This is indeed very interesting and very --

JUDGE MAY: Well, it may be, but I wonder if you can assist us --

MR. VUCICEVIC: Thank you, Mr. Semenovic, and, Your Honour, if I can just have a minute to consult with co-counsel, whether we have any more questions?

Thank you, Your Honours. We don't have any more questions for this witness.

JUDGE MAY: Mr. Keegan, any re-examination?

MR. KEEGAN: Yes, Your Honour, we do have some brief re-examination, but in light of the long discussion about the camp and the position, relative ⁷¹⁷ position of things, we had a diagram prepared over the lunch, but I haven't had an opportunity to show it to the Defence. I wonder if we might take the break early in order to do that, and some film that would also help.

JUDGE MAY: Yes. I hope this can be dealt with fairly rapidly so we can make a start with another witness.

MR. KEEGAN: Yes, Your Honour.

JUDGE MAY: Perhaps I can add this while you're on your feet, Mr. Keegan. The Trial Chamber have been considering arrangements for Friday. We don't intend sitting late at all that day. There are other matters we have to attend to. And, in fact, we have in mind finishing at 1.00 p.m. and starting at 9.00, slightly earlier than usual. I don't imagine that is going to cause anybody any inconvenience.

MR. KEEGAN: No, Your Honour.

MR. VUCICEVIC: No, Your Honour

--- Recess taken at 3.24 p.m.

--- On resuming at 3.48 p.m.

JUDGE MAY: Mr. Keegan, we appear to have lost nearly ten minutes during that break. That was no fault of yours, of course, but we will sit on till ten past five to make up. ⁷¹⁸

MR. KEEGAN: Yes, Your Honour Re-examined by Mr. Keegan:

Q. Mr. Semenovic, with respect to the issue or the questions regarding the order of the government of Bosnia and Herzegovina for the mobilisation of the Territorial Defence forces on about April 8th, as you testified, earlier you had testified as to your knowledge about attacks on Muslim areas in eastern Bosnia, including Zvornik and Bijeljina and others. Are you aware, did those attacks come before or after this issuance of the formation of the Territorial Defence for Bosnia-Herzegovina?

A. It came before the order on the establishment of the Territorial Defence of Bosnia and Herzegovina.

MR. KEEGAN: If I could have this photo marked, shown to the witness, and then put on the ELMO, please. I apologise, Your Honour, we got it quickly during the break and we only have one available. It can be produced to others. It was shown to the Defence during the break.

THE REGISTRAR: The photo is marked number 44.

MR. KEEGAN: Could you put it on the ELMO, please? Thank you.

Q. Mr. Semenovic, I'm directing your attention ⁷¹⁹ to the uniform that that individual is wearing. Do you recognise what type of uniform that is?

A. Yes. This is the uniform of the special police, the one that I have mentioned several times and explained. It was a camouflage uniform but with -- in purple hues, so it's darker than the regular camouflage uniforms.

MR. KEEGAN: Thank you. Could that photograph be given to the Judges, please, so they can actually see the colours?

Next, Your Honour, we have a diagram of the -- a diagram to present to the witness, a copy has already been provided to the Defence during the break. This would be Exhibit 45, Your Honour.

Q. Mr. Semenovic, do you recognise that diagram, please, what that represents?

A. Yes.

Q. What is that, please?

A. It represents Trnopolje and, in the middle of the drawing are the sketches of the local commune and the school buildings and then there's a soccer field --

Q. Mr. Semenovic, if we could put that on the overhead, then you can describe it so everyone can see what you are pointing to on the screen, please. Could that be panned back just a bit, please? Thank you. ⁷²⁰ That's good.

First question, Mr. Semenovic: Do you recognise the roads that are depicted there?

A. Yes. This is the road, Trnopolje-Kozarac.

Q. Could you please put a "K" on that diagram, write a "K" at the end of the road in the direction of Kozarac, please?

A. (Indicates).

Q. Thank you. Now, the other road that is depicted, it runs basically left to right as it is now existing on that diagram and on the computer screens.

A. This is the road Trnopolje-Prijedor.

Q. Could you put a "P" on the diagram at the end of the road in the direction of Prijedor?

A. (Indicates)

Q. If that road were to continue to the left, to what area in the municipality would it go?

A. It would continue towards Omarska, not towards the municipality but towards Omarska, and that is the road.

Q. And could you put an "O" there then, please?

A. (Indicates)

Q. Thank you. Now, if I could direct your attention to the buildings that you had begun to describe when you first received the diagram, you ⁷²¹ referred to the building of the local commune or Mjesna Zajednica. Could you please point that out?

A. This complex of structures is the local commune. This structure here is the old cinema theatre, and in the middle were the offices of the local commune.

Q. Could you please, Mr. Semenovic, put a "T" next to the building which contained the theatre, as you described, or the cinema, excuse me, put a "T" next to that building?

A. (Indicates)

Q. You also mentioned in your -- I'm sorry. Could you also then describe the next building to the right of the Mjesna Zajednica complex. Could you please describe what that is?

A. This is the building of the elementary school, and here it is on the drawing. This is the part where the classrooms were, and this farther part is the sports hall that was part of the school complex.

Q. And could you please put an "S" next to the school building?

A. (Indicates)

Q. If you could please pan back from that in the audio booth? Thank you.

Now, Mr. Semenovic, could you please give, ⁷²² on the diagram, a general indication of the area from which you entered the camp?

A. In this area (indicated).

Q. Could you please put an "A" in that area?

A. (Indicates)

Q. Thank you. At this point, Your Honour, we also have a video, it was a video provided to the Defence on 3 July. I believe it shows the areas that the Defence was interested in this morning in a much more clear resolution, as well as the area behind the local commune building and the school area, as the witness has described. If we could run that tape, please?

That would be Exhibit 46, Your Honour, the tape.

If we could hold the film there for a minute, please?

(Videotape played)

Q. Mr. Semenovic, do you recognise the area that has just been shown on this segment of the video?

A. Yes, I do recognise it.

Q. What is that, please?

A. This is the building where the storage house of the agricultural co-op was, and the thing next to the wire fence was the yard belonging to the co-op. ⁷²³

Q. If you could advance the film, please? Continue the film?

(Videotape played) What road would that be shot from? Where would the cameraman be standing, Mr. Semenovic, on which of the two roads?

A. On the road Trnopolje-Kozarac.

Q. No, I'm sorry. I apologise. I meant the prior scene? That shot there.

A. The camera man is on the intersection of the Trnopolje-Kozarac and Trnopolje-Prijedor roads, and the electrical power substation is to the left of the image.

Q. Thank you. Now if you could advance the film, please?

(Videotape played) Hold the film there, please? Now, from this shot, Mr. Semenovic, can you recognise where the camera man would be standing?

A. The camera man is on the road, the Trnopolje-Kozarac near the place which I described before, maybe 30 metres farther down, and behind the wire fence and the people there is the building where the cinema theatre was, and next to it we see the local commune building. ⁷²⁴

Q. Advance the film, please. Advance the film, please.

(Videotape played) If you could hold the film right there?

Mr. Semenovic, can you recognise the uniform that the man on the right, far right, on the other side of the fence, is wearing?

A. The man on the right has the uniform of the special police unit.

Q. Thank you. If you could advance the film, please?

(Videotape played) And if you could turn up the volume, please? Never mind then. Just fast-forward the tape, please, to the next section.

(Videotape played) That's sufficient, thank you. If you would advance the film? Stop. Thank you. If you hold the film right there, please?

Mr. Semenovic, can you tell from that shot what area the camera man is now standing in?

A. I think the camera man is at the beginning of the road, Trnopolje-Prijedor.

Q. If you could back the film up slightly, please? Right there is good. ⁷²⁵ What is the building that we're looking at there, Mr. Semenovic, in the picture, that's the large building and it takes up most of the picture?

A. It's the building of the old cinema.

Q. The building then that you see to the far right in front of the cinema with the orange roof, which building would that be?

A. It's one of the houses that are across from the local commune building.

Q. Thank you. If you could advance the film, please?

(Videotape played) You can fast-forward it. And if you could now hold the film, please? Thank you. Back it up slightly and then just play at normal speed. Back it up, please?

(Videotape played) Now play at normal speed. Thank you. You may advance it.

Q. Mr. Semenovic, do you recognise this field area with the woods behind it?

A. Yes. I think that this is the area behind the school.

MR. KEEGAN: Thank you. You may stop the film. ⁷²⁶ Your Honour, we would offer the entirety of the tape. We will provide -- we pulled it together rather quickly, but we will provide a complete transcript in addition to the number of interviews that are conducted in English. Thank you.

Q. Mr. Semenovic, one final question: When Mr. Kupresanin came to take you from the camp and then all of the events that transpired, which you've already discussed, did he come to take you out of the camp before or after the international press had visited Omarska camp?

A. The following morning after the foreign journalists and international representatives came to visit the camp.

MR. KEEGAN: Thank you. I have no further questions, Your Honour.

JUDGE MAY: Mr. Semenovic, thank you for coming. You are released.

MR. KEEGAN: I'm sorry, I didn't know if there were any further questions. We would like to make him subject to recall, please.

THE WITNESS: Thank you, Your Honour.

JUDGE MAY: I hope it will be only be for a very good reason indeed. He's been here for the better part of the week. ⁷²⁷

MR. VUCICEVIC: We object to that, Your Honour. Just for the record.

JUDGE MAY: I don't think you can object, but, Mr. Semenovic, I hope that you will not have to come back because you have given evidence for long enough, but subject to that, you are released. Thank you for coming.

(The witness withdrew).

MR. KEEGAN: The next witness, Your Honour, would be Mr. Edward Vulliamy, it's V-U-L-L-I-A-M-Y.

MR. VUCICEVIC: Your Honour, if I may just approach the registrar for 30 seconds?

JUDGE MAY: Yes

(The witness entered court)

JUDGE MAY: Yes. Let the witness make the solemn declaration.

THE WITNESS: I solemnly declare that I shall speak the truth, the whole truth, and nothing but the truth.

MR. KEEGAN: You may be seated. Thank you.

WITNESS: EDWARD VULLIAMY Examined by Mr. Keegan:

Q. Would you please state for the record your full name?

A. Edward Sebastian Vulliamy. ⁷²⁸

Q. Mr. Vulliamy, you're a citizen of the United Kingdom?

A. Yes.

Q. Where did you attend university, and what were your major areas of studies?

A. I was educated at Oxford University in the United Kingdom where I studied philosophy with politics and briefly at the University of Florence in Italy, again studying philosophy.

Q. And after completing your studies, did you become a journalist?

A. Yes, I did.

Q. What organisation do you currently work for?

A. I work for the Guardian newspaper in the United Kingdom and for its sister paper, The Observer.

Q. What areas of interest do you generally cover?

A. Well, I've been covering a number of things over the past 15 years. Conflicts in various parts of the world for both my newspaper and a television company before that and during the past six years or so, overwhelmingly the wars in the former Yugoslavia.

Q. And what particular awards have you received as a journalist?

A. Before Yugoslavia, I won an award called the ⁷²⁹ Royal Television Society Award for Current Affairs that was for a film unconnected with Yugoslavia. Since covering the wars, I have won the British Press Award International Reporter of the Year, '92. The same year I won, I think, the Foreign Correspondent of the Year awarded by a program called "What The Papers Say." I won Amnesty International Award for Journalism in '93, I won a thing called the James Cameron award in '94, which is referred to as the British Pulitzer award, and then last year I won the British Press Award's International Reporter of the Year, again for a retrospective history of the war in Bosnia-Herzegovina.

Q. So when did you first begin to cover the break-up of the former Yugoslavia?

A. I first went to the former Yugoslavia, professionally that is, in the summer of 1991, June 1991, initially to cover the conflict that had -- that was breaking out in what was then the west of Yugoslavia in Slovenia, the first shots of the war, really.

MR. KEEGAN: If we could have the map provided to the witness, please? I want the witness to put it on the ELMO, please. A copy of this map has already been provided to the Defence, Your Honour. The purpose of this particular map is because ⁷³⁰ it lists the towns within the former Yugoslavia, many of them important towns, without any other sort of interference, the topographical kinds of marks or roads that can distract from where the towns are.

THE REGISTRAR: The map is marked Exhibit 47.

MR. KEEGAN: If we could have the overhead turned on, please? Thank you.

Q. Mr. Vulliamy, if you could, you indicated that you first began your coverage in Slovenia. Can you briefly describe the areas you covered there?

A. Yes. I'm afraid we start off slightly off this map, off the top left-hand corner, you can see Slovenia sort of peeping in here. I was in this area here, in the Slovenia capital of Ljubljana, which is about here, off the map, and in this area in the east of Slovenia adjacent to Croatia. That was the first phase.

Q. And from there, where did you next go in the conflict?

A. Well, a fresh phase of the war began in Croatia, and I was assigned to move with it, and I worked for the next few months in Croatia.

Q. And if you could indicate that area on the map, please?

A. Yes. I worked in Zagreb, the capital, ⁷³¹ obviously, in what was a frontline between the emergent Croatian forces and the then Yugoslav People's Army, the JNA, firstly around this area, Sisak, Petrinja, Glina; down here, Slunj; and this area on the edge of what was called the Krajina where the Croatian populations and Serbian populations met. I worked for the most part in this area here, in the east of Croatia and the west of what is now Serbia, on the Croatian side, in the town of Osijek, which was under siege by the JNA, in Vukovar, right here on the border, also under siege by the JNA. I was in Vukovar until I think the penultimate day when you could be. Came out through a road cut through the cornfields. Thereafter covered the siege of Vukovar from a town called Vinkovci, which is here, and a little village called Mustar (phoen), which is not marked; and during this period, I was also working on the JNA side with the Yugoslav People's Army, which was in the process of becoming the Serbian army, at a place called Bogojevo, which is not marked. It's here somewhere; a garrison town. At this place, which was an important town called Sid, and in all this area here, Sombor, indeed, and you could go through Hungary to skirt the frontlines there. Then the third area in Croatia I worked during 1991 was down here on the ⁷³² coast, most particularly Dubrovnik which was under siege as well, and in the towns of Sibenik, further up the coast, and Zadar, further up again, which were also under shell fire and attack.

Q. Now, if we could move back to the area in eastern Croatia, around Vukovar, Vinkovci. Can you describe the type of forces that were engaged on both sides of the conflict and the type of weaponry which they had arrayed there?

A. Yes.

MR. VUCICEVIC: Your Honour, I object to this questioning. It is outside the Prijedor area, outside of Bosnia-Herzegovina.

JUDGE MAY: Well, Mr. Keegan, that prima facie seems a reasonable objection. What is your answer to this? What's the relevance of it, interesting though it is, about what the witness has to say? How is it going to assist us to try this case?

MR. KEEGAN: The description of the conflict here, Your Honour, will go to help establish the plan and pattern which you see later emerge within the Autonomous Region of Krajina and which is employed, in fact, in the Prijedor area and the municipalities surrounding it. Of course, keeping in mind the nature of the elements we have to prove for certain of the ⁷³³ charges, the legal elements, we believe it is relevant. We will try and keep it brief, but we believe its relevance will be indicated as we get into the evidence.

JUDGE MAY: Mr. Keegan, we shan't stop you adducing this evidence. We accept your point about the width of the charges which you have to prove. But at the same time we shall encourage you to limit the evidence until we come to what is directly relevant here, and that's events in Prijedor.

MR. KEEGAN: Yes, Your Honour. Certainly.

Q. Mr. Vulliamy, could you please describe the way that the forces were structured on both sides and the type of weaponry which were employed?

A. Yes. And I note the request for brevity. The Croatian army was a nascent army, a mixture of police, former soldiers, civilians, initially scantily armed, and a hodge-podge really of former regular soldiers and various militias which were formed often locally.

On the other side, on the JNA side, you had a regular army, the Yugoslav People's Army, with the armaments at its disposal which were apparently considerable, as far as one could see. Acting as a director of and support echelon of irregulars who were ⁷³⁴ fighting out in the villages that I worked in, on the Yugoslav/Serbian side. So you had an entwinement, really of an irregular army with irregulars with whom I spent a great deal of time.

Q. Were you able to discern a pattern in the manner in which the attacks were conducted during the time you spent in this area on the Serbian side with the Serbian forces?

MR. OSTOJIC: Your Honour, if I may object, and I want to thank you for giving me an opportunity to speak yesterday. My name is John Ostojic, and we object to both the form and foundation of the question asked by Mr. Keegan.

JUDGE MAY: We have just ruled it admissible. Yes?

MR. KEEGAN: Thank you.

A. The pattern was roughly as follows. Bogojevo, which is here --

Q. I don't believe the video monitor is on. I'm sorry, it is.

A. Bogojevo, which is roughly here, and Sid roughly there were essentially garrison towns where the armies would be based, where the echelons would be based, artillery and tanks and transport vehicles repaired, troops billeted. Sid would then feed the ⁷³⁵ frontline, siege lines, for Vukovar and the artillery lines and water lines and tank lines around Vukovar, and Bogojevo would be similar deployed with regards to Osijek, and so the operation was astride the border, if you like, with the main bases and garrisons on the Serbian side and the fighting over on the Croatian side.

I recall one particular night in a place called Bijelo Brdo, which is about here, where you could see it was fairly obviously arraigned, I was actually on the edge of a field across which the fighting was taking place. At the very frontline you had the irregulars with their machine guns, behind them were rows of tanks, and so the small arms fire would be between the irregulars across the field with the Croatians, the tanks and the actual shelling of Osijek, as it was in that case, was coming from directly behind them, a matter of 500 yards behind them, and then the logistics would all be taking place over the border back in Serbia. Given that you want me to be brief, I shan't go over it all again, but the same thing was happening in Sid over here regarding the siege of Vukovar, so you had this entwinement between regular and irregular forces with the officers, in particular a Colonel Uzelac I got to know quite well, making it ⁷³⁶ plain that they were in charge of both.

Q. Did you have, during the time you spent there, discussions with these irregular forces as to what their role and purpose in the conflict was?

A. At length, yes, because we used to hang around with them in the cafes and so on and got to know what their aims were, which were the establishment of Serbian-only territory within Croatia, and indeed also, I must say, about their fears and the unpleasant experiences they had had in the nascent Croatia, a lot of them lost their jobs and so on, so they explained not only what they were fighting for, but why they were doing it. We spent a lot of time with them.

Q. What did they see as their purpose with respect to the non-Serb population in those areas?

A. Well, they wanted to push them back as far as possible. They wanted to take Osijek, they wanted to push the Croats back as far as Zagreb, and if you allow me to be anecdotal, a chap once went "Zagreb, vroom" -- yes, that's the vernacular, I apologise. They wanted to take Osijek and push the Croats back as far as possible.

Q. Now, when you later moved on in the war, did you come across a very similar type of scenario in 1992 between the areas of Serbia and Bosnia? ⁷³⁷

A. Yes. There was a -- this was -- this would be the beginning of August 1992, so a different year, different war. And this was a place called Loznica, let's see if I can find it -- it's here. Just inside Serbia, on the border of Bosnia-Herzegovina. I went down there because we were looking at places where deportees, refugees, and alleged prisoners were being kept. Loznica was one of the camps where Bosnian Muslims who had been deported from this area were being kept within Serbia. That's another matter. But if I understand the question, and the point is that Loznica was once again a garrison town. You could see equipment being maintained, a lot of traffic across the border into this little place that I went to called Zepak from whence the deportees had come, and there was actually so much military movement going forward to furnish the troops here that we were able to cross the border ourselves without even being asked to show any papers; the border didn't really exist.

The only difference really was that whereas in the first war there was actual fighting going on, because the Croats had armies which were indeed intimidating some of those who were fighting, very considerably, and indeed advancing at some points, here ⁷³⁸ there was no actual fighting so much as simply occupation, deportation of civilians. So that was the difference, but the pattern was the same: garrison town and the military action, as it were, astride the border.

Q. And the nature, the composition of the forces which you saw in that area crossing from Loznica into eastern Bosnia and Herzegovina, what was the composition of the types of forces that you saw there?

A. Well, by now the JNA had been pretty much disbanded and was now the Yugoslav Army because Communism -- the pretense that Communism had gone and they were now just the Yugoslav National Army or Yugoslav Army. So you had that, the regular army and, again, groups of irregulars, men in semi-fatigues, maybe a T-shirt and camouflage trousers, or the other way around, so this same interaction between troops and militias and armed semi-civilians, if you like. Irregular troops.

Q. What types of cooperation did you observe, if any, between those irregular forces, the militias, and the Yugoslav Army?

A. Well, they would -- I mean, they would share quarters, they would share billets; the weaponry was fairly obviously coming from the regular army and ⁷³⁹ supplied to the irregulars; the transportation would be that of the regular army, even if men who were not in irregular uniforms were using it. So, if you like, one could say that the logistics, the military expertise, such as it was, was being furnished by the regular army for the benefit of the irregulars who it was arming.

Q. Did you witness the movement of any heavy weaponry, such as artillery or tanks?

A. Yes, yes, yes. I mean, there was less heavy artillery and tanks crossing over at that particular point into Bosnia than there were towards Vukovar, there was less actual fighting going on. But, oh, yes, there was, I mean, heavy artillery, mortar transport, and some tanks too, yes.

Q. Now, could you please describe, while we still have the map on the screen, describe very briefly, just pointing out the other areas of the conflict which you covered between 1992 and 1995?

A. Right. Well, this is spanning a considerable time, so I'll be as quick as I can. I'll do this chronologically inasmuch as I can. Probably simplest. During the summer of 1992, I was in the

capital, Sarajevo and Pale, which was the capital of the Serbian part; I was in Banja Luka, which is here; Prijedor, which is here; in the area - in circumstances ⁷⁴⁰ we'll come to - around Prijedor, going into the government-held territory; Omarska, Trnopolje, and then, for a while, I was working around here, in Travnik - that was held by the government, Turbe - Novi Travnik, Zenica, Vitez. These were towns mixed between Muslims and Croats. Up in Tuzla, which is mixed between all three ethnic groups but in government hands.

I worked, again still during that summer, down here in Herzegovina area, Mostar, there; Trpinja. I worked, going into the autumn now, up here in what's called the Bihac pocket. It's now contiguous with the government territory but was then isolated and cut off.

I worked, into '93, a great deal around here in Central Bosnia, around Travnik, the fighting here, a great deal down here. '93 again, Sarajevo. '94, concentrating in Mostar. I was then out of Bosnia for ten months when I came back. At the end of the war, Zenica, Central Bosnia again, Sarajevo again. And when the war was over, for the first time I was able to go into parts which were impossible to visit during the war, the Drina valley area here through Visegrad, Foca, and once again to Prijedor and Banja Luka, and also these parts here. All over, in other words. ⁷⁴¹

Q. During that time, did you cover the conflict involving all three of the main groups involved, that being the Bosnian Muslims, the Bosnian Croats, and the Serbian forces?

A. Yes. In a way, this was the difficulty. There were, for long periods of time, two wars going on: one between the supposed Muslim-Croat alliance and the Serbian nationalist side, and another between Croatians in Bosnia and Muslims in Bosnia, and I had to cover both wars, depending on what the call was, really, and what seemed to be the priority at the moment.

Q. Did you spend time with and report on stories from participants in each of those wars?

A. Oh, yes, yes. I spent a great deal of time with participants on all three sides.

Q. Did you speak with military commanders, police commanders, and paramilitary members?

A. Of all kinds on all sides, yes.

Q. Did you speak with victims of all three nationalities or ethnic groups?

A. Yes, I did indeed, yes.

Q. In those conversations, did you focus on their respective roles in the conflict, how they were conducting it, or how they were victimised, as well as ⁷⁴² its origins and purposes?

A. Yes. With the soldiers, one talked about little else other than what they were trying to do and what they were fighting for; and with the victims, one spoke of little else but that which had happened to them on all three sides, yes.

Q. In your research for stories and reporting on events in Bosnia-Herzegovina, particularly in 1992, as well as in the research for your book, did you speak with fellow journalists, review archive records about the events that were occurring in different regions in Bosnia-Herzegovina?

A. Yes, indeed. Well, as you can imagine, the journalists, as regards the fellow journalists, we were quite a clan and would end every day after dark talking a great deal amongst ourselves as to what had happened and comparing experiences and helping each other out, actually, unusually, and we obviously would talk to the agencies that were deployed internationally, the UNHCR, the Red Cross. They would often be sharing quarters with them or pitching up at the same motels or whatever. And, yeah, I tried to read as much as I possibly could. A lot of material was being produced, and we read everything we could get our hands on, indeed. ⁷⁴³

Q. Did that include official reports by government and non-governmental agencies, organisations?

A. Official reports from, most notably, the UNHCR, United Nations High Commission for Refugees, the International Red Cross, most certainly, and indeed, using our translators, we would read anything we could being put out by the three governments, yes; that is to say, Croatian, Yugoslav/Serbian, and the government in Sarajevo, and the self-established government in Pale, of course.

Q. Based upon your experiences and your conversations, particularly with people of Serbian descent in the areas known as the Krajinas, that is, both the area in the Croatian area, Croatian Krajina, and the Bosnian Krajina area, did you determine that there was a difference and a perspective toward people that were considered to be Bosnian Muslims as opposed to those who were considered to be of Croatian descent?

A. Yes. I mean, this inference developed slowly over a period of time, but there was quite an important difference.

If you will permit me, I will say -- when I say "Serbs," I mean Serbs, who, as it were, followed the ideology and the call to arms because there were ⁷⁴⁴ large numbers of Serbs who found this ideology obnoxious, so I might occasionally use the word "Serbs" to mean Serbian nationalists, and I stand to be corrected if I ever do. There were, indeed, tens of thousands of Serbs who fought against that ideology. So as a rider to my reply but, yes, there was a difference.

Serbs who fought, or Serbs who accepted the ideology of nationalism, feared and despised, in a way, but also respected the Croats. There was a very strong sense of this word "narod," "a people"; not as in sort of people at a bus stop but "the people," as in the German "das Volk," and the Serbs respected the Croats as a legitimate sort of "narod" in that sense. The war in Croatia, which I talked about earlier, I got the impression at the end it was being fought sort of by mutual agreement. I mean, both sides were fighting for something they wanted to achieve, and they opposed but respected each other. Serbs were justifiably fearful of the Croats, and given the history of this century and their suffering in the Second World War, that is unsurprising. So there was a mixture of hostility, fear, and respect, if you like, but certainly not disdain.

With the Muslims, it was something very ⁷⁴⁵ different. The language was different. They would be talked about as undesirable, dirty. There is a word "balija," which translates roughly - and I stand corrected by our friends if I'm wrong - but it's sort of "dirty gypsy," sort of thing.

Nikola Koljevic, who was the Vice-President of the Republic of Srpska --

MR. VUCICEVIC: Your Honour, we object to the translation of this word.

JUDGE MAY: Well, no doubt a translation can be agreed in due course.

THE WITNESS: Well, I will defer to whatever the translators agree upon.

But the point I'm trying to make is that I think Koljevic, the Deputy President of the Republic of Srpska, talked about a "breeding war" against the Serbs by the Muslims. General Mladic said, "If you let one in, he'll bring his five wives, and you'll have a village." It was a different language being used, that they weren't a proper sort of race, they weren't a proper narod, they were a false people, and that I heard quite a lot.

But over the years, I came to realise, I think rightly, that this disdain felt by a large number of but by no means all Serbs - and I stress that ⁷⁴⁶ again - was entwined with a sort of envy or it was envy-masked as disdain, because in many of these places that I worked in and met people from, the Muslims would perhaps be overrepresented among the merchants or the intelligentsia, they would often be better educated, so that there was this odd entwinement between disdain and hatred but also a degree of envy, and that I sort of started to realise over a period of time as it became clear that it was the mercantilist and sort of the intelligentsia that were bearing the brunt of this hatred.

So, yes, there were - sorry to be lengthy - there were differences, yes.

Q. In your conversations, you mentioned Professor Koljevic who at that time was Vice-President of what was referred to as the Republic of Srpska. In that conversation, did the term "racial memory" ever arise?

A. I had quite a few conversations with Professor Koljevic --

JUDGE MAY: Yes. If you would like to go on?

A. Yes. I had a number of --

MR. VUCICEVIC: Your Honour, just a small point here. In the United States, I would raise the ⁷⁴⁷ "dead man's rule." Because Mr. Koljevic is dead and has been dead for a while, there would be no way to cross-examine what was said and what he said. I don't know whether it is applicable here or not so ...

JUDGE MAY: We don't have that rule here and we admit hearsay and, of course, you can cross-examine as best you can.

But, Mr. Keegan, I think we could limit these views as far as possible.

MR. KEEGAN: Yes, Your Honour. We're going to actually relate to -- not specifically to what Professor Koljevic said but how this term and the ideas for it are relevant and were relevant in Prijedor in 1992.

JUDGE MAY: Yes. If you could get on with that as quickly as you can.

MR. KEEGAN:

Q. What was your understanding based on the conversations of the context of that term? What did it allude to?

A. Well, actually, Professor Koljevic was in the process of sending us down to Prijedor in 1992 and I had the first of my conversations with him. "Racial memory" was what he regarded as the great sort of blessing of the Serbs. He said it was ⁷⁴⁸ very important to have it, that the Serbs had one, and that the Muslims did not have any racial memory, and he -- I won't go into it all -- but he was very articulate, he was an intelligent man and talked a lot about what he thought this racial memory meant in terms of poetry, awareness of history, in many cases vindication of history, and that I think is what he meant by "racial memory," and he didn't think the Muslims had a racial memory.

Q. Was there, from your observations, a relationship between this concept as discussed and the use of propaganda by Serb leaders from the beginning of the conflict and throughout its duration?

A. Certainly in terms of what Professor Koljevic called "racial memory," what we can call "history," yes, indeed, there was. I mean, if you will forgive me, I mean, one of our jokes as a community of journalists was you ask a question about why the mortar fell yesterday and the answer begins in

1360-something. History infused and informed an awful lot of what happened, and these echoes had come down certainly the decades since World War II and indeed the centuries.

Professor Koljevic, during that conversation on the eve of my first visit to Prijedor, talked about ⁷⁴⁹ this being the third Great Balkan War, the third Great Serbian uprising, the first two having been against the Ottoman and Austro-Hungarian Empires respectively. History was invoked in the propaganda. You asked me about propaganda. Yes, it was relentless. It was on television, in magazines, cartoons. People from outside found it banal, perhaps, but I think it was very --

THE INTERPRETER: Mr. Keegan, could you ask the witness to speak somewhat slower?

MR. KEEGAN:

Q. Mr. Vulliamy, I have a request from the translators, if you could please speak a bit more slowly in your responses?

A. My apologies to them.

Q. Did you see, in your experiences during your time there, the use of these historical examples and how were they focused, particularly with respect towards Bosnian Muslims?

A. Well, one of the landmarks in all this is said to be President Milosevic of Serbia's visit to the field of Kosovo Polje which was a defeat of the Serbs by the Ottomans back in the, I think, 13th century, and the promise of revenge against the Turks, which was another word often used to describe Bosnian Muslims. ⁷⁵⁰ Certainly the invocations of the Serbian suffering during the Second World War was deployed a great deal, not least the disinternment of bodies on the eve of war, Serbian bodies. This didn't appear to be directed so much at the Muslims but at the Croats, but one later found that the Muslims were implicated in this as well. Yes, I mean, specific episodes in Serbian history were always being invoked to justify what appeared to be the infliction of suffering in this time, yes.

Q. In your research and in your experience, did you find that there was a relation with these historical examples between the use of propaganda and paramilitary forces that was similar to what you saw in your experiences in '91, from '91 through '95?

A. Well, I've tried to describe the relationship between the regular armies and irregulars. Obviously I'm speaking from what I've read in books here, so ... Yes, there did appear to be a relationship between, whether it was the Serbian Royal Army and irregulars, the various militias that fought in World War II. Yes, you always had this irregular sort of underbelly or element in the Serbian forces. In the old days, they were called the "Ceta," as I recall, and that is the source of the word "Chetnik" which you hear ⁷⁵¹ now sometimes to describe these irregulars.

Q. Slow down, please.

A. But, yes, the pattern seemed, from what I could gather in researching the history of Yugoslavia, to repeat itself at these various junctures.

Q. In the examples that you saw both in your research and in the propaganda, what had been the role of that paramilitary or irregular forces?

A. The dirty work, really, going in before, ahead of the main troops, rather as shock troops, if you like, against invariably civilians, or the other end of the process, mop-up operations, getting rid of pockets of resistance and/or civilians they didn't want to be around.

Q. In your meetings with Bosnian Serb leaders, both civilian and military, were there particular documents or writings which they relied upon in promoting their ideals in these historical arguments you referred to?

A. There were a number of tracts, yes, mostly produced in the 1940s, to justify the Greater Serbia, as it was called then, and older material too, and some of this stuff was reproduced in handbooks that troops would carry, proclamations, maps. In many ways, this was a war of maps. I always thought -- people always ⁷⁵² had a map to justify whatever was going on and, yes, these maps and tracts would be physically produced on television, read out in political speeches, and indeed, in some cases, carried by troops in little diaries that they were given.

Q. In this concept of Greater Serbia which you became aware of, what territory or area of the former Yugoslavia was encompassed within that idea?

A. Well, it varied according to which time we're talking about. The maps that I was most often shown dated from the late '30s, early '40s of this century, and they would cover most -- well, a lot of Croatia, usually all of Bosnia, with Dalmatia as a sort of vassal statelet down on the Adriatic coast, and they certainly were to contain all the areas, and this is, I think, the crucial point, if I understood them rightly, all the areas where the Serbs lived, whether this be Bosnia or Croatia or anywhere else, that was the propelling idea behind the Greater Serbia, which was that wherever there is a Serb is Serbia, and this idea informed the maps.

Q. Now, having followed the break-up of the former Yugoslavia from the beginning, were you aware of whether there were periodic statements about the crisis involving refugees and the commission of atrocities ⁷⁵³ from U.N. agencies, the ICRC, from newspapers on all sides of the conflict, that would be within Bosnia and without, as well as statements from political and military leaders of all the republics?

A. Well, I was out of Bosnia for the first few months -- the first couple of months of the war, in the spring of '92, but obviously I was following it closely, and, yes, the UNHCR in particular and the International Red Cross, inasmuch as they felt empowered to, and governments, particularly the Croatian government, were talking about what one man from the UNHCR, whose name is, I think it was Peter Keslar, called the worst forced movement of population since the Second World War, and the newspapers -- well, I was reading the British and American newspapers -- and television reports were reporting a vast influx of people from the Prijedor-Banja Luka area across the Croatian border into the border town of Karlovac where testimonies were being collected and, yes, the international agencies, the media, and the Western governments were almost, all of them, thrown into disarray by the size of this movement of population, and the Croatian government in particular was worried because the population of the country, itself coming out of war, was being increased by a matter of hundreds ⁷⁵⁴ of thousands.

Q. In August of 1992, as you re-entered the area of the former Yugoslavia, did you come across an example of this type of transfer of population or, as it's been referred to, "ethnic cleansing" in the area of Loznica which you described earlier?

A. Yes, this was my first direct taste of it. I was there on my way to Bosnia and visited a camp. That was the first -- well, it wasn't actually a camp, it was a place in which the Serbian authorities, the Yugoslav authorities, were billeting people who had come from eastern Bosnia, in the case of the people I spoke to a village that I visited called Zepak, and they were the first people I spoke to and met. Their condition, I have to say, was not bad. They were being treated with -- well, all things are relative, I now know -- fairly well, but they were my first encounter with this massive movement of population and, I have to say, the other end of the country, not where the main influx was coming, which was out of Prijedor and Banja Luka.

Q. Did the individuals in that location in Loznica indicate to you how they had come across the border and why they were in that area, that centre?

A. Troops had arrived at their houses and told ⁷⁵⁵ them they were leaving on pain of -- I don't think they bothered to ask. Yes, they were deported.

Q. Did they indicate where they were told they were going to be taken to?

A. They were told that they were going to a place called Subotica, which is in the north of Yugoslavia near the Hungarian border, and they were told that papers had been organised for them to leave the country and to go to Hungary and Austria and Germany, I think, but there was no sign of that having happened when we spoke to them.

Q. Did they indicate how long they had been in the camp?

A. They had been there a matter of weeks rather than months.

Q. What type of forces were arrayed around this area, the centre?

A. Yugoslav police, uniformed police officers.

Q. At what distance were you from the border with Bosnia and Herzegovina?

A. Almost no distance at all. Loznica is a border town, and actually, the deportees could see their village from -- I don't actually like to call that place a camp. It wasn't. That really was a deportee centre. From the yard of that centre, which ⁷⁵⁶ was a converted school, they could actually see their village over the border and point it out to us and even gave us instructions to find their houses. Some of them could even see their houses.

Q. How was it that you came to be in Loznica?

A. Well, it was the first stage in what would be quite a journey. It was one of a list of alleged concentration camps which the Bosnian government had put out, and we were visiting it for that reason. It turned out to be anything but a concentration camp. The background is this: These reports I was talking about, the massive influx of people into Karlovac, across the border into Croatia from the Prijedor and Banja Luka area, were accompanied by reports also of camps.

Q. Do you recall the date that those reports were published in the Western press?

A. These would be the last ten days of July.

Q. Of what year?

A. Sorry, 1992.

Q. After those reports of mass movement of people and of the existence of camps, what occurred?

A. Well, British and American newspapers were reporting the existence of these camps and progressively mentioning some of them by name. The ⁷⁵⁷ testimony was initially based on people who were coming into Croatia, Manjaca was one that was being mentioned, also Trnopolje and, finally Omarska, and Dr. Radovan Karadzic, the President of what was then called the Serb Republic of Bosnia-Herzegovina, happened to be in London for a meeting on the day that my paper and others published a story based on people who had come across into Croatia and were talking about Omarska and describing alleged conditions in Omarska and other camps.

A man called Roy Gutman had been writing similar material in a newspaper called News Day which is published in New York. Dr. Karadzic was challenged on television about this, on ITN, and said that these reports were lies and exaggerations, that no civilians were being held prisoner, and he wrote a letter to The Guardian, my paper, to that effect as well, and both his -- which was published later, a couple of days later.

His rejection of these allegations was accompanied by a challenge to journalists, specifically, I think, ITN on whose network he was speaking and in The Guardian where the Omarska allegations had appeared, a challenge to come and see for ourselves. He said, "These are untrue, they're ⁷⁵⁸ fabrications," and I'll paraphrase him - you can get the exact words - "Come and see for yourselves." My boss, my foreign editor, said, "Well, all right, we will, if that's okay," and so did ITN.

I don't know quite what kind of time frame he had in mind for our visit, but my foreign editor, a man called Paul Webster, phoned Dr. Karadzic on a mobile phone when he was going to the airport and said, "Well, we're on our way," and I think there was some talk about two weeks, but he said, "No, I've got a reporter ready to go now," and that was me. So that's how -- well, we got to Loznica because Loznica was the first one on the list, but that's how we ended up in Belgrade and in a position to visit Loznica. It was the result of Dr. Karadzic's challenge/invitation.

Q. When you arrived in Belgrade, did you have to accredit yourself with anyone?

A. Yes, we got to Belgrade the next day, and first thing we had to do was to accredit ourselves with a thing called the SRNA, S-R-N-A, I think, which was the Serbian News Agency, Yugoslav Serbian News Agency, and we had to have their papers to be able to proceed with this trip, this investigation.

Q. How many days did you end up staying in Belgrade? ⁷⁵⁹

A. Well, we stayed there longer than we had hoped, actually. We wanted to get straight on to Omarska as soon as possible. But we ended up staying in Belgrade three days while we waited for the various authorities to make arrangements for us to travel and to get the necessary clearances and, indeed, to listen to Professor Koljevic, as I mentioned before; and it was during that time that -- well, rather than just waste our time in Belgrade, we thought, "Well, while we're here, let's have a look at some of the places on the list supplied by the Bosnian government of alleged concentration camps and see if they match the description which indeed they did not.

Q. Who took you to the camp at Loznica, the centre?

A. ITN went with -- we were allowed to go of our own accord to those places. I went with my translator and a freelance colleague who worked in Belgrade. There was no problem going down there at all. Once we had the SRNA paper and told the authorities where we were going, indeed told the Professor where we were going, that wasn't a problem. I can understand having seen Loznica and another place at Subotica, that they didn't have any problem with us going there because although the situation was tragic, the term ⁷⁶⁰ "concentration camp" was clearly inappropriate.

MR. KEEGAN: Might that be a convenient time?

JUDGE MAY: Yes. We'll adjourn now. Mr. Vulliamy, will you be back, please, at half past nine tomorrow morning?

THE WITNESS: Yes, Your Honour.

--- Whereupon proceedings adjourned at 5.07 p.m., to be reconvened on

Wednesday, the 15th day of July, 1998, at 9.30 a.m.