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

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(1)Wednesday, 15 March 2000
[Open session]

--- Upon commencing at 9.32 a.m.
[The witness entered court]

(5) JUDGE RODRIGUES: [Int.] Good morning, ladies and gentlemen; good morning to the technicians, to the interpreters. Can you hear me? Thank you. Good morning to the counsel for the Prosecution, the counsel for Defence; good morning, (10)General Krstic. We will continue with our case. We know it's the Krstic case. I will give the floor to Mr. Harmon, and I believe we will go on with the testimony of Mr. Ruez. (15)Is that the case, Mr. Harmon?

MR. HARMON: That is the case, Mr. President. Good morning, Mr. President; good morning, Your Honours; good morning, counsel.
[The witness entered court]

(20) WITNESS: JEAN-RENE RUEZ [RESUMED]

JUDGE RODRIGUES: [Int.] Good morning, Mr. Ruez. We will continue your testimony. I will give the floor immediately to Mr. Harmon. I just want to remind you that you're still under an oath and (25)that you will be answering questions put to you by

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(1)Mr. Harmon.

MR. HARMON: While Mr. Ruez gets himself organised, Mr. President and Your Honours, we're going to be now turning our attention now to Volume 2, (5)Exhibits 14 through 27.

• EXAMINED by Mr. Harmon:

• Q.: Mr. Ruez, we're now going to turn our attention to Prosecutor's Exhibit 14, which is the Nova Kasaba graves, and I believe we have a videotape that (10)we are going to play to begin this presentation.

• A.: Yes. We are going to start with the Exhibit 14/12, which is a short videotape showing the area of these graves of Nova Kasaba.

• Q.: Before we show the video, Mr. Ruez, would you (15)please point out to the Judges the location of those particular grave sites?

• A.: So we are still in the area of Nova Kasaba, which is located just south of the intersection of Konjevici. The precise location of graves we are now (20)going to show is where the yellow dot is marked here as a primary, undisturbed mass-grave area.

MR. HARMON: Could we have the audio booth please now dim the lights, and we could start with the film 14/12.
(25) [Videotape played]

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(1) • A.: On the left was the intersection of Konjevici. Just underneath here is the exit of the little road that goes towards the valley of Cerska. This road goes towards the soccer field of Nova (5)Kasaba. On the left is still the hill on which all the people were jammed and witnessing events. Here, just after the curve of this road, you have an opening of ground. This is the location number 1. (10)Just a bit further on, in front of the group of houses on the opposite side of the road, in between the river and the houses is an area here where we'll currently zoom in, which is the site of the second grave area. And this stretch of road continues a (15)little bit, arrives to the soccer field here. Nova Kasaba town is just behind the name of the town has changed recently. I don't have it in mind at this moment. This is again a view of this valley going (20)towards Konjevici, the direction north. That was the final view. Above Nova Kasaba town, looking towards the soccer field, the grave area being now behind the hill in the curve. (25)We -- no. The film continues, because now we

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(1)are flying above this hill from where the people could overlook. So one can indeed see that from this location it's a very good view on the road. We are returning towards these grave area, which are now above (5)the road, and here is the first one we saw, just in this curve, in a very specific shape.

MR. HARMON:

• Q.: Mr. Ruez, why don't you proceed by putting some photographs on the ELMO, and if we could take (10)Prosecutor's Exhibit 14/1.

• A.: So this is an aerial photograph taken 13 July 1995. There is nothing to be noticed specifically on this photograph. It is a reference for the next one. Two areas are squared on this photograph, (15)which mark the grave areas which we saw on the video. The one at the bottom left is the one we saw first and then last, the one which has this specific shape. The one on the right hand on the photograph is the one that we saw and that which I mentioned was the site was in (20)between the river and the road. The site is, in fact, just at the edge of the river. We'll see that later.

• Q.: Keep that photograph on the ELMO for just a minute, because the caption says "Areas of disturbed earth," and this picture doesn't show any disturbed (25)earth. So these rectangles represent areas where earth

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(1)would be later disturbed; is that correct?

• A.: Yes. That is correct. Again, the label is because this photograph is in connection with another one and, in fact, the stack of photographs related to (5)that specific crime scene is labelled "Area of disturbed earth."

• Q.: Now if you would turn next to the photograph that relates to this photograph, you can make the demonstration. I'm referring Prosecutor's (10)Exhibit 14/2.

• A.: This exhibit, 14/2 is, is an aerial photograph dated 27 July 1995, so in between the time of the events and the time of reburial. On these photographs, one can see very clearly, on the left side (15)or the left part of the photograph, in between the road and the river, close to the river, an area of disturbed soil which is split, in fact, in several smaller disturbances. On the right of the picture, which is south (20)on the map, towards Nova Kasaba, is an another area very close to the river where a disturbance it is to be noted.

• Q.: Mr. Ruez, would you turn your attention next to Prosecutor's Exhibit 14/4? 14/4, Mr. Ruez. That's (25)14/3.

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(1) • A.: Exhibit 14/4 is the same photograph as Exhibit 14/3, with the difference that the markings are put on this photograph. The markings indicate the code names which were given during the exhumation of this (5)site. The exhumation of this specific site was done in 1996. This photograph is one of the two which was shown by Madeleine Albright, who at that time was US Ambassador at the United Nations, and this (10)photograph was shown -- was made public on 10 August 1995. The exhumation of this place was conducted in 1996. I won't provide the full details about the results since someone will come and develop the entire (15)results for all the exhumation which was conducted from 1996 through 1999 and will continue this year, but on this specific location, 33 bodies were exhumed in 1996. The exhumation is completed here. The site was split in four graves. (20)The next exhibit is the photograph marked 14/5, which is the same grave area we previously saw. The interesting part here, aside seeing it in colour, is if you reverse it, you will have exactly the same photograph than the previous one, where you can see -- (25)we'll circle the areas.

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(1)The area on the left of the aerial photograph is in between these two trees of line [marks], and the other one is an area of disturbance which was here
[marks]

(5) MR. HARMON: For the record, Mr. President and Your Honours, on this Exhibit Mr. Ruez has circled three areas with a red pen.

• A.: The next photograph is also a photograph from the helicopter, photographed in 1999, as the previous (10)one, and this is again the same site but seen from the west, towards the east, and I will again circle the locations since now with this one, one is very obvious. The other one is nearly invisible because it's hidden behind a tree line. I'll start with the (15)one most at the left of the picture, which is the most north on the ground [marks] This area here [marks] and the second one is this area here [marks] On this photograph, a small digression, but you can also have here a very good view on the location (20)which I exposed yesterday, which is this execution field in between two houses. I will very briefly return on this point, not to say that there is a connection between the execution site and these mass graves, but the location is exactly there on this (25)photograph with all the reference points which I

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(1)indicated to you yesterday. Here you have a pylon [marks], nearby which someone was witnessing the events. Here you have a white house and the house on top of the hill here
(5) [marks], which would be the two houses in between which the person could see the event. This area here
[marks] -- or a bit more on the left, I'm sorry, this area here [marks] is the approximate -- it's smaller on the ground, but it's the approximate area where the (10)execution took place.

MR. HARMON:

• Q.: So the record is clear, would you put the number 1 next to the area where the executions took place.

(15) • A.: Number 1 is the area where the execution took place; number 2 is the house which was on the left-hand side of the person who was seeing the events; the house at number 3 is the house which probably was on the right-hand side of the person who could see the events; (20)number 4 will be the pylon in the vicinity the person was standing. And now returning to the Nova Kasaba graves, I will mark "A" for the site which is the most -- at the left in the picture and letter "B" for the one that is on the right of the picture.

(25) • Q.: Please continue.

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(1) • A.: The next exhibit is a photograph which was taken at the moment we did a probe of this site in 1996. The aim of presenting you this one is to give you an indication of what it means when we say that we (5)are probing a site. What we are doing in these circumstances is that we are digging in a location where we suspect the presence of a mass grave until we find multiple remains, multiple remains indicating the presence of a (10)mass grave. Once this is successfully conducted, then we schedule the site for exhumation, depending on the priorities we think are the most appropriate at the moment. On this photograph, we did a bit more than (15)exposing only multiple remains, since we exposed nearly complete bodies. On this photograph you can see, in fact, one body part belonging to one individual here
[marks] You can see one individual lying here with his head under the soil and his hands in the back. (20)There is one more individual here [marks] There is one individual lying on his belly here [marks], with his hands attached in the back. You have one individual lying here [marks] with his hands attached in the back, and he is lying on top of another (25)individual which is underneath him here [marks], and

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(1)his hands are on the head of another individual which is also underneath him.

• Q.: For the record, that exhibit is Prosecutor's Exhibit 14/7.

(5) • A.: Exhibit 14/7. This operation was conducted in April 1996. The following exhibit, Exhibit 14/8, is just a close-up on one of the bodies I just pinpointed, the one who has his hands on the head of the individual (10)underneath him, and I am just going to pinpoint for you on this photograph two elements which were pinpointed already at the public hearing in July 1996, which are the wedding ring of this man --

• Q.: Which you're circling in red.

(15) • A.: Which I just circled and I will mark "A"
[marks], and I will mark "B" the wire ligature which is binding the wrists of this man. The following exhibit, Exhibit 14/9, is a view of a second grave area which was already shown on (20)the broader view, which was showing these two sites. This is the one which is the most south, so it was on the right of the general overview of this area. And the next exhibit marks the location of the graves which are exhumed in 1999.

(25) • Q.: That's Exhibit 14/10.

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(1) • A.: This is Exhibit 14/10. You can see here that the site is divided into several subsites. The total number of individuals exhumed in this location in August and September 1999 is 55 individuals. The (5)details about the bodies, the other findings in the graves, will be the topic of a specific expos‚. Exhibit 14/11 is a photograph taken in 1999 which shows the same site as the one that was on the aerial imagery, and I'm going to mark the location of (10)the site on this photograph as being "1". This is the main site.

• Q.: Now, have you completed your presentation in respect of these particular grave sites, Mr. Ruez? Shall we move to a different topic?

(15) • A.: Yes.

MR. HARMON: We will now move, Your Honours, to Prosecutor's Exhibit 15, KP-1. In this particular case, we do not have a video. We will start directly with Mr. Ruez orienting Your Honours to the locations (20)of KP-1 on the large map.

• A.: On this large map, there is really no possibility to differentiate this location from the other ones. On the right here, this is very close by, as you can see on the video filmed from the (25)helicopter. All the locations we are mentioning here

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(1)are along a stretch of road which is less than three kilometres long, going from north to south. The precise location of the grave we're going to show now would be here [indicates], just nearby the exit of the (5)Cerska Valley. Exhibit 15/A is a photocopy of the map of the area, and the circle marks approximately the area of the site and the green dot marks the more precise location for this grave, which is on the right-hand (10)side of the road when travelling from the north to the south, so from the top of the picture towards the bottom of the map. I'm going to skip Exhibit 15/1 which is exactly the same exhibit as 15/2. (15)Exhibit 15/2 has some markings on it. So this is an aerial photograph, dated 14 August 1995, on which one can see, going from the left towards the right, the dirt road that goes towards the Cerska Valley and which exits in the plain of Nova (20)Kasaba-Konjevici. It hits the road that goes from the bottom of the picture towards Nova Kasaba, and at the top of the picture towards Konjevic Polje. In the curve, behind a little group of trees, is an area of disturbed soil which is marked "KP-1". (25)You can see on this picture that there is another area

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(1)of disturbed soil which is squared and which is just at the exit of the Cerska Valley. I won't develop this one any longer since we probed it and there was absolutely nothing to be found there, so we have no (5)explanation for the presence of this disturbance. Returning to KP-1, I shall like -- it's another one that was the equivalent to this one. I'm still going to show you the photograph 15/1 for the reason that that one was dated 27 July. The site which (10)is on the left of the photograph is the one which I indicated was negative -- the probe was negative when we conducted it in 1998. But the site did not exist prior to 27 July 1995, so it is a site which was created between 27 July 1995 and 14 August 1995. We (15)have no explanation for that. There is still one possibility that I would like you to know about, it is only a possibility, but since the aerial photographs which were shown previously have been disclosed in public on the 10th of (20)August, there is the elimination of the theory that it could be linked with some -- this creation of deception sites following the presentation. This could have been a military position, a tank position, or a position of a gun, or something like this. (25)Where were we at this point?

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(1) • Q.: We are about to move to Prosecutor's 15/4, which is a colour image.

• A.: Yes. Exhibit 15/4 is a view of this same area but from a helicopter, a colour photograph. The (5)reference points to match it with the aerial photograph would be the exit of the road coming from the valley of Cerska, which is at the top right of the photograph and which arrives on the asphalt road. This view is a view from north towards south, from the intersection of (10)Konjevici towards Nova Kasaba. The little group of trees which could be seen on the aerial photograph is the group of trees I'm going to circle on the picture [marks] The buses which were transporting the people (15)deported from the enclave towards Kladanj were passing along this road, coming from the bottom of the picture towards the top of the picture. So this is a very good location to hide a grave here since no one can see from the road what is happening behind this tree line. (20)The location of a small grave found here -- I'm going to mark it with an arrow [marks] -- is just behind the trees on the right hand of this group of trees, so hidden from the road.

• Q.: Exhibit 15/5 has now been placed on the (25)ELMO.

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(1) • A.: Yes. Exhibit 15/5 is just to show you what happened when we went to probe this site in 1999, and we discovered very soon on this site here is half of a skull close to the bucket of this backhoe. This was (5)the first finding in this grave. The exhumation was completed there and 19 bodies have been found in this one.

• Q.: Mr. Ruez, now let's move to Cerska, which is your presentation beginning with Prosecutor's Exhibit (10)16/1 or 16/A, I'm sorry. Again --

• A.: On this main exhibit, the valley of Cerska is going from the asphalt road towards the hamlet of Cerska. We had a situation here where several witnesses talked about a series of events and the (15)pasting of their information finally enabled us to find more about it. Some people saw buses getting inside the valley followed by an APC, and later on heard intense shooting coming from the area. Another person managed (20)to cross that area during the night, didn't see the previous event, but when walking along this path at one point walked in a pool of blood. The person was barefoot, saw a few bodies, and was scared, ran away. Another group of people who had imagined to (25)pass and didn't know about the event were hiding on top

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(1)of the valley of Cerska after we [sic] had decided to return to Srebrenica because they had no idea where to go. On their way back they smelt a disgusting smell and noticed an area of disturbed soil. (5)So the pasting of all this information enabled us to go to the valley. We didn't initially find anything suspect here, but it's a long valley and the method to find the graves is not really a hundred per cent efficient. It is picking with a probe in the (10)soil and then sieve the other to find out if there is something underneath. So in such large place it is not very easy to do. Nevertheless, we filmed the entire valley from the top to the bottom of it and presented that (15)film to one of the persons who walked down that area one week after the events, and that person enabled us to find the grave by pinpointing the area where he remembered having seen and smelled the thing.

• Q.: Mr. Ruez, you want to commence your (20)demonstration by showing a video. If we could have the lights dimmed and we could turn to 16/5 and show the video. Mr. Ruez, narrate as you find appropriate.

• A.: There will be sound on the video. Mr. Peter Nicholson, who was doing the video in 1996, will speak (25)on it.

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(1) [Videotape played]

• A.: So this was the intersection of Konjevici. This is again the main hill we constantly refer to at this moment. Here is the little intersection that (5)leads right to the valley of Cerska. We had another view just before of this group of trees with the grave behind it. This is the dirt road that leads towards the valley. No. Sorry. This is still the asphalt road (10)that goes, at this moment, from Nova Kasaba towards Konjevic Polje. Here, on the left, is the entrance of the valley of Cerska in which we're going to fly into. As you can see, it's a narrow entrance. It is also a bit -- on the side it's -- on the road it (15)seems to be a very remote place, and it is indeed a remote place. This follows the dirt road up to the site. There is nothing there except destroyed houses, a few destroyed houses. This valley was an area of intense (20)fighting in 1993 when the Bosnian Serb army crashed the forces of the 28th Division in this area. This was a little intersection which leads to the village of Macesi, which is a destroyed village. This is a view of the valley, towards the top. (25)This is first an area where we suspected an

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(1)execution having taken place, but we have disregarded the information since we didn't find any shell casings in the area which was designated as being the execution site. (5)This is the location of the execution of ... that was the area of scooped soil. The date on the video is irrelevant. It might be a correct one, but most of the time in 1996 the dates on the videos were not correct. So we have (10)to listen to what he says at the beginning in fact. This is again the spot of the grave, and we're going to exit the valley to show somehow remote this location is.

MR. HARMON:

(15) • Q.: Mr. Ruez, please continue with your presentation.

• A.: The Exhibit 16/A was the map of the area which pinpoints the precise location of the grave in the valley of Cerska. (20)The exhumation was completed in 1996, and the initial information was that three buses of prisoners were taken for execution towards this valley. A hundred and fifty bodies have been recovered in that location. (25)The exhumation report will enable to

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(1)reconstruct the events on the spot and give all the details of the cause of death and the bindings found on these prisoners. Exhibit 16/1 and 16/2 are the same, so I will (5)show immediately the 16/2. Among the numerous elements which enable us to provide you with the certainty that we are indeed talking about victims from Srebrenica, July 1995, and not other possible victims in this area or victims from events from other dates, this aerial (10)photograph shows the grave of the valley of Cerska which we discovered. On the left of the photograph you can see the ground dated 5 July 1995. There is no disturbance on the ground. On the right of this picture you can see the same location at 27 July 1995. (15)You have here a massive disturbance on the left side of the road and also a smaller disturbance on the right hand of this road. So the event is, without any doubt, in between the 5th July 1995 and the 27th July 1995. The next exhibit is 16/3. It summarises, in (20)fact, the video we just saw since all the observations can be summarised on this one. You have on the left side of the road the area where the collection of shell casings is ongoing. The area of shell casings, in fact, matches the size of (25)the graven which is on the edge of the road, on the

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(1)right of the picture, where currently people dressed in blue are conducting the probe. Where the vehicles are standing on the dirt road, on the left of these vehicles is an area of (5)disturbance which is, in fact, soil which has scooped away from this hill. An excavator entering this valley was witnessed by a person approximately half an hour after the three buses entered the valley, and that excavator probably scooped away this soil and just (10)dumped the soil on top of the bodies which fell at the edge of this dirt road towards the meadow which is underneath, and they were just covered with the soil taken from the opposite hill. The Exhibit 16/4 is an additional summary of (15)that grave which shows at the bottom of the picture the shoes and the legs which we exposed. On top of this mound of soil, which is, in fact, the bank of the road, is one individual that shows the location of the road, and just at the top of the picture is the area where (20)the soil has been scooped away from the hill on the opposite side.

• Q.: Now, if I could have the assistance of the usher, and I'd like to present Prosecutor's Exhibit 16/6 to Mr. Ruez, and have him take it out of (25)the envelope and explain exactly what it is.

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(1) • A.: This is a piece of wire which is, in fact, a ligature for the wrists which was found on one of the bodies exhumed from this grave. All the details will come later about this, but in this grave -- as far as I (5)have on my note here, 48 individuals were ligatured with this kind of ligature and other style of ligatures.

• Q.: Thank you, Mr. Ruez. You can put that back in the envelope and seal it. (10)We've completed our presentation on the Cerska Valley. We will now move to the next exhibit, Prosecutor's Exhibit 17, KP-2. Again, why don't we start with the orientation first, Mr. Ruez, and will you take us through this particular presentation?

(15) • A.: The next site is a very small site but it's a good example of -- sorry. The next site we are going to go to is a very small site compared with the one we have just exposed, but it's a good indication of how multiple the events (20)were in this area. We have events of various scales, executions going from one individual to obviously 150 individuals in this area. We know some of them. We certainly don't know all of them. I indicated yesterday that it's particularly (25)difficult to find small graves. We still have found

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(1)some of this. The site we are going to show now is at the east of the intersection of Konjevic Polje driving towards Bratunac, 1.7 kilometres east from this intersection. So all these events are part of a kind (5)of package of events happening in this area.

• Q.: Mr. Ruez, if you would go directly to Prosecutor's 17/2 and 17/3. I will explain the error in 17/1 to the Court after you complete your presentation.

(10) • A.: Exhibit 17/2 is the map of the area --

• Q.: I'm sorry. That's 17/A.

• A.: Sorry. Exhibit 17/A is a map of the area, scale 1:50.000. The circle marks the approximate location of the grave, and the yellow dot on this map (15)is misplaced, it should be at the south of the picture, which is the bottom of the map. Going towards Bratunac, the site is to the right of the road, and this spot marks the left. In this location -- we managed to find this (20)location from an aerial photograph, which I will not present, since the only feature to be seen on it is a little disturbance under a tree line. We went to probe the area, thinking it was a mass grave. We didn't find a mass grave. But when we returned to continue the (25)probe, since there was really no reason for this

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(1)disturbance to occur there without anything to hide, with some insistence we uncovered a grave which contained one individual. This is Exhibit 17/3. It shows that person (5)inside this grave. The grave was a pre-dug whole in which, in fact, the person has been dumped into, probably -- the person certainly -- probably didn't die at this location. The causes of death of this individual are multiple gunshot wounds. (10)On the next exhibit, which is 17/4 -- sorry, 17/2, one can see the skull of a person with a big hole in it, but this hole might have been done when the body of this man was moved with heavy equipment. Just nearby it is another grave with two individuals in it. (15)The area of disturbance indicates that most probably these persons were not killed on the spot, but killed in the vicinity and then moved to this location, probably in the bucket of an excavator, and then just unloaded into these holes which already existed and (20)then left there, covered with soil. Just an example to highlight the fact that there are probably many of these small sites in this area, but we will never find them.

MR. HARMON: Mr. President and Your Honours, (25)there's been a photograph that has been placed out of

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(1)order that belongs in Prosecutor's Exhibit 8, and that is the first photographic exhibit, Prosecutor's 17/1, and I will have Mr. Ruez explain to you the location that's relevant in this particular photograph, which is (5)the Kravica warehouse. We will spend just a minute to correct the error on this.

• Q.: Mr. Ruez, if you would inform the Judges of the importance of this photograph and the location of the Kravica warehouse, we can then move on.

(10) • A.: Yes. On this photograph, it is a view from the west towards the east, and you can have a good view here of the Kravica warehouse, which I circle [marks], which enables us also to have a view on the tree line, which is just behind the warehouse, and also on the (15)open meadow, which is a corn field which is behind the warehouse. It also gives a view of the hill, which is on the right of the picture, south on the map, where you can see the power line that people were following. Not (20)necessarily in this location, but this power line continues towards Konjevici, and I'm going to just draw a line along it [marks] That's the power line. There is a little path going uphill, and then at this power line, there's more open ground. This power line goes (25)towards Konjevici.

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(1) MR. HARMON: So this exhibit, Mr. President and Your Honours, should be considered in conjunction with the other exhibits in the Prosecutor's series commencing with 8.

(5) • Q.: Now, Mr. Ruez, we can turn our attention to the next part of your presentation, which is commencing with Prosecutor's Exhibit 18. Would you orient the Judges, as we normally do, and then inform the Judges about this particular area.

(10) • A.: Among the numerous events which happened in this area at the moment people were surrendering, one event is that persons who were surrendering in the vicinity of Konjevic Polje were first taken towards various buildings in this area, including the (15)guardhouse of the 5th Engineer unit, which was billeting in the area of Konjevic Polje. Destroyed houses. One hangar, which is visible on photographs dated 1996 and on aerial imagery dated 1995, was then transformed into a gas station. (20)When these people surrendered, at least one of them, together with 15 others, were taken on board of a bus and driven north towards the canyon of Drinjaca, which is the entrance towards the Drina River. The bus stopped on the right-hand side of the (25)road, and then the people were marched towards the bank

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(1)of the Jadar River, where they were immediately executed as soon as they arrived at the edge of the river. One of them managed to survive and provided us with information. (5)Unfortunately, in terms of possibilities to conduct forensics here, it is impossible, since the river has changed in its flow and all the evidence has probably been washed away. We couldn't find any shell casings. But there were big wood logs blocked by other (10)trees which clearly show that the river, at one point, was probably nearly a metre higher than it was when we came there. So all the shell casings in the vicinity of the place the person thought was the execution site had been washed away, we didn't find anything, and we (15)didn't insist much on this one, since it was obvious that we would not be able to find anything. So the film you're going to see will only indicate the reference points that the person had, which is a huge cliff, on top of which was previously a (20)mosque; a parking spot for a bus, which for him is a reference point of where they were then unloaded from the bus and taken towards the river. This footage will also show the difference of ground between the area south and the area north in (25)which we're going to enter now. It's quite a

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(1)significant switch in the area. The landscape between the south and the north is extremely different because of the Drina River, and also this gives a feeling, once you pass this place, of being in a completely different (5)area. So not only is it efficient to move people away from here, towards the north, in order to avoid some witnesses who could report about the events of what is happening in the south, like the UN soldiers who were still continuing to move in that place, but even (10)psychologically to give the feeling that you are entering another world as soon as you have passed this canyon. So you will see that on the video, and we will return to that small piece later.

• Q.: If the audio booth could play us the (15)Prosecutor's exhibit which is marked 18/2, we can proceed.

• A.: Exhibit 18/2 is a photocopy of the map of the area -- do we have the video?

• Q.: Yes.
(20) [Videotape played]

• A.: So this is the road that goes from Konjevici towards Zvornik and which at this moment is entering, what we call, the canyon of Drinjaca. It is the intersection of the Jadar River and Drinjaca. This is (25)still the Jadar River. Here is the cliff, on top of

• Page 698 • {28/103}

(1)which is a white ruin which was a mosque. On the left of it is the road. Just here, after this curve, here is a parking lot where a bus is standing. The location (5)where the person indicated the bus was standing is on the right-hand side of the road, a bit more there. And also there is another ground feature which we could find which is a concrete water reservoir, which is nearby these buildings which are the former territorial (10)barracks, where the person who survived the execution then stopped to heal his wound. These are the former barracks of the Territorial Defence in the area, and used at the time of the events. So Exhibit 8/1 [sic] marks the precise spot (15)where the event took place.

MR. HARMON:

• Q.: That's 18/A; is that correct?

• A.: Exhibit 18/A. And Exhibit 18/1 is a view of the cliff which is the reference point for this area, (20)and the parking lot for the bus is approximately 100 metres further on this road, driving in the direction we are driving on the picture, which is from south to north. So this is more or less the vicinity of the execution site which is close to the river. I didn't (25)show any pictures since, aside from the rubbish hanging

• Page 699 • {29/103}

(1)from the bottom of trees that shows the difference in the height of the river, there is not much that I would be able to show you on this site.

• Q.: Mr. Ruez, we're now going to proceed to the (5)Grbavci school, which commences at Exhibit 19, and we're going to move north from the events in the Srebrenica enclave at this point. Can you approach the large map and explain to the Judges where we're going and what these events relate to?

(10) • A.: We're now, in fact, entering the new phase of this expos‚ and entering the heart of the subject here.
[Microphone not activated]

• A.: As I said, we are now entering a new phase of the expos‚ and, in fact, also a new phase of the (15)events. All that I've been explaining until now are the events which happened in what we call "the area south." These events are a lot of killings happening, for sure, but not in a very organised fashion, if one can say so. From now on, we are going to talk about a (20)process which is formally organised and structured, as you will notice. We are now in a situation where we are in the night of the 13th to the 14th, where all the people who have survived the events we have unfolded in these last (25)days, all of them are in Bratunac town. All the people

• Page 700 • {30/103}

(1)who survived that process are now in Bratunac town, and the evacuation of these prisoners towards the execution sites is starting on the 14th, in the first hours of the day. (5)The first convoy filled with men takes the direction of Zvornik, with a promise of exchange given to them by General Mladic when he came to the warehouse where these people were jammed inside, many of them killed during the night through beatings and treatment (10)like this. The survivors of this warehouse, the majority of them -- because it was not on the extermination site, it was just a killing site -- all these men were then taken in a column of buses and trucks towards Zvornik, where they turned left, (15)thinking they would reach the zone of separation that leads to Tuzla for exchange, but then turned right and were stopped at a school where they had to enter the gymnasium of a school. During the day, the gymnasium filled, and at (20)some point, the execution of all these men started, as we are going to develop through the exhibits. First I will show you Exhibit 19/A. Exhibit 19/A is a photocopy of a map of the area. On this map, one can see -- this circle indicates the approximate (25)area where the school is. The green dot inside the

• Page 701 • {31/103}

(1)circle marks the position of the Grbavci school. As you can see, there is no where written "Grbavci". There's a hamlet here. You can see "Lazete" and "Lukici," but the name of the school is the Grbavci (5)school. Just above where it is written "Lukici," you can see "Grbavci Donji," so the area of Grbavci. This is why the school is named the Grbavci school. On the left, you can also see Orahovac, which is a little village, not to be confused with the same (10)village or the same area in Kosovo; this is a very different situation. What you can also see on this map is a railroad line, which is marked on this map and which comes from this direction [indicates], towards the (15)north. This railroad line exists on this map, but it did not exist on previous maps, and this was an important feature on the ground to recognise the area. I will say a few words about this later. I'm going to show now the next exhibit, which (20)is the school, Exhibit 19/1. This is a photograph of that school taken in January 1996. You can see a part of a building, but with the main elements, which is, just in front, on the right, the school itself. Then at the left of the school, the white construction is (25)the gymnasium in which the men were held.

• Page 702 • {32/103}

(1)We only know about the gymnasium as a detention site, since all the four men who survived the following execution were, all four of them, taken to the gym. They didn't arrive at the same time of the (5)day. The gym stated to fill in in the morning, continued to fill during the day, convoy after convoy, until it was completely full and only then the execution started. An important element on this picture is right (10)in the middle of the picture. In between the gym and the school is a high fence which runs along the wall of the school towards the entrance, the small entrance. The main entrance being on the main building, but the prisoners took the entrance that goes to the gym, where (15)once inside it leads either right to the school or left to the gym. I'll show the next exhibit, which is 19/2. This is a photograph which was taken in 1996, in May, and this one is another view of the gymnasium with the (20)playground on it. It has also the interest to show the access for the buses and trucks. The fence here is destroyed, as you can see in the middle part of the picture, and the trucks and -- or the trucks parked on the playground. The people had to disembark there and (25)then had to abandon their clothing nearby the fence

• Page 703 • {33/103}

(1)before entering the gym. You will also see on this picture, and I'm going to circle it now, the exit door of the gymnasium
[marks] The construction that I'm going to mark on (5)the photograph [marks] This is the wardrobe of the gymnasium. This is the room where the people went through, got blindfolded, received a little sip of water, and then were taken on board of the little TAM trucks towards the execution site. This is the exit. (10)The entrance, I'm going to mark it with an arrow [marks] The entrance is here. The next photograph is 19/3. It is a closer view of the access to the gym. The photograph also dated January 1996. Again you can see the fence (15)running along the wall of the school on the right of the picture. This fence leads to the entrance which I'm going to circle [marks] The main building behind the white structure is the gymnasium and the small building in front of it (20)is the wardrobe. On the left part of this little building is the wardrobe. Before showing the next photographs, the best would be to first view the film.

• Q.: If we could dim the lights and show (25)Prosecutor's Exhibit 19/12.

• Page 704 • {34/103}

(1) [Videotape played]

• A.: So we are again in the canyon of Drinjaca here. We have passed the area where previously the event had taken place. The shiny zone in the middle of (5)the picture now is the Drinjaca River which is going to enter the Drina River, which you can see on the film at the moment. This is to you an indication of the landscape. To give you an indication of the distances, the best would have been to show you a film where we (10)travelled by road but this would have been really boring. From now on we are travelling only by helicopter. The crime scene is so large this is the only method to give you a feeling of the place. On the opposite side of the river, on the (15)right hand of the river you have the Federal Republic of Yugoslavia, the reason why the helicopter is only flying on the left. I won't be able to show you the entire road because the road would just be underneath the helicopter. (20)This is again the Drina Valley going north. This is the Dam just before arriving in Zvornik, and the road on the left is going along this river. Here we have passed Zvornik. We are flying towards the Grbavci School. On the left is the railroad line that (25)goes towards Zvornik, and you can see there are

• Page 705 • {35/103}

(1)tunnels. There were tunnels along this -- the railroad line was passing inside a tunnel. There are several bridges also in between Zvornik and Grbavci. The railroad line is the main reference point (5)for the people who survived the execution there. They didn't know where they were. We managed to find the area following their description and by finding a piece of map which had indeed at the time the railroad marked on it. Following this discovery, we could then request (10)additional elements and make a request for imagery to pinpoint the location of the site. This is the Grbavci School. You can see the fence on the right and the entrance. That's where the people had to abandon their clothing and personal (15)belongings. This gymnasium was completely filled with men except on the left part of this gym. On the right part here there was an opening space, a free space. All the rest was filled with men. Many of the men were men (20)separated in Potocari and many of them were old men separated in Potocari. A few kids also have been separated and were in a specific part of that gym. We initially thought that the kids had been spared in this operation, but as you will see in the exhumation (25)reports, the bodies of the youngsters have been found

• Page 706 • {36/103}

(1)in Glogova.

JUDGE RIAD: There holes in the wall?

THE WITNESS: No. There are no -- yes. There are a few bullet holes which I will show you on (5)still photographs. The selection of the pieces of cloth that we kept was done according to the colour and texture. So it was a representative sample of, in fact, all the rest which was found in that location. (10)This is not the entire film but it's a summary of it. Many shell casings were found in the area, but there was no execution, as far as we know, happening at that school. The people were not mistreated in this school. They were waiting all day (15)long. Soldiers were from time to time shooting inside the gymnasium but above the people, towards the windows or towards the ceiling, just to keep them quiet. Because when they were starting to talk, with the numbers it was making too much noise and the soldiers (20)wanted them to stay quiet. Aside from that, there was no beating and no murders reported in this location. That school --

MR. HARMON:

• Q.: Mr. Ruez, before you continue with your (25)presentation, it's time for a pause and you will

• Page 707 • {37/103}

(1)continue after.

JUDGE RODRIGUES: [Int.] Yes, Mr. Harmon. We are going to have a 20-minute break, and after that we will proceed. Thank you.

(5) --- Recess taken at 10.51 a.m.

--- On resuming at 11.15 a.m.

JUDGE RODRIGUES: [Int.] Yes, Mr. Harmon. You can move on, if you like.

MR. HARMON: Mr. President, I will await the (10)arrival of the accused.
[The accused entered court]

JUDGE RODRIGUES: [Int.] I'm sorry. My mistake. Thank you very much. You may be seated, Mr. Krstic. (15)Mr. Harmon, you may continue.

• Q.: Mr. Ruez, when we left, you were in the middle of your presentation on the Grbavci school. Will you please continue with your presentation?

• A.: Yes. One thing I wanted to comment about on (20)this film is all the shell casings and the other military devices which could be found there, like the Caterpillar tracks. There were more of these Caterpillar tracks in the trash site. All these gas canisters. All these items are not necessarily related (25)to the executions which followed or to the precise

• Page 708 • {38/103}

(1)events which happened in the gymnasium. This school, we have the knowledge that it was used on a regular basis by both the army and the police, who were coming in and coming out of that location, more or less at (5)will, during the entire period of the war. So this material could be totally unrelated. The material which we believe is related to the next series of events is the presence of these blindfolds at the school. (10)I will now present to you Exhibit 19/4, which, when entering the gymnasium, this is the wall on the left-hand side. The interesting things on this picture are the windows on the top left of the picture, running along the wall at the top of the picture. It's (15)a feature recognised by the people. And in the middle of the picture, where I'm going to mark the arrow
[marks] is the exit to the wardrobe, and when turning right here is the exit through the wardrobe, to the concrete playground outside. (20)The next photograph is 19/5, which had also been used before we could bring people back to these locations, to identify the place. And this row of windows is also an element that people can recognise. Photograph 19/6 is a photograph of one of (25)these windows, which is running along the right wall

• Page 709 • {39/103}

(1)when entering. As you can see, there are holes in the window. I'm going to mark them; one here, another one here, another one here, and another one here [marks] This could be a result of the shooting that happened (5)from time to time inside the warehouse, when the guards wanted the prisoners to be quiet inside --

• Q.: Mr. Ruez, you said "inside the warehouse," you mean "inside the gymnasium."

• A.: Sorry. Inside the gymnasium; that's (10)correct. One could consider that since this is a school, children are playing, and the fact is that sometimes children throw stones at windows. It would be, indeed, quite hard to see the difference between a (15)stone and a bullet. Despite what one would think, sometimes the result is very similar. That's the reason why I'm going to show you the next photograph, which is 19/7, which is the ceiling of the gymnasium, metallic ceiling, where you can see here a bullet hole (20)also [marks] This one is a bullet hole. The following photograph is 19/8. This is the only photograph of this type which is dated 1999. It is a photograph which we took when we returned to this location with two of the people who survived the (25)events here. On this photograph, you can see both the

• Page 710 • {40/103}

(1)entrance of the gymnasium, which is the door I'm going to mark number "1" [marks] and the exit of the gymnasium, which is the access to the wardrobe, which is number "2" [marks] (5)The approximate position where the people were sitting, I can only tell you for two of them, since two could not join the mission where we returned to this location, one was sitting here [marks], position "A"; another one who arrived earlier was (10)sitting here [marks] The gym started to fill, starting from the bottom of the picture towards the entrance, and once it was full, the evacuation started through this wardrobe, where there was a bucket of water. The people were (15)given a sip of water, and there was a stack of blindfolds of various colours; in fact, several stacks which were, according to the people, dumped in the area nearby the exit.

• Q.: Mr. Ruez, would you put the letter "B" above (20)the second location where the individual was sitting?

• A.: [Marks]

• Q.: Thank you.

• A.: The following picture is 19/9. This photograph is dated January 1996, and on this one, we (25)can see the exit of the wardrobe. There are a few

• Page 711 • {41/103}

(1)steps. No one is talking about going down steps for the reason that the truck which was parked nearby this exit had a kind of ramp at the back, so that the people accessed directly the truck from the wardrobe. So no (5)one has a recollection of having climbed down a few steps. This is the only time we could take this photograph. Later on, this opening has been walled. Exhibit 19/10 is a photograph of one of the pieces of cloth we collected there. We will have later (10)on a presentation about the connections that were made based on these blindfolds. The analysis of all the blindfolds collected both at the school, in the primary graves and in the secondary graves, all this material is currently being handled by a judicial laboratory in (15)order to make connections between these blindfolds and connect the sites each with another. The reports of these connections are still not provided -- yes, they have been provided, just recently then. They are ready.

(20) • Q.: Now, Mr. Ruez, if you would turn your attention to Prosecutor's 19/11, which is a very important exhibit, and take your time explaining this particular exhibit.

• A.: So this exhibit is going to already introduce (25)the next site, which is the execution site also. It is

• Page 712 • {42/103}

(1)an aerial photograph which was taken in 1998. It's a series of pictures shot from a helicopter by the SFOR-ICTY liaison officer at the time. It creates a panorama which enables us to see (5)both on the right of the picture the school and on the left the site. I'm going to pass it under the ELMO.

• Q.: Would you circle with a pen the particular features of importance.

• A.: I will have to use another one. First at the (10)extreme right of the photograph, the first circle is going to be the school [marks]

• Q.: Put a letter, please, Mr. Ruez, or a number next to that.

• A.: Letter "A." On this photo you can recognise (15)the main building of the school. We have no indication of the presence of prisoners in this school. Not that we are sure that no one was kept inside, it's only that we don't have any report about people who might have been kept inside. The survivors have all been kept (20)inside the gymnasium, not inside the school. So we have no information about what happened inside the school. The important location for us, therefore, is the gymnasium on which I'm putting an arrow [marks] One other important element on this (25)photograph is that you can see the railroad which runs

• Page 713 • {43/103}

(1)in that direction towards Zvornik [marks], and in that direction there is a series of bridges passing above the road that goes from Zvornik to Tuzla. There is also a tunnel, which is approximately 300 metres long, (5)a few kilometres in the direction of Zvornik. These are elements that people might talk about, since for them it is reference points to try to identify where they are. And they can get mixed very easily about the situation, since if you take the opposite direction, (10)which is then the direction going north, this railroad line will make the tour of a hill, take the direction west and will arrive at a very long tunnel, which is 4.7 kilometres long, which is called the Kirizevici tunnel. (15)I say all this because one witness is very confused about this situation and believes he went through the Kirizevici tunnel, which would have led him directly towards the confrontation line and to his capture. In reality, he went through a bridge which (20)was about 300 metres long. He went in the direction south towards Zvornik, but he doesn't know that. I never told him yet. If we start from the school and follow the road towards the left of the picture, which is north on (25)the ground [marks], that is the road followed by the

• Page 714 • {44/103}

(1)trucks carrying the prisoners to the execution field was taking, arrived at this intersection here. The vehicle turned, took the dirt road. The reason why people say that at the end of the track it was bumpy, (5)they take this dirt road, they pass under the railroad line where there is an underpass here I'm going to circle [marks], and then the truck stopped somewhere in this area here, which is the beginning of the execution site, the first execution site. We call this place (10)LZ-2. The reason is initially we called that area Lazete. As you could see on the exhibit which is the map of the area the place where the Grbavci school is, the hamlet is named Lazete. The reason why is in 1996 we called this site Lazete. (15)This one is Lazete-2, and the size of the meadow here on this photograph would be like this
[marks] This would be the area of the execution site. It continues like this [marks], and it is also the area of mass graves located here.

(20) • Q.: Mr. Ruez, would you move that up so it's more -- thank you very much.

• A.: Once the executions were over on this part, the executioners moved to another site which is, in fact, here [marks] We initially called that site (25)Lazete-1. The reason is that we thought that the logic

• Page 715 • {45/103}

(1)will be that the first site used was the one closest to the school, and then when the time it came to switch sites, they moved to the second site. The reality is exactly the opposite, and we could determine that only (5)by bringing the witnesses back to the site. One main interrogation here was how could it be that people who are inside the gymnasium, which is very precisely 800 metres away from the site we call Lazete-1, how could it come that since the execution (10)lasted all the afternoon and the evening, the people who were still inside the gym after the beginning of the execution didn't hear the sound of the execution? The reasons for that are, in fact, quite simple. Reason number one is that inside the (15)gymnasium, people were speaking. So there was constant murmur inside covering noises. Also the fact that the soldiers, some from time to time shot in the air to make the people stop making this noise, creates a buzziness in the ears that also can weaken their (20)ability to hear. But the main reason is that the site, Lazete-2, once you pass under the railroad line, this is quite a high elevation of soil on, in fact, which the railroad is constructed, and this most probably creates a natural sound barrier. So the Lazete-2 site (25)indeed is not far away, in terms of air distance, from

• Page 716 • {46/103}

(1)the gymnasium, but it is very possible that the sound is very much weakened by this elevation of the ground. An additional site to pinpoint on this photograph, which will make also the aerial ones more (5)easy to understand, once having passed the railroad, through the underpass, the path continues a little bit uphill and then turns towards this direction, and very precisely here is a place I'm going to mark "B." This will be "B." This will be "C" [marks], which is a (10)garbage dump site.

• Q.: So the dump site is where you marked the letter "C"?

• A.: Yes. Where I marked the letter"C" is a garbage dump site. We will see more details about this (15)dump site in the film we will see very soon. Before viewing the film, we might first get through the first photographs of the second one.

• Q.: Well, that concludes the presentation, does it not, on Exhibit 19, which is the Grbavci school? (20)Now we're going to turn the execution site and the presentation about that; is that correct?

• A.: That is correct.

• Q.: Very briefly, if you could point the execution site out on the large map and then proceed (25)with your demonstration.

• Page 717 • {47/103}

(1) • A.: So we have just talked about the Grbavci school, which on the main map is pinpointed with the symbol concentration spot for prisoners, and the site we are now going to go to is, as I said, 800 metres (5)away from the Grbavci school and consists into two execution meadows and two areas of mass graves which are marked with the symbol red dot execution site and mass grave attached to it. This mass grave, as you can see on this symbol, is a disturbed one. (10)Exhibit 20/A marks the area of the site on the map. The cross [marks] is a more precise pinpointing. I marked a cross inside the circle to more precisely pinpoint the location of these two execution sites and mass graves.

(15) • Q.: Mr. Ruez, shall we show the film which is Prosecutor's Exhibit 20/16?

• A.: Yes. But, in fact, before that, showing the -- more sense now to show the Rule 70 pictures. Then we'll have better reference points for the video. (20)I won't show the 20/1 since it is exactly same one as the 20/2. Sorry. The 20/2 is the same photograph as 20/1 but has markings on it. So I will show directly this one. So on this photograph, first of all, the one (25)on the left is a photograph dated -- my photograph

• Page 718 • {48/103}

(1)doesn't show the two sites.

• Q.: 5th of July?

• A.: Yes. In fact, we should show the film now. I didn't realise I broke it into two sides. We have to (5)show the film now and return back on each of them.

• Q.: Could we have the lights dimmed and could we play 20/16.
[Videotape played]

• A.: So this is again the Grbavci school, and (10)we'll fly towards the execution site. The road going to the left is the road leading towards the execution site. I forgot to pinpoint that just in front of the site on the left of the picture now you can see the (15)railroad line, and on the photograph on which I had marked some details, there is one detail to be marked also, which is a construction just next to this railroad line and which is what one person thinks is a railroad station, in fact. It's a construction just (20)next to the railroad. Here we are arriving towards the site. You can see the little dirt road that goes towards the railroad line here. The main house in the middle of the field. Behind it was the railroad line. Here is a (25)short view of the site behind it.

• Page 719 • {49/103}

(1)This is the Lazete-2 execution and mass grave site. William Hagland is describing the piece of evidence found there, human residues and clothing. The (5)underpass. No. It's not finished. This is the garbage dump site. Unfortunately, rotten documents. In fact, we can stop here. There are a few other items which are not very significant.

(10) • Q.: All right.

• A.: There is the cane of an old man, there is some live ammunition, and things like this. That's fine.

• Q.: All right. We can raise the lights and stop (15)the video, and Mr. Ruez, then, please continue with your presentation.

• A.: I'm returning to Exhibit 20/2.

• Q.: Exhibit 20/2.

• A.: Exhibit 20/2, which first shows the ground, (20)dated the 5th of July, 1995, and then shows the site as it looked on 27 July 1995. We have two massive areas of disturbance which were created in between these dates. We believe that they were created, in fact, during the night of the 14th to the 15th, since heavy (25)equipment was operating on the ground at the moment the

• Page 720 • {50/103}

(1)execution was going on, and the executioners continued the operation, using the lights these of excavators. The Lazete-2 site is the first site where the execution took place and Lazete-1 is the one which was (5)used afterwards. The reason why we believe that this is the chronology that happened is that the witnesses all mention that the meadow was full -- covered with bodies, entirely covered with bodies. So initially we wondered how this could be possible, that the Lazete-1 (10)site had been the first site, since the meadow is extremely large and it's more or less impossible to completely cover it. The second site, it's absolutely feasible, it's not such a large site. So once the Lazete-2 site was, indeed, completely covered with (15)bodies, the executioners decided to switch sites, made a command to take the ammunition box, and went to the other one. The other one is -- first of all, this Lazete-2 site has been fully exhumed in 1996. I don't (20)have the figures with me. The site has been totally disturbed, but on this one, like in all the other ones which have been disturbed, those who did the disturbance did a very sloppy job and forgot, each time, a significant number of bodies. In this site, (25)the precise number will be given to you. It is

• Page 721 • {51/103}

(1)approximately 100 bodies that had been forgotten by those who erased this grave. Photograph 20/4 is a panorama view of the Lazete-1 site which has not been exhumed yet. We (5)intend to exhume this site this year.

THE REGISTRAR: [Int.] Sorry to interrupt you, but what's happening with Exhibit 20/3, please?

THE WITNESS: Sorry.

(10) • A.: Exhibit 20/3 is another view of the site. In fact, in one piece of the photograph which was used to create the panorama, you can see in colour the situation which can be seen on the black and white aerial photographs, where you can see -- you can (15)compare this one and the aerial photograph, the style of disturbances. As an example, here you can see clearly track marks from wheeled excavators [marks] and you can compare these traces with the ones you can see on the (20)aerial imagery in black and white, they are perfectly similar. Here, again, you have a dump site, you have the underpass, and a piece of the Lazete-2 site. Exhibit 20/4 is a view of the Lazete-1 site, seen from the railroad. This house did not exist in (25)1995, it was a ruin in 1995. But there was a house

• Page 722 • {52/103}

(1)there, and you will hear details about a water pipe which was running from that location towards the site and which was probably severed during the disturbance, and the piece was found in a secondary site -- nearby a (5)secondary site. The Exhibit 20/5 is a view from the railroad line, just above the underpass which leads from the Lazete-1 site towards the Lazete-2 site, and this is the path that leads to the so-called dump site, the (10)path going a little bit uphill and then turning left. We won't show you any pictures, but going a little bit further up, there was the body of a man lying on the ground. We could think that he could come either from the execution or any other situation; therefore, we do (15)not develop on him. He was just lying on the ground, and the peasants living nearby were driving over his body every day. Exhibit 20/6 is a view from the operation we did on the dump site which shows all the items which (20)were collected there -- not all of them were collected. Only the blindfolds were collected for further selection. The photograph, Exhibit 20/7, is a view from the back of the site on which one can clearly see the (25)Lazete-2 site with a specific shape, and one can assess

• Page 723 • {53/103}

(1)its size very well from this picture. I will mark the location [marks] This is the size of the area, and this area which we will see on another photograph, was probably the "rest area" for the execution team.

(5) • Q.: The area you've marked on the right-hand side with the image --

• A.: I will mark completely with red. This is an area, we think it is a "rest area" for the reason that here is a place where we found little labels of boxes, (10)packaging casings. So this is the location where they were reloading the magazines of their weapons. It is also a location where, behind the tree line, we found a box of 1.200 rounds of ammunition, an empty box and also two bottles, empty bottles lying there which could (15)be there or could have belonged to the perpetrators. The other site, Lazete-1, is also clearly visible on the picture, and I'm going to circle it.

• Q.: I'm sorry. Just slow down a little bit. Thank you.

(20) • A.: Exhibit photograph 20/8, on the -- just in front of the picture, on the right of the picture is the area of the execution site and the grave, and in front is the area which is taped with yellow tape here
[indicates] is the so-called rest area. The area where (25)I'm going to put an arrow [marks] is the area where we

• Page 724 • {54/103}

(1)found the ammunition box. Here you can see that the reference point which you had on the video, which is the underpass, the excavation of the first remains which were found there, were approximately just here, (5)in the middle right of the photograph [marks] All the yellow markers on this photograph mark either elements of clothing, bones, or casings. Exhibit 20/9 is a photograph of the ammunition box which was found close to the so-called (10)rest area. It was piece of evidence number 31. Exhibit 20/10 is a photograph of a label on a carton box, which indicates that this is related to ammunition of calibre .762. We think it is a packaging of ammunition inside a box, and I will show you on the (15)next exhibits how, in fact, this style of ammunition is packaged. Exhibit 20/11 is a photograph taken in June 1996, at the top of the valley of Cerska, and the village of Cerska is unrelated, but it shows a wooden (20)ammunition box which contained .762 ammunition boxes inside this big box. And inside these kind of boxes is an aluminium box, the same one that we have found on the site, and within this aluminium box, when you open it, you have the ammunition packaged in small carton (25)boxes. Every one has a little label. This is the same

• Page 725 • {55/103}

(1)style of elements that we could find on the meadow. Exhibit 20/13 is a part of the Lazete-2 site as it was when we first approached that site, and these markers are marking bones, human bones. (5)The two next ones, 20/14 and 20/15, assembled together can form a panorama. The 20/14 is taken from the railroad and shows the -- at the left hand, the west where Lazete-2 site is. Lazete-2 site would be on your left, looking like this, in this direction. The (10)area of this photograph, is, in fact, to reach the second one, 20/15, which is the same view but right hand. This is an area that a witness recognises as -- he went on top of the railroad and later on snuck towards a corn field which led him towards an area (15)where he could hear water flowing, and, indeed, there is a little brook flowing just behind this tree line. He believes that the corn field on the right hand of this picture is still the same corn field through which he snuck. This photograph is dated 1999. There will (20)be a next one to be put on the right of it which shows that this corn is rotting on the spot since years. It could very well be, indeed, the same corn field he went through at the time of the events.

• Q.: Mr. Ruez, that completes your presentation on (25)Grahovac. We are now going to move to the Petkovci

• Page 726 • {56/103}

(1)school. If you would approach the large map and orient the Judges, please.

• A.: That same morning of the 14th of July, 1995, when the men started to be evacuated from Bratunac in (5)columns of buses and trucks towards the final concentration spots and execution sites, groups of men were taken, at the same time the operation was being conducted at Orahovac, the same operation was being conducted towards Petkovci. Convoys were driving these (10)men towards Zvornik, Karakaj. They passed Karakaj, turned left towards the school called Petkovci. It was the same day, the 14th of July, 1995. Exhibit 21/A is the map of the area where you can see the road that goes from the Petkovci school, (15)towards Karakaj and Zvornik. The next exhibit, 21/1, is a view, photograph 99, a helicopter view of the Petkovci school, seen from the front, from the road that goes from Petkovci towards Karakaj, and also goes towards the Dam. The (20)access is done through that path which I'm going to mark [marks], and behind that is a concrete playground and also a white construction, which I'm going to circle as "A"; the school will be "B" [marks] Photograph 21/2 is a view of a construction (25)which was marked "A" on the previous exhibit and which

• Page 727 • {57/103}

(1)is a construction which is immediately recognised by one of two survivors of this location. Aside from the fact that it's an element of identification, there is no knowledge about any criminal event on this spot. (5)Exhibit 21/3 is the same school but seen from the back, where one can see again the playground, which is also a kind of parking lot. There is no gymnasium attached to this school. The only school in this area which has a gym attached to it is the Grbavci school. (10)This is the element that initially led us to identify that place, since teachers who operated in that place knew that the only school in the area of Zvornik with a gym attached to it was the Grbavci school. This one, for example, has no gym. But it has recognisable (15)details. When the prisoners were taken towards that place, they were unloaded from the trucks on this parking lot, and then they had to walk downstairs, in between two rows of soldiers beating them. (20)Exhibit 21/4 shows the stairs which access to the school. The entrance of the school is the door on the right of the photograph. The Exhibit 21/5. These photographs are dated 1997. We could not visit the place -- we visited (25)the place very briefly in 1996 but could not stay

• Page 728 • {58/103}

(1)because of the pressure of refugees who were staying inside. So we returned in 1997. It was emptied of refugees, and we could take additional pictures and make observations inside. (5)This is a very specific designed staircase inside the school, which had been described by the survivors before even coming back there and was immediately recognised by them once they got inside. The place had no problem at all in terms of (10)recognition. These are the class -- this is the hall leading to the schools on the first floor of the building. The two survivors from this location were kept inside classrooms on the first floor. They (15)strongly believe there were also people on the ground floor. This is one of the last ones on this corridor which was used for these people. This is the view of the inside --

JUDGE RODRIGUES: [Int.] Sorry for (20)interrupting you, but for the record, you have to say that this is Exhibit 21/6, isn't it?

• A.: [Previous translation continues] ... which shows the hall of the first floor leading to the classrooms on the right of the photograph. (25)The Exhibit 21/7 is the inside of the

• Page 729 • {59/103}

(1)classroom, which is at the end of this corridor the last classroom on the right. The next one is 21/8. There have been some repairs made in these classrooms on the walls, but (5)there was still one detail in one of them that we photographed in order to confirm one part of the story which is that when people were standing up, soldiers who were outside of the school shot from the outside towards the inside to impeded the people to get to the (10)windows and to get fresh air or even look outside. There is a report of one man who was killed in such a fashion. On the blackboard of this school, there were some impacts on the blackboard, caused probably by (15)ricochets of bullets. The one I'm going to circle on this picture here is a hole [marks] The other ones are only impacts without perforations. This one is perforated. This is why I could stick a pen inside. There are no other traces like this in the classroom, (20)which is partially renewed like the ones in this school but only partially. This closes the presentation for the school.

MR. HARMON:

• Q.: All right. Mr. Ruez, let's move to (25)Prosecutor's Exhibit 22, the site we referred to as the

• Page 730 • {60/103}

(1)Dam.

• A.: In the afternoon of the 14th, once the school was also filled with prisoners, transportation of these prisoners started. There was a different situation (5)than at the Grbavci school, not only in terms of the treatment of the prisoners, which was, as I said, not so bad at the Grbavci school, but very, very violent behaviour at the Petkovci school, as you will hear from the people, and people were not blindfolded but only (10)the hands attached and taken on board of little trucks towards the Dam. The Dam is approximately 2 kilometres away from the school. It takes approximately five, six minutes of driving at very slow speed to reach the Dam (15)from the school, and we will see the distance from the video, which shows a helicopter view flying from the school to the Dam. The Dam is -- you will see the colour of the Dam is red. The reason is that it's not a lake. It (20)is, in fact, a reservoir of waste for the aluminium factory. So it's full of chemical waste, in fact.

• Q.: Mr. Ruez, we have a film. Should we commence with the film, which is Prosecutor's Exhibit 22/10? Then you can orient the Judges through the film and (25)then to the ensuing exhibits. So if we could have the

• Page 731 • {61/103}

(1)lights dimmed, we could play Prosecutor's Exhibit 22/10, please.
[Videotape played]

• A.: Yes. The Petkovci school seen from the back (5)where the staircase is. This is now the school seen from the front. At the bottom of the picture, the road that leads towards Zvornik but also towards the Dam. We can double-check the distance on the map. Here you can see the Dam. But to access the Dam, you (10)will see -- this is the execution site already to be seen on the Dam, at the bottom, and the road now goes here at the middle of the picture. Here it turns left. This is now the access road to the Dam. The total distance is more three kilometres than two. (15)This is again the view of the execution site, the plateau at the bottom of the Dam. In front is a hill with a wood. This is the top of the Dam with the so-called peninsula full of chemical waste. Flying above the barrage, and this is the (20)plateau of the Dam, the execution site, the wood on the hill in front of it. This was the first arrival on the site. William Hagland was the forensic expert on this site that day. The site is absolutely scattered with (25)bones. On this one we won't see the pieces of skull.

• Page 732 • {62/103}

(1)We didn't spend a long time that day on it but we returned. You will have extensive reports on the findings at this location. That's the execution site, all this here, (5)where the people are standing and all this environment. It's a very large site. The interest of the wooded hill in front is that this is the location where the two survivors managed to sneak away from the site after the (10)execution. This is an area where the people then had to cross in order to find another hiding place, all the area here along this ridge, going uphill. The main bones found on the surface and (15)scattered on the surface of the plateau are skull fragments, and that matches the description that the survivors give of the next day where during the entire day of the 15th of July they could hear single shots of -- it was the finishing of the wounded. The wounded (20)were begging to be killed during the night. The executioners took all their time and only finished them the next day. They could hear single shots all along the day. We came back there in June 1996, and the in (25)first collection operation we collected 1.031 shell

• Page 733 • {63/103}

(1)casings on the surface of the plateau, only the ones which were lying on the surface, not those embedded who are a little bit in the ground. And it was only a visual search without metal detectors. When the (5)exhumation took place in 1998 an additional 750 shell casings were found with a metal detector. These last ones have been very precisely plotted on the ground, together with skull fragments, and you will see all these mappings in the report of Professor Richard (10)Wright, which gives a clear view of the site, the size of the execution field, and other elements of interest. This is a view from the top of the Dam, which is going to be a 360-degree view to have a complete (15)sighting of the entire area. That is the lake, in fact, the waste, the chemical waste. The view is turning towards the west. There is a guardhouse on top of the Dam. This is the view just in front of the Dam. This is the access path.

(20) MR. HARMON:

• Q.: Mr. Ruez, please continue.

• A.: The Exhibit 22/A is the map of the area which marks the location of the Dam. The Exhibit 22/1 is an aerial imagery of the (25)site. The left part of the picture is a photograph

• Page 734 • {64/103}

(1)dated 5th July, 1995, and shows the -- how the ground looks like at that date. The one next to it is the same location photographed the 27th July, 1995 and shows a clear area of recently disturbed soil, the same (5)area that you could see on the video where at one moment that was group of men on it, and it was clearly visible that there was a difference of soil at that location. The follow exhibit is 22/2. This is a (10)helicopter view from the same location. The location of interest here are the surface of the plateau. I'm going to circle the approximate size of the execution area. We know about the size of the execution area due to the repartition of both the shell casings and the (15)skull fragments on the site, and roughly it would occupy that part of the field [marks] I on purpose tried to make it maybe smaller than larger. What you also have here, and we'll have closer views on it, is kind of a concrete canal that (20)goes from the top of the Dam to the bottom. It is in case of an overflow of water. It's a canal that enables the water then to flow towards the valley, and it goes down from here, down towards the valley
[indicates] It's an element of recollection for the (25)witnesses, because they had to crawl through this

• Page 735 • {65/103}

(1)before managing to reach the wooded area which I circle on the picture [marks] Then later, but seen from above, is something that these people might have then some difficulties to (5)orient themselves with. This is the exfiltration path for these two men. The Exhibit 22/3 is a panorama, which is a photograph from the middle height of the plateau. Here you have a very clear view on the disturbance which was (10)visible on the aerial imagery shown previously. It is a photograph which was dated end of April, early May 1995, so not a very long time after the events. I'm going to circle around the area of disturbance which is very clearly visible on the aerial (15)imagery [marks] I'll mark it 1, area 1. This is the approximate outline of the mass grave which was dug in this location and later on disturbed. On this one, it will be easier for me now to mark you the size of the execution area according to (20)the observations made by the witnesses, since this is a little mound of rocks which can be used as a reference point. Approximately from here [marks] to the end, covering the entire surface of the plateau, nearly going to the edge of it [marks], is the size of the (25)execution area, which was, according to the witnesses,

• Page 736 • {66/103}

(1)covered with bodies on which they had to walk to find a free spot.

THE REGISTRAR: [Int.] At the end of the record, the year indicated for the photograph is (5)1995.

THE WITNESS: We didn't enter the territory Republika Srpska in 1995. This is the location where the American journalist David Rhodes has been arrested. He went to this site, to this one was in end (10)of October 1995, I think, and went to this location in order to implement the reports which were coming out about the atrocities which happened in this area and saw bones also sticking from the ground, but this place is under constant surveillance, since it was a military (15)zone during the war. There were artillery positions in the area, and it was constantly guarded. So he got arrested and gaoled and even tried for having spied this military facility.

JUDGE RIAD: Can you tell us how much it is (20)in square metres?

THE INTERPRETER: Microphone for Judge Riad, please.

THE WITNESS: I cannot give you that precise answer at this moment. In the report of exhumation, (25)all these measurements will be mentioned. I can just

• Page 737 • {67/103}

(1)give you the rough outline from the picture. I don't have these measurements with me.

JUDGE RIAD: Can you give us an outline?

THE WITNESS: No. I would just give you (5)approximation. I would say a hundred metres in -- large and 50 metres long, I would say. I would say roughly here 50 [marks], but all these precise measurements are in the report of Professor Wright. But this would be approximately 50 metres and this (10)would be approximately, from east to west, 100 metres
[marks], but this needs to be confirmed through his report. I just say it as an indication.

JUDGE RIAD: Thank you.

• A.: On Exhibit 22/4, one can see both the (15)watchtower on top of the hill [marks] -- the guardhouse, not the watchtower. Also, one interesting element, since this photograph is, as I said, early 1996, so not a very long time after the events, one witness describes the fact that the light -- the scene (20)was lit by projectors coming from the top of the Dam which was providing the light beam for the execution scene, and the projectors are still there in early 1996. This is the ramp of projectors which was illuminating the execution area at the time of the (25)events, to assist the executioners to do their job.

• Page 738 • {68/103}

(1)This concrete canal, which is going downhill, is the one the witnesses had to crawl into in order to reach the little wood on the little hill, just on the opposite side. (5)Exhibit 22/5 is another view that shows that same little canal, and you can also see on this view a path which I'm going to mark [marks] The reason why I'm mentioning this one is that on the 15th, in the morning, the people could see from the opposite side of (10)this hill and noticed that a tractor was transporting bodies on a little trailer. From the position the men were, they couldn't see at one point where this little tractor was going. But we will have then other photographs which will give us more details about (15)that. So during the day of the 15th, the bodies were taken away, but at a very slow speed.

MR. HARMON:

• Q.: Mr. Ruez, why don't you wait just a moment. (20)We apparently have a technical problem.
[Trial Chamber confers with legal officer]

JUDGE RODRIGUES: [Int.] Mr. Harmon, it appears that we have a small technical problem, but (25)it's also time for our break. We will have a 20-minute

• Page 739 • {69/103}

(1)break, and I hope that the problem will be solved in the meantime. Thank you.

--- Recess taken at 12.30 p.m.

--- On resuming at 12.54 p.m.

(5) JUDGE RODRIGUES: [Int.] Mr. Harmon, we have one and a half hours of work. Maybe it's going to be a bit too long. I don't know how much time you still need to finish this testimony.

MR. HARMON: I think I will finish my direct (10)examination, Mr. President and Your Honours, within the allotted time of today. I don't know how much time there will be on cross-examination or the Judges' questions, but we should finish our presentation today.

(15) JUDGE RODRIGUES: [Int.] Very well. Then we could perhaps have a ten-minute break half-way through. I'm addressing the interpreters now. If we still need five or ten minutes more to finish today, I (20)don't know whether you will be agreeable to that. It seems that it is okay. So more or less ten minutes. Thank you very much. Mr. Harmon, please bear this time framework in mind. You may proceed. Thank you.

(25) MR. HARMON:

• Page 740 • {70/103}

(1) • Q.: Mr. Ruez, we took the break as you were starting to explain Prosecutor's Exhibit 22/5. So would you please continue?

• A.: Yes. We are going now to pass immediately to (5)22/6. Again, on 22/6, the important element here is, again, the ditch, the concrete ditch, through which the survivors managed to sneak through. So here, again, we have this ditch going towards the valley. The next exhibit, 22/7, is a helicopter (10)overview of the area which shows a few other very interesting places. First of all, again, the area of disturbance, which marks the initial position of the grave. You have also, just on the top right of the picture, the ditch [marks], which I am outlining with a (15)red line, the wood on top of the hill in front [marks], and then a line that goes from the top right to the left of the photograph, which I'm marking with a dotted line [marks] and which will be the exfiltration way of the survivors. (20)The other interesting part here is that, as I said, a tractor transporting bodies loaded on the trailer was seen taking the little path going uphill, but at that moment, the witnesses were somewhere in this area here [marks], and once on the ground here
(25) [indicates], due to the elevation of the ground, you

• Page 741 • {71/103}

(1)lose the vehicle from sight once it arrives approximately in this area here [marks] Our assumption is that the bodies have been transported towards this direction [marks] and dumped (5)in the water, somewhere in this vicinity [indicates] A survey was done through aerial imagery which didn't enable us to find any grave site or disturbed soil, other than this disturbance. Therefore, we made the conclusion that the only possible location would be (10)this one. This location, Professor Wright will explain that it was checked, trenched, with limited results, except one area which I think was approximately this one [indicates], where all these chemicals had been (15)dumped, and even some which obviously looked dangerous. So no trenching could be done, and the negative result here is not concluded yet. But so far, we don't know where these first bodies were taken to. This lasted only during the day of the 15th. (20)There was heavy rain falling in the area at the end of the day of the 15th, and that most probably stopped the slow evacuation of all these bodies, and that's why then heavy equipment came to finish the burial. And, as I said, then the sight has been disturbed, and these (25)bodies have been taken to various locations, which we

• Page 742 • {72/103}

(1)have later on identified.

• Q.: So the record is clear, Mr. Ruez, the area that you said where no trenching was done is the area at the tip of the peninsula, and you've put parallel (5)red lines in that location; is that correct?

• A.: Yes. This is a rough indication. Since Professor Wright is the one who did this operation, I'm just roughly indicating the location. It's very clearly indicated in his reports. (10)The next picture is 22/8. This is a picture which was taken in April 1997, when we went to this site to probe the area and, in fact, dig a hole in order to assess if the place was disturbed or not. We couldn't dig very far in it, since, as you can see, (15)it's a very rocky environment. These are small stones, but underneath there are big rocks. Just underneath the surface where we started to dig, we found this piece of cloth which looks like a wrist ligature. We have it in evidence. (20)We dug a one-metre-deep hole, and we finally were lucky to find a skull, part of a skull, which sparked the decision to exhume the place. In reality, we had been extremely lucky. This is the only piece of skull that was to be found among tonnes of rocks. The (25)final result of the exhumation here, this number will

• Page 743 • {73/103}

(1)have to be confirmed through Professor Wright, but it's roughly the human remains belonging to 50 different individuals. But this is only the elements which were left in the grave after the disturbance. We will talk (5)about these bodies later on when we will discuss the massive operation which was aimed to transfer all these victims into smaller graves scattered in the area.

• Q.: For the record, the exhibit that has been referred to is 22/9. (10)Mr. Ruez, we're now going to turn our attention to the Pilica school, and would you orient the Judges, please.

• A.: The events we know in this location have been provided by several people. In fact, we have three (15)survivors from the events we are going to unfold now. On 15 July, a convoy of prisoners left Bratunac town and took the direction north, past Zvornik, continued even more north, and reached the area of Branjevo/Kula. The school in the hamlet Kula (20)is called the Pilica school. Pilica is, in fact, the entire area here [indicates] So the Pilica school, it's a big building. There were possibly already men inside this school before that date, but the school was still (25)continued to be filled with prisoners the day of the

• Page 744 • {74/103}

(1)15th. This is the location we're going to start with now. The first exhibit is 23/A and is a photocopy of a map of the area with a red circle around the (5)so-called area of Luke -- Kula, sorry, where the Pilica school is, and there is a yellow-green dot which roughly marks the position of the school within this circle. The national road that goes from Zvornik (10)towards Bijeljina, is along the Drina on the right of the map, which is the east. Exhibit 23/1 is a view from -- a helicopter view, dated 1999, of the Pilica school, where one can see first the access road to the school, which I'm (15)marking with a red line [marks] The main building, which I'll mark "A," is the school [marks] The building next to it, marked "B," is the gymnasium. Both the gymnasium and the school were apparently packed with prisoners. (20)At some point during the night, between the 15th and the 16th, one prisoner exited, on request of his guards, the gymnasium in order to go and fetch water. Upon arrival, the people were taken on the playground where there are stairs going up to the (25)school, and this is the way the person took to exit it

• Page 745 • {75/103}

(1) [marks], and going a little path down behind the school there is an area where there is a water pump that the person described precisely in his initial statement.

• Q.: Will you mark that with a letter "C," please?

(5) • A.: Which I mark with a letter "C." The following exhibit is 23/2, which is the plaque on which the name of the school is written and also the location, Pilica, which I circle on this plaque [marks] (10)The next photograph is the Exhibit 23/3, and shows the stairs which was the access way for the prisoners and also the way that the person who went to fetch the water took. The following one could be assembled with the (15)previous one to form a panorama. The next one is the Exhibit 23/4, and shows the gymnasium seen from the back of the school. These two pictures could form a panorama like this. The following one, the 23/5, is the inside of (20)the gymnasium, which had been renewed at the time we could access the inside of the school. We accessed the inside in 1998. We have not presented these photographs, I think, to the survivors. The windows could be clearly recognised on (25)the left hand, and on the next Exhibit, 23/6, the

• Page 746 • {76/103}

(1)windows on the right hand when entering the gym. We have videotapes of all these locations, if needed. Exhibit 23/7, is the view one has when going behind the school and willing to access the water (5)reservoir. This is the reservoir. I'm going to circle it [marks], water pump.

• Q.: The water pump is the location that you mentioned in 23/1 marked with the letter "C"?

• A.: That is correct. In fact, it is described as (10)being water pipes, and indeed on Exhibit 23/8, one can see what is referred to as the water pipe. I'm going to circle it [marks] This is the water pipe which was described by the person who went to fetch the water. That same person is the one describing then (15)the murder of a bus load of prisoners. I will very briefly return on the Exhibit 23/1, which is the aerial view of the school. It will make more sense to explain the location. When the person was coming back from the (20)water pipe, arriving more or less here [marks] -- the person was with us when he provided these explanations -- with an angle of view which allowed him to have a view of this area here, which I mark with a line and bars on it [marks] In this area, a bus full (25)of prisoners stopped more or less where the parking

• Page 747 • {77/103}

(1)place is here and the persons were disembarking there. Apparently, soldiers were in the vicinity of the road, and once the people were assembled next to the school, they opened fire on them and apparently killed all of (5)them. This is the location where the event happened, Exhibit number 23/9.

JUDGE RODRIGUES: [Int.] Excuse me, Mr. Prosecutor. Perhaps it would be useful to mark (10)this, which Mr. Ruez has mentioned, in 23/1.

• A.: Yes. I'll call it area "D" [marks]

MR. HARMON:

• Q.: Area "D" is the area where the execution took place?

(15) • A.: Yes. The next exhibit is going to have a better view on this point, Exhibit 23/9. This is, at the very right of the picture, an old tower, which is also a reference point. You can see at the extreme right the playground, which was more or less the (20)location where the person would e coming from the water pumps. The area in between these pictures, where the trees are and a little bit more and the right, so I'm going to circle the area. The approximate area where the group of men were standing, according to the (25)witness, will be, [marks] on this photograph, the area

• Page 748 • {78/103}

(1)I would mark "A." A few shooters committed the operation. The person didn't see how many. These few individuals were, according to him, standing in this area here
(5) [indicates], which I'm going to circle, roughly. And the shooting happened from the circled area towards the squared area marked "A." I will mark "B" the position of the shooters. As one can already see on this photograph, (10)there are some marks on the wall. Unfortunately, there have been some repairs and we cannot very precisely date these repairs, but there are still some traces not covered by repairs, like the two holes that I'm going to circle on the right part of the picture of the right (15)wall [marks] These are the most obvious ones. There are smaller traces on this wall, not in significant number, but you have also repair traces here. The windows had been repaired, but some of them, in 1996, still had marks on them. At the time we didn't know (20)where the event happened -- we only found out about it in 1999 -- so we couldn't conduct observations inside to confirm what could have been observed from the outside. Nevertheless, on the photograph which is (25)Exhibit 23/10, one can see, in fact, the view the

• Page 749 • {79/103}

(1)perpetrators had on the scene. I'm going to circle again the area where the men were standing [marks], which I'm going to mark area "A." Again, you can see through that angle the traces and also these two holes
(5) [marks] We have a photo documentation available taken in April 1996 of the outside.

• Q.: Wait just a minute, Mr. Ruez, please.

• A.: 23/11. This is the row of windows. I (10)selected this one as an example, where one can see broken glass here and a hole here [marks] I would add the same comment that I made for the Grbavci school. One could claim that these holes are also done by children throwing stones. We would not challenge (15)that. 23/12 is a close-up on the wall from the same facade, on the extreme right where you can see again the two holes which were marked on the previous photographs [marks] You can also see smaller little (20)pockmarks. I'll circle some of them [marks] Much smaller scratches on this wall. On the Exhibit 23/13 is the angle of that same area. This is the approximate location where probably the person who was the most at the left, (25)looking at these prisoners, would be standing and

• Page 750 • {80/103}

(1)shooting in that direction. There are marks on the left part of the wall which have been repaired, but due to their angle, it could very well be also that this could be the results of shooting on someone who'd tried (5)to escape from the position in front towards that part of the school. It is a possibility. We collected shell casings in 1999 on this location. I will have other photographs to present to you regarding this survey for shell casings. I'll (10)return very briefly on the Exhibit 23/10, which is not the best photograph to describe what I'm going to say now, but in this area which is a bit out of the frame of the picture, just on the right hand of the frame of this photograph, is the area where we still managed to (15)find 11 shell casings on a first visit and 11 more on a second visit, in this area here, and also on the little stretch of road which is just where I'm standing currently to take this photograph. All the other ones could have been collected by children playing. The (20)ones we found were the ones completely embedded in the ground and that no one picked up. When we went there the first time in 1996, we collected a certain number of shell casings in the vicinity of this area where the playground is, the (25)concrete playground, but this might have also been

• Page 751 • {81/103}

(1)moved from one location to another. So the only ones we will consider at this point were the ones which were embedded in the ground, because these ones, at least, we can assume that they didn't move too much in the (5)months following the events. The last exhibit for the school will be the 23/14, which is a view of the main entrance of the school. The main entrance is in between the school building and the gymnasium, and the area which I'm (10)going to circle [marks] is the area where the men were standing prior to their transportation on a bus allegedly towards freedom and exchange. Also when entering the school, there are other elements that we could show and we could show on (15)video which implement descriptions given by the survivors, like the presence of a little kitchen on the left when entering the school.

• Q.: Mr. Ruez, this Pilica school is associated with an execution site that we're now going to turn our (20)attention to. Can you approach the map and then explain to the Judges what that site is and where it's located?

• A.: Once the people exited the school and were lined up at the location I just pinpointed on the --

(25) JUDGE RODRIGUES: Microphone.

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(1) • A.: When the prisoners exited the school and were lined up on the area just marked on the photograph, they were taken on board of buses and told that they would go for exchange. The bus quit the area towards (5)the asphalt road but didn't reach the asphalt road, immediately continued along this dirt road and went behind a hill towards the Branjevo Farm. The first ones who arrived there arrived at 10.00, and at that location they were awaited by an (10)execution squad who conducted the extermination of all the prisoners who were inside the school, the execution lasting from 10.00 in the morning through 1500 hours in the afternoon. This is the situation which has been described through the testimony of Drazen Erdemovic, (15)the events on the Branjevo Farm.

MR. HARMON:

• Q.: Now, Mr. Ruez, the Branjevo Farm, is that a normal farm or is it associated with the military in any way?

(20) • A.: It is called the Branjevo Military Farm. It is a farm controlled by the army where they raise pigs to feed the troops.

• Q.: Mr. Ruez, we're going to start with a video presentation, and if I could have the lights lowered (25)and we could turn to Prosecutor's Exhibit 24/10,

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(1)please.
[Videotape played]

• A.: This is the Pilica school, and we are going to fly along the road that leads to the Branjevo Farm. (5)The main element here that you can see to recognise is the tower, the old tower which is behind the school, behind the playground. Here you can see the school and the gym attached to it, and this in front, where the vehicle is driving towards east, is the road that goes (10)both towards the main asphalt road, the highway, Bijeljina-Zvornik, but also leading to the dirt road that leads to the Branjevo Farm. This is a view to show how the landscape is in this area. It's very different than the area south. It's still a hilly area (15)but then it opens on the Drina plain. We are still following the road. We don't always have it in sight, but we are still following it. Here we can see it again. Here one can already begin -- it's still going on. (20)Now we can see also the main road going -- now this is the one just here, which is turning towards the Branjevo Farm. It continues. Here it is a shortcut, in fact, that leads to the farm. The road is here, just in the middle of the picture. It's a dirt (25)road. It's not the national road.

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(1)That dirt road which is on top of a hill, the highway just being the opposite side of the hill here. Here is already the Branjevo Farm. You will see several buildings. The interesting part of the field (5)is on top of the picture. Now here we have a few on the farm and in a straight line is also the execution field. This is showing the environment. These are pigsties. This is the access to the farm, it's already (10)inside the farm. This shows the environment. This is the back of the farm. This is the area where the grave is here [indicates], just here. This is the area of the execution field. This is the Drina River. The Federal Republic is just on the other side. The corn (15)field on the left is the execution field. Here you can see a vehicle going on the highway, towards Pilica, Janja, Bijeljina and you have a hill which no one can see from there, so the farm is quite a distance from the highway, and you have a hill (20)also, no one can see from the road. This is our first arrival in -- no, not the first arrival, the second arrival. That's the shed where there are vehicles. This is the area of the grave. Just before was the area of the execution (25)site. This is seen from the grave area. This was in

• Page 755 • {85/103}

(1)April 1996. The first time we went there was in March 1996. Behind this shed was the team of the 10th Sabotage Detachment persons. This is the area of the execution field. The (5)tree on the left is a very common feature recognised by the survivors. This is the shed, garage, and now here, all this is the area where the execution took place. All this area you have just in front of you now is the execution field that we will see on the aerial imagery, (10)all this area in front. It's a large -- very large site. Now we are going towards a bridge. The reason is that this bridge had been described and then later on recognised by one of the survivors who escaped (15)the area and then stayed hidden for a couple of days under the bridge, with destroyed vehicles underneath. This is the bridge under which he was hidden, very nearby the farm. In April 1996, the trash was still in place. (20)Behind me is the direction of the school, and in front, the direction of the farm. This is approximately two kilometres away from the farm by foot. I will just pinpoint for you this bridge on (25)the main exhibit. The farm being here, the school

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(1)being --

JUDGE RODRIGUES: Microphone.

• A.: Sorry. The farm being where the marking "farm" is, the school being where the marking "school" (5)is. This bridge is just here [indicates], more or less where the intersection is of the path reaching then -- before going to the school, just here on the map
[indicates]

MR. HARMON:

(10) • Q.: Mr. Ruez, using the exhibits that are found in Prosecutor's Exhibit 24, would you continue your explanation of the Branjevo Military Farm, please?

• A.: The first exhibit, number 24/A, is the map of the area, with the Branjevo Farm circled. The Branjevo (15)Farm is very visible on this map. No, it's not on this one, I'm sorry. Yes, it is, sorry. The map is mismarked, this is the reason why I couldn't find it. You will have to recircle it. Under the markings -- I don't have this -- (20)this was the map that was supposed to be for the Pilica Cultural Dom. So under the circle which you have on your map, approximately one kilometre south is a little grouping of buildings with two little bars and one dot on top of it. This is exactly the location of the (25)Branjevo Farm.

• Page 757 • {87/103}

(1) • Q.: Would you keep that map under the ELMO for just a minute? The Judges may want to make a correction on their maps. I take it, then, the large circle, the Judges can ignore that on this exhibit; is (5)that correct?

• A.: Absolutely. And I'm going to use the opportunity to also mark the bridge, which is more or less here [marks]

• Q.: Would you put an arrow next to the bridge, (10)please?

• A.: [Marks] Returning briefly to comments of the film, the number of shell casings collected during this operation that day was only 73 shell casings. The reason is that we conducted only a visual check of the (15)field, we didn't use any metal detector. As you can see, the field has been cultivated, so the soil turned upside down. These were only the ones which were obvious on the surface. We didn't make a very thorough search, we were just a handful of people there on a (20)huge field. So there is certainly much more under the ground than above the ground. Our intention was not to have a final count of these shell casings but only to collect enough of them for future comparison with other sites. And this (25)is what we are doing with all the shell casings we are

• Page 758 • {88/103}

(1)collecting, we then use them in order to match sites with each other. You will notice them when we talk about the elements found in primary graves and secondary graves, these shell casings are a very clear (5)indication of from where our elements are coming from. They can also be used for other things, like matching guns with shell casings, but that's another phase in which we are not entering at this point and for which we are still awaiting lab results.

(10) • Q.: Mr. Ruez, since Exhibit 24/1 is -- I'm sorry. Proceed with 24/1.

• A.: Yes. 24/1 is an aerial photograph taken of the farm, the 5th of July, 1995. These pictures were found after the first declarations of Drazen Erdemovic, (15)upon his arrest in Belgrade. So this shows the field as it looked the 5th of July, 1995. I'm going to circle two areas on it; the first area is the approximate area of the execution, which, in reality, is approximately -- (20)according to what we saw on the film, starting more or less here [marks], and continuing even out of the frame of this picture. The fact is that the size of the field -- of the execution field, as we could observe it, due to the markings on the ground, is not (25)necessarily the one which existed at the time, since

• Page 759 • {89/103}

(1)shell casings might have been moved by the truck that was plowing the field and transported a distance. So we could only use concentration -- areas of concentration of these casings. So if we would do it, (5)it would shrink, a bit, the size of this field. But roughly this is more or less the position on this photograph, and the grave area would be this area here
[marks] I'm now going to show you the next --

(10) • Q.: Mr. Ruez, would you mark an "A" and a "B" to identify each of those areas.

• A.: [Marks]

• Q.: And "A" is the area of the execution and "B" is the area of the grave, for the purposes of this (15)exhibit.

• A.: Exactly. On Exhibit 24/2, the main elements are marked. I will start with the farm. The building which is on top of the photograph, which is, in fact, (20)the east, is a pigsty; the one at the west, at the bottom of the photograph, is a pigsty as well. You have here also an illustrated building [indicates] You can see the tree which is next to the parking shed. The parking shed is an element that Drazen (25)Erdemovic described in his testimony. The tree is an

• Page 760 • {90/103}

(1)element recognised by the survivors. Since they had to walk, looking at their feet, but passed along this part, the tree is an element that they all talk about. What you can also see on this picture is the (5)area circled and named "Bodies". These are bodies still on the ground on the 17th of July, 1995. It is not the entire number of dead people here, since the cleaning process of the area has already started, as one can see from the tyre traces. So the area where (10)tyre traces are, indeed, an area where bodies were picked. You can also see clearly on this photograph, with an attentive look, mounds of soil leading to the grave. You can see the access ramp to the mass grave. (15)You can also see a stack of dots, which has been indicated were possibly bodies as well. And where the mound of soil is is where the human remains had been filmed on the video, when they were still lying on the ground. But this is a photograph taken before the (20)disturbance. This was the same photograph as the Exhibit 2/3. Exhibit 2/3 has the markings which give it --

• Q.: You mean 24/3.

• A.: Yes, 24/3. (25)Exhibit 24/4 is dated the 21st of September,

• Page 761 • {91/103}

(1)so after the initial burial and before the disturbance. You can see the area of burial and the traces left on the execution meadow. I've also marked on this photograph the dirt road which leads to the (5)highway, not to have this dirt road confused with the National Highway, which is out of the frame of this picture, so much more east if we were on the ground, approximately 800 metres by air and out of sight. The following photograph is 24/5, it's a (10)helicopter view, dated March 1996, which shows the farm, the access path. All this is seen from the east towards the west. And you can also see on the photograph the area with the shed and the tree. I'm going to circle it [marks] This was the rest area for (15)the execution squad. The extreme right of this exhibit connects with the next one, the 24/6. This is a view that shows the execution site. On the extreme left of the photograph you can see the garage shed, which I'm going to circle again as (20)"A". Then in front of it, you have the area where the execution took place. We collected shell casings approximately where Peter Nicholson was standing and making the comment that he indeed filmed a shell casing further from the distance -- I'm not going to use that (25)one -- but the last area which is approximately this

• Page 762 • {92/103}

(1)line here [marks]

• Q.: Put a letter next to that, please, Mr. Ruez.

• A.: The letter "B". Letter "C" which is the arrow is the position of the grave. The scale is (5)likely provided on this photograph by the little men which I'm going to circle without putting any numbers. These are military personnel provided for the circumstance, which was the day of the visit of Madeline Albright to the Branjevo Farm, in March 1996, (10)following the revelations of Drazen Erdemovic. The next exhibit is 24/7 --

• Q.: Just wait a minute, Mr. Ruez, until the Judges have an opportunity to remove theirs from the plastic sleeves. (15)Please proceed, Mr. Ruez.

• A.: This panorama composed of three photographs, attached each to another, show the access way to the farm, where the buses were lined and the people on board had the opportunity to watch everything that was (20)going on and just had to wait for their turn. The buses were parked at exactly this location. On the right of the photograph, if I slip it through the ELMO, you can see the shed and the tree, which was previously marked on the photographs. Behind (25)that line is the area of the execution meadow.

• Page 763 • {93/103}

(1)Unfortunately, the helicopter is standing right where it is, but this gives also an indication, since you have the men walking here at the right of the picture where the helicopter is, this marks more or less the (5)extreme right of the execution area. And, indeed, the execution area goes at least, if not further, than the last man on this picture, which I'm going to circle
[marks] Exhibit 24/8 --

(10) • Q.: Just wait a minute, Mr. Ruez.

• A.: Okay.

• Q.: Mr. Ruez, please continue.

• A.: Exhibit 24/8 is a photograph taken in 1999, when we came back to that site with one of the (15)survivors. The ground has changed. You can see that now the entrance of the garage shed is blocked, and the tree is still there and was immediately recognised by that person. The corn now is high on the field, so it created a bit of a difficulty for him to position (20)himself on the ground. It's hard to see on this photograph, but he marked his position on that field, approximately where I'm putting the arrow, but that doesn't indicate the distance. It is about 100 metres in that direction where the arrow is. (25)Exhibit 24/9 is just a reference opening to

• Page 764 • {94/103}

(1)the next step of activities on this site, which was exhumation. These are some human remains which were found there and left by the perpetrators who committed the disturbance of the site. (5)They -- in addition to this, they forgot approximately 150 bodies in this main grave. The exhumation was conducted in 1996. Since then we have localised, identified, and probed all the locations where the secondary sites are to be found and who (10)contain the bodies of those killed at the Branjevo Farm.

• Q.: Mr. Ruez, the Branjevo Military Farm is connected now to our next area, which is the Pilica Cultural Dom. Can you outline the Judges, please, to (15)that, and then we'll turn our attention to Prosecutor's Exhibit 25?

• A.: As Drazen Erdemovic explained in his testimony, once the execution of all these prisoners was over approximately at 1500 hours in the afternoon (20)of 15 July -- sorry, 16 July 1995, the squad was instructed to move towards the Dom Kulture, the house of culture of Pilica, where they were instructed to kill 500 prisoners who were in the cultural centre, under the pretext that these people were attempting to (25)flee that location.

• Page 765 • {95/103}

(1)As you know from his testimony, he opposed the move and others volunteered to go do the job. So while some were killing the prisoners inside the House of Culture, himself and members of his squad others (5)were having coffee and slivovitz in a cafe just in front of the house of culture. We'll show you all these places now.

JUDGE RODRIGUES: [Int.] Mr. Harmon, perhaps we could now make a 10-minute break and then (10)move to Pilica.

--- Recess taken at 1.52 p.m.

--- On resuming at 2.02 p.m.

JUDGE RODRIGUES: [Int.] Mr. Harmon.

(15) MR. HARMON: Thank you very much, Mr. President.

• Q.: Mr. Ruez, now let's turn our attention, please, to Prosecutor's Exhibit 25, Pilica Cultural Centre, and we shall begin, first of all, with the (20)video film. If I could have the lights dimmed, please, and we could show Prosecutor's 25/17, please.
[Videotape played]

• A.: On this video -- in fact, it's a live video of our arrival in the first location. We were, in (25)fact, looking for it at this moment. We didn't know

• Page 766 • {96/103}

(1)precisely where it was, and we even intended to show the film to Drazen Erdemovic identification of the place, but we found it that day. If you turn left here, you arrive both at the (5)school of Pilica or at the Branjevo Farm, one continues straight or turns left. So driving towards ... here we passed it. I've left a little piece and the rest of the footage in order to give you an indication of how populated the (10)location is, what it looks like. This is the only killing site which is inside a populated location. All the other ones have been carefully selected outside of populated areas. So indeed something might have happened here which sparked the decision to kill the (15)people on the spot instead of transferring them elsewhere. It's not going to be long. Here we are driving back towards the centre of this hamlet. The house of culture is also the municipal (20)building. This is the front. Inside was a little brand new telephone centre. The person tried to make us believe that there was no cultural centre here, there was nothing. On the right here is the cafe where Erdemovic and his team and Lieutenant Colonel were (25)having drinks. Meanwhile, the execution was going on.

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(1)Again the cafe. This is the plaque with "Pilica" on it. This little structure was hiding the view from the cafe to the entrance or exit of the house of culture, the (5)reason why Drazen Erdemovic couldn't see what was happening just at the door, but he could see men running out and being shot in the street. Then the killers were searching their pockets for valuables. This is a sealed access to the room which is (10)behind. This is the telephone centre I was talking about. That's the first view on the place where the execution took place. This is the door, the entrance door. There (15)is one next to it that goes up to the place where the projectionist was showing movies. This is also a movie theatre. The shooters used these holes also to spray bullets on the people who were inside. Allegedly (20)500 men were jammed in this place, according to the Lieutenant Colonel who gave the instruction. We'll know the final number once we have finalised all the exhumations. Drazen Erdemovic explained that killings were (25)conducted with rifles and also with grenades, and

• Page 768 • {98/103}

(1)indeed there are some obvious traces of explosion, mainly where the area of the stage is. He's filming the ceiling. There is a little mistake in the editing of (5)this film, was supposed to be shorter than that. The ejection for an AK-47 is on the right hand, so it's normal that casings for a shooter who was shooting through these holes end up in the staircase. And the place was clean but very cursory. So each time (10)you can see it's cleaned and then you have a little pile of trash and everywhere there is casings left. The process was really badly done. At this moment we were trying to open it. We ended up breaking the lock. (15)This is irrelevant. These zoomings are of no interest. That's the construction obstructing the view from the cafe. These are the posters of Karadzic which were (20)all over the place at that time. I missed a bit. The editing of this tape was supposed to be shorter than that. They show the environment of the entrance door with a house just in front of it. (25)That's the area where men managed to get out

• Page 769 • {99/103}

(1)and were shot outside. The plastic glove might have been used during the, in brackets, "cleaning process" of the in side of Dom Kulture. (5)Now the door has been opened. Probably no one entered this place in between the moment we are entering now and the moment the last ones who cleaned the place exited this place. I will explain you the reason why we believe that. (10)What can be seen on the wall when it is not bullet holes is mainly human residues.

• Q.: Mr. Ruez, when you say human residues, what do you mean by that?

• A.: Blood, hair, peel, skin. And all items which (15)have been taken by experts who went to fully process this place in September or October 1996, they have provided a full report of their findings on the spot and of the samples which they have collected which were processed and have a human origin. He's making a tour (20)of the location. Now that's the right wall when entering. The area where the stage is is the one where the destruction is the most obvious. The reason is that this was most probably the last location where the (25)people were compressed, trying to avoid the situation,

• Page 770 • {100/103}

(1)with no where to flee. Some were even hiding under the stage. It was full of blood under the stage as well. Part of the destruction of the stage was probably not caused by the killing operation but during the cleaning (5)process. A bullet head; probably went through a body before lying on the ground. If not, it would be crushed somewhere. In the cleaning of the place, a total of 71 shell casings were collected in that (10)location. The number is enough for us to be able to make connections between several sites. Another bullet head. And Pilica.

MR. HARMON: Mr. President --

JUDGE RODRIGUES: [Int.] Mr. Harmon, (15)do you think we could finish within ten minutes, realistically speaking?

MR. HARMON: Realistically speaking, I don't think so, Mr. President. I apologise. The presentation on the film was a little bit longer, but I (20)think it was useful to the Court and the public. I would imagine, at the most, Mr. President, if we continue on Monday, we would have 30 minutes.

JUDGE RODRIGUES: [Int.] Very well. In that case, we shall also be realistic when we make (25)our decision.

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(1) blank page inserted to ensure pagination corresponds between the english and french transcripts

• Page 772 • {102/103}

(1)However, I should like now to turn to Mr. Petrusic. Mr. Petrusic, how long will you need for the cross-examination of Mr. Ruez? What do you think? Do you have an idea?

(5) MR. PETRUSIC: [Int.] Yes, Mr. President. As things stand now, and in view of what we have seen so far, we hope that it will take us something between 60 and 90 minutes. But we shall do our best to bring it down to 60 minutes, that is, one (10)hour, bearing in mind that Mr. Ruez is an investigator only, that is, one of the witnesses, and that we shall have witnesses testifying about each of these individual examples. Thank you.

JUDGE RODRIGUES: [Int.] This is (15)becoming important now because, Mr. Harmon, you have also to call other witnesses next Monday, I believe, and you should be prepared for that. As you already know, appropriate measures need to be taken to have the witnesses called for not only in the next week, but the (20)week after, and for the first week of April. I believe that Mr. Fourmy will need all this information. So will you please take care and see if we can really perhaps save some time and use best the time that we have at our disposal. (25)Very well. As I have already told you, there

• Page 773 • {103/103}

(1)will be no hearing on Friday. Tomorrow is a holiday. So we shall adjourn now and resume our work on Monday, at 9.30. I also wish to tell you that myself and Ms. Patricia Wald will be sitting here, since Judge (5)Riad will not be able to attend. That is what I had to tell you today. I wish you a nice weekend. I hope you have a good rest, but also work. Until Monday then.

--- Whereupon the hearing adjourned at (10)2.33 p.m., to be reconvened on Monday, the 20th day of March, 2000, at 9.30 a.m.